Audit 331221

2023-003 Reporting U.S. Department of Education: Student Financial Assistance Cluster – Federal Pell Grant Program (ALN 84.063) Federal Award Number and Year: P063P201813 (7/1/22 – 6/30/23) Statistically Valid Sample: The sample was not intended to be, and was not, a statistically valid sample. Prior Year Finding: 2022-004 Finding Type: Material Weakness and Material Noncompliance Criteria Institutions submit Direct Loan, Pell Grant, TEACH Grant, and IASG origination records and disbursement records to the COD system. Origination records can be sent well in advance of any disbursements, as early as the institution chooses to submit them for any student the institution reasonably believes will be eligible for a payment. An institution follows up with a disbursement record for that student no earlier than (1) seven calendar days prior to the disbursement date under the Advance or Heightened Cash Monitoring 1 payment methods, or (2) the date of the disbursement under the Reimbursement or Heightened Cash Monitoring 2 Payment Method (see Federal Register, Volume 85, Number 134, July 14, 2020). The disbursement record reports the actual disbursement date and the amount of the disbursement. ED processes origination and/or disbursement records and returns acknowledgments to the institution. The acknowledgments identify the processing status of each record: Rejected, Accepted with Corrections, or Accepted. Institutions must report student disbursement data within 15 calendar days after the institution makes a disbursement or becomes aware of the need to make an adjustment to previously reported student disbursement data or expected student disbursement data. Institutions may do this by reporting once every 15 calendar days, bi-weekly or weekly, or may set up their own system to ensure that changes are reported in a timely manner. Additionally, in accordance with Federal requirements, the University shall maintain internal controls over Federal programs designed to provide reasonable assurance that the Pell reporting requirements are executed in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award that could have a direct and material effect on a Federal program. Condition and Context The University has a process in place to submit the required information to COD on a weekly basis. For the 40 selections we tested, there were 8 instances of noncompliance where the University failed to report student disbursement data related to Pell Awards within 15 calendar days. Additionally, the University did not have a properly designed and operating effectively internal control in place to review the ED acknowledgement reports or to ensure disbursement data was reported within the 15-calendar day requirement. Cause The University did not have a process in place to maintain the documentation regarding the existence or performance of the control. Effect The University is not in compliance with the Federal requirements to report disbursement data and maintain documentation of its internal controls over the 15-calendar day reporting compliance requirement. Questioned Costs There are no known questioned costs related to this finding. Recommendation We recommend that the University strengthen its policies, procedures and controls over Pell reporting in relation to the Student Financial Assistance Cluster. We also recommend that the University ensure that internal controls in place surrounding the 15-calendar day reporting process are performed as designed and documentation is maintained. Views of Responsible Official The University agrees with the finding. The University has had a significant amount of staff turnover and reorganization in fiscal year 2023 in the financial aid office. The Interim Director of Financial Aid is collaborating with the Controller’s office to make sure that the University has internal controls in place over Federal programs to assure that the Pell reporting requirements are executed in compliance with Federal statutes, regulation and terms and conditions of the federal award. The University is investing in making sure that the Financial Aid Office is staffed and creates policies and procedures that assure that we improve internal controls over the Pell reporting process.

2023-002 Activities Allowed or Unallowed and Allowable Costs/ Cost Principles U.S. Department of Education: Education Stabilization Fund – Higher Education Emergency Relief Fund (HEERF) Student Aid Portion (ALN 84.425E) Federal Award Numbers and Years: P425F200214 (4/21/20 – 6/30/23) Statistically Valid Sample: The sample was not intended to be, and was not, a statistically valid sample. Prior Year Finding: Not applicable Finding Type: Material Weakness and Material Noncompliance Criteria As it relates to expenditures under the HEERF II and HEERF III (a)(1) Student Aid Portion or for additional emergency financial aid grants made using other HEERF grant funds, ED required that (1) the institution had a documented plan to distribute funds to students, (2) that institutions prioritized grants to students with exceptional need, (3) that the institution did not place any restrictions on the expenditure of those funds beyond what is in the statute, above, (4) the institution expended the entirety of the Student Aid Portion grant on Emergency financial aid grants to students, and (5) that the institution did not reimburse itself for any costs or expenses previously issued to students. Additionally, in accordance with Federal requirements, the University shall maintain internal controls over Federal programs designed to provide reasonable assurance that transactions are executed in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award that could have a direct and material effect on a Federal program. Condition and Context One out of the forty students selected for testwork did not properly fill out an application to ensure they were eligible to receive the HEERF funding through the University. The University’s documented plan outlines that the student must complete an application and then the HEERF award amount would be based on the answers within the application. The University did not properly design internal controls to ensure that all students had completed an application before HEERF awarding. Cause The University did not have policies and procedures in place to ensure that all students had completed an application before awarding HEERF funds. Effect Ineligible students may have received HEERF awards. Questioned Costs There are no known questioned costs related to this finding. Recommendation We recommend that the University strengthen its policies and procedures over the student awarding process in relation to the HEERF funds. We also recommend that the University ensure that internal controls are properly designed to ensure compliance with awarding students HEERF funds. Views of Responsible Official The University concurs with this finding but cannot respond why the student was awarded outside the of procedure and methodology set up for awarding HEERF Funds. The decisions were made by individuals no longer with the University and no documentation was found to determine why the student was awarded outside the policy in place. The Controller’s Office and Financial Aid Office are working together to make sure that in future funds like the HEERF will have documentation attached to secure that we follow procedure and policy and document any exceptions.

2023-001 Reporting U.S. Department of Education: COVID-19 Education Stabilization Fund – Higher Education Emergency Relief Fund (HEERF) Student Aid Portion and Institutional Aid Portion (ALN 84.425E & 84.425F) Federal Award Number and Year: P425F200214 (4/21/20 – 6/30/23) Statistically Valid Sample: The sample was not intended to be, and was not, a statistically valid sample. Prior Year Finding: 2022-002 Finding Type: Material Weakness and Material Noncompliance Criteria There are three components to reporting for HEERF: 1) public reporting on the (a)(1) Student Aid; 2) public reporting on the (a)(1) Institutional Portion (a)(2) and (a)(3) subprograms (Quarterly Reporting Form), as applicable; and 3) the annual report. The Department of Education requires that institutions who received the Section 18004(a)(1) Student Aid Portion of higher education emergency relief funding (HEERF) to publicly post certain information on their website every calendar quarter. The report must be updated no later than 10 days after the end of each calendar quarter (October 10, January 10, April 10, and July 10). All institutions of higher education that received HEERF grant awards are required to submit a HEERF Annual Report. The next reporting cycle is the Year 3 report covering January 1, 2022, through December 31, 2022. The HEERF Annual Report portal will open on March 6, 2023, and will close on March 24, 2023. Additionally, in accordance with Federal requirements, the University shall maintain internal controls over Federal programs designed to provide reasonable assurance that transactions are executed in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award that could have a direct and material effect on a Federal program. Condition and Context Website reporting: During 2023, the University did not update their website each quarter. The University only updated its website for the quarter ending June 30, 2023. In addition, the University could not provide evidence that the information for the quarter ended June 30, 2023 was updated on the website timely or appropriately reviewed prior to posting. Annual reporting: The University could not provide evidence that the original report was submitted by the required deadline of March 2023. Additionally, the compliance supplement outlined two key line items. The first key line item was question 5 on the annual report. The University did not complete that section of the report. The second key line item related to the section “Conducting direct outreach to financial aid applicants.” According to the compliance supplement, this category of spending could not be zero for the life of the HEERF grant. The University has reported zero for this category of spending on the annual report filed for fiscal year 2023 and fiscal year 2022. Institutional quarterly reporting: For the June 30, 2023 quarterly reporting for the institutional portion of the HEERF funding, the University’s support did not match the amount that was submitted to the U.S. Department of Education. For the line item “HEERF (a)(1) Student Aid Portion Amount Disbursed” the amount reported was $20,647,007 however the correct amount was $20,674,007. The University did not properly design internal controls to ensure that information displayed on the website was reported timely, and was complete and accurate. Cause Website reporting: The University did not have policies and procedures in place to ensure that the website was appropriately updated on a quarterly basis. In addition, the University did not maintain documentation that the information was reported timely and was properly reviewed by someone other than the preparer with knowledge of the subject matter. Annual reporting: The University did not have policies and procedures in place to ensure that the annual report was submitted timely and they also did not have policies and procedures in place to ensure the report contained all required elements before submission. Institutional quarterly reporting: The University did not have policies and procedures in place to ensure that the June 30, 2023 quarterly report was accurate. Effect Website reporting: The information displayed on the University’s website was not current throughout fiscal year 2023. Annual reporting: The report was submitted late and did not include all required information as outlined by the U.S. Department of Education. Institutional quarterly reporting: The information submitted by the University was not accurate. Questioned Costs Cannot be determined Recommendation We recommend that the University strengthen its policies and procedures over the website reporting, annual reporting and the institutional quarterly reporting in relation to the Education Stabilization Fund program. We also recommend that the University ensure that internal controls in place surrounding the review of all of the reporting requirements are performed as designed and that documentation supporting the amounts reported is adequately maintained, along with evidence that the information was adequately reviewed by someone other than the preparer with knowledge of the subject matter. Views of Responsible Official The University agrees with the finding and acknowledges the finding was also reported in the previous fiscal year. Despite high staff turnover, the Director of the Financial Aid Office and in collaboration with the Controller’s Office, the issue is being addressed for any future reporting.

2023-001 Reporting U.S. Department of Education: COVID-19 Education Stabilization Fund – Higher Education Emergency Relief Fund (HEERF) Student Aid Portion and Institutional Aid Portion (ALN 84.425E & 84.425F) Federal Award Number and Year: P425F200214 (4/21/20 – 6/30/23) Statistically Valid Sample: The sample was not intended to be, and was not, a statistically valid sample. Prior Year Finding: 2022-002 Finding Type: Material Weakness and Material Noncompliance Criteria There are three components to reporting for HEERF: 1) public reporting on the (a)(1) Student Aid; 2) public reporting on the (a)(1) Institutional Portion (a)(2) and (a)(3) subprograms (Quarterly Reporting Form), as applicable; and 3) the annual report. The Department of Education requires that institutions who received the Section 18004(a)(1) Student Aid Portion of higher education emergency relief funding (HEERF) to publicly post certain information on their website every calendar quarter. The report must be updated no later than 10 days after the end of each calendar quarter (October 10, January 10, April 10, and July 10). All institutions of higher education that received HEERF grant awards are required to submit a HEERF Annual Report. The next reporting cycle is the Year 3 report covering January 1, 2022, through December 31, 2022. The HEERF Annual Report portal will open on March 6, 2023, and will close on March 24, 2023. Additionally, in accordance with Federal requirements, the University shall maintain internal controls over Federal programs designed to provide reasonable assurance that transactions are executed in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award that could have a direct and material effect on a Federal program. Condition and Context Website reporting: During 2023, the University did not update their website each quarter. The University only updated its website for the quarter ending June 30, 2023. In addition, the University could not provide evidence that the information for the quarter ended June 30, 2023 was updated on the website timely or appropriately reviewed prior to posting. Annual reporting: The University could not provide evidence that the original report was submitted by the required deadline of March 2023. Additionally, the compliance supplement outlined two key line items. The first key line item was question 5 on the annual report. The University did not complete that section of the report. The second key line item related to the section “Conducting direct outreach to financial aid applicants.” According to the compliance supplement, this category of spending could not be zero for the life of the HEERF grant. The University has reported zero for this category of spending on the annual report filed for fiscal year 2023 and fiscal year 2022. Institutional quarterly reporting: For the June 30, 2023 quarterly reporting for the institutional portion of the HEERF funding, the University’s support did not match the amount that was submitted to the U.S. Department of Education. For the line item “HEERF (a)(1) Student Aid Portion Amount Disbursed” the amount reported was $20,647,007 however the correct amount was $20,674,007. The University did not properly design internal controls to ensure that information displayed on the website was reported timely, and was complete and accurate. Cause Website reporting: The University did not have policies and procedures in place to ensure that the website was appropriately updated on a quarterly basis. In addition, the University did not maintain documentation that the information was reported timely and was properly reviewed by someone other than the preparer with knowledge of the subject matter. Annual reporting: The University did not have policies and procedures in place to ensure that the annual report was submitted timely and they also did not have policies and procedures in place to ensure the report contained all required elements before submission. Institutional quarterly reporting: The University did not have policies and procedures in place to ensure that the June 30, 2023 quarterly report was accurate. Effect Website reporting: The information displayed on the University’s website was not current throughout fiscal year 2023. Annual reporting: The report was submitted late and did not include all required information as outlined by the U.S. Department of Education. Institutional quarterly reporting: The information submitted by the University was not accurate. Questioned Costs Cannot be determined Recommendation We recommend that the University strengthen its policies and procedures over the website reporting, annual reporting and the institutional quarterly reporting in relation to the Education Stabilization Fund program. We also recommend that the University ensure that internal controls in place surrounding the review of all of the reporting requirements are performed as designed and that documentation supporting the amounts reported is adequately maintained, along with evidence that the information was adequately reviewed by someone other than the preparer with knowledge of the subject matter. Views of Responsible Official The University agrees with the finding and acknowledges the finding was also reported in the previous fiscal year. Despite high staff turnover, the Director of the Financial Aid Office and in collaboration with the Controller’s Office, the issue is being addressed for any future reporting.

2023-003 Reporting U.S. Department of Education: Student Financial Assistance Cluster – Federal Pell Grant Program (ALN 84.063) Federal Award Number and Year: P063P201813 (7/1/22 – 6/30/23) Statistically Valid Sample: The sample was not intended to be, and was not, a statistically valid sample. Prior Year Finding: 2022-004 Finding Type: Material Weakness and Material Noncompliance Criteria Institutions submit Direct Loan, Pell Grant, TEACH Grant, and IASG origination records and disbursement records to the COD system. Origination records can be sent well in advance of any disbursements, as early as the institution chooses to submit them for any student the institution reasonably believes will be eligible for a payment. An institution follows up with a disbursement record for that student no earlier than (1) seven calendar days prior to the disbursement date under the Advance or Heightened Cash Monitoring 1 payment methods, or (2) the date of the disbursement under the Reimbursement or Heightened Cash Monitoring 2 Payment Method (see Federal Register, Volume 85, Number 134, July 14, 2020). The disbursement record reports the actual disbursement date and the amount of the disbursement. ED processes origination and/or disbursement records and returns acknowledgments to the institution. The acknowledgments identify the processing status of each record: Rejected, Accepted with Corrections, or Accepted. Institutions must report student disbursement data within 15 calendar days after the institution makes a disbursement or becomes aware of the need to make an adjustment to previously reported student disbursement data or expected student disbursement data. Institutions may do this by reporting once every 15 calendar days, bi-weekly or weekly, or may set up their own system to ensure that changes are reported in a timely manner. Additionally, in accordance with Federal requirements, the University shall maintain internal controls over Federal programs designed to provide reasonable assurance that the Pell reporting requirements are executed in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award that could have a direct and material effect on a Federal program. Condition and Context The University has a process in place to submit the required information to COD on a weekly basis. For the 40 selections we tested, there were 8 instances of noncompliance where the University failed to report student disbursement data related to Pell Awards within 15 calendar days. Additionally, the University did not have a properly designed and operating effectively internal control in place to review the ED acknowledgement reports or to ensure disbursement data was reported within the 15-calendar day requirement. Cause The University did not have a process in place to maintain the documentation regarding the existence or performance of the control. Effect The University is not in compliance with the Federal requirements to report disbursement data and maintain documentation of its internal controls over the 15-calendar day reporting compliance requirement. Questioned Costs There are no known questioned costs related to this finding. Recommendation We recommend that the University strengthen its policies, procedures and controls over Pell reporting in relation to the Student Financial Assistance Cluster. We also recommend that the University ensure that internal controls in place surrounding the 15-calendar day reporting process are performed as designed and documentation is maintained. Views of Responsible Official The University agrees with the finding. The University has had a significant amount of staff turnover and reorganization in fiscal year 2023 in the financial aid office. The Interim Director of Financial Aid is collaborating with the Controller’s office to make sure that the University has internal controls in place over Federal programs to assure that the Pell reporting requirements are executed in compliance with Federal statutes, regulation and terms and conditions of the federal award. The University is investing in making sure that the Financial Aid Office is staffed and creates policies and procedures that assure that we improve internal controls over the Pell reporting process.

2023-002 Activities Allowed or Unallowed and Allowable Costs/ Cost Principles U.S. Department of Education: Education Stabilization Fund – Higher Education Emergency Relief Fund (HEERF) Student Aid Portion (ALN 84.425E) Federal Award Numbers and Years: P425F200214 (4/21/20 – 6/30/23) Statistically Valid Sample: The sample was not intended to be, and was not, a statistically valid sample. Prior Year Finding: Not applicable Finding Type: Material Weakness and Material Noncompliance Criteria As it relates to expenditures under the HEERF II and HEERF III (a)(1) Student Aid Portion or for additional emergency financial aid grants made using other HEERF grant funds, ED required that (1) the institution had a documented plan to distribute funds to students, (2) that institutions prioritized grants to students with exceptional need, (3) that the institution did not place any restrictions on the expenditure of those funds beyond what is in the statute, above, (4) the institution expended the entirety of the Student Aid Portion grant on Emergency financial aid grants to students, and (5) that the institution did not reimburse itself for any costs or expenses previously issued to students. Additionally, in accordance with Federal requirements, the University shall maintain internal controls over Federal programs designed to provide reasonable assurance that transactions are executed in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award that could have a direct and material effect on a Federal program. Condition and Context One out of the forty students selected for testwork did not properly fill out an application to ensure they were eligible to receive the HEERF funding through the University. The University’s documented plan outlines that the student must complete an application and then the HEERF award amount would be based on the answers within the application. The University did not properly design internal controls to ensure that all students had completed an application before HEERF awarding. Cause The University did not have policies and procedures in place to ensure that all students had completed an application before awarding HEERF funds. Effect Ineligible students may have received HEERF awards. Questioned Costs There are no known questioned costs related to this finding. Recommendation We recommend that the University strengthen its policies and procedures over the student awarding process in relation to the HEERF funds. We also recommend that the University ensure that internal controls are properly designed to ensure compliance with awarding students HEERF funds. Views of Responsible Official The University concurs with this finding but cannot respond why the student was awarded outside the of procedure and methodology set up for awarding HEERF Funds. The decisions were made by individuals no longer with the University and no documentation was found to determine why the student was awarded outside the policy in place. The Controller’s Office and Financial Aid Office are working together to make sure that in future funds like the HEERF will have documentation attached to secure that we follow procedure and policy and document any exceptions.

2023-001 Reporting U.S. Department of Education: COVID-19 Education Stabilization Fund – Higher Education Emergency Relief Fund (HEERF) Student Aid Portion and Institutional Aid Portion (ALN 84.425E & 84.425F) Federal Award Number and Year: P425F200214 (4/21/20 – 6/30/23) Statistically Valid Sample: The sample was not intended to be, and was not, a statistically valid sample. Prior Year Finding: 2022-002 Finding Type: Material Weakness and Material Noncompliance Criteria There are three components to reporting for HEERF: 1) public reporting on the (a)(1) Student Aid; 2) public reporting on the (a)(1) Institutional Portion (a)(2) and (a)(3) subprograms (Quarterly Reporting Form), as applicable; and 3) the annual report. The Department of Education requires that institutions who received the Section 18004(a)(1) Student Aid Portion of higher education emergency relief funding (HEERF) to publicly post certain information on their website every calendar quarter. The report must be updated no later than 10 days after the end of each calendar quarter (October 10, January 10, April 10, and July 10). All institutions of higher education that received HEERF grant awards are required to submit a HEERF Annual Report. The next reporting cycle is the Year 3 report covering January 1, 2022, through December 31, 2022. The HEERF Annual Report portal will open on March 6, 2023, and will close on March 24, 2023. Additionally, in accordance with Federal requirements, the University shall maintain internal controls over Federal programs designed to provide reasonable assurance that transactions are executed in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award that could have a direct and material effect on a Federal program. Condition and Context Website reporting: During 2023, the University did not update their website each quarter. The University only updated its website for the quarter ending June 30, 2023. In addition, the University could not provide evidence that the information for the quarter ended June 30, 2023 was updated on the website timely or appropriately reviewed prior to posting. Annual reporting: The University could not provide evidence that the original report was submitted by the required deadline of March 2023. Additionally, the compliance supplement outlined two key line items. The first key line item was question 5 on the annual report. The University did not complete that section of the report. The second key line item related to the section “Conducting direct outreach to financial aid applicants.” According to the compliance supplement, this category of spending could not be zero for the life of the HEERF grant. The University has reported zero for this category of spending on the annual report filed for fiscal year 2023 and fiscal year 2022. Institutional quarterly reporting: For the June 30, 2023 quarterly reporting for the institutional portion of the HEERF funding, the University’s support did not match the amount that was submitted to the U.S. Department of Education. For the line item “HEERF (a)(1) Student Aid Portion Amount Disbursed” the amount reported was $20,647,007 however the correct amount was $20,674,007. The University did not properly design internal controls to ensure that information displayed on the website was reported timely, and was complete and accurate. Cause Website reporting: The University did not have policies and procedures in place to ensure that the website was appropriately updated on a quarterly basis. In addition, the University did not maintain documentation that the information was reported timely and was properly reviewed by someone other than the preparer with knowledge of the subject matter. Annual reporting: The University did not have policies and procedures in place to ensure that the annual report was submitted timely and they also did not have policies and procedures in place to ensure the report contained all required elements before submission. Institutional quarterly reporting: The University did not have policies and procedures in place to ensure that the June 30, 2023 quarterly report was accurate. Effect Website reporting: The information displayed on the University’s website was not current throughout fiscal year 2023. Annual reporting: The report was submitted late and did not include all required information as outlined by the U.S. Department of Education. Institutional quarterly reporting: The information submitted by the University was not accurate. Questioned Costs Cannot be determined Recommendation We recommend that the University strengthen its policies and procedures over the website reporting, annual reporting and the institutional quarterly reporting in relation to the Education Stabilization Fund program. We also recommend that the University ensure that internal controls in place surrounding the review of all of the reporting requirements are performed as designed and that documentation supporting the amounts reported is adequately maintained, along with evidence that the information was adequately reviewed by someone other than the preparer with knowledge of the subject matter. Views of Responsible Official The University agrees with the finding and acknowledges the finding was also reported in the previous fiscal year. Despite high staff turnover, the Director of the Financial Aid Office and in collaboration with the Controller’s Office, the issue is being addressed for any future reporting.

2023-001 Reporting U.S. Department of Education: COVID-19 Education Stabilization Fund – Higher Education Emergency Relief Fund (HEERF) Student Aid Portion and Institutional Aid Portion (ALN 84.425E & 84.425F) Federal Award Number and Year: P425F200214 (4/21/20 – 6/30/23) Statistically Valid Sample: The sample was not intended to be, and was not, a statistically valid sample. Prior Year Finding: 2022-002 Finding Type: Material Weakness and Material Noncompliance Criteria There are three components to reporting for HEERF: 1) public reporting on the (a)(1) Student Aid; 2) public reporting on the (a)(1) Institutional Portion (a)(2) and (a)(3) subprograms (Quarterly Reporting Form), as applicable; and 3) the annual report. The Department of Education requires that institutions who received the Section 18004(a)(1) Student Aid Portion of higher education emergency relief funding (HEERF) to publicly post certain information on their website every calendar quarter. The report must be updated no later than 10 days after the end of each calendar quarter (October 10, January 10, April 10, and July 10). All institutions of higher education that received HEERF grant awards are required to submit a HEERF Annual Report. The next reporting cycle is the Year 3 report covering January 1, 2022, through December 31, 2022. The HEERF Annual Report portal will open on March 6, 2023, and will close on March 24, 2023. Additionally, in accordance with Federal requirements, the University shall maintain internal controls over Federal programs designed to provide reasonable assurance that transactions are executed in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award that could have a direct and material effect on a Federal program. Condition and Context Website reporting: During 2023, the University did not update their website each quarter. The University only updated its website for the quarter ending June 30, 2023. In addition, the University could not provide evidence that the information for the quarter ended June 30, 2023 was updated on the website timely or appropriately reviewed prior to posting. Annual reporting: The University could not provide evidence that the original report was submitted by the required deadline of March 2023. Additionally, the compliance supplement outlined two key line items. The first key line item was question 5 on the annual report. The University did not complete that section of the report. The second key line item related to the section “Conducting direct outreach to financial aid applicants.” According to the compliance supplement, this category of spending could not be zero for the life of the HEERF grant. The University has reported zero for this category of spending on the annual report filed for fiscal year 2023 and fiscal year 2022. Institutional quarterly reporting: For the June 30, 2023 quarterly reporting for the institutional portion of the HEERF funding, the University’s support did not match the amount that was submitted to the U.S. Department of Education. For the line item “HEERF (a)(1) Student Aid Portion Amount Disbursed” the amount reported was $20,647,007 however the correct amount was $20,674,007. The University did not properly design internal controls to ensure that information displayed on the website was reported timely, and was complete and accurate. Cause Website reporting: The University did not have policies and procedures in place to ensure that the website was appropriately updated on a quarterly basis. In addition, the University did not maintain documentation that the information was reported timely and was properly reviewed by someone other than the preparer with knowledge of the subject matter. Annual reporting: The University did not have policies and procedures in place to ensure that the annual report was submitted timely and they also did not have policies and procedures in place to ensure the report contained all required elements before submission. Institutional quarterly reporting: The University did not have policies and procedures in place to ensure that the June 30, 2023 quarterly report was accurate. Effect Website reporting: The information displayed on the University’s website was not current throughout fiscal year 2023. Annual reporting: The report was submitted late and did not include all required information as outlined by the U.S. Department of Education. Institutional quarterly reporting: The information submitted by the University was not accurate. Questioned Costs Cannot be determined Recommendation We recommend that the University strengthen its policies and procedures over the website reporting, annual reporting and the institutional quarterly reporting in relation to the Education Stabilization Fund program. We also recommend that the University ensure that internal controls in place surrounding the review of all of the reporting requirements are performed as designed and that documentation supporting the amounts reported is adequately maintained, along with evidence that the information was adequately reviewed by someone other than the preparer with knowledge of the subject matter. Views of Responsible Official The University agrees with the finding and acknowledges the finding was also reported in the previous fiscal year. Despite high staff turnover, the Director of the Financial Aid Office and in collaboration with the Controller’s Office, the issue is being addressed for any future reporting.