Audit 329972

Student Financial Assistance Cluster Federal Supplemental Educational Opportunity Grants, ALN 84.007; Federal Work-Study Program, ALN 84.033 Federal Pell Grant Program, ALN 84.063 Federal Direct Student Loans, ALN 84.268 Teacher Education Assistance for College and Higher Education Grants, ALN 84.379 U.S. Department of Education Program Year 2023-2024 Criteria or specific requirement – Special Tests and Provisions – Return of Title IV Funds (34 CFR 668.22(a)(1) through (a)(5) Condition – The University’s internal controls did not ensure the calculation of amounts to be returned to the U.S. Department of Education were correct and were performed timely. Questioned costs - $0 Context – Out of the population of 73 students who withdrew, 11 were selected for testing. Our sampling method was not, and was not intended to be, statistically valid. Total days in the semester for the fall semester was calculated incorrectly due to using an incorrect number of break days. Additionally, 2 students did not receive timely post-withdrawal disbursements. Effect – One student completed 60 percent of the semester, but the return of Title IV funds amount was calculated showing an amount to be returned to the U.S. Department of Education. Additionally, 2 students received post-withdrawal disbursements approximately 10 months after their withdrawal. Cause – The University’s internal controls did not ensure proper inputting of semester information into the calculation of returns of Title IV funds based on total days in the semester and total days attended, and did not ensure student received post-withdrawal disbursements timely. Identification as a repeat finding, if applicable – 2023-001 and 2022-001 Recommendation – The University should update their controls to ensure total days in the semester are calculated correctly and post-withdrawal disbursements are made timely. Views of responsible officials and planned corrective actions – With the new Financial Aid leadership, the university has already implemented many new strategies to strengthen the Return of Title IV Funds (R2T4) process. The University created a new position, Financial Aid Business Analyst, whose primary responsibility is to maintain financial aid systems, maintain process documentation and provide staff system training and to oversee the R2T4 process. The Financial Aid Business Analyst has two years of previous experience being responsible for R2T4 calculations, completed the National Association of Student Financial Aid Administrators (NASFAA) R2T4 five-week certification program on October 14, 2024, and is in the process of training a Financial Advisor in performing R2T4 calculations. Other areas that have been identified will improve the R2T4 process are as follows: 1. Earlier Availability of the Academic Calendar: The Financial Aid Office leadership (Director, Assistant Director, Financial Aid Business Analyst) will work with the Office of Student Records (Registrar and Deputy Registrar) to ensure that there is an accurate R2T4/academic calendar. Both offices will work to develop such calendars with a clear description of the dates the University is closed for students, and that calendars can be developed years in advance. This will facilitate accurate determination of begin/end dates, break days and the total number of class days within any term. This will also encourage greater levels of transparency and oversight by both offices. The R2T4/academic calendar will also be shared with the Student Accounts Office, adding additional transparency and understanding. Timeline: The calendar for the Spring semester 2025 and the 2025-2026 academic calendar has already been developed and approved. The 2026-2027 academic calendar has been submitted to faculty for their input and will be completed by November 30, 2024. 2. Daily Percentage Calculator: The Financial Aid Business Analyst developed a daily percentage calculator that, implemented for Fall 2024, when combined with the academic calendar, will enable the accurate input of all term dates to generate precise daily percentage calculations for R2T4 purposes. This is also being expanded to create sub-term daily percentage calculations to eliminate the need for manual completion with each module-type calculation. 1. Post-Withdrawal Disbursements: The Financial Aid Business Analyst worked with Information Technology to ensure required communications related to R2T4 including post withdrawals (PWD) are now an automated process after completion of the calculations. This automation was implemented in August 2024. The PWD findings in this audit were the work by previous leadership within the Financial Aid Office. 2. Collaboration with IT for Updated Reporting: Financial Aid Office leadership (Financial Aid Business Analyst, Director) are collaborating with the IT to develop updated reports that will help accurately identify students who have unofficially withdrawn and require review during the R2T4 process. This initiative aims to create a preventive control that identifies errors and ensure timely calculations. The timeline for completion of the updated report is November 30, 2024. 3. Strengthening Internal Controls: The Director of Financial Aid has identified a Financial Aid Advisor who is currently being trained on R2T4 process, and who will eventually assume the primary responsibility for R2T4 calculations. The Financial Aid Business Analyst will provide secondary reviews to ensure accuracy and consistency. Note: The two PWDs from the Fall 2023 semester highlight a significant oversight by previous financial aid leadership. The inadvertent miscalculation of break days stemmed from confusion about the academic calendar. It appeared to suggest that students were required to attend classes on the weekend proceeding Thanksgiving week, while in reality, classes concluded the prior Friday. As a result, the Fall break should have been calculated as 9 days instead of 7.

Student Financial Assistance Cluster Federal Supplemental Educational Opportunity Grants, ALN 84.007; Federal Work-Study Program, ALN 84.033 Federal Pell Grant Program, ALN 84.063 Federal Direct Student Loans, ALN 84.268 Teacher Education Assistance for College and Higher Education Grants, ALN 84.379 U.S. Department of Education Program Year 2023-2024 Criteria or specific requirement – Special Tests and Provisions – Return of Title IV Funds (34 CFR 668.22(a)(1) through (a)(5) Condition – The University’s internal controls did not ensure the calculation of amounts to be returned to the U.S. Department of Education were correct and were performed timely. Questioned costs - $0 Context – Out of the population of 73 students who withdrew, 11 were selected for testing. Our sampling method was not, and was not intended to be, statistically valid. Total days in the semester for the fall semester was calculated incorrectly due to using an incorrect number of break days. Additionally, 2 students did not receive timely post-withdrawal disbursements. Effect – One student completed 60 percent of the semester, but the return of Title IV funds amount was calculated showing an amount to be returned to the U.S. Department of Education. Additionally, 2 students received post-withdrawal disbursements approximately 10 months after their withdrawal. Cause – The University’s internal controls did not ensure proper inputting of semester information into the calculation of returns of Title IV funds based on total days in the semester and total days attended, and did not ensure student received post-withdrawal disbursements timely. Identification as a repeat finding, if applicable – 2023-001 and 2022-001 Recommendation – The University should update their controls to ensure total days in the semester are calculated correctly and post-withdrawal disbursements are made timely. Views of responsible officials and planned corrective actions – With the new Financial Aid leadership, the university has already implemented many new strategies to strengthen the Return of Title IV Funds (R2T4) process. The University created a new position, Financial Aid Business Analyst, whose primary responsibility is to maintain financial aid systems, maintain process documentation and provide staff system training and to oversee the R2T4 process. The Financial Aid Business Analyst has two years of previous experience being responsible for R2T4 calculations, completed the National Association of Student Financial Aid Administrators (NASFAA) R2T4 five-week certification program on October 14, 2024, and is in the process of training a Financial Advisor in performing R2T4 calculations. Other areas that have been identified will improve the R2T4 process are as follows: 1. Earlier Availability of the Academic Calendar: The Financial Aid Office leadership (Director, Assistant Director, Financial Aid Business Analyst) will work with the Office of Student Records (Registrar and Deputy Registrar) to ensure that there is an accurate R2T4/academic calendar. Both offices will work to develop such calendars with a clear description of the dates the University is closed for students, and that calendars can be developed years in advance. This will facilitate accurate determination of begin/end dates, break days and the total number of class days within any term. This will also encourage greater levels of transparency and oversight by both offices. The R2T4/academic calendar will also be shared with the Student Accounts Office, adding additional transparency and understanding. Timeline: The calendar for the Spring semester 2025 and the 2025-2026 academic calendar has already been developed and approved. The 2026-2027 academic calendar has been submitted to faculty for their input and will be completed by November 30, 2024. 2. Daily Percentage Calculator: The Financial Aid Business Analyst developed a daily percentage calculator that, implemented for Fall 2024, when combined with the academic calendar, will enable the accurate input of all term dates to generate precise daily percentage calculations for R2T4 purposes. This is also being expanded to create sub-term daily percentage calculations to eliminate the need for manual completion with each module-type calculation. 1. Post-Withdrawal Disbursements: The Financial Aid Business Analyst worked with Information Technology to ensure required communications related to R2T4 including post withdrawals (PWD) are now an automated process after completion of the calculations. This automation was implemented in August 2024. The PWD findings in this audit were the work by previous leadership within the Financial Aid Office. 2. Collaboration with IT for Updated Reporting: Financial Aid Office leadership (Financial Aid Business Analyst, Director) are collaborating with the IT to develop updated reports that will help accurately identify students who have unofficially withdrawn and require review during the R2T4 process. This initiative aims to create a preventive control that identifies errors and ensure timely calculations. The timeline for completion of the updated report is November 30, 2024. 3. Strengthening Internal Controls: The Director of Financial Aid has identified a Financial Aid Advisor who is currently being trained on R2T4 process, and who will eventually assume the primary responsibility for R2T4 calculations. The Financial Aid Business Analyst will provide secondary reviews to ensure accuracy and consistency. Note: The two PWDs from the Fall 2023 semester highlight a significant oversight by previous financial aid leadership. The inadvertent miscalculation of break days stemmed from confusion about the academic calendar. It appeared to suggest that students were required to attend classes on the weekend proceeding Thanksgiving week, while in reality, classes concluded the prior Friday. As a result, the Fall break should have been calculated as 9 days instead of 7.

Student Financial Assistance Cluster Federal Supplemental Educational Opportunity Grants, ALN 84.007; Federal Work-Study Program, ALN 84.033 Federal Pell Grant Program, ALN 84.063 Federal Direct Student Loans, ALN 84.268 Teacher Education Assistance for College and Higher Education Grants, ALN 84.379 U.S. Department of Education Program Year 2023-2024 Criteria or specific requirement – Special Tests and Provisions – Return of Title IV Funds (34 CFR 668.22(a)(1) through (a)(5) Condition – The University’s internal controls did not ensure the calculation of amounts to be returned to the U.S. Department of Education were correct and were performed timely. Questioned costs - $0 Context – Out of the population of 73 students who withdrew, 11 were selected for testing. Our sampling method was not, and was not intended to be, statistically valid. Total days in the semester for the fall semester was calculated incorrectly due to using an incorrect number of break days. Additionally, 2 students did not receive timely post-withdrawal disbursements. Effect – One student completed 60 percent of the semester, but the return of Title IV funds amount was calculated showing an amount to be returned to the U.S. Department of Education. Additionally, 2 students received post-withdrawal disbursements approximately 10 months after their withdrawal. Cause – The University’s internal controls did not ensure proper inputting of semester information into the calculation of returns of Title IV funds based on total days in the semester and total days attended, and did not ensure student received post-withdrawal disbursements timely. Identification as a repeat finding, if applicable – 2023-001 and 2022-001 Recommendation – The University should update their controls to ensure total days in the semester are calculated correctly and post-withdrawal disbursements are made timely. Views of responsible officials and planned corrective actions – With the new Financial Aid leadership, the university has already implemented many new strategies to strengthen the Return of Title IV Funds (R2T4) process. The University created a new position, Financial Aid Business Analyst, whose primary responsibility is to maintain financial aid systems, maintain process documentation and provide staff system training and to oversee the R2T4 process. The Financial Aid Business Analyst has two years of previous experience being responsible for R2T4 calculations, completed the National Association of Student Financial Aid Administrators (NASFAA) R2T4 five-week certification program on October 14, 2024, and is in the process of training a Financial Advisor in performing R2T4 calculations. Other areas that have been identified will improve the R2T4 process are as follows: 1. Earlier Availability of the Academic Calendar: The Financial Aid Office leadership (Director, Assistant Director, Financial Aid Business Analyst) will work with the Office of Student Records (Registrar and Deputy Registrar) to ensure that there is an accurate R2T4/academic calendar. Both offices will work to develop such calendars with a clear description of the dates the University is closed for students, and that calendars can be developed years in advance. This will facilitate accurate determination of begin/end dates, break days and the total number of class days within any term. This will also encourage greater levels of transparency and oversight by both offices. The R2T4/academic calendar will also be shared with the Student Accounts Office, adding additional transparency and understanding. Timeline: The calendar for the Spring semester 2025 and the 2025-2026 academic calendar has already been developed and approved. The 2026-2027 academic calendar has been submitted to faculty for their input and will be completed by November 30, 2024. 2. Daily Percentage Calculator: The Financial Aid Business Analyst developed a daily percentage calculator that, implemented for Fall 2024, when combined with the academic calendar, will enable the accurate input of all term dates to generate precise daily percentage calculations for R2T4 purposes. This is also being expanded to create sub-term daily percentage calculations to eliminate the need for manual completion with each module-type calculation. 1. Post-Withdrawal Disbursements: The Financial Aid Business Analyst worked with Information Technology to ensure required communications related to R2T4 including post withdrawals (PWD) are now an automated process after completion of the calculations. This automation was implemented in August 2024. The PWD findings in this audit were the work by previous leadership within the Financial Aid Office. 2. Collaboration with IT for Updated Reporting: Financial Aid Office leadership (Financial Aid Business Analyst, Director) are collaborating with the IT to develop updated reports that will help accurately identify students who have unofficially withdrawn and require review during the R2T4 process. This initiative aims to create a preventive control that identifies errors and ensure timely calculations. The timeline for completion of the updated report is November 30, 2024. 3. Strengthening Internal Controls: The Director of Financial Aid has identified a Financial Aid Advisor who is currently being trained on R2T4 process, and who will eventually assume the primary responsibility for R2T4 calculations. The Financial Aid Business Analyst will provide secondary reviews to ensure accuracy and consistency. Note: The two PWDs from the Fall 2023 semester highlight a significant oversight by previous financial aid leadership. The inadvertent miscalculation of break days stemmed from confusion about the academic calendar. It appeared to suggest that students were required to attend classes on the weekend proceeding Thanksgiving week, while in reality, classes concluded the prior Friday. As a result, the Fall break should have been calculated as 9 days instead of 7.

Student Financial Assistance Cluster Federal Supplemental Educational Opportunity Grants, ALN 84.007; Federal Work-Study Program, ALN 84.033 Federal Pell Grant Program, ALN 84.063 Federal Direct Student Loans, ALN 84.268 Teacher Education Assistance for College and Higher Education Grants, ALN 84.379 U.S. Department of Education Program Year 2023-2024 Criteria or specific requirement – Special Tests and Provisions – Return of Title IV Funds (34 CFR 668.22(a)(1) through (a)(5) Condition – The University’s internal controls did not ensure the calculation of amounts to be returned to the U.S. Department of Education were correct and were performed timely. Questioned costs - $0 Context – Out of the population of 73 students who withdrew, 11 were selected for testing. Our sampling method was not, and was not intended to be, statistically valid. Total days in the semester for the fall semester was calculated incorrectly due to using an incorrect number of break days. Additionally, 2 students did not receive timely post-withdrawal disbursements. Effect – One student completed 60 percent of the semester, but the return of Title IV funds amount was calculated showing an amount to be returned to the U.S. Department of Education. Additionally, 2 students received post-withdrawal disbursements approximately 10 months after their withdrawal. Cause – The University’s internal controls did not ensure proper inputting of semester information into the calculation of returns of Title IV funds based on total days in the semester and total days attended, and did not ensure student received post-withdrawal disbursements timely. Identification as a repeat finding, if applicable – 2023-001 and 2022-001 Recommendation – The University should update their controls to ensure total days in the semester are calculated correctly and post-withdrawal disbursements are made timely. Views of responsible officials and planned corrective actions – With the new Financial Aid leadership, the university has already implemented many new strategies to strengthen the Return of Title IV Funds (R2T4) process. The University created a new position, Financial Aid Business Analyst, whose primary responsibility is to maintain financial aid systems, maintain process documentation and provide staff system training and to oversee the R2T4 process. The Financial Aid Business Analyst has two years of previous experience being responsible for R2T4 calculations, completed the National Association of Student Financial Aid Administrators (NASFAA) R2T4 five-week certification program on October 14, 2024, and is in the process of training a Financial Advisor in performing R2T4 calculations. Other areas that have been identified will improve the R2T4 process are as follows: 1. Earlier Availability of the Academic Calendar: The Financial Aid Office leadership (Director, Assistant Director, Financial Aid Business Analyst) will work with the Office of Student Records (Registrar and Deputy Registrar) to ensure that there is an accurate R2T4/academic calendar. Both offices will work to develop such calendars with a clear description of the dates the University is closed for students, and that calendars can be developed years in advance. This will facilitate accurate determination of begin/end dates, break days and the total number of class days within any term. This will also encourage greater levels of transparency and oversight by both offices. The R2T4/academic calendar will also be shared with the Student Accounts Office, adding additional transparency and understanding. Timeline: The calendar for the Spring semester 2025 and the 2025-2026 academic calendar has already been developed and approved. The 2026-2027 academic calendar has been submitted to faculty for their input and will be completed by November 30, 2024. 2. Daily Percentage Calculator: The Financial Aid Business Analyst developed a daily percentage calculator that, implemented for Fall 2024, when combined with the academic calendar, will enable the accurate input of all term dates to generate precise daily percentage calculations for R2T4 purposes. This is also being expanded to create sub-term daily percentage calculations to eliminate the need for manual completion with each module-type calculation. 1. Post-Withdrawal Disbursements: The Financial Aid Business Analyst worked with Information Technology to ensure required communications related to R2T4 including post withdrawals (PWD) are now an automated process after completion of the calculations. This automation was implemented in August 2024. The PWD findings in this audit were the work by previous leadership within the Financial Aid Office. 2. Collaboration with IT for Updated Reporting: Financial Aid Office leadership (Financial Aid Business Analyst, Director) are collaborating with the IT to develop updated reports that will help accurately identify students who have unofficially withdrawn and require review during the R2T4 process. This initiative aims to create a preventive control that identifies errors and ensure timely calculations. The timeline for completion of the updated report is November 30, 2024. 3. Strengthening Internal Controls: The Director of Financial Aid has identified a Financial Aid Advisor who is currently being trained on R2T4 process, and who will eventually assume the primary responsibility for R2T4 calculations. The Financial Aid Business Analyst will provide secondary reviews to ensure accuracy and consistency. Note: The two PWDs from the Fall 2023 semester highlight a significant oversight by previous financial aid leadership. The inadvertent miscalculation of break days stemmed from confusion about the academic calendar. It appeared to suggest that students were required to attend classes on the weekend proceeding Thanksgiving week, while in reality, classes concluded the prior Friday. As a result, the Fall break should have been calculated as 9 days instead of 7.

Student Financial Assistance Cluster Federal Supplemental Educational Opportunity Grants, ALN 84.007; Federal Work-Study Program, ALN 84.033 Federal Pell Grant Program, ALN 84.063 Federal Direct Student Loans, ALN 84.268 Teacher Education Assistance for College and Higher Education Grants, ALN 84.379 U.S. Department of Education Program Year 2023-2024 Criteria or specific requirement – Special Tests and Provisions – Return of Title IV Funds (34 CFR 668.22(a)(1) through (a)(5) Condition – The University’s internal controls did not ensure the calculation of amounts to be returned to the U.S. Department of Education were correct and were performed timely. Questioned costs - $0 Context – Out of the population of 73 students who withdrew, 11 were selected for testing. Our sampling method was not, and was not intended to be, statistically valid. Total days in the semester for the fall semester was calculated incorrectly due to using an incorrect number of break days. Additionally, 2 students did not receive timely post-withdrawal disbursements. Effect – One student completed 60 percent of the semester, but the return of Title IV funds amount was calculated showing an amount to be returned to the U.S. Department of Education. Additionally, 2 students received post-withdrawal disbursements approximately 10 months after their withdrawal. Cause – The University’s internal controls did not ensure proper inputting of semester information into the calculation of returns of Title IV funds based on total days in the semester and total days attended, and did not ensure student received post-withdrawal disbursements timely. Identification as a repeat finding, if applicable – 2023-001 and 2022-001 Recommendation – The University should update their controls to ensure total days in the semester are calculated correctly and post-withdrawal disbursements are made timely. Views of responsible officials and planned corrective actions – With the new Financial Aid leadership, the university has already implemented many new strategies to strengthen the Return of Title IV Funds (R2T4) process. The University created a new position, Financial Aid Business Analyst, whose primary responsibility is to maintain financial aid systems, maintain process documentation and provide staff system training and to oversee the R2T4 process. The Financial Aid Business Analyst has two years of previous experience being responsible for R2T4 calculations, completed the National Association of Student Financial Aid Administrators (NASFAA) R2T4 five-week certification program on October 14, 2024, and is in the process of training a Financial Advisor in performing R2T4 calculations. Other areas that have been identified will improve the R2T4 process are as follows: 1. Earlier Availability of the Academic Calendar: The Financial Aid Office leadership (Director, Assistant Director, Financial Aid Business Analyst) will work with the Office of Student Records (Registrar and Deputy Registrar) to ensure that there is an accurate R2T4/academic calendar. Both offices will work to develop such calendars with a clear description of the dates the University is closed for students, and that calendars can be developed years in advance. This will facilitate accurate determination of begin/end dates, break days and the total number of class days within any term. This will also encourage greater levels of transparency and oversight by both offices. The R2T4/academic calendar will also be shared with the Student Accounts Office, adding additional transparency and understanding. Timeline: The calendar for the Spring semester 2025 and the 2025-2026 academic calendar has already been developed and approved. The 2026-2027 academic calendar has been submitted to faculty for their input and will be completed by November 30, 2024. 2. Daily Percentage Calculator: The Financial Aid Business Analyst developed a daily percentage calculator that, implemented for Fall 2024, when combined with the academic calendar, will enable the accurate input of all term dates to generate precise daily percentage calculations for R2T4 purposes. This is also being expanded to create sub-term daily percentage calculations to eliminate the need for manual completion with each module-type calculation. 1. Post-Withdrawal Disbursements: The Financial Aid Business Analyst worked with Information Technology to ensure required communications related to R2T4 including post withdrawals (PWD) are now an automated process after completion of the calculations. This automation was implemented in August 2024. The PWD findings in this audit were the work by previous leadership within the Financial Aid Office. 2. Collaboration with IT for Updated Reporting: Financial Aid Office leadership (Financial Aid Business Analyst, Director) are collaborating with the IT to develop updated reports that will help accurately identify students who have unofficially withdrawn and require review during the R2T4 process. This initiative aims to create a preventive control that identifies errors and ensure timely calculations. The timeline for completion of the updated report is November 30, 2024. 3. Strengthening Internal Controls: The Director of Financial Aid has identified a Financial Aid Advisor who is currently being trained on R2T4 process, and who will eventually assume the primary responsibility for R2T4 calculations. The Financial Aid Business Analyst will provide secondary reviews to ensure accuracy and consistency. Note: The two PWDs from the Fall 2023 semester highlight a significant oversight by previous financial aid leadership. The inadvertent miscalculation of break days stemmed from confusion about the academic calendar. It appeared to suggest that students were required to attend classes on the weekend proceeding Thanksgiving week, while in reality, classes concluded the prior Friday. As a result, the Fall break should have been calculated as 9 days instead of 7.

Federal Pell Grant Program, ALN 84.063 Federal Direct Student Loans, ALN 84.268 U.S. Department of Education Program Year 2023-2024 Criteria or specific requirement – Special Tests and Provisions – Enrollment Reporting (34 CFR 690.93(b)(2); 34 CFR 682.610; 34 CFR 685.309). Institutions are required to report enrollment information. Condition – The University’s processes did not ensure timely and accurate student status reporting to National Student Loan Data System (NSLDS). Questioned costs – $0 Context – Out of the population of 580 students with changes in enrollment status, a sample of 25 students were selected for testing. Our sampling method was not, and was not intended to be, statistically valid. There were 14 attributes tested for each student with at least one status change. Campus-Level Records: 1. OPEID Number 2. Enrollment Effective Date 3. Enrollment Status 4. Certification Date Program-Level Records 5. OPEID 6. CIP Code 7. CIP Year 8. Credential Level 9. Published Program Length Measurement 10. Published Program Length 11. Program Begin Date 12. Program Enrollment Status 13. Program Enrollment Effective Date Other Records 14. Student changed his or her permanent address The University reported the incorrect Program Begin Date for 4 students. The University did not report one status change for 3 students who had multiple status changes. The University did not timely report status changes for 3 students. Effect – The University reported incorrect dates and statuses for students’ status changes and did not report the status changes timely. Cause – The University’s processes did not ensure status changes were reported timely and accurately. Identification as repeat finding, if applicable – 2023-002 Recommendation – The University should update their controls to ensure changes in students’ enrollment status are reported in a timely and accurate manner. Views of responsible officials and planned corrective actions – The Deputy Registrar from the Office of Student Records (OSR) is responsible for enrollment reporting to the National Student Loan Data System (NSLDS). The university uses a servicer, National Student Clearinghouse (NSC) to complete the reporting requirement. Enrollment data is scheduled to be transmitted to the NSC every thirty days to ensure timely reporting to the National Student Loan Data System (NSLDS). The University has consistently met this 30-day reporting to NSC. The audit noted four students had incorrect program start dates in NSLDS from April 2022 and August 2022, each off by one day. The University’s Student Information System (SIS) reflects the correct program start dates, indicating a potential issue in the data transmission between NSC and NSLDS. In July 2022, several announcements were made concerning the technical issues with NSLDS which prevented reporting for periods of time, including “NSLDS Professional Access – Documentation of Enrollment Reporting and Post screening Delays for Audit Purposes” published on August 31, 2022. The audit noted three errors related to timely reporting. The university’s SIS records indicate these records were reported to NSC within the 30-day timeframe. However, these records were not transmitted from NSC to NSLDS timely. The Deputy Registrar is currently collaborating with the NSC Compliance division to determine the cause of these discrepancies and how best to correct the records in NSLDS. A response from NSC is anticipated by October 31, 2024. The audit also noted three students who were less than full-time that were not reported to NSC or NSLDS. The Deputy Registrar is researching the SIS system rules to determine the root cause of these errors so they can be corrected. The Deputy Registrar will ensure the reporting rules will be corrected by November 30, 2024, and will ensure any less than full time students are corrected in NSLDS by December 30, 2024. To enhance the enrollment reporting process, the Deputy Registrar, Registrar, and Director of Financial Aid will meet with NSC staff and IT staff to establish a method for comparing monthly data submitted to NSC with the data in the NSLDS system. This will help identify any discrepancies for immediate correction. This project is expected to be completed by December 30, 2024.

Federal Pell Grant Program, ALN 84.063 Federal Direct Student Loans, ALN 84.268 U.S. Department of Education Program Year 2023-2024 Criteria or specific requirement – Special Tests and Provisions – Enrollment Reporting (34 CFR 690.93(b)(2); 34 CFR 682.610; 34 CFR 685.309). Institutions are required to report enrollment information. Condition – The University’s processes did not ensure timely and accurate student status reporting to National Student Loan Data System (NSLDS). Questioned costs – $0 Context – Out of the population of 580 students with changes in enrollment status, a sample of 25 students were selected for testing. Our sampling method was not, and was not intended to be, statistically valid. There were 14 attributes tested for each student with at least one status change. Campus-Level Records: 1. OPEID Number 2. Enrollment Effective Date 3. Enrollment Status 4. Certification Date Program-Level Records 5. OPEID 6. CIP Code 7. CIP Year 8. Credential Level 9. Published Program Length Measurement 10. Published Program Length 11. Program Begin Date 12. Program Enrollment Status 13. Program Enrollment Effective Date Other Records 14. Student changed his or her permanent address The University reported the incorrect Program Begin Date for 4 students. The University did not report one status change for 3 students who had multiple status changes. The University did not timely report status changes for 3 students. Effect – The University reported incorrect dates and statuses for students’ status changes and did not report the status changes timely. Cause – The University’s processes did not ensure status changes were reported timely and accurately. Identification as repeat finding, if applicable – 2023-002 Recommendation – The University should update their controls to ensure changes in students’ enrollment status are reported in a timely and accurate manner. Views of responsible officials and planned corrective actions – The Deputy Registrar from the Office of Student Records (OSR) is responsible for enrollment reporting to the National Student Loan Data System (NSLDS). The university uses a servicer, National Student Clearinghouse (NSC) to complete the reporting requirement. Enrollment data is scheduled to be transmitted to the NSC every thirty days to ensure timely reporting to the National Student Loan Data System (NSLDS). The University has consistently met this 30-day reporting to NSC. The audit noted four students had incorrect program start dates in NSLDS from April 2022 and August 2022, each off by one day. The University’s Student Information System (SIS) reflects the correct program start dates, indicating a potential issue in the data transmission between NSC and NSLDS. In July 2022, several announcements were made concerning the technical issues with NSLDS which prevented reporting for periods of time, including “NSLDS Professional Access – Documentation of Enrollment Reporting and Post screening Delays for Audit Purposes” published on August 31, 2022. The audit noted three errors related to timely reporting. The university’s SIS records indicate these records were reported to NSC within the 30-day timeframe. However, these records were not transmitted from NSC to NSLDS timely. The Deputy Registrar is currently collaborating with the NSC Compliance division to determine the cause of these discrepancies and how best to correct the records in NSLDS. A response from NSC is anticipated by October 31, 2024. The audit also noted three students who were less than full-time that were not reported to NSC or NSLDS. The Deputy Registrar is researching the SIS system rules to determine the root cause of these errors so they can be corrected. The Deputy Registrar will ensure the reporting rules will be corrected by November 30, 2024, and will ensure any less than full time students are corrected in NSLDS by December 30, 2024. To enhance the enrollment reporting process, the Deputy Registrar, Registrar, and Director of Financial Aid will meet with NSC staff and IT staff to establish a method for comparing monthly data submitted to NSC with the data in the NSLDS system. This will help identify any discrepancies for immediate correction. This project is expected to be completed by December 30, 2024.

Student Financial Assistance Cluster Federal Supplemental Educational Opportunity Grants, ALN 84.007; Federal Work-Study Program, ALN 84.033 Federal Pell Grant Program, ALN 84.063 Federal Direct Student Loans, ALN 84.268 Teacher Education Assistance for College and Higher Education Grants, ALN 84.379 U.S. Department of Education Program Year 2023-2024 Criteria or specific requirement – Special Tests and Provisions – Verification (34 CFR 668.51 through 668.61) Institutions responsible for verifying applicant information for those applicants selected by verification by the U.S. Department of Education. Condition – The University’s processes did not ensure corrections were made to student application data. Questioned costs – Unknown Context – Out of the population of 189 students selected for verification, a sample of 19 students were selected for testing. Our sampling method was not, and was not intended to be, statistically valid. The number of household members was not corrected on the student’s Institutional Student Information Record (ISIR) for one student, and the adjusted gross income was not corrected on the student’s ISIR for one student. Effect – The student’s applicant data was not correct when used for packaging and awarding aid. Identification as a repeat finding, if applicable – N/A Recommendation – The University should update their controls to ensure student data is properly corrected on the students’ ISIRs in the verification process. Views of responsible officials and planned corrective actions – The auditors identified two issues related to verification of financial aid data supplied on the FAFSA by students. Both findings were from the fall of 2023 and in both cases a secondary review was completed and still was not accurately completed. The Office of Financial Aid developed and implemented a comprehensive Business Process Guide (BPG) on October 17, 2024. The guide is aimed at ensuring that all required fields within the verification process are meticulously reviewed and corrected as needed. This guide serves as a crucial resource for staff involved in the financial aid verification process, outlining best practices and standard procedures to maintain compliance and accuracy. The verification correction process follows a two-step approach: 1. Initial Review and Correction: Staff members are required to conduct a thorough review of the required data fields. This involves checking the required ISIR data fields against other supplemental information to identify any discrepancies or inaccuracies. Once identified, corrections are made to ensure that all data aligns with federal and institutional requirements. 2. Final Confirmation and Awarding: After the necessary corrections are implemented, a secondary review is conducted by the Assistant Director to confirm that the adjustments are accurate. This ensures that students receive the correct financial aid awards based on updated and verified information. To maintain transparency, accountability, and an adequate documentation trail. It is imperative that any comments added to student accounts are detailed and include pertinent information regarding the verification process. This documentation serves as a record of the actions taken and aids in future audits and reviews. The Assistant Director of Financial Aid is a very experienced financial aid professional and holds NASFAA certifications in Verification, R2T4, Student Eligibility, Direct Loans and Professional Judgement. The Assistant Director plays a pivotal role in the verification process, being responsible for updating the BPG to reflect any changes in regulations or best practices. Additionally, the Assistant Director will lead training sessions for staff members to ensure they are well-versed in the verification procedures outlined in the BPG. Ongoing training will be provided as needed to accommodate changes in policies or technologies. By implementing this structured approach to verification corrections, the University aims to enhance the accuracy of financial aid processing and improve the overall student experience.

Student Financial Assistance Cluster Federal Supplemental Educational Opportunity Grants, ALN 84.007; Federal Work-Study Program, ALN 84.033 Federal Pell Grant Program, ALN 84.063 Federal Direct Student Loans, ALN 84.268 Teacher Education Assistance for College and Higher Education Grants, ALN 84.379 U.S. Department of Education Program Year 2023-2024 Criteria or specific requirement – Special Tests and Provisions – Verification (34 CFR 668.51 through 668.61) Institutions responsible for verifying applicant information for those applicants selected by verification by the U.S. Department of Education. Condition – The University’s processes did not ensure corrections were made to student application data. Questioned costs – Unknown Context – Out of the population of 189 students selected for verification, a sample of 19 students were selected for testing. Our sampling method was not, and was not intended to be, statistically valid. The number of household members was not corrected on the student’s Institutional Student Information Record (ISIR) for one student, and the adjusted gross income was not corrected on the student’s ISIR for one student. Effect – The student’s applicant data was not correct when used for packaging and awarding aid. Identification as a repeat finding, if applicable – N/A Recommendation – The University should update their controls to ensure student data is properly corrected on the students’ ISIRs in the verification process. Views of responsible officials and planned corrective actions – The auditors identified two issues related to verification of financial aid data supplied on the FAFSA by students. Both findings were from the fall of 2023 and in both cases a secondary review was completed and still was not accurately completed. The Office of Financial Aid developed and implemented a comprehensive Business Process Guide (BPG) on October 17, 2024. The guide is aimed at ensuring that all required fields within the verification process are meticulously reviewed and corrected as needed. This guide serves as a crucial resource for staff involved in the financial aid verification process, outlining best practices and standard procedures to maintain compliance and accuracy. The verification correction process follows a two-step approach: 1. Initial Review and Correction: Staff members are required to conduct a thorough review of the required data fields. This involves checking the required ISIR data fields against other supplemental information to identify any discrepancies or inaccuracies. Once identified, corrections are made to ensure that all data aligns with federal and institutional requirements. 2. Final Confirmation and Awarding: After the necessary corrections are implemented, a secondary review is conducted by the Assistant Director to confirm that the adjustments are accurate. This ensures that students receive the correct financial aid awards based on updated and verified information. To maintain transparency, accountability, and an adequate documentation trail. It is imperative that any comments added to student accounts are detailed and include pertinent information regarding the verification process. This documentation serves as a record of the actions taken and aids in future audits and reviews. The Assistant Director of Financial Aid is a very experienced financial aid professional and holds NASFAA certifications in Verification, R2T4, Student Eligibility, Direct Loans and Professional Judgement. The Assistant Director plays a pivotal role in the verification process, being responsible for updating the BPG to reflect any changes in regulations or best practices. Additionally, the Assistant Director will lead training sessions for staff members to ensure they are well-versed in the verification procedures outlined in the BPG. Ongoing training will be provided as needed to accommodate changes in policies or technologies. By implementing this structured approach to verification corrections, the University aims to enhance the accuracy of financial aid processing and improve the overall student experience.

Student Financial Assistance Cluster Federal Supplemental Educational Opportunity Grants, ALN 84.007; Federal Work-Study Program, ALN 84.033 Federal Pell Grant Program, ALN 84.063 Federal Direct Student Loans, ALN 84.268 Teacher Education Assistance for College and Higher Education Grants, ALN 84.379 U.S. Department of Education Program Year 2023-2024 Criteria or specific requirement – Special Tests and Provisions – Verification (34 CFR 668.51 through 668.61) Institutions responsible for verifying applicant information for those applicants selected by verification by the U.S. Department of Education. Condition – The University’s processes did not ensure corrections were made to student application data. Questioned costs – Unknown Context – Out of the population of 189 students selected for verification, a sample of 19 students were selected for testing. Our sampling method was not, and was not intended to be, statistically valid. The number of household members was not corrected on the student’s Institutional Student Information Record (ISIR) for one student, and the adjusted gross income was not corrected on the student’s ISIR for one student. Effect – The student’s applicant data was not correct when used for packaging and awarding aid. Identification as a repeat finding, if applicable – N/A Recommendation – The University should update their controls to ensure student data is properly corrected on the students’ ISIRs in the verification process. Views of responsible officials and planned corrective actions – The auditors identified two issues related to verification of financial aid data supplied on the FAFSA by students. Both findings were from the fall of 2023 and in both cases a secondary review was completed and still was not accurately completed. The Office of Financial Aid developed and implemented a comprehensive Business Process Guide (BPG) on October 17, 2024. The guide is aimed at ensuring that all required fields within the verification process are meticulously reviewed and corrected as needed. This guide serves as a crucial resource for staff involved in the financial aid verification process, outlining best practices and standard procedures to maintain compliance and accuracy. The verification correction process follows a two-step approach: 1. Initial Review and Correction: Staff members are required to conduct a thorough review of the required data fields. This involves checking the required ISIR data fields against other supplemental information to identify any discrepancies or inaccuracies. Once identified, corrections are made to ensure that all data aligns with federal and institutional requirements. 2. Final Confirmation and Awarding: After the necessary corrections are implemented, a secondary review is conducted by the Assistant Director to confirm that the adjustments are accurate. This ensures that students receive the correct financial aid awards based on updated and verified information. To maintain transparency, accountability, and an adequate documentation trail. It is imperative that any comments added to student accounts are detailed and include pertinent information regarding the verification process. This documentation serves as a record of the actions taken and aids in future audits and reviews. The Assistant Director of Financial Aid is a very experienced financial aid professional and holds NASFAA certifications in Verification, R2T4, Student Eligibility, Direct Loans and Professional Judgement. The Assistant Director plays a pivotal role in the verification process, being responsible for updating the BPG to reflect any changes in regulations or best practices. Additionally, the Assistant Director will lead training sessions for staff members to ensure they are well-versed in the verification procedures outlined in the BPG. Ongoing training will be provided as needed to accommodate changes in policies or technologies. By implementing this structured approach to verification corrections, the University aims to enhance the accuracy of financial aid processing and improve the overall student experience.

Student Financial Assistance Cluster Federal Supplemental Educational Opportunity Grants, ALN 84.007; Federal Work-Study Program, ALN 84.033 Federal Pell Grant Program, ALN 84.063 Federal Direct Student Loans, ALN 84.268 Teacher Education Assistance for College and Higher Education Grants, ALN 84.379 U.S. Department of Education Program Year 2023-2024 Criteria or specific requirement – Special Tests and Provisions – Verification (34 CFR 668.51 through 668.61) Institutions responsible for verifying applicant information for those applicants selected by verification by the U.S. Department of Education. Condition – The University’s processes did not ensure corrections were made to student application data. Questioned costs – Unknown Context – Out of the population of 189 students selected for verification, a sample of 19 students were selected for testing. Our sampling method was not, and was not intended to be, statistically valid. The number of household members was not corrected on the student’s Institutional Student Information Record (ISIR) for one student, and the adjusted gross income was not corrected on the student’s ISIR for one student. Effect – The student’s applicant data was not correct when used for packaging and awarding aid. Identification as a repeat finding, if applicable – N/A Recommendation – The University should update their controls to ensure student data is properly corrected on the students’ ISIRs in the verification process. Views of responsible officials and planned corrective actions – The auditors identified two issues related to verification of financial aid data supplied on the FAFSA by students. Both findings were from the fall of 2023 and in both cases a secondary review was completed and still was not accurately completed. The Office of Financial Aid developed and implemented a comprehensive Business Process Guide (BPG) on October 17, 2024. The guide is aimed at ensuring that all required fields within the verification process are meticulously reviewed and corrected as needed. This guide serves as a crucial resource for staff involved in the financial aid verification process, outlining best practices and standard procedures to maintain compliance and accuracy. The verification correction process follows a two-step approach: 1. Initial Review and Correction: Staff members are required to conduct a thorough review of the required data fields. This involves checking the required ISIR data fields against other supplemental information to identify any discrepancies or inaccuracies. Once identified, corrections are made to ensure that all data aligns with federal and institutional requirements. 2. Final Confirmation and Awarding: After the necessary corrections are implemented, a secondary review is conducted by the Assistant Director to confirm that the adjustments are accurate. This ensures that students receive the correct financial aid awards based on updated and verified information. To maintain transparency, accountability, and an adequate documentation trail. It is imperative that any comments added to student accounts are detailed and include pertinent information regarding the verification process. This documentation serves as a record of the actions taken and aids in future audits and reviews. The Assistant Director of Financial Aid is a very experienced financial aid professional and holds NASFAA certifications in Verification, R2T4, Student Eligibility, Direct Loans and Professional Judgement. The Assistant Director plays a pivotal role in the verification process, being responsible for updating the BPG to reflect any changes in regulations or best practices. Additionally, the Assistant Director will lead training sessions for staff members to ensure they are well-versed in the verification procedures outlined in the BPG. Ongoing training will be provided as needed to accommodate changes in policies or technologies. By implementing this structured approach to verification corrections, the University aims to enhance the accuracy of financial aid processing and improve the overall student experience.

Student Financial Assistance Cluster Federal Supplemental Educational Opportunity Grants, ALN 84.007; Federal Work-Study Program, ALN 84.033 Federal Pell Grant Program, ALN 84.063 Federal Direct Student Loans, ALN 84.268 Teacher Education Assistance for College and Higher Education Grants, ALN 84.379 U.S. Department of Education Program Year 2023-2024 Criteria or specific requirement – Special Tests and Provisions – Verification (34 CFR 668.51 through 668.61) Institutions responsible for verifying applicant information for those applicants selected by verification by the U.S. Department of Education. Condition – The University’s processes did not ensure corrections were made to student application data. Questioned costs – Unknown Context – Out of the population of 189 students selected for verification, a sample of 19 students were selected for testing. Our sampling method was not, and was not intended to be, statistically valid. The number of household members was not corrected on the student’s Institutional Student Information Record (ISIR) for one student, and the adjusted gross income was not corrected on the student’s ISIR for one student. Effect – The student’s applicant data was not correct when used for packaging and awarding aid. Identification as a repeat finding, if applicable – N/A Recommendation – The University should update their controls to ensure student data is properly corrected on the students’ ISIRs in the verification process. Views of responsible officials and planned corrective actions – The auditors identified two issues related to verification of financial aid data supplied on the FAFSA by students. Both findings were from the fall of 2023 and in both cases a secondary review was completed and still was not accurately completed. The Office of Financial Aid developed and implemented a comprehensive Business Process Guide (BPG) on October 17, 2024. The guide is aimed at ensuring that all required fields within the verification process are meticulously reviewed and corrected as needed. This guide serves as a crucial resource for staff involved in the financial aid verification process, outlining best practices and standard procedures to maintain compliance and accuracy. The verification correction process follows a two-step approach: 1. Initial Review and Correction: Staff members are required to conduct a thorough review of the required data fields. This involves checking the required ISIR data fields against other supplemental information to identify any discrepancies or inaccuracies. Once identified, corrections are made to ensure that all data aligns with federal and institutional requirements. 2. Final Confirmation and Awarding: After the necessary corrections are implemented, a secondary review is conducted by the Assistant Director to confirm that the adjustments are accurate. This ensures that students receive the correct financial aid awards based on updated and verified information. To maintain transparency, accountability, and an adequate documentation trail. It is imperative that any comments added to student accounts are detailed and include pertinent information regarding the verification process. This documentation serves as a record of the actions taken and aids in future audits and reviews. The Assistant Director of Financial Aid is a very experienced financial aid professional and holds NASFAA certifications in Verification, R2T4, Student Eligibility, Direct Loans and Professional Judgement. The Assistant Director plays a pivotal role in the verification process, being responsible for updating the BPG to reflect any changes in regulations or best practices. Additionally, the Assistant Director will lead training sessions for staff members to ensure they are well-versed in the verification procedures outlined in the BPG. Ongoing training will be provided as needed to accommodate changes in policies or technologies. By implementing this structured approach to verification corrections, the University aims to enhance the accuracy of financial aid processing and improve the overall student experience.

Student Financial Assistance Cluster Federal Supplemental Educational Opportunity Grants, ALN 84.007; Federal Work-Study Program, ALN 84.033 Federal Pell Grant Program, ALN 84.063 Federal Direct Student Loans, ALN 84.268 Teacher Education Assistance for College and Higher Education Grants, ALN 84.379 U.S. Department of Education Program Year 2023-2024 Criteria or specific requirement – Eligibility – Students must maintain good standing, or satisfactory academic progress (34 CFRs 668.16, 668.32(f), 668.34, 690.75, 675.9, 676.9, 685.200, 686.11, 20 USC 1070h; 42 CFR 57.306; 42 USC 293a(d)(2)). Condition – A student was awarded aid who did not meet satisfactory academic progress standards per the University’s policy Questioned costs - $6,761 – ALN 84.268 Context – Out of a population of 1,724 students who received aid, a sample of 25 students was selected for testing. Our sampling method was not, and was not intended to be, statistically valid. One student received aid who had not met satisfactory academic progress standards per the University’s policy. Effect – Aid was awarded to one student who was not eligible to receive aid. Identification as a repeat finding, if applicable – N/A Recommendation – The University should update their controls to ensure no students receive aid who have not met satisfactory academic progress standards. Views of responsible officials and planned corrective actions – The audit noted one student was awarded financial aid despite not meeting Satisfactory Academic Progress (SAP) standards. The issue stemmed from a lapse in the SAP review process at the end of the Fall 2023 term, which was primarily attributed to staff turnover and insufficient training for remaining personnel. When the student did not enroll for the Spring term but later registered for the Summer 2024 session, there were no safeguards in place to prevent the system from awarding financial aid. This oversight highlighted a gap in the current process, emphasizing the need for a more robust mechanism to flag students who are not in compliance with SAP prior to awarding financial aid. In the new organizational structure, the Financial Aid Business Analyst is responsible for executing the SAP process. This individual has approximately 10 years of experience working with SAP processes. During the 2023-2024 academic year the University worked diligently to respond to a Federal Program Review from the U.S. Department of Education, (ED). As a result of the corrective actions being undertaken by the University new procedures in many areas were being drafted and implemented. A new Director of Financial Aid, with over 30 years of experience in financial aid, was hired to improve the overall student service and compliance with the Federal Title IV program. The new director commenced his duties on February 1, 2024. Since that time the University has reorganized the financial aid office by creating an Assistant Director and Financial Aid Business Analyst position who have increased the expertise and overall years of financial aid experience. A leadership team including the Director of Financial Aid, Registrar, Director of Student Accounts, Associate Provost, Provost and Vice President for Finance and Administration was created in January 2024 and meet bi-weekly to discuss Title IV compliance topics, process improvement and customer service. Most of the Financial Aid team’s time in the spring and summer was spent working on the new FAFSA, the team has redirected their efforts in training, standardizing, documenting and improving processes to ensure Title IV compliance and better serve students.

Student Financial Assistance Cluster Federal Supplemental Educational Opportunity Grants, ALN 84.007; Federal Work-Study Program, ALN 84.033 Federal Pell Grant Program, ALN 84.063 Federal Direct Student Loans, ALN 84.268 Teacher Education Assistance for College and Higher Education Grants, ALN 84.379 U.S. Department of Education Program Year 2023-2024 Criteria or specific requirement – Eligibility – Students must maintain good standing, or satisfactory academic progress (34 CFRs 668.16, 668.32(f), 668.34, 690.75, 675.9, 676.9, 685.200, 686.11, 20 USC 1070h; 42 CFR 57.306; 42 USC 293a(d)(2)). Condition – A student was awarded aid who did not meet satisfactory academic progress standards per the University’s policy Questioned costs - $6,761 – ALN 84.268 Context – Out of a population of 1,724 students who received aid, a sample of 25 students was selected for testing. Our sampling method was not, and was not intended to be, statistically valid. One student received aid who had not met satisfactory academic progress standards per the University’s policy. Effect – Aid was awarded to one student who was not eligible to receive aid. Identification as a repeat finding, if applicable – N/A Recommendation – The University should update their controls to ensure no students receive aid who have not met satisfactory academic progress standards. Views of responsible officials and planned corrective actions – The audit noted one student was awarded financial aid despite not meeting Satisfactory Academic Progress (SAP) standards. The issue stemmed from a lapse in the SAP review process at the end of the Fall 2023 term, which was primarily attributed to staff turnover and insufficient training for remaining personnel. When the student did not enroll for the Spring term but later registered for the Summer 2024 session, there were no safeguards in place to prevent the system from awarding financial aid. This oversight highlighted a gap in the current process, emphasizing the need for a more robust mechanism to flag students who are not in compliance with SAP prior to awarding financial aid. In the new organizational structure, the Financial Aid Business Analyst is responsible for executing the SAP process. This individual has approximately 10 years of experience working with SAP processes. During the 2023-2024 academic year the University worked diligently to respond to a Federal Program Review from the U.S. Department of Education, (ED). As a result of the corrective actions being undertaken by the University new procedures in many areas were being drafted and implemented. A new Director of Financial Aid, with over 30 years of experience in financial aid, was hired to improve the overall student service and compliance with the Federal Title IV program. The new director commenced his duties on February 1, 2024. Since that time the University has reorganized the financial aid office by creating an Assistant Director and Financial Aid Business Analyst position who have increased the expertise and overall years of financial aid experience. A leadership team including the Director of Financial Aid, Registrar, Director of Student Accounts, Associate Provost, Provost and Vice President for Finance and Administration was created in January 2024 and meet bi-weekly to discuss Title IV compliance topics, process improvement and customer service. Most of the Financial Aid team’s time in the spring and summer was spent working on the new FAFSA, the team has redirected their efforts in training, standardizing, documenting and improving processes to ensure Title IV compliance and better serve students.

Student Financial Assistance Cluster Federal Supplemental Educational Opportunity Grants, ALN 84.007; Federal Work-Study Program, ALN 84.033 Federal Pell Grant Program, ALN 84.063 Federal Direct Student Loans, ALN 84.268 Teacher Education Assistance for College and Higher Education Grants, ALN 84.379 U.S. Department of Education Program Year 2023-2024 Criteria or specific requirement – Eligibility – Students must maintain good standing, or satisfactory academic progress (34 CFRs 668.16, 668.32(f), 668.34, 690.75, 675.9, 676.9, 685.200, 686.11, 20 USC 1070h; 42 CFR 57.306; 42 USC 293a(d)(2)). Condition – A student was awarded aid who did not meet satisfactory academic progress standards per the University’s policy Questioned costs - $6,761 – ALN 84.268 Context – Out of a population of 1,724 students who received aid, a sample of 25 students was selected for testing. Our sampling method was not, and was not intended to be, statistically valid. One student received aid who had not met satisfactory academic progress standards per the University’s policy. Effect – Aid was awarded to one student who was not eligible to receive aid. Identification as a repeat finding, if applicable – N/A Recommendation – The University should update their controls to ensure no students receive aid who have not met satisfactory academic progress standards. Views of responsible officials and planned corrective actions – The audit noted one student was awarded financial aid despite not meeting Satisfactory Academic Progress (SAP) standards. The issue stemmed from a lapse in the SAP review process at the end of the Fall 2023 term, which was primarily attributed to staff turnover and insufficient training for remaining personnel. When the student did not enroll for the Spring term but later registered for the Summer 2024 session, there were no safeguards in place to prevent the system from awarding financial aid. This oversight highlighted a gap in the current process, emphasizing the need for a more robust mechanism to flag students who are not in compliance with SAP prior to awarding financial aid. In the new organizational structure, the Financial Aid Business Analyst is responsible for executing the SAP process. This individual has approximately 10 years of experience working with SAP processes. During the 2023-2024 academic year the University worked diligently to respond to a Federal Program Review from the U.S. Department of Education, (ED). As a result of the corrective actions being undertaken by the University new procedures in many areas were being drafted and implemented. A new Director of Financial Aid, with over 30 years of experience in financial aid, was hired to improve the overall student service and compliance with the Federal Title IV program. The new director commenced his duties on February 1, 2024. Since that time the University has reorganized the financial aid office by creating an Assistant Director and Financial Aid Business Analyst position who have increased the expertise and overall years of financial aid experience. A leadership team including the Director of Financial Aid, Registrar, Director of Student Accounts, Associate Provost, Provost and Vice President for Finance and Administration was created in January 2024 and meet bi-weekly to discuss Title IV compliance topics, process improvement and customer service. Most of the Financial Aid team’s time in the spring and summer was spent working on the new FAFSA, the team has redirected their efforts in training, standardizing, documenting and improving processes to ensure Title IV compliance and better serve students.

Student Financial Assistance Cluster Federal Supplemental Educational Opportunity Grants, ALN 84.007; Federal Work-Study Program, ALN 84.033 Federal Pell Grant Program, ALN 84.063 Federal Direct Student Loans, ALN 84.268 Teacher Education Assistance for College and Higher Education Grants, ALN 84.379 U.S. Department of Education Program Year 2023-2024 Criteria or specific requirement – Eligibility – Students must maintain good standing, or satisfactory academic progress (34 CFRs 668.16, 668.32(f), 668.34, 690.75, 675.9, 676.9, 685.200, 686.11, 20 USC 1070h; 42 CFR 57.306; 42 USC 293a(d)(2)). Condition – A student was awarded aid who did not meet satisfactory academic progress standards per the University’s policy Questioned costs - $6,761 – ALN 84.268 Context – Out of a population of 1,724 students who received aid, a sample of 25 students was selected for testing. Our sampling method was not, and was not intended to be, statistically valid. One student received aid who had not met satisfactory academic progress standards per the University’s policy. Effect – Aid was awarded to one student who was not eligible to receive aid. Identification as a repeat finding, if applicable – N/A Recommendation – The University should update their controls to ensure no students receive aid who have not met satisfactory academic progress standards. Views of responsible officials and planned corrective actions – The audit noted one student was awarded financial aid despite not meeting Satisfactory Academic Progress (SAP) standards. The issue stemmed from a lapse in the SAP review process at the end of the Fall 2023 term, which was primarily attributed to staff turnover and insufficient training for remaining personnel. When the student did not enroll for the Spring term but later registered for the Summer 2024 session, there were no safeguards in place to prevent the system from awarding financial aid. This oversight highlighted a gap in the current process, emphasizing the need for a more robust mechanism to flag students who are not in compliance with SAP prior to awarding financial aid. In the new organizational structure, the Financial Aid Business Analyst is responsible for executing the SAP process. This individual has approximately 10 years of experience working with SAP processes. During the 2023-2024 academic year the University worked diligently to respond to a Federal Program Review from the U.S. Department of Education, (ED). As a result of the corrective actions being undertaken by the University new procedures in many areas were being drafted and implemented. A new Director of Financial Aid, with over 30 years of experience in financial aid, was hired to improve the overall student service and compliance with the Federal Title IV program. The new director commenced his duties on February 1, 2024. Since that time the University has reorganized the financial aid office by creating an Assistant Director and Financial Aid Business Analyst position who have increased the expertise and overall years of financial aid experience. A leadership team including the Director of Financial Aid, Registrar, Director of Student Accounts, Associate Provost, Provost and Vice President for Finance and Administration was created in January 2024 and meet bi-weekly to discuss Title IV compliance topics, process improvement and customer service. Most of the Financial Aid team’s time in the spring and summer was spent working on the new FAFSA, the team has redirected their efforts in training, standardizing, documenting and improving processes to ensure Title IV compliance and better serve students.

Student Financial Assistance Cluster Federal Supplemental Educational Opportunity Grants, ALN 84.007; Federal Work-Study Program, ALN 84.033 Federal Pell Grant Program, ALN 84.063 Federal Direct Student Loans, ALN 84.268 Teacher Education Assistance for College and Higher Education Grants, ALN 84.379 U.S. Department of Education Program Year 2023-2024 Criteria or specific requirement – Eligibility – Students must maintain good standing, or satisfactory academic progress (34 CFRs 668.16, 668.32(f), 668.34, 690.75, 675.9, 676.9, 685.200, 686.11, 20 USC 1070h; 42 CFR 57.306; 42 USC 293a(d)(2)). Condition – A student was awarded aid who did not meet satisfactory academic progress standards per the University’s policy Questioned costs - $6,761 – ALN 84.268 Context – Out of a population of 1,724 students who received aid, a sample of 25 students was selected for testing. Our sampling method was not, and was not intended to be, statistically valid. One student received aid who had not met satisfactory academic progress standards per the University’s policy. Effect – Aid was awarded to one student who was not eligible to receive aid. Identification as a repeat finding, if applicable – N/A Recommendation – The University should update their controls to ensure no students receive aid who have not met satisfactory academic progress standards. Views of responsible officials and planned corrective actions – The audit noted one student was awarded financial aid despite not meeting Satisfactory Academic Progress (SAP) standards. The issue stemmed from a lapse in the SAP review process at the end of the Fall 2023 term, which was primarily attributed to staff turnover and insufficient training for remaining personnel. When the student did not enroll for the Spring term but later registered for the Summer 2024 session, there were no safeguards in place to prevent the system from awarding financial aid. This oversight highlighted a gap in the current process, emphasizing the need for a more robust mechanism to flag students who are not in compliance with SAP prior to awarding financial aid. In the new organizational structure, the Financial Aid Business Analyst is responsible for executing the SAP process. This individual has approximately 10 years of experience working with SAP processes. During the 2023-2024 academic year the University worked diligently to respond to a Federal Program Review from the U.S. Department of Education, (ED). As a result of the corrective actions being undertaken by the University new procedures in many areas were being drafted and implemented. A new Director of Financial Aid, with over 30 years of experience in financial aid, was hired to improve the overall student service and compliance with the Federal Title IV program. The new director commenced his duties on February 1, 2024. Since that time the University has reorganized the financial aid office by creating an Assistant Director and Financial Aid Business Analyst position who have increased the expertise and overall years of financial aid experience. A leadership team including the Director of Financial Aid, Registrar, Director of Student Accounts, Associate Provost, Provost and Vice President for Finance and Administration was created in January 2024 and meet bi-weekly to discuss Title IV compliance topics, process improvement and customer service. Most of the Financial Aid team’s time in the spring and summer was spent working on the new FAFSA, the team has redirected their efforts in training, standardizing, documenting and improving processes to ensure Title IV compliance and better serve students.

Student Financial Assistance Cluster Federal Supplemental Educational Opportunity Grants, ALN 84.007; Federal Work-Study Program, ALN 84.033 Federal Pell Grant Program, ALN 84.063 Federal Direct Student Loans, ALN 84.268 Teacher Education Assistance for College and Higher Education Grants, ALN 84.379 U.S. Department of Education Program Year 2023-2024 Criteria or specific requirement – Special Tests and Provisions – Return of Title IV Funds (34 CFR 668.22(a)(1) through (a)(5) Condition – The University’s internal controls did not ensure the calculation of amounts to be returned to the U.S. Department of Education were correct and were performed timely. Questioned costs - $0 Context – Out of the population of 73 students who withdrew, 11 were selected for testing. Our sampling method was not, and was not intended to be, statistically valid. Total days in the semester for the fall semester was calculated incorrectly due to using an incorrect number of break days. Additionally, 2 students did not receive timely post-withdrawal disbursements. Effect – One student completed 60 percent of the semester, but the return of Title IV funds amount was calculated showing an amount to be returned to the U.S. Department of Education. Additionally, 2 students received post-withdrawal disbursements approximately 10 months after their withdrawal. Cause – The University’s internal controls did not ensure proper inputting of semester information into the calculation of returns of Title IV funds based on total days in the semester and total days attended, and did not ensure student received post-withdrawal disbursements timely. Identification as a repeat finding, if applicable – 2023-001 and 2022-001 Recommendation – The University should update their controls to ensure total days in the semester are calculated correctly and post-withdrawal disbursements are made timely. Views of responsible officials and planned corrective actions – With the new Financial Aid leadership, the university has already implemented many new strategies to strengthen the Return of Title IV Funds (R2T4) process. The University created a new position, Financial Aid Business Analyst, whose primary responsibility is to maintain financial aid systems, maintain process documentation and provide staff system training and to oversee the R2T4 process. The Financial Aid Business Analyst has two years of previous experience being responsible for R2T4 calculations, completed the National Association of Student Financial Aid Administrators (NASFAA) R2T4 five-week certification program on October 14, 2024, and is in the process of training a Financial Advisor in performing R2T4 calculations. Other areas that have been identified will improve the R2T4 process are as follows: 1. Earlier Availability of the Academic Calendar: The Financial Aid Office leadership (Director, Assistant Director, Financial Aid Business Analyst) will work with the Office of Student Records (Registrar and Deputy Registrar) to ensure that there is an accurate R2T4/academic calendar. Both offices will work to develop such calendars with a clear description of the dates the University is closed for students, and that calendars can be developed years in advance. This will facilitate accurate determination of begin/end dates, break days and the total number of class days within any term. This will also encourage greater levels of transparency and oversight by both offices. The R2T4/academic calendar will also be shared with the Student Accounts Office, adding additional transparency and understanding. Timeline: The calendar for the Spring semester 2025 and the 2025-2026 academic calendar has already been developed and approved. The 2026-2027 academic calendar has been submitted to faculty for their input and will be completed by November 30, 2024. 2. Daily Percentage Calculator: The Financial Aid Business Analyst developed a daily percentage calculator that, implemented for Fall 2024, when combined with the academic calendar, will enable the accurate input of all term dates to generate precise daily percentage calculations for R2T4 purposes. This is also being expanded to create sub-term daily percentage calculations to eliminate the need for manual completion with each module-type calculation. 1. Post-Withdrawal Disbursements: The Financial Aid Business Analyst worked with Information Technology to ensure required communications related to R2T4 including post withdrawals (PWD) are now an automated process after completion of the calculations. This automation was implemented in August 2024. The PWD findings in this audit were the work by previous leadership within the Financial Aid Office. 2. Collaboration with IT for Updated Reporting: Financial Aid Office leadership (Financial Aid Business Analyst, Director) are collaborating with the IT to develop updated reports that will help accurately identify students who have unofficially withdrawn and require review during the R2T4 process. This initiative aims to create a preventive control that identifies errors and ensure timely calculations. The timeline for completion of the updated report is November 30, 2024. 3. Strengthening Internal Controls: The Director of Financial Aid has identified a Financial Aid Advisor who is currently being trained on R2T4 process, and who will eventually assume the primary responsibility for R2T4 calculations. The Financial Aid Business Analyst will provide secondary reviews to ensure accuracy and consistency. Note: The two PWDs from the Fall 2023 semester highlight a significant oversight by previous financial aid leadership. The inadvertent miscalculation of break days stemmed from confusion about the academic calendar. It appeared to suggest that students were required to attend classes on the weekend proceeding Thanksgiving week, while in reality, classes concluded the prior Friday. As a result, the Fall break should have been calculated as 9 days instead of 7.

Student Financial Assistance Cluster Federal Supplemental Educational Opportunity Grants, ALN 84.007; Federal Work-Study Program, ALN 84.033 Federal Pell Grant Program, ALN 84.063 Federal Direct Student Loans, ALN 84.268 Teacher Education Assistance for College and Higher Education Grants, ALN 84.379 U.S. Department of Education Program Year 2023-2024 Criteria or specific requirement – Special Tests and Provisions – Return of Title IV Funds (34 CFR 668.22(a)(1) through (a)(5) Condition – The University’s internal controls did not ensure the calculation of amounts to be returned to the U.S. Department of Education were correct and were performed timely. Questioned costs - $0 Context – Out of the population of 73 students who withdrew, 11 were selected for testing. Our sampling method was not, and was not intended to be, statistically valid. Total days in the semester for the fall semester was calculated incorrectly due to using an incorrect number of break days. Additionally, 2 students did not receive timely post-withdrawal disbursements. Effect – One student completed 60 percent of the semester, but the return of Title IV funds amount was calculated showing an amount to be returned to the U.S. Department of Education. Additionally, 2 students received post-withdrawal disbursements approximately 10 months after their withdrawal. Cause – The University’s internal controls did not ensure proper inputting of semester information into the calculation of returns of Title IV funds based on total days in the semester and total days attended, and did not ensure student received post-withdrawal disbursements timely. Identification as a repeat finding, if applicable – 2023-001 and 2022-001 Recommendation – The University should update their controls to ensure total days in the semester are calculated correctly and post-withdrawal disbursements are made timely. Views of responsible officials and planned corrective actions – With the new Financial Aid leadership, the university has already implemented many new strategies to strengthen the Return of Title IV Funds (R2T4) process. The University created a new position, Financial Aid Business Analyst, whose primary responsibility is to maintain financial aid systems, maintain process documentation and provide staff system training and to oversee the R2T4 process. The Financial Aid Business Analyst has two years of previous experience being responsible for R2T4 calculations, completed the National Association of Student Financial Aid Administrators (NASFAA) R2T4 five-week certification program on October 14, 2024, and is in the process of training a Financial Advisor in performing R2T4 calculations. Other areas that have been identified will improve the R2T4 process are as follows: 1. Earlier Availability of the Academic Calendar: The Financial Aid Office leadership (Director, Assistant Director, Financial Aid Business Analyst) will work with the Office of Student Records (Registrar and Deputy Registrar) to ensure that there is an accurate R2T4/academic calendar. Both offices will work to develop such calendars with a clear description of the dates the University is closed for students, and that calendars can be developed years in advance. This will facilitate accurate determination of begin/end dates, break days and the total number of class days within any term. This will also encourage greater levels of transparency and oversight by both offices. The R2T4/academic calendar will also be shared with the Student Accounts Office, adding additional transparency and understanding. Timeline: The calendar for the Spring semester 2025 and the 2025-2026 academic calendar has already been developed and approved. The 2026-2027 academic calendar has been submitted to faculty for their input and will be completed by November 30, 2024. 2. Daily Percentage Calculator: The Financial Aid Business Analyst developed a daily percentage calculator that, implemented for Fall 2024, when combined with the academic calendar, will enable the accurate input of all term dates to generate precise daily percentage calculations for R2T4 purposes. This is also being expanded to create sub-term daily percentage calculations to eliminate the need for manual completion with each module-type calculation. 1. Post-Withdrawal Disbursements: The Financial Aid Business Analyst worked with Information Technology to ensure required communications related to R2T4 including post withdrawals (PWD) are now an automated process after completion of the calculations. This automation was implemented in August 2024. The PWD findings in this audit were the work by previous leadership within the Financial Aid Office. 2. Collaboration with IT for Updated Reporting: Financial Aid Office leadership (Financial Aid Business Analyst, Director) are collaborating with the IT to develop updated reports that will help accurately identify students who have unofficially withdrawn and require review during the R2T4 process. This initiative aims to create a preventive control that identifies errors and ensure timely calculations. The timeline for completion of the updated report is November 30, 2024. 3. Strengthening Internal Controls: The Director of Financial Aid has identified a Financial Aid Advisor who is currently being trained on R2T4 process, and who will eventually assume the primary responsibility for R2T4 calculations. The Financial Aid Business Analyst will provide secondary reviews to ensure accuracy and consistency. Note: The two PWDs from the Fall 2023 semester highlight a significant oversight by previous financial aid leadership. The inadvertent miscalculation of break days stemmed from confusion about the academic calendar. It appeared to suggest that students were required to attend classes on the weekend proceeding Thanksgiving week, while in reality, classes concluded the prior Friday. As a result, the Fall break should have been calculated as 9 days instead of 7.

Student Financial Assistance Cluster Federal Supplemental Educational Opportunity Grants, ALN 84.007; Federal Work-Study Program, ALN 84.033 Federal Pell Grant Program, ALN 84.063 Federal Direct Student Loans, ALN 84.268 Teacher Education Assistance for College and Higher Education Grants, ALN 84.379 U.S. Department of Education Program Year 2023-2024 Criteria or specific requirement – Special Tests and Provisions – Return of Title IV Funds (34 CFR 668.22(a)(1) through (a)(5) Condition – The University’s internal controls did not ensure the calculation of amounts to be returned to the U.S. Department of Education were correct and were performed timely. Questioned costs - $0 Context – Out of the population of 73 students who withdrew, 11 were selected for testing. Our sampling method was not, and was not intended to be, statistically valid. Total days in the semester for the fall semester was calculated incorrectly due to using an incorrect number of break days. Additionally, 2 students did not receive timely post-withdrawal disbursements. Effect – One student completed 60 percent of the semester, but the return of Title IV funds amount was calculated showing an amount to be returned to the U.S. Department of Education. Additionally, 2 students received post-withdrawal disbursements approximately 10 months after their withdrawal. Cause – The University’s internal controls did not ensure proper inputting of semester information into the calculation of returns of Title IV funds based on total days in the semester and total days attended, and did not ensure student received post-withdrawal disbursements timely. Identification as a repeat finding, if applicable – 2023-001 and 2022-001 Recommendation – The University should update their controls to ensure total days in the semester are calculated correctly and post-withdrawal disbursements are made timely. Views of responsible officials and planned corrective actions – With the new Financial Aid leadership, the university has already implemented many new strategies to strengthen the Return of Title IV Funds (R2T4) process. The University created a new position, Financial Aid Business Analyst, whose primary responsibility is to maintain financial aid systems, maintain process documentation and provide staff system training and to oversee the R2T4 process. The Financial Aid Business Analyst has two years of previous experience being responsible for R2T4 calculations, completed the National Association of Student Financial Aid Administrators (NASFAA) R2T4 five-week certification program on October 14, 2024, and is in the process of training a Financial Advisor in performing R2T4 calculations. Other areas that have been identified will improve the R2T4 process are as follows: 1. Earlier Availability of the Academic Calendar: The Financial Aid Office leadership (Director, Assistant Director, Financial Aid Business Analyst) will work with the Office of Student Records (Registrar and Deputy Registrar) to ensure that there is an accurate R2T4/academic calendar. Both offices will work to develop such calendars with a clear description of the dates the University is closed for students, and that calendars can be developed years in advance. This will facilitate accurate determination of begin/end dates, break days and the total number of class days within any term. This will also encourage greater levels of transparency and oversight by both offices. The R2T4/academic calendar will also be shared with the Student Accounts Office, adding additional transparency and understanding. Timeline: The calendar for the Spring semester 2025 and the 2025-2026 academic calendar has already been developed and approved. The 2026-2027 academic calendar has been submitted to faculty for their input and will be completed by November 30, 2024. 2. Daily Percentage Calculator: The Financial Aid Business Analyst developed a daily percentage calculator that, implemented for Fall 2024, when combined with the academic calendar, will enable the accurate input of all term dates to generate precise daily percentage calculations for R2T4 purposes. This is also being expanded to create sub-term daily percentage calculations to eliminate the need for manual completion with each module-type calculation. 1. Post-Withdrawal Disbursements: The Financial Aid Business Analyst worked with Information Technology to ensure required communications related to R2T4 including post withdrawals (PWD) are now an automated process after completion of the calculations. This automation was implemented in August 2024. The PWD findings in this audit were the work by previous leadership within the Financial Aid Office. 2. Collaboration with IT for Updated Reporting: Financial Aid Office leadership (Financial Aid Business Analyst, Director) are collaborating with the IT to develop updated reports that will help accurately identify students who have unofficially withdrawn and require review during the R2T4 process. This initiative aims to create a preventive control that identifies errors and ensure timely calculations. The timeline for completion of the updated report is November 30, 2024. 3. Strengthening Internal Controls: The Director of Financial Aid has identified a Financial Aid Advisor who is currently being trained on R2T4 process, and who will eventually assume the primary responsibility for R2T4 calculations. The Financial Aid Business Analyst will provide secondary reviews to ensure accuracy and consistency. Note: The two PWDs from the Fall 2023 semester highlight a significant oversight by previous financial aid leadership. The inadvertent miscalculation of break days stemmed from confusion about the academic calendar. It appeared to suggest that students were required to attend classes on the weekend proceeding Thanksgiving week, while in reality, classes concluded the prior Friday. As a result, the Fall break should have been calculated as 9 days instead of 7.

Student Financial Assistance Cluster Federal Supplemental Educational Opportunity Grants, ALN 84.007; Federal Work-Study Program, ALN 84.033 Federal Pell Grant Program, ALN 84.063 Federal Direct Student Loans, ALN 84.268 Teacher Education Assistance for College and Higher Education Grants, ALN 84.379 U.S. Department of Education Program Year 2023-2024 Criteria or specific requirement – Special Tests and Provisions – Return of Title IV Funds (34 CFR 668.22(a)(1) through (a)(5) Condition – The University’s internal controls did not ensure the calculation of amounts to be returned to the U.S. Department of Education were correct and were performed timely. Questioned costs - $0 Context – Out of the population of 73 students who withdrew, 11 were selected for testing. Our sampling method was not, and was not intended to be, statistically valid. Total days in the semester for the fall semester was calculated incorrectly due to using an incorrect number of break days. Additionally, 2 students did not receive timely post-withdrawal disbursements. Effect – One student completed 60 percent of the semester, but the return of Title IV funds amount was calculated showing an amount to be returned to the U.S. Department of Education. Additionally, 2 students received post-withdrawal disbursements approximately 10 months after their withdrawal. Cause – The University’s internal controls did not ensure proper inputting of semester information into the calculation of returns of Title IV funds based on total days in the semester and total days attended, and did not ensure student received post-withdrawal disbursements timely. Identification as a repeat finding, if applicable – 2023-001 and 2022-001 Recommendation – The University should update their controls to ensure total days in the semester are calculated correctly and post-withdrawal disbursements are made timely. Views of responsible officials and planned corrective actions – With the new Financial Aid leadership, the university has already implemented many new strategies to strengthen the Return of Title IV Funds (R2T4) process. The University created a new position, Financial Aid Business Analyst, whose primary responsibility is to maintain financial aid systems, maintain process documentation and provide staff system training and to oversee the R2T4 process. The Financial Aid Business Analyst has two years of previous experience being responsible for R2T4 calculations, completed the National Association of Student Financial Aid Administrators (NASFAA) R2T4 five-week certification program on October 14, 2024, and is in the process of training a Financial Advisor in performing R2T4 calculations. Other areas that have been identified will improve the R2T4 process are as follows: 1. Earlier Availability of the Academic Calendar: The Financial Aid Office leadership (Director, Assistant Director, Financial Aid Business Analyst) will work with the Office of Student Records (Registrar and Deputy Registrar) to ensure that there is an accurate R2T4/academic calendar. Both offices will work to develop such calendars with a clear description of the dates the University is closed for students, and that calendars can be developed years in advance. This will facilitate accurate determination of begin/end dates, break days and the total number of class days within any term. This will also encourage greater levels of transparency and oversight by both offices. The R2T4/academic calendar will also be shared with the Student Accounts Office, adding additional transparency and understanding. Timeline: The calendar for the Spring semester 2025 and the 2025-2026 academic calendar has already been developed and approved. The 2026-2027 academic calendar has been submitted to faculty for their input and will be completed by November 30, 2024. 2. Daily Percentage Calculator: The Financial Aid Business Analyst developed a daily percentage calculator that, implemented for Fall 2024, when combined with the academic calendar, will enable the accurate input of all term dates to generate precise daily percentage calculations for R2T4 purposes. This is also being expanded to create sub-term daily percentage calculations to eliminate the need for manual completion with each module-type calculation. 1. Post-Withdrawal Disbursements: The Financial Aid Business Analyst worked with Information Technology to ensure required communications related to R2T4 including post withdrawals (PWD) are now an automated process after completion of the calculations. This automation was implemented in August 2024. The PWD findings in this audit were the work by previous leadership within the Financial Aid Office. 2. Collaboration with IT for Updated Reporting: Financial Aid Office leadership (Financial Aid Business Analyst, Director) are collaborating with the IT to develop updated reports that will help accurately identify students who have unofficially withdrawn and require review during the R2T4 process. This initiative aims to create a preventive control that identifies errors and ensure timely calculations. The timeline for completion of the updated report is November 30, 2024. 3. Strengthening Internal Controls: The Director of Financial Aid has identified a Financial Aid Advisor who is currently being trained on R2T4 process, and who will eventually assume the primary responsibility for R2T4 calculations. The Financial Aid Business Analyst will provide secondary reviews to ensure accuracy and consistency. Note: The two PWDs from the Fall 2023 semester highlight a significant oversight by previous financial aid leadership. The inadvertent miscalculation of break days stemmed from confusion about the academic calendar. It appeared to suggest that students were required to attend classes on the weekend proceeding Thanksgiving week, while in reality, classes concluded the prior Friday. As a result, the Fall break should have been calculated as 9 days instead of 7.

Student Financial Assistance Cluster Federal Supplemental Educational Opportunity Grants, ALN 84.007; Federal Work-Study Program, ALN 84.033 Federal Pell Grant Program, ALN 84.063 Federal Direct Student Loans, ALN 84.268 Teacher Education Assistance for College and Higher Education Grants, ALN 84.379 U.S. Department of Education Program Year 2023-2024 Criteria or specific requirement – Special Tests and Provisions – Return of Title IV Funds (34 CFR 668.22(a)(1) through (a)(5) Condition – The University’s internal controls did not ensure the calculation of amounts to be returned to the U.S. Department of Education were correct and were performed timely. Questioned costs - $0 Context – Out of the population of 73 students who withdrew, 11 were selected for testing. Our sampling method was not, and was not intended to be, statistically valid. Total days in the semester for the fall semester was calculated incorrectly due to using an incorrect number of break days. Additionally, 2 students did not receive timely post-withdrawal disbursements. Effect – One student completed 60 percent of the semester, but the return of Title IV funds amount was calculated showing an amount to be returned to the U.S. Department of Education. Additionally, 2 students received post-withdrawal disbursements approximately 10 months after their withdrawal. Cause – The University’s internal controls did not ensure proper inputting of semester information into the calculation of returns of Title IV funds based on total days in the semester and total days attended, and did not ensure student received post-withdrawal disbursements timely. Identification as a repeat finding, if applicable – 2023-001 and 2022-001 Recommendation – The University should update their controls to ensure total days in the semester are calculated correctly and post-withdrawal disbursements are made timely. Views of responsible officials and planned corrective actions – With the new Financial Aid leadership, the university has already implemented many new strategies to strengthen the Return of Title IV Funds (R2T4) process. The University created a new position, Financial Aid Business Analyst, whose primary responsibility is to maintain financial aid systems, maintain process documentation and provide staff system training and to oversee the R2T4 process. The Financial Aid Business Analyst has two years of previous experience being responsible for R2T4 calculations, completed the National Association of Student Financial Aid Administrators (NASFAA) R2T4 five-week certification program on October 14, 2024, and is in the process of training a Financial Advisor in performing R2T4 calculations. Other areas that have been identified will improve the R2T4 process are as follows: 1. Earlier Availability of the Academic Calendar: The Financial Aid Office leadership (Director, Assistant Director, Financial Aid Business Analyst) will work with the Office of Student Records (Registrar and Deputy Registrar) to ensure that there is an accurate R2T4/academic calendar. Both offices will work to develop such calendars with a clear description of the dates the University is closed for students, and that calendars can be developed years in advance. This will facilitate accurate determination of begin/end dates, break days and the total number of class days within any term. This will also encourage greater levels of transparency and oversight by both offices. The R2T4/academic calendar will also be shared with the Student Accounts Office, adding additional transparency and understanding. Timeline: The calendar for the Spring semester 2025 and the 2025-2026 academic calendar has already been developed and approved. The 2026-2027 academic calendar has been submitted to faculty for their input and will be completed by November 30, 2024. 2. Daily Percentage Calculator: The Financial Aid Business Analyst developed a daily percentage calculator that, implemented for Fall 2024, when combined with the academic calendar, will enable the accurate input of all term dates to generate precise daily percentage calculations for R2T4 purposes. This is also being expanded to create sub-term daily percentage calculations to eliminate the need for manual completion with each module-type calculation. 1. Post-Withdrawal Disbursements: The Financial Aid Business Analyst worked with Information Technology to ensure required communications related to R2T4 including post withdrawals (PWD) are now an automated process after completion of the calculations. This automation was implemented in August 2024. The PWD findings in this audit were the work by previous leadership within the Financial Aid Office. 2. Collaboration with IT for Updated Reporting: Financial Aid Office leadership (Financial Aid Business Analyst, Director) are collaborating with the IT to develop updated reports that will help accurately identify students who have unofficially withdrawn and require review during the R2T4 process. This initiative aims to create a preventive control that identifies errors and ensure timely calculations. The timeline for completion of the updated report is November 30, 2024. 3. Strengthening Internal Controls: The Director of Financial Aid has identified a Financial Aid Advisor who is currently being trained on R2T4 process, and who will eventually assume the primary responsibility for R2T4 calculations. The Financial Aid Business Analyst will provide secondary reviews to ensure accuracy and consistency. Note: The two PWDs from the Fall 2023 semester highlight a significant oversight by previous financial aid leadership. The inadvertent miscalculation of break days stemmed from confusion about the academic calendar. It appeared to suggest that students were required to attend classes on the weekend proceeding Thanksgiving week, while in reality, classes concluded the prior Friday. As a result, the Fall break should have been calculated as 9 days instead of 7.

Federal Pell Grant Program, ALN 84.063 Federal Direct Student Loans, ALN 84.268 U.S. Department of Education Program Year 2023-2024 Criteria or specific requirement – Special Tests and Provisions – Enrollment Reporting (34 CFR 690.93(b)(2); 34 CFR 682.610; 34 CFR 685.309). Institutions are required to report enrollment information. Condition – The University’s processes did not ensure timely and accurate student status reporting to National Student Loan Data System (NSLDS). Questioned costs – $0 Context – Out of the population of 580 students with changes in enrollment status, a sample of 25 students were selected for testing. Our sampling method was not, and was not intended to be, statistically valid. There were 14 attributes tested for each student with at least one status change. Campus-Level Records: 1. OPEID Number 2. Enrollment Effective Date 3. Enrollment Status 4. Certification Date Program-Level Records 5. OPEID 6. CIP Code 7. CIP Year 8. Credential Level 9. Published Program Length Measurement 10. Published Program Length 11. Program Begin Date 12. Program Enrollment Status 13. Program Enrollment Effective Date Other Records 14. Student changed his or her permanent address The University reported the incorrect Program Begin Date for 4 students. The University did not report one status change for 3 students who had multiple status changes. The University did not timely report status changes for 3 students. Effect – The University reported incorrect dates and statuses for students’ status changes and did not report the status changes timely. Cause – The University’s processes did not ensure status changes were reported timely and accurately. Identification as repeat finding, if applicable – 2023-002 Recommendation – The University should update their controls to ensure changes in students’ enrollment status are reported in a timely and accurate manner. Views of responsible officials and planned corrective actions – The Deputy Registrar from the Office of Student Records (OSR) is responsible for enrollment reporting to the National Student Loan Data System (NSLDS). The university uses a servicer, National Student Clearinghouse (NSC) to complete the reporting requirement. Enrollment data is scheduled to be transmitted to the NSC every thirty days to ensure timely reporting to the National Student Loan Data System (NSLDS). The University has consistently met this 30-day reporting to NSC. The audit noted four students had incorrect program start dates in NSLDS from April 2022 and August 2022, each off by one day. The University’s Student Information System (SIS) reflects the correct program start dates, indicating a potential issue in the data transmission between NSC and NSLDS. In July 2022, several announcements were made concerning the technical issues with NSLDS which prevented reporting for periods of time, including “NSLDS Professional Access – Documentation of Enrollment Reporting and Post screening Delays for Audit Purposes” published on August 31, 2022. The audit noted three errors related to timely reporting. The university’s SIS records indicate these records were reported to NSC within the 30-day timeframe. However, these records were not transmitted from NSC to NSLDS timely. The Deputy Registrar is currently collaborating with the NSC Compliance division to determine the cause of these discrepancies and how best to correct the records in NSLDS. A response from NSC is anticipated by October 31, 2024. The audit also noted three students who were less than full-time that were not reported to NSC or NSLDS. The Deputy Registrar is researching the SIS system rules to determine the root cause of these errors so they can be corrected. The Deputy Registrar will ensure the reporting rules will be corrected by November 30, 2024, and will ensure any less than full time students are corrected in NSLDS by December 30, 2024. To enhance the enrollment reporting process, the Deputy Registrar, Registrar, and Director of Financial Aid will meet with NSC staff and IT staff to establish a method for comparing monthly data submitted to NSC with the data in the NSLDS system. This will help identify any discrepancies for immediate correction. This project is expected to be completed by December 30, 2024.

Federal Pell Grant Program, ALN 84.063 Federal Direct Student Loans, ALN 84.268 U.S. Department of Education Program Year 2023-2024 Criteria or specific requirement – Special Tests and Provisions – Enrollment Reporting (34 CFR 690.93(b)(2); 34 CFR 682.610; 34 CFR 685.309). Institutions are required to report enrollment information. Condition – The University’s processes did not ensure timely and accurate student status reporting to National Student Loan Data System (NSLDS). Questioned costs – $0 Context – Out of the population of 580 students with changes in enrollment status, a sample of 25 students were selected for testing. Our sampling method was not, and was not intended to be, statistically valid. There were 14 attributes tested for each student with at least one status change. Campus-Level Records: 1. OPEID Number 2. Enrollment Effective Date 3. Enrollment Status 4. Certification Date Program-Level Records 5. OPEID 6. CIP Code 7. CIP Year 8. Credential Level 9. Published Program Length Measurement 10. Published Program Length 11. Program Begin Date 12. Program Enrollment Status 13. Program Enrollment Effective Date Other Records 14. Student changed his or her permanent address The University reported the incorrect Program Begin Date for 4 students. The University did not report one status change for 3 students who had multiple status changes. The University did not timely report status changes for 3 students. Effect – The University reported incorrect dates and statuses for students’ status changes and did not report the status changes timely. Cause – The University’s processes did not ensure status changes were reported timely and accurately. Identification as repeat finding, if applicable – 2023-002 Recommendation – The University should update their controls to ensure changes in students’ enrollment status are reported in a timely and accurate manner. Views of responsible officials and planned corrective actions – The Deputy Registrar from the Office of Student Records (OSR) is responsible for enrollment reporting to the National Student Loan Data System (NSLDS). The university uses a servicer, National Student Clearinghouse (NSC) to complete the reporting requirement. Enrollment data is scheduled to be transmitted to the NSC every thirty days to ensure timely reporting to the National Student Loan Data System (NSLDS). The University has consistently met this 30-day reporting to NSC. The audit noted four students had incorrect program start dates in NSLDS from April 2022 and August 2022, each off by one day. The University’s Student Information System (SIS) reflects the correct program start dates, indicating a potential issue in the data transmission between NSC and NSLDS. In July 2022, several announcements were made concerning the technical issues with NSLDS which prevented reporting for periods of time, including “NSLDS Professional Access – Documentation of Enrollment Reporting and Post screening Delays for Audit Purposes” published on August 31, 2022. The audit noted three errors related to timely reporting. The university’s SIS records indicate these records were reported to NSC within the 30-day timeframe. However, these records were not transmitted from NSC to NSLDS timely. The Deputy Registrar is currently collaborating with the NSC Compliance division to determine the cause of these discrepancies and how best to correct the records in NSLDS. A response from NSC is anticipated by October 31, 2024. The audit also noted three students who were less than full-time that were not reported to NSC or NSLDS. The Deputy Registrar is researching the SIS system rules to determine the root cause of these errors so they can be corrected. The Deputy Registrar will ensure the reporting rules will be corrected by November 30, 2024, and will ensure any less than full time students are corrected in NSLDS by December 30, 2024. To enhance the enrollment reporting process, the Deputy Registrar, Registrar, and Director of Financial Aid will meet with NSC staff and IT staff to establish a method for comparing monthly data submitted to NSC with the data in the NSLDS system. This will help identify any discrepancies for immediate correction. This project is expected to be completed by December 30, 2024.

Student Financial Assistance Cluster Federal Supplemental Educational Opportunity Grants, ALN 84.007; Federal Work-Study Program, ALN 84.033 Federal Pell Grant Program, ALN 84.063 Federal Direct Student Loans, ALN 84.268 Teacher Education Assistance for College and Higher Education Grants, ALN 84.379 U.S. Department of Education Program Year 2023-2024 Criteria or specific requirement – Special Tests and Provisions – Verification (34 CFR 668.51 through 668.61) Institutions responsible for verifying applicant information for those applicants selected by verification by the U.S. Department of Education. Condition – The University’s processes did not ensure corrections were made to student application data. Questioned costs – Unknown Context – Out of the population of 189 students selected for verification, a sample of 19 students were selected for testing. Our sampling method was not, and was not intended to be, statistically valid. The number of household members was not corrected on the student’s Institutional Student Information Record (ISIR) for one student, and the adjusted gross income was not corrected on the student’s ISIR for one student. Effect – The student’s applicant data was not correct when used for packaging and awarding aid. Identification as a repeat finding, if applicable – N/A Recommendation – The University should update their controls to ensure student data is properly corrected on the students’ ISIRs in the verification process. Views of responsible officials and planned corrective actions – The auditors identified two issues related to verification of financial aid data supplied on the FAFSA by students. Both findings were from the fall of 2023 and in both cases a secondary review was completed and still was not accurately completed. The Office of Financial Aid developed and implemented a comprehensive Business Process Guide (BPG) on October 17, 2024. The guide is aimed at ensuring that all required fields within the verification process are meticulously reviewed and corrected as needed. This guide serves as a crucial resource for staff involved in the financial aid verification process, outlining best practices and standard procedures to maintain compliance and accuracy. The verification correction process follows a two-step approach: 1. Initial Review and Correction: Staff members are required to conduct a thorough review of the required data fields. This involves checking the required ISIR data fields against other supplemental information to identify any discrepancies or inaccuracies. Once identified, corrections are made to ensure that all data aligns with federal and institutional requirements. 2. Final Confirmation and Awarding: After the necessary corrections are implemented, a secondary review is conducted by the Assistant Director to confirm that the adjustments are accurate. This ensures that students receive the correct financial aid awards based on updated and verified information. To maintain transparency, accountability, and an adequate documentation trail. It is imperative that any comments added to student accounts are detailed and include pertinent information regarding the verification process. This documentation serves as a record of the actions taken and aids in future audits and reviews. The Assistant Director of Financial Aid is a very experienced financial aid professional and holds NASFAA certifications in Verification, R2T4, Student Eligibility, Direct Loans and Professional Judgement. The Assistant Director plays a pivotal role in the verification process, being responsible for updating the BPG to reflect any changes in regulations or best practices. Additionally, the Assistant Director will lead training sessions for staff members to ensure they are well-versed in the verification procedures outlined in the BPG. Ongoing training will be provided as needed to accommodate changes in policies or technologies. By implementing this structured approach to verification corrections, the University aims to enhance the accuracy of financial aid processing and improve the overall student experience.

Student Financial Assistance Cluster Federal Supplemental Educational Opportunity Grants, ALN 84.007; Federal Work-Study Program, ALN 84.033 Federal Pell Grant Program, ALN 84.063 Federal Direct Student Loans, ALN 84.268 Teacher Education Assistance for College and Higher Education Grants, ALN 84.379 U.S. Department of Education Program Year 2023-2024 Criteria or specific requirement – Special Tests and Provisions – Verification (34 CFR 668.51 through 668.61) Institutions responsible for verifying applicant information for those applicants selected by verification by the U.S. Department of Education. Condition – The University’s processes did not ensure corrections were made to student application data. Questioned costs – Unknown Context – Out of the population of 189 students selected for verification, a sample of 19 students were selected for testing. Our sampling method was not, and was not intended to be, statistically valid. The number of household members was not corrected on the student’s Institutional Student Information Record (ISIR) for one student, and the adjusted gross income was not corrected on the student’s ISIR for one student. Effect – The student’s applicant data was not correct when used for packaging and awarding aid. Identification as a repeat finding, if applicable – N/A Recommendation – The University should update their controls to ensure student data is properly corrected on the students’ ISIRs in the verification process. Views of responsible officials and planned corrective actions – The auditors identified two issues related to verification of financial aid data supplied on the FAFSA by students. Both findings were from the fall of 2023 and in both cases a secondary review was completed and still was not accurately completed. The Office of Financial Aid developed and implemented a comprehensive Business Process Guide (BPG) on October 17, 2024. The guide is aimed at ensuring that all required fields within the verification process are meticulously reviewed and corrected as needed. This guide serves as a crucial resource for staff involved in the financial aid verification process, outlining best practices and standard procedures to maintain compliance and accuracy. The verification correction process follows a two-step approach: 1. Initial Review and Correction: Staff members are required to conduct a thorough review of the required data fields. This involves checking the required ISIR data fields against other supplemental information to identify any discrepancies or inaccuracies. Once identified, corrections are made to ensure that all data aligns with federal and institutional requirements. 2. Final Confirmation and Awarding: After the necessary corrections are implemented, a secondary review is conducted by the Assistant Director to confirm that the adjustments are accurate. This ensures that students receive the correct financial aid awards based on updated and verified information. To maintain transparency, accountability, and an adequate documentation trail. It is imperative that any comments added to student accounts are detailed and include pertinent information regarding the verification process. This documentation serves as a record of the actions taken and aids in future audits and reviews. The Assistant Director of Financial Aid is a very experienced financial aid professional and holds NASFAA certifications in Verification, R2T4, Student Eligibility, Direct Loans and Professional Judgement. The Assistant Director plays a pivotal role in the verification process, being responsible for updating the BPG to reflect any changes in regulations or best practices. Additionally, the Assistant Director will lead training sessions for staff members to ensure they are well-versed in the verification procedures outlined in the BPG. Ongoing training will be provided as needed to accommodate changes in policies or technologies. By implementing this structured approach to verification corrections, the University aims to enhance the accuracy of financial aid processing and improve the overall student experience.

Student Financial Assistance Cluster Federal Supplemental Educational Opportunity Grants, ALN 84.007; Federal Work-Study Program, ALN 84.033 Federal Pell Grant Program, ALN 84.063 Federal Direct Student Loans, ALN 84.268 Teacher Education Assistance for College and Higher Education Grants, ALN 84.379 U.S. Department of Education Program Year 2023-2024 Criteria or specific requirement – Special Tests and Provisions – Verification (34 CFR 668.51 through 668.61) Institutions responsible for verifying applicant information for those applicants selected by verification by the U.S. Department of Education. Condition – The University’s processes did not ensure corrections were made to student application data. Questioned costs – Unknown Context – Out of the population of 189 students selected for verification, a sample of 19 students were selected for testing. Our sampling method was not, and was not intended to be, statistically valid. The number of household members was not corrected on the student’s Institutional Student Information Record (ISIR) for one student, and the adjusted gross income was not corrected on the student’s ISIR for one student. Effect – The student’s applicant data was not correct when used for packaging and awarding aid. Identification as a repeat finding, if applicable – N/A Recommendation – The University should update their controls to ensure student data is properly corrected on the students’ ISIRs in the verification process. Views of responsible officials and planned corrective actions – The auditors identified two issues related to verification of financial aid data supplied on the FAFSA by students. Both findings were from the fall of 2023 and in both cases a secondary review was completed and still was not accurately completed. The Office of Financial Aid developed and implemented a comprehensive Business Process Guide (BPG) on October 17, 2024. The guide is aimed at ensuring that all required fields within the verification process are meticulously reviewed and corrected as needed. This guide serves as a crucial resource for staff involved in the financial aid verification process, outlining best practices and standard procedures to maintain compliance and accuracy. The verification correction process follows a two-step approach: 1. Initial Review and Correction: Staff members are required to conduct a thorough review of the required data fields. This involves checking the required ISIR data fields against other supplemental information to identify any discrepancies or inaccuracies. Once identified, corrections are made to ensure that all data aligns with federal and institutional requirements. 2. Final Confirmation and Awarding: After the necessary corrections are implemented, a secondary review is conducted by the Assistant Director to confirm that the adjustments are accurate. This ensures that students receive the correct financial aid awards based on updated and verified information. To maintain transparency, accountability, and an adequate documentation trail. It is imperative that any comments added to student accounts are detailed and include pertinent information regarding the verification process. This documentation serves as a record of the actions taken and aids in future audits and reviews. The Assistant Director of Financial Aid is a very experienced financial aid professional and holds NASFAA certifications in Verification, R2T4, Student Eligibility, Direct Loans and Professional Judgement. The Assistant Director plays a pivotal role in the verification process, being responsible for updating the BPG to reflect any changes in regulations or best practices. Additionally, the Assistant Director will lead training sessions for staff members to ensure they are well-versed in the verification procedures outlined in the BPG. Ongoing training will be provided as needed to accommodate changes in policies or technologies. By implementing this structured approach to verification corrections, the University aims to enhance the accuracy of financial aid processing and improve the overall student experience.

Student Financial Assistance Cluster Federal Supplemental Educational Opportunity Grants, ALN 84.007; Federal Work-Study Program, ALN 84.033 Federal Pell Grant Program, ALN 84.063 Federal Direct Student Loans, ALN 84.268 Teacher Education Assistance for College and Higher Education Grants, ALN 84.379 U.S. Department of Education Program Year 2023-2024 Criteria or specific requirement – Special Tests and Provisions – Verification (34 CFR 668.51 through 668.61) Institutions responsible for verifying applicant information for those applicants selected by verification by the U.S. Department of Education. Condition – The University’s processes did not ensure corrections were made to student application data. Questioned costs – Unknown Context – Out of the population of 189 students selected for verification, a sample of 19 students were selected for testing. Our sampling method was not, and was not intended to be, statistically valid. The number of household members was not corrected on the student’s Institutional Student Information Record (ISIR) for one student, and the adjusted gross income was not corrected on the student’s ISIR for one student. Effect – The student’s applicant data was not correct when used for packaging and awarding aid. Identification as a repeat finding, if applicable – N/A Recommendation – The University should update their controls to ensure student data is properly corrected on the students’ ISIRs in the verification process. Views of responsible officials and planned corrective actions – The auditors identified two issues related to verification of financial aid data supplied on the FAFSA by students. Both findings were from the fall of 2023 and in both cases a secondary review was completed and still was not accurately completed. The Office of Financial Aid developed and implemented a comprehensive Business Process Guide (BPG) on October 17, 2024. The guide is aimed at ensuring that all required fields within the verification process are meticulously reviewed and corrected as needed. This guide serves as a crucial resource for staff involved in the financial aid verification process, outlining best practices and standard procedures to maintain compliance and accuracy. The verification correction process follows a two-step approach: 1. Initial Review and Correction: Staff members are required to conduct a thorough review of the required data fields. This involves checking the required ISIR data fields against other supplemental information to identify any discrepancies or inaccuracies. Once identified, corrections are made to ensure that all data aligns with federal and institutional requirements. 2. Final Confirmation and Awarding: After the necessary corrections are implemented, a secondary review is conducted by the Assistant Director to confirm that the adjustments are accurate. This ensures that students receive the correct financial aid awards based on updated and verified information. To maintain transparency, accountability, and an adequate documentation trail. It is imperative that any comments added to student accounts are detailed and include pertinent information regarding the verification process. This documentation serves as a record of the actions taken and aids in future audits and reviews. The Assistant Director of Financial Aid is a very experienced financial aid professional and holds NASFAA certifications in Verification, R2T4, Student Eligibility, Direct Loans and Professional Judgement. The Assistant Director plays a pivotal role in the verification process, being responsible for updating the BPG to reflect any changes in regulations or best practices. Additionally, the Assistant Director will lead training sessions for staff members to ensure they are well-versed in the verification procedures outlined in the BPG. Ongoing training will be provided as needed to accommodate changes in policies or technologies. By implementing this structured approach to verification corrections, the University aims to enhance the accuracy of financial aid processing and improve the overall student experience.

Student Financial Assistance Cluster Federal Supplemental Educational Opportunity Grants, ALN 84.007; Federal Work-Study Program, ALN 84.033 Federal Pell Grant Program, ALN 84.063 Federal Direct Student Loans, ALN 84.268 Teacher Education Assistance for College and Higher Education Grants, ALN 84.379 U.S. Department of Education Program Year 2023-2024 Criteria or specific requirement – Special Tests and Provisions – Verification (34 CFR 668.51 through 668.61) Institutions responsible for verifying applicant information for those applicants selected by verification by the U.S. Department of Education. Condition – The University’s processes did not ensure corrections were made to student application data. Questioned costs – Unknown Context – Out of the population of 189 students selected for verification, a sample of 19 students were selected for testing. Our sampling method was not, and was not intended to be, statistically valid. The number of household members was not corrected on the student’s Institutional Student Information Record (ISIR) for one student, and the adjusted gross income was not corrected on the student’s ISIR for one student. Effect – The student’s applicant data was not correct when used for packaging and awarding aid. Identification as a repeat finding, if applicable – N/A Recommendation – The University should update their controls to ensure student data is properly corrected on the students’ ISIRs in the verification process. Views of responsible officials and planned corrective actions – The auditors identified two issues related to verification of financial aid data supplied on the FAFSA by students. Both findings were from the fall of 2023 and in both cases a secondary review was completed and still was not accurately completed. The Office of Financial Aid developed and implemented a comprehensive Business Process Guide (BPG) on October 17, 2024. The guide is aimed at ensuring that all required fields within the verification process are meticulously reviewed and corrected as needed. This guide serves as a crucial resource for staff involved in the financial aid verification process, outlining best practices and standard procedures to maintain compliance and accuracy. The verification correction process follows a two-step approach: 1. Initial Review and Correction: Staff members are required to conduct a thorough review of the required data fields. This involves checking the required ISIR data fields against other supplemental information to identify any discrepancies or inaccuracies. Once identified, corrections are made to ensure that all data aligns with federal and institutional requirements. 2. Final Confirmation and Awarding: After the necessary corrections are implemented, a secondary review is conducted by the Assistant Director to confirm that the adjustments are accurate. This ensures that students receive the correct financial aid awards based on updated and verified information. To maintain transparency, accountability, and an adequate documentation trail. It is imperative that any comments added to student accounts are detailed and include pertinent information regarding the verification process. This documentation serves as a record of the actions taken and aids in future audits and reviews. The Assistant Director of Financial Aid is a very experienced financial aid professional and holds NASFAA certifications in Verification, R2T4, Student Eligibility, Direct Loans and Professional Judgement. The Assistant Director plays a pivotal role in the verification process, being responsible for updating the BPG to reflect any changes in regulations or best practices. Additionally, the Assistant Director will lead training sessions for staff members to ensure they are well-versed in the verification procedures outlined in the BPG. Ongoing training will be provided as needed to accommodate changes in policies or technologies. By implementing this structured approach to verification corrections, the University aims to enhance the accuracy of financial aid processing and improve the overall student experience.

Student Financial Assistance Cluster Federal Supplemental Educational Opportunity Grants, ALN 84.007; Federal Work-Study Program, ALN 84.033 Federal Pell Grant Program, ALN 84.063 Federal Direct Student Loans, ALN 84.268 Teacher Education Assistance for College and Higher Education Grants, ALN 84.379 U.S. Department of Education Program Year 2023-2024 Criteria or specific requirement – Eligibility – Students must maintain good standing, or satisfactory academic progress (34 CFRs 668.16, 668.32(f), 668.34, 690.75, 675.9, 676.9, 685.200, 686.11, 20 USC 1070h; 42 CFR 57.306; 42 USC 293a(d)(2)). Condition – A student was awarded aid who did not meet satisfactory academic progress standards per the University’s policy Questioned costs - $6,761 – ALN 84.268 Context – Out of a population of 1,724 students who received aid, a sample of 25 students was selected for testing. Our sampling method was not, and was not intended to be, statistically valid. One student received aid who had not met satisfactory academic progress standards per the University’s policy. Effect – Aid was awarded to one student who was not eligible to receive aid. Identification as a repeat finding, if applicable – N/A Recommendation – The University should update their controls to ensure no students receive aid who have not met satisfactory academic progress standards. Views of responsible officials and planned corrective actions – The audit noted one student was awarded financial aid despite not meeting Satisfactory Academic Progress (SAP) standards. The issue stemmed from a lapse in the SAP review process at the end of the Fall 2023 term, which was primarily attributed to staff turnover and insufficient training for remaining personnel. When the student did not enroll for the Spring term but later registered for the Summer 2024 session, there were no safeguards in place to prevent the system from awarding financial aid. This oversight highlighted a gap in the current process, emphasizing the need for a more robust mechanism to flag students who are not in compliance with SAP prior to awarding financial aid. In the new organizational structure, the Financial Aid Business Analyst is responsible for executing the SAP process. This individual has approximately 10 years of experience working with SAP processes. During the 2023-2024 academic year the University worked diligently to respond to a Federal Program Review from the U.S. Department of Education, (ED). As a result of the corrective actions being undertaken by the University new procedures in many areas were being drafted and implemented. A new Director of Financial Aid, with over 30 years of experience in financial aid, was hired to improve the overall student service and compliance with the Federal Title IV program. The new director commenced his duties on February 1, 2024. Since that time the University has reorganized the financial aid office by creating an Assistant Director and Financial Aid Business Analyst position who have increased the expertise and overall years of financial aid experience. A leadership team including the Director of Financial Aid, Registrar, Director of Student Accounts, Associate Provost, Provost and Vice President for Finance and Administration was created in January 2024 and meet bi-weekly to discuss Title IV compliance topics, process improvement and customer service. Most of the Financial Aid team’s time in the spring and summer was spent working on the new FAFSA, the team has redirected their efforts in training, standardizing, documenting and improving processes to ensure Title IV compliance and better serve students.

Student Financial Assistance Cluster Federal Supplemental Educational Opportunity Grants, ALN 84.007; Federal Work-Study Program, ALN 84.033 Federal Pell Grant Program, ALN 84.063 Federal Direct Student Loans, ALN 84.268 Teacher Education Assistance for College and Higher Education Grants, ALN 84.379 U.S. Department of Education Program Year 2023-2024 Criteria or specific requirement – Eligibility – Students must maintain good standing, or satisfactory academic progress (34 CFRs 668.16, 668.32(f), 668.34, 690.75, 675.9, 676.9, 685.200, 686.11, 20 USC 1070h; 42 CFR 57.306; 42 USC 293a(d)(2)). Condition – A student was awarded aid who did not meet satisfactory academic progress standards per the University’s policy Questioned costs - $6,761 – ALN 84.268 Context – Out of a population of 1,724 students who received aid, a sample of 25 students was selected for testing. Our sampling method was not, and was not intended to be, statistically valid. One student received aid who had not met satisfactory academic progress standards per the University’s policy. Effect – Aid was awarded to one student who was not eligible to receive aid. Identification as a repeat finding, if applicable – N/A Recommendation – The University should update their controls to ensure no students receive aid who have not met satisfactory academic progress standards. Views of responsible officials and planned corrective actions – The audit noted one student was awarded financial aid despite not meeting Satisfactory Academic Progress (SAP) standards. The issue stemmed from a lapse in the SAP review process at the end of the Fall 2023 term, which was primarily attributed to staff turnover and insufficient training for remaining personnel. When the student did not enroll for the Spring term but later registered for the Summer 2024 session, there were no safeguards in place to prevent the system from awarding financial aid. This oversight highlighted a gap in the current process, emphasizing the need for a more robust mechanism to flag students who are not in compliance with SAP prior to awarding financial aid. In the new organizational structure, the Financial Aid Business Analyst is responsible for executing the SAP process. This individual has approximately 10 years of experience working with SAP processes. During the 2023-2024 academic year the University worked diligently to respond to a Federal Program Review from the U.S. Department of Education, (ED). As a result of the corrective actions being undertaken by the University new procedures in many areas were being drafted and implemented. A new Director of Financial Aid, with over 30 years of experience in financial aid, was hired to improve the overall student service and compliance with the Federal Title IV program. The new director commenced his duties on February 1, 2024. Since that time the University has reorganized the financial aid office by creating an Assistant Director and Financial Aid Business Analyst position who have increased the expertise and overall years of financial aid experience. A leadership team including the Director of Financial Aid, Registrar, Director of Student Accounts, Associate Provost, Provost and Vice President for Finance and Administration was created in January 2024 and meet bi-weekly to discuss Title IV compliance topics, process improvement and customer service. Most of the Financial Aid team’s time in the spring and summer was spent working on the new FAFSA, the team has redirected their efforts in training, standardizing, documenting and improving processes to ensure Title IV compliance and better serve students.

Student Financial Assistance Cluster Federal Supplemental Educational Opportunity Grants, ALN 84.007; Federal Work-Study Program, ALN 84.033 Federal Pell Grant Program, ALN 84.063 Federal Direct Student Loans, ALN 84.268 Teacher Education Assistance for College and Higher Education Grants, ALN 84.379 U.S. Department of Education Program Year 2023-2024 Criteria or specific requirement – Eligibility – Students must maintain good standing, or satisfactory academic progress (34 CFRs 668.16, 668.32(f), 668.34, 690.75, 675.9, 676.9, 685.200, 686.11, 20 USC 1070h; 42 CFR 57.306; 42 USC 293a(d)(2)). Condition – A student was awarded aid who did not meet satisfactory academic progress standards per the University’s policy Questioned costs - $6,761 – ALN 84.268 Context – Out of a population of 1,724 students who received aid, a sample of 25 students was selected for testing. Our sampling method was not, and was not intended to be, statistically valid. One student received aid who had not met satisfactory academic progress standards per the University’s policy. Effect – Aid was awarded to one student who was not eligible to receive aid. Identification as a repeat finding, if applicable – N/A Recommendation – The University should update their controls to ensure no students receive aid who have not met satisfactory academic progress standards. Views of responsible officials and planned corrective actions – The audit noted one student was awarded financial aid despite not meeting Satisfactory Academic Progress (SAP) standards. The issue stemmed from a lapse in the SAP review process at the end of the Fall 2023 term, which was primarily attributed to staff turnover and insufficient training for remaining personnel. When the student did not enroll for the Spring term but later registered for the Summer 2024 session, there were no safeguards in place to prevent the system from awarding financial aid. This oversight highlighted a gap in the current process, emphasizing the need for a more robust mechanism to flag students who are not in compliance with SAP prior to awarding financial aid. In the new organizational structure, the Financial Aid Business Analyst is responsible for executing the SAP process. This individual has approximately 10 years of experience working with SAP processes. During the 2023-2024 academic year the University worked diligently to respond to a Federal Program Review from the U.S. Department of Education, (ED). As a result of the corrective actions being undertaken by the University new procedures in many areas were being drafted and implemented. A new Director of Financial Aid, with over 30 years of experience in financial aid, was hired to improve the overall student service and compliance with the Federal Title IV program. The new director commenced his duties on February 1, 2024. Since that time the University has reorganized the financial aid office by creating an Assistant Director and Financial Aid Business Analyst position who have increased the expertise and overall years of financial aid experience. A leadership team including the Director of Financial Aid, Registrar, Director of Student Accounts, Associate Provost, Provost and Vice President for Finance and Administration was created in January 2024 and meet bi-weekly to discuss Title IV compliance topics, process improvement and customer service. Most of the Financial Aid team’s time in the spring and summer was spent working on the new FAFSA, the team has redirected their efforts in training, standardizing, documenting and improving processes to ensure Title IV compliance and better serve students.

Student Financial Assistance Cluster Federal Supplemental Educational Opportunity Grants, ALN 84.007; Federal Work-Study Program, ALN 84.033 Federal Pell Grant Program, ALN 84.063 Federal Direct Student Loans, ALN 84.268 Teacher Education Assistance for College and Higher Education Grants, ALN 84.379 U.S. Department of Education Program Year 2023-2024 Criteria or specific requirement – Eligibility – Students must maintain good standing, or satisfactory academic progress (34 CFRs 668.16, 668.32(f), 668.34, 690.75, 675.9, 676.9, 685.200, 686.11, 20 USC 1070h; 42 CFR 57.306; 42 USC 293a(d)(2)). Condition – A student was awarded aid who did not meet satisfactory academic progress standards per the University’s policy Questioned costs - $6,761 – ALN 84.268 Context – Out of a population of 1,724 students who received aid, a sample of 25 students was selected for testing. Our sampling method was not, and was not intended to be, statistically valid. One student received aid who had not met satisfactory academic progress standards per the University’s policy. Effect – Aid was awarded to one student who was not eligible to receive aid. Identification as a repeat finding, if applicable – N/A Recommendation – The University should update their controls to ensure no students receive aid who have not met satisfactory academic progress standards. Views of responsible officials and planned corrective actions – The audit noted one student was awarded financial aid despite not meeting Satisfactory Academic Progress (SAP) standards. The issue stemmed from a lapse in the SAP review process at the end of the Fall 2023 term, which was primarily attributed to staff turnover and insufficient training for remaining personnel. When the student did not enroll for the Spring term but later registered for the Summer 2024 session, there were no safeguards in place to prevent the system from awarding financial aid. This oversight highlighted a gap in the current process, emphasizing the need for a more robust mechanism to flag students who are not in compliance with SAP prior to awarding financial aid. In the new organizational structure, the Financial Aid Business Analyst is responsible for executing the SAP process. This individual has approximately 10 years of experience working with SAP processes. During the 2023-2024 academic year the University worked diligently to respond to a Federal Program Review from the U.S. Department of Education, (ED). As a result of the corrective actions being undertaken by the University new procedures in many areas were being drafted and implemented. A new Director of Financial Aid, with over 30 years of experience in financial aid, was hired to improve the overall student service and compliance with the Federal Title IV program. The new director commenced his duties on February 1, 2024. Since that time the University has reorganized the financial aid office by creating an Assistant Director and Financial Aid Business Analyst position who have increased the expertise and overall years of financial aid experience. A leadership team including the Director of Financial Aid, Registrar, Director of Student Accounts, Associate Provost, Provost and Vice President for Finance and Administration was created in January 2024 and meet bi-weekly to discuss Title IV compliance topics, process improvement and customer service. Most of the Financial Aid team’s time in the spring and summer was spent working on the new FAFSA, the team has redirected their efforts in training, standardizing, documenting and improving processes to ensure Title IV compliance and better serve students.

Student Financial Assistance Cluster Federal Supplemental Educational Opportunity Grants, ALN 84.007; Federal Work-Study Program, ALN 84.033 Federal Pell Grant Program, ALN 84.063 Federal Direct Student Loans, ALN 84.268 Teacher Education Assistance for College and Higher Education Grants, ALN 84.379 U.S. Department of Education Program Year 2023-2024 Criteria or specific requirement – Eligibility – Students must maintain good standing, or satisfactory academic progress (34 CFRs 668.16, 668.32(f), 668.34, 690.75, 675.9, 676.9, 685.200, 686.11, 20 USC 1070h; 42 CFR 57.306; 42 USC 293a(d)(2)). Condition – A student was awarded aid who did not meet satisfactory academic progress standards per the University’s policy Questioned costs - $6,761 – ALN 84.268 Context – Out of a population of 1,724 students who received aid, a sample of 25 students was selected for testing. Our sampling method was not, and was not intended to be, statistically valid. One student received aid who had not met satisfactory academic progress standards per the University’s policy. Effect – Aid was awarded to one student who was not eligible to receive aid. Identification as a repeat finding, if applicable – N/A Recommendation – The University should update their controls to ensure no students receive aid who have not met satisfactory academic progress standards. Views of responsible officials and planned corrective actions – The audit noted one student was awarded financial aid despite not meeting Satisfactory Academic Progress (SAP) standards. The issue stemmed from a lapse in the SAP review process at the end of the Fall 2023 term, which was primarily attributed to staff turnover and insufficient training for remaining personnel. When the student did not enroll for the Spring term but later registered for the Summer 2024 session, there were no safeguards in place to prevent the system from awarding financial aid. This oversight highlighted a gap in the current process, emphasizing the need for a more robust mechanism to flag students who are not in compliance with SAP prior to awarding financial aid. In the new organizational structure, the Financial Aid Business Analyst is responsible for executing the SAP process. This individual has approximately 10 years of experience working with SAP processes. During the 2023-2024 academic year the University worked diligently to respond to a Federal Program Review from the U.S. Department of Education, (ED). As a result of the corrective actions being undertaken by the University new procedures in many areas were being drafted and implemented. A new Director of Financial Aid, with over 30 years of experience in financial aid, was hired to improve the overall student service and compliance with the Federal Title IV program. The new director commenced his duties on February 1, 2024. Since that time the University has reorganized the financial aid office by creating an Assistant Director and Financial Aid Business Analyst position who have increased the expertise and overall years of financial aid experience. A leadership team including the Director of Financial Aid, Registrar, Director of Student Accounts, Associate Provost, Provost and Vice President for Finance and Administration was created in January 2024 and meet bi-weekly to discuss Title IV compliance topics, process improvement and customer service. Most of the Financial Aid team’s time in the spring and summer was spent working on the new FAFSA, the team has redirected their efforts in training, standardizing, documenting and improving processes to ensure Title IV compliance and better serve students.