Audit 340029

Criteria or Specific Requirements 34 CFR 668.173(b): Return of Title IV funds are required to be deposited or transferred into the Student Financial Assistance (SFA) account or electronic funds transfer initiated to ED as soon as possible, but no later than 45 days after the date the institution determines that the student withdrew. Returns by check are late if the check is issued more than 45 days after the institution determined the student withdrew, or the date on the cancelled check shows the check was endorsed more than 60 days after the date the institution determined that the student withdrew. OMB Compliance Supplement, 34 CFR section 668.22(e)(f): The amount of Title IV assistance earned by the student is calculated by dividing the number of days completed by the student within the period of enrollment by the total number of days in the enrollment period. The enrollment period includes all days within the period that the student was scheduled to complete, except that scheduled breaks of at least five consecutive days are excluded from the total number of calendar days in the period of enrollment and the number of calendar days completed in that period. Condition Significant Deficiency in Internal Control over Compliance – We noted the following instances of noncompliance: - For one of the sixty students tested, the District did not return the required funds to the Department of Education within the 45-day requirement. - For three of the sixty students tested, the District inaccurately calculated the Return to Title IV funds. Cause The District’s internal controls over Return to Title IV calculations were not sufficient to ensure compliance with relevant requirements. Effect The District is not in compliance with the aforementioned criteria. Questioned Costs There are no questioned costs associated with this finding. Context The District performed 541 Return to Title IV calculations during the year ended June 30, 2024. Repeat Finding (Yes or No) No. Recommendation The District should review policies and procedures over the Return to Title IV calculations to ensure that the procedures are in line with the compliance requirements of the program. The District should strengthen internal controls over the review of the Return to Title IV calculations to ensure that the data utilized in preparing the calculation is accurate and that required funds are returned in a timely manner.

Criteria or Specific Requirements 34 CFR 668.173(b): Return of Title IV funds are required to be deposited or transferred into the Student Financial Assistance (SFA) account or electronic funds transfer initiated to ED as soon as possible, but no later than 45 days after the date the institution determines that the student withdrew. Returns by check are late if the check is issued more than 45 days after the institution determined the student withdrew, or the date on the cancelled check shows the check was endorsed more than 60 days after the date the institution determined that the student withdrew. OMB Compliance Supplement, 34 CFR section 668.22(e)(f): The amount of Title IV assistance earned by the student is calculated by dividing the number of days completed by the student within the period of enrollment by the total number of days in the enrollment period. The enrollment period includes all days within the period that the student was scheduled to complete, except that scheduled breaks of at least five consecutive days are excluded from the total number of calendar days in the period of enrollment and the number of calendar days completed in that period. Condition Significant Deficiency in Internal Control over Compliance – We noted the following instances of noncompliance: - For one of the sixty students tested, the District did not return the required funds to the Department of Education within the 45-day requirement. - For three of the sixty students tested, the District inaccurately calculated the Return to Title IV funds. Cause The District’s internal controls over Return to Title IV calculations were not sufficient to ensure compliance with relevant requirements. Effect The District is not in compliance with the aforementioned criteria. Questioned Costs There are no questioned costs associated with this finding. Context The District performed 541 Return to Title IV calculations during the year ended June 30, 2024. Repeat Finding (Yes or No) No. Recommendation The District should review policies and procedures over the Return to Title IV calculations to ensure that the procedures are in line with the compliance requirements of the program. The District should strengthen internal controls over the review of the Return to Title IV calculations to ensure that the data utilized in preparing the calculation is accurate and that required funds are returned in a timely manner.

Criteria or Specific Requirements 34 CFR 668.173(b): Return of Title IV funds are required to be deposited or transferred into the Student Financial Assistance (SFA) account or electronic funds transfer initiated to ED as soon as possible, but no later than 45 days after the date the institution determines that the student withdrew. Returns by check are late if the check is issued more than 45 days after the institution determined the student withdrew, or the date on the cancelled check shows the check was endorsed more than 60 days after the date the institution determined that the student withdrew. OMB Compliance Supplement, 34 CFR section 668.22(e)(f): The amount of Title IV assistance earned by the student is calculated by dividing the number of days completed by the student within the period of enrollment by the total number of days in the enrollment period. The enrollment period includes all days within the period that the student was scheduled to complete, except that scheduled breaks of at least five consecutive days are excluded from the total number of calendar days in the period of enrollment and the number of calendar days completed in that period. Condition Significant Deficiency in Internal Control over Compliance – We noted the following instances of noncompliance: - For one of the sixty students tested, the District did not return the required funds to the Department of Education within the 45-day requirement. - For three of the sixty students tested, the District inaccurately calculated the Return to Title IV funds. Cause The District’s internal controls over Return to Title IV calculations were not sufficient to ensure compliance with relevant requirements. Effect The District is not in compliance with the aforementioned criteria. Questioned Costs There are no questioned costs associated with this finding. Context The District performed 541 Return to Title IV calculations during the year ended June 30, 2024. Repeat Finding (Yes or No) No. Recommendation The District should review policies and procedures over the Return to Title IV calculations to ensure that the procedures are in line with the compliance requirements of the program. The District should strengthen internal controls over the review of the Return to Title IV calculations to ensure that the data utilized in preparing the calculation is accurate and that required funds are returned in a timely manner.

Criteria or Specific Requirements 34 CFR 668.173(b): Return of Title IV funds are required to be deposited or transferred into the Student Financial Assistance (SFA) account or electronic funds transfer initiated to ED as soon as possible, but no later than 45 days after the date the institution determines that the student withdrew. Returns by check are late if the check is issued more than 45 days after the institution determined the student withdrew, or the date on the cancelled check shows the check was endorsed more than 60 days after the date the institution determined that the student withdrew. OMB Compliance Supplement, 34 CFR section 668.22(e)(f): The amount of Title IV assistance earned by the student is calculated by dividing the number of days completed by the student within the period of enrollment by the total number of days in the enrollment period. The enrollment period includes all days within the period that the student was scheduled to complete, except that scheduled breaks of at least five consecutive days are excluded from the total number of calendar days in the period of enrollment and the number of calendar days completed in that period. Condition Significant Deficiency in Internal Control over Compliance – We noted the following instances of noncompliance: - For one of the sixty students tested, the District did not return the required funds to the Department of Education within the 45-day requirement. - For three of the sixty students tested, the District inaccurately calculated the Return to Title IV funds. Cause The District’s internal controls over Return to Title IV calculations were not sufficient to ensure compliance with relevant requirements. Effect The District is not in compliance with the aforementioned criteria. Questioned Costs There are no questioned costs associated with this finding. Context The District performed 541 Return to Title IV calculations during the year ended June 30, 2024. Repeat Finding (Yes or No) No. Recommendation The District should review policies and procedures over the Return to Title IV calculations to ensure that the procedures are in line with the compliance requirements of the program. The District should strengthen internal controls over the review of the Return to Title IV calculations to ensure that the data utilized in preparing the calculation is accurate and that required funds are returned in a timely manner.

Criteria or Specific Requirements 34 CFR 668.173(b): Return of Title IV funds are required to be deposited or transferred into the Student Financial Assistance (SFA) account or electronic funds transfer initiated to ED as soon as possible, but no later than 45 days after the date the institution determines that the student withdrew. Returns by check are late if the check is issued more than 45 days after the institution determined the student withdrew, or the date on the cancelled check shows the check was endorsed more than 60 days after the date the institution determined that the student withdrew. OMB Compliance Supplement, 34 CFR section 668.22(e)(f): The amount of Title IV assistance earned by the student is calculated by dividing the number of days completed by the student within the period of enrollment by the total number of days in the enrollment period. The enrollment period includes all days within the period that the student was scheduled to complete, except that scheduled breaks of at least five consecutive days are excluded from the total number of calendar days in the period of enrollment and the number of calendar days completed in that period. Condition Significant Deficiency in Internal Control over Compliance – We noted the following instances of noncompliance: - For one of the sixty students tested, the District did not return the required funds to the Department of Education within the 45-day requirement. - For three of the sixty students tested, the District inaccurately calculated the Return to Title IV funds. Cause The District’s internal controls over Return to Title IV calculations were not sufficient to ensure compliance with relevant requirements. Effect The District is not in compliance with the aforementioned criteria. Questioned Costs There are no questioned costs associated with this finding. Context The District performed 541 Return to Title IV calculations during the year ended June 30, 2024. Repeat Finding (Yes or No) No. Recommendation The District should review policies and procedures over the Return to Title IV calculations to ensure that the procedures are in line with the compliance requirements of the program. The District should strengthen internal controls over the review of the Return to Title IV calculations to ensure that the data utilized in preparing the calculation is accurate and that required funds are returned in a timely manner.

Criteria or Specific Requirements 34 CFR 668.173(b): Return of Title IV funds are required to be deposited or transferred into the Student Financial Assistance (SFA) account or electronic funds transfer initiated to ED as soon as possible, but no later than 45 days after the date the institution determines that the student withdrew. Returns by check are late if the check is issued more than 45 days after the institution determined the student withdrew, or the date on the cancelled check shows the check was endorsed more than 60 days after the date the institution determined that the student withdrew. OMB Compliance Supplement, 34 CFR section 668.22(e)(f): The amount of Title IV assistance earned by the student is calculated by dividing the number of days completed by the student within the period of enrollment by the total number of days in the enrollment period. The enrollment period includes all days within the period that the student was scheduled to complete, except that scheduled breaks of at least five consecutive days are excluded from the total number of calendar days in the period of enrollment and the number of calendar days completed in that period. Condition Significant Deficiency in Internal Control over Compliance – We noted the following instances of noncompliance: - For one of the sixty students tested, the District did not return the required funds to the Department of Education within the 45-day requirement. - For three of the sixty students tested, the District inaccurately calculated the Return to Title IV funds. Cause The District’s internal controls over Return to Title IV calculations were not sufficient to ensure compliance with relevant requirements. Effect The District is not in compliance with the aforementioned criteria. Questioned Costs There are no questioned costs associated with this finding. Context The District performed 541 Return to Title IV calculations during the year ended June 30, 2024. Repeat Finding (Yes or No) No. Recommendation The District should review policies and procedures over the Return to Title IV calculations to ensure that the procedures are in line with the compliance requirements of the program. The District should strengthen internal controls over the review of the Return to Title IV calculations to ensure that the data utilized in preparing the calculation is accurate and that required funds are returned in a timely manner.

Criteria or Specific Requirements 34 CFR 668.173(b): Return of Title IV funds are required to be deposited or transferred into the Student Financial Assistance (SFA) account or electronic funds transfer initiated to ED as soon as possible, but no later than 45 days after the date the institution determines that the student withdrew. Returns by check are late if the check is issued more than 45 days after the institution determined the student withdrew, or the date on the cancelled check shows the check was endorsed more than 60 days after the date the institution determined that the student withdrew. OMB Compliance Supplement, 34 CFR section 668.22(e)(f): The amount of Title IV assistance earned by the student is calculated by dividing the number of days completed by the student within the period of enrollment by the total number of days in the enrollment period. The enrollment period includes all days within the period that the student was scheduled to complete, except that scheduled breaks of at least five consecutive days are excluded from the total number of calendar days in the period of enrollment and the number of calendar days completed in that period. Condition Significant Deficiency in Internal Control over Compliance – We noted the following instances of noncompliance: - For one of the sixty students tested, the District did not return the required funds to the Department of Education within the 45-day requirement. - For three of the sixty students tested, the District inaccurately calculated the Return to Title IV funds. Cause The District’s internal controls over Return to Title IV calculations were not sufficient to ensure compliance with relevant requirements. Effect The District is not in compliance with the aforementioned criteria. Questioned Costs There are no questioned costs associated with this finding. Context The District performed 541 Return to Title IV calculations during the year ended June 30, 2024. Repeat Finding (Yes or No) No. Recommendation The District should review policies and procedures over the Return to Title IV calculations to ensure that the procedures are in line with the compliance requirements of the program. The District should strengthen internal controls over the review of the Return to Title IV calculations to ensure that the data utilized in preparing the calculation is accurate and that required funds are returned in a timely manner.

Criteria or Specific Requirements OMB Compliance Supplement, OMB No. 1845-0035 – Institutions are required to report enrollment information under the Pell grant and the Direct Loan and Federal Family Educational Loan (FFEL) programs via the National Student Loan Data System (NSLDS). Institutions are responsible for accurately reporting the following significant data elements under the Campus-Level Record that ED considers high risk: - OPEID Number – This is the OPEID for the location that the student is attending. - Enrollment Effective Date – The date that the current enrollment status reported for a student was first effective. - Enrollment Status – The student’s enrollment status as of the reporting date; full-time (F), three-quarter time (Q), half-time (H), less than half-time (L), leave of absence (A), graduated (G), withdrawn (W), deceased (D), never attended (X) and record not found (Z) - Certification Date – The date enrollment was certified by the District. At a minimum, schools are required to certify enrollment every 60 days. Institutions are responsible for accurately reporting the following significant data elements under the Program-Level Record that ED considers high risk: - OPEID Number – This is the OPEID for the location that the student is attending. - CIP Code – The code that defines the student’s field of study. - CIP Year – The year that corresponds with the CIP Code. - Credential Level – The level of a credential the student will receive for the program the student is attending. - Published Program Length Measurement – How the program length is measured by the institution whether it be in days, weeks, or years. - Published Program Length – The time it takes to complete a program as determined by the College. - Program Begin Date – The date the student first began attending the program being reported. - Program Enrollment Status – The student’s enrollment status as of the reporting date; full-time (F), three-quarter time (Q), half-time (H), less than half-time (L), leave of absence (A), graduated (G), withdrawn (W), deceased (D), never attended (X) and record not found (Z) - Program Enrollment Effective Date – The date when the student’s current program status first took effect. Institutions are responsible for timely and accurate reporting, whether they report directly or through a third-party servicer. Condition Significant Deficiency in Internal Control over Compliance – During our review of the enrollment reporting requirements we observed the following: - For one of sixty students who had a change in their enrollment status during the period subject to audit, the District did not accurately report the effective date of the change. - For four of sixty students tested, there was no enrollment information reported to NSLDS during the period under audit. - For one of sixty students tested, the student’s field of study was not correctly reported to NSLDS. Cause The District did not accurately report enrollment information for students under the Pell grant and Direct loan programs via NSLDS. The administration of the Title IV programs depends heavily on the accuracy and timeliness of the enrollment information reported by institutions. Effect The District is not in compliance with the aforementioned criteria. Questioned Costs There are no questioned costs associated with this finding. Context During the 2023-2024 fiscal year, the District distributed student financial aid to approximately 9,260 students. Repeat Finding (Yes or No) No. Recommendation The District should implement a process to review, update, and verify student enrollment information that appear on the Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS Professional Access (NSLDSFAP) website.

Criteria or Specific Requirements OMB Compliance Supplement, OMB No. 1845-0035 – Institutions are required to report enrollment information under the Pell grant and the Direct Loan and Federal Family Educational Loan (FFEL) programs via the National Student Loan Data System (NSLDS). Institutions are responsible for accurately reporting the following significant data elements under the Campus-Level Record that ED considers high risk: - OPEID Number – This is the OPEID for the location that the student is attending. - Enrollment Effective Date – The date that the current enrollment status reported for a student was first effective. - Enrollment Status – The student’s enrollment status as of the reporting date; full-time (F), three-quarter time (Q), half-time (H), less than half-time (L), leave of absence (A), graduated (G), withdrawn (W), deceased (D), never attended (X) and record not found (Z) - Certification Date – The date enrollment was certified by the District. At a minimum, schools are required to certify enrollment every 60 days. Institutions are responsible for accurately reporting the following significant data elements under the Program-Level Record that ED considers high risk: - OPEID Number – This is the OPEID for the location that the student is attending. - CIP Code – The code that defines the student’s field of study. - CIP Year – The year that corresponds with the CIP Code. - Credential Level – The level of a credential the student will receive for the program the student is attending. - Published Program Length Measurement – How the program length is measured by the institution whether it be in days, weeks, or years. - Published Program Length – The time it takes to complete a program as determined by the College. - Program Begin Date – The date the student first began attending the program being reported. - Program Enrollment Status – The student’s enrollment status as of the reporting date; full-time (F), three-quarter time (Q), half-time (H), less than half-time (L), leave of absence (A), graduated (G), withdrawn (W), deceased (D), never attended (X) and record not found (Z) - Program Enrollment Effective Date – The date when the student’s current program status first took effect. Institutions are responsible for timely and accurate reporting, whether they report directly or through a third-party servicer. Condition Significant Deficiency in Internal Control over Compliance – During our review of the enrollment reporting requirements we observed the following: - For one of sixty students who had a change in their enrollment status during the period subject to audit, the District did not accurately report the effective date of the change. - For four of sixty students tested, there was no enrollment information reported to NSLDS during the period under audit. - For one of sixty students tested, the student’s field of study was not correctly reported to NSLDS. Cause The District did not accurately report enrollment information for students under the Pell grant and Direct loan programs via NSLDS. The administration of the Title IV programs depends heavily on the accuracy and timeliness of the enrollment information reported by institutions. Effect The District is not in compliance with the aforementioned criteria. Questioned Costs There are no questioned costs associated with this finding. Context During the 2023-2024 fiscal year, the District distributed student financial aid to approximately 9,260 students. Repeat Finding (Yes or No) No. Recommendation The District should implement a process to review, update, and verify student enrollment information that appear on the Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS Professional Access (NSLDSFAP) website.

Criteria or Specific Requirements OMB Compliance Supplement, OMB No. 1845-0035 – Institutions are required to report enrollment information under the Pell grant and the Direct Loan and Federal Family Educational Loan (FFEL) programs via the National Student Loan Data System (NSLDS). Institutions are responsible for accurately reporting the following significant data elements under the Campus-Level Record that ED considers high risk: - OPEID Number – This is the OPEID for the location that the student is attending. - Enrollment Effective Date – The date that the current enrollment status reported for a student was first effective. - Enrollment Status – The student’s enrollment status as of the reporting date; full-time (F), three-quarter time (Q), half-time (H), less than half-time (L), leave of absence (A), graduated (G), withdrawn (W), deceased (D), never attended (X) and record not found (Z) - Certification Date – The date enrollment was certified by the District. At a minimum, schools are required to certify enrollment every 60 days. Institutions are responsible for accurately reporting the following significant data elements under the Program-Level Record that ED considers high risk: - OPEID Number – This is the OPEID for the location that the student is attending. - CIP Code – The code that defines the student’s field of study. - CIP Year – The year that corresponds with the CIP Code. - Credential Level – The level of a credential the student will receive for the program the student is attending. - Published Program Length Measurement – How the program length is measured by the institution whether it be in days, weeks, or years. - Published Program Length – The time it takes to complete a program as determined by the College. - Program Begin Date – The date the student first began attending the program being reported. - Program Enrollment Status – The student’s enrollment status as of the reporting date; full-time (F), three-quarter time (Q), half-time (H), less than half-time (L), leave of absence (A), graduated (G), withdrawn (W), deceased (D), never attended (X) and record not found (Z) - Program Enrollment Effective Date – The date when the student’s current program status first took effect. Institutions are responsible for timely and accurate reporting, whether they report directly or through a third-party servicer. Condition Significant Deficiency in Internal Control over Compliance – During our review of the enrollment reporting requirements we observed the following: - For one of sixty students who had a change in their enrollment status during the period subject to audit, the District did not accurately report the effective date of the change. - For four of sixty students tested, there was no enrollment information reported to NSLDS during the period under audit. - For one of sixty students tested, the student’s field of study was not correctly reported to NSLDS. Cause The District did not accurately report enrollment information for students under the Pell grant and Direct loan programs via NSLDS. The administration of the Title IV programs depends heavily on the accuracy and timeliness of the enrollment information reported by institutions. Effect The District is not in compliance with the aforementioned criteria. Questioned Costs There are no questioned costs associated with this finding. Context During the 2023-2024 fiscal year, the District distributed student financial aid to approximately 9,260 students. Repeat Finding (Yes or No) No. Recommendation The District should implement a process to review, update, and verify student enrollment information that appear on the Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS Professional Access (NSLDSFAP) website.

Criteria or Specific Requirements OMB Compliance Supplement, OMB No. 1845-0035 – Institutions are required to report enrollment information under the Pell grant and the Direct Loan and Federal Family Educational Loan (FFEL) programs via the National Student Loan Data System (NSLDS). Institutions are responsible for accurately reporting the following significant data elements under the Campus-Level Record that ED considers high risk: - OPEID Number – This is the OPEID for the location that the student is attending. - Enrollment Effective Date – The date that the current enrollment status reported for a student was first effective. - Enrollment Status – The student’s enrollment status as of the reporting date; full-time (F), three-quarter time (Q), half-time (H), less than half-time (L), leave of absence (A), graduated (G), withdrawn (W), deceased (D), never attended (X) and record not found (Z) - Certification Date – The date enrollment was certified by the District. At a minimum, schools are required to certify enrollment every 60 days. Institutions are responsible for accurately reporting the following significant data elements under the Program-Level Record that ED considers high risk: - OPEID Number – This is the OPEID for the location that the student is attending. - CIP Code – The code that defines the student’s field of study. - CIP Year – The year that corresponds with the CIP Code. - Credential Level – The level of a credential the student will receive for the program the student is attending. - Published Program Length Measurement – How the program length is measured by the institution whether it be in days, weeks, or years. - Published Program Length – The time it takes to complete a program as determined by the College. - Program Begin Date – The date the student first began attending the program being reported. - Program Enrollment Status – The student’s enrollment status as of the reporting date; full-time (F), three-quarter time (Q), half-time (H), less than half-time (L), leave of absence (A), graduated (G), withdrawn (W), deceased (D), never attended (X) and record not found (Z) - Program Enrollment Effective Date – The date when the student’s current program status first took effect. Institutions are responsible for timely and accurate reporting, whether they report directly or through a third-party servicer. Condition Significant Deficiency in Internal Control over Compliance – During our review of the enrollment reporting requirements we observed the following: - For one of sixty students who had a change in their enrollment status during the period subject to audit, the District did not accurately report the effective date of the change. - For four of sixty students tested, there was no enrollment information reported to NSLDS during the period under audit. - For one of sixty students tested, the student’s field of study was not correctly reported to NSLDS. Cause The District did not accurately report enrollment information for students under the Pell grant and Direct loan programs via NSLDS. The administration of the Title IV programs depends heavily on the accuracy and timeliness of the enrollment information reported by institutions. Effect The District is not in compliance with the aforementioned criteria. Questioned Costs There are no questioned costs associated with this finding. Context During the 2023-2024 fiscal year, the District distributed student financial aid to approximately 9,260 students. Repeat Finding (Yes or No) No. Recommendation The District should implement a process to review, update, and verify student enrollment information that appear on the Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS Professional Access (NSLDSFAP) website.

Criteria or Specific Requirements OMB Compliance Supplement, OMB No. 1845-0035 – Institutions are required to report enrollment information under the Pell grant and the Direct Loan and Federal Family Educational Loan (FFEL) programs via the National Student Loan Data System (NSLDS). Institutions are responsible for accurately reporting the following significant data elements under the Campus-Level Record that ED considers high risk: - OPEID Number – This is the OPEID for the location that the student is attending. - Enrollment Effective Date – The date that the current enrollment status reported for a student was first effective. - Enrollment Status – The student’s enrollment status as of the reporting date; full-time (F), three-quarter time (Q), half-time (H), less than half-time (L), leave of absence (A), graduated (G), withdrawn (W), deceased (D), never attended (X) and record not found (Z) - Certification Date – The date enrollment was certified by the District. At a minimum, schools are required to certify enrollment every 60 days. Institutions are responsible for accurately reporting the following significant data elements under the Program-Level Record that ED considers high risk: - OPEID Number – This is the OPEID for the location that the student is attending. - CIP Code – The code that defines the student’s field of study. - CIP Year – The year that corresponds with the CIP Code. - Credential Level – The level of a credential the student will receive for the program the student is attending. - Published Program Length Measurement – How the program length is measured by the institution whether it be in days, weeks, or years. - Published Program Length – The time it takes to complete a program as determined by the College. - Program Begin Date – The date the student first began attending the program being reported. - Program Enrollment Status – The student’s enrollment status as of the reporting date; full-time (F), three-quarter time (Q), half-time (H), less than half-time (L), leave of absence (A), graduated (G), withdrawn (W), deceased (D), never attended (X) and record not found (Z) - Program Enrollment Effective Date – The date when the student’s current program status first took effect. Institutions are responsible for timely and accurate reporting, whether they report directly or through a third-party servicer. Condition Significant Deficiency in Internal Control over Compliance – During our review of the enrollment reporting requirements we observed the following: - For one of sixty students who had a change in their enrollment status during the period subject to audit, the District did not accurately report the effective date of the change. - For four of sixty students tested, there was no enrollment information reported to NSLDS during the period under audit. - For one of sixty students tested, the student’s field of study was not correctly reported to NSLDS. Cause The District did not accurately report enrollment information for students under the Pell grant and Direct loan programs via NSLDS. The administration of the Title IV programs depends heavily on the accuracy and timeliness of the enrollment information reported by institutions. Effect The District is not in compliance with the aforementioned criteria. Questioned Costs There are no questioned costs associated with this finding. Context During the 2023-2024 fiscal year, the District distributed student financial aid to approximately 9,260 students. Repeat Finding (Yes or No) No. Recommendation The District should implement a process to review, update, and verify student enrollment information that appear on the Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS Professional Access (NSLDSFAP) website.

Criteria or Specific Requirements OMB Compliance Supplement, OMB No. 1845-0035 – Institutions are required to report enrollment information under the Pell grant and the Direct Loan and Federal Family Educational Loan (FFEL) programs via the National Student Loan Data System (NSLDS). Institutions are responsible for accurately reporting the following significant data elements under the Campus-Level Record that ED considers high risk: - OPEID Number – This is the OPEID for the location that the student is attending. - Enrollment Effective Date – The date that the current enrollment status reported for a student was first effective. - Enrollment Status – The student’s enrollment status as of the reporting date; full-time (F), three-quarter time (Q), half-time (H), less than half-time (L), leave of absence (A), graduated (G), withdrawn (W), deceased (D), never attended (X) and record not found (Z) - Certification Date – The date enrollment was certified by the District. At a minimum, schools are required to certify enrollment every 60 days. Institutions are responsible for accurately reporting the following significant data elements under the Program-Level Record that ED considers high risk: - OPEID Number – This is the OPEID for the location that the student is attending. - CIP Code – The code that defines the student’s field of study. - CIP Year – The year that corresponds with the CIP Code. - Credential Level – The level of a credential the student will receive for the program the student is attending. - Published Program Length Measurement – How the program length is measured by the institution whether it be in days, weeks, or years. - Published Program Length – The time it takes to complete a program as determined by the College. - Program Begin Date – The date the student first began attending the program being reported. - Program Enrollment Status – The student’s enrollment status as of the reporting date; full-time (F), three-quarter time (Q), half-time (H), less than half-time (L), leave of absence (A), graduated (G), withdrawn (W), deceased (D), never attended (X) and record not found (Z) - Program Enrollment Effective Date – The date when the student’s current program status first took effect. Institutions are responsible for timely and accurate reporting, whether they report directly or through a third-party servicer. Condition Significant Deficiency in Internal Control over Compliance – During our review of the enrollment reporting requirements we observed the following: - For one of sixty students who had a change in their enrollment status during the period subject to audit, the District did not accurately report the effective date of the change. - For four of sixty students tested, there was no enrollment information reported to NSLDS during the period under audit. - For one of sixty students tested, the student’s field of study was not correctly reported to NSLDS. Cause The District did not accurately report enrollment information for students under the Pell grant and Direct loan programs via NSLDS. The administration of the Title IV programs depends heavily on the accuracy and timeliness of the enrollment information reported by institutions. Effect The District is not in compliance with the aforementioned criteria. Questioned Costs There are no questioned costs associated with this finding. Context During the 2023-2024 fiscal year, the District distributed student financial aid to approximately 9,260 students. Repeat Finding (Yes or No) No. Recommendation The District should implement a process to review, update, and verify student enrollment information that appear on the Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS Professional Access (NSLDSFAP) website.

Criteria or Specific Requirements OMB Compliance Supplement, OMB No. 1845-0035 – Institutions are required to report enrollment information under the Pell grant and the Direct Loan and Federal Family Educational Loan (FFEL) programs via the National Student Loan Data System (NSLDS). Institutions are responsible for accurately reporting the following significant data elements under the Campus-Level Record that ED considers high risk: - OPEID Number – This is the OPEID for the location that the student is attending. - Enrollment Effective Date – The date that the current enrollment status reported for a student was first effective. - Enrollment Status – The student’s enrollment status as of the reporting date; full-time (F), three-quarter time (Q), half-time (H), less than half-time (L), leave of absence (A), graduated (G), withdrawn (W), deceased (D), never attended (X) and record not found (Z) - Certification Date – The date enrollment was certified by the District. At a minimum, schools are required to certify enrollment every 60 days. Institutions are responsible for accurately reporting the following significant data elements under the Program-Level Record that ED considers high risk: - OPEID Number – This is the OPEID for the location that the student is attending. - CIP Code – The code that defines the student’s field of study. - CIP Year – The year that corresponds with the CIP Code. - Credential Level – The level of a credential the student will receive for the program the student is attending. - Published Program Length Measurement – How the program length is measured by the institution whether it be in days, weeks, or years. - Published Program Length – The time it takes to complete a program as determined by the College. - Program Begin Date – The date the student first began attending the program being reported. - Program Enrollment Status – The student’s enrollment status as of the reporting date; full-time (F), three-quarter time (Q), half-time (H), less than half-time (L), leave of absence (A), graduated (G), withdrawn (W), deceased (D), never attended (X) and record not found (Z) - Program Enrollment Effective Date – The date when the student’s current program status first took effect. Institutions are responsible for timely and accurate reporting, whether they report directly or through a third-party servicer. Condition Significant Deficiency in Internal Control over Compliance – During our review of the enrollment reporting requirements we observed the following: - For one of sixty students who had a change in their enrollment status during the period subject to audit, the District did not accurately report the effective date of the change. - For four of sixty students tested, there was no enrollment information reported to NSLDS during the period under audit. - For one of sixty students tested, the student’s field of study was not correctly reported to NSLDS. Cause The District did not accurately report enrollment information for students under the Pell grant and Direct loan programs via NSLDS. The administration of the Title IV programs depends heavily on the accuracy and timeliness of the enrollment information reported by institutions. Effect The District is not in compliance with the aforementioned criteria. Questioned Costs There are no questioned costs associated with this finding. Context During the 2023-2024 fiscal year, the District distributed student financial aid to approximately 9,260 students. Repeat Finding (Yes or No) No. Recommendation The District should implement a process to review, update, and verify student enrollment information that appear on the Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS Professional Access (NSLDSFAP) website.

Criteria or Specific Requirements Common Origination and Disbursement (COD) System (OMB No. 1845-0039) – Institutions submit Direct Loan and Pell Grant origination records and disbursement records to Department of Education through the COD system. Origination records can be sent well in advance of any disbursements, as early as the school chooses to submit them for any student the school reasonably believes will be eligible for a payment. 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 school. Institutions must report student payment data within 15 calendar days after the school makes a payment, or becomes aware of the need to make an adjustment to previously reported student payment data or expected student payment data. Condition Significant Deficiency in Internal Control over Compliance – The District inaccurately reported the disbursement date for one of sixty disbursements tested during the course of our audit. Cause The District’s internal controls over COD Reporting were not performed as prescribed to prevent erroneous reporting. Effect The District is not in compliance with the aforementioned criteria. Context During the 2023-2024 fiscal year, the District distributed student financial aid to approximately 9,260 students. Questioned Costs There are no questioned costs associated with this finding. Repeat Finding (Yes or No) No. Recommendation The District should continue to monitor and review their policies and control procedures in place over COD reporting to confirm they operate as intended to ensure compliance with Federal requirements.

Criteria or Specific Requirements Common Origination and Disbursement (COD) System (OMB No. 1845-0039) – Institutions submit Direct Loan and Pell Grant origination records and disbursement records to Department of Education through the COD system. Origination records can be sent well in advance of any disbursements, as early as the school chooses to submit them for any student the school reasonably believes will be eligible for a payment. 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 school. Institutions must report student payment data within 15 calendar days after the school makes a payment, or becomes aware of the need to make an adjustment to previously reported student payment data or expected student payment data. Condition Significant Deficiency in Internal Control over Compliance – The District inaccurately reported the disbursement date for one of sixty disbursements tested during the course of our audit. Cause The District’s internal controls over COD Reporting were not performed as prescribed to prevent erroneous reporting. Effect The District is not in compliance with the aforementioned criteria. Context During the 2023-2024 fiscal year, the District distributed student financial aid to approximately 9,260 students. Questioned Costs There are no questioned costs associated with this finding. Repeat Finding (Yes or No) No. Recommendation The District should continue to monitor and review their policies and control procedures in place over COD reporting to confirm they operate as intended to ensure compliance with Federal requirements.

Criteria or Specific Requirements Common Origination and Disbursement (COD) System (OMB No. 1845-0039) – Institutions submit Direct Loan and Pell Grant origination records and disbursement records to Department of Education through the COD system. Origination records can be sent well in advance of any disbursements, as early as the school chooses to submit them for any student the school reasonably believes will be eligible for a payment. 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 school. Institutions must report student payment data within 15 calendar days after the school makes a payment, or becomes aware of the need to make an adjustment to previously reported student payment data or expected student payment data. Condition Significant Deficiency in Internal Control over Compliance – The District inaccurately reported the disbursement date for one of sixty disbursements tested during the course of our audit. Cause The District’s internal controls over COD Reporting were not performed as prescribed to prevent erroneous reporting. Effect The District is not in compliance with the aforementioned criteria. Context During the 2023-2024 fiscal year, the District distributed student financial aid to approximately 9,260 students. Questioned Costs There are no questioned costs associated with this finding. Repeat Finding (Yes or No) No. Recommendation The District should continue to monitor and review their policies and control procedures in place over COD reporting to confirm they operate as intended to ensure compliance with Federal requirements.

Criteria or Specific Requirements Common Origination and Disbursement (COD) System (OMB No. 1845-0039) – Institutions submit Direct Loan and Pell Grant origination records and disbursement records to Department of Education through the COD system. Origination records can be sent well in advance of any disbursements, as early as the school chooses to submit them for any student the school reasonably believes will be eligible for a payment. 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 school. Institutions must report student payment data within 15 calendar days after the school makes a payment, or becomes aware of the need to make an adjustment to previously reported student payment data or expected student payment data. Condition Significant Deficiency in Internal Control over Compliance – The District inaccurately reported the disbursement date for one of sixty disbursements tested during the course of our audit. Cause The District’s internal controls over COD Reporting were not performed as prescribed to prevent erroneous reporting. Effect The District is not in compliance with the aforementioned criteria. Context During the 2023-2024 fiscal year, the District distributed student financial aid to approximately 9,260 students. Questioned Costs There are no questioned costs associated with this finding. Repeat Finding (Yes or No) No. Recommendation The District should continue to monitor and review their policies and control procedures in place over COD reporting to confirm they operate as intended to ensure compliance with Federal requirements.

Criteria or Specific Requirements Common Origination and Disbursement (COD) System (OMB No. 1845-0039) – Institutions submit Direct Loan and Pell Grant origination records and disbursement records to Department of Education through the COD system. Origination records can be sent well in advance of any disbursements, as early as the school chooses to submit them for any student the school reasonably believes will be eligible for a payment. 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 school. Institutions must report student payment data within 15 calendar days after the school makes a payment, or becomes aware of the need to make an adjustment to previously reported student payment data or expected student payment data. Condition Significant Deficiency in Internal Control over Compliance – The District inaccurately reported the disbursement date for one of sixty disbursements tested during the course of our audit. Cause The District’s internal controls over COD Reporting were not performed as prescribed to prevent erroneous reporting. Effect The District is not in compliance with the aforementioned criteria. Context During the 2023-2024 fiscal year, the District distributed student financial aid to approximately 9,260 students. Questioned Costs There are no questioned costs associated with this finding. Repeat Finding (Yes or No) No. Recommendation The District should continue to monitor and review their policies and control procedures in place over COD reporting to confirm they operate as intended to ensure compliance with Federal requirements.

Criteria or Specific Requirements Common Origination and Disbursement (COD) System (OMB No. 1845-0039) – Institutions submit Direct Loan and Pell Grant origination records and disbursement records to Department of Education through the COD system. Origination records can be sent well in advance of any disbursements, as early as the school chooses to submit them for any student the school reasonably believes will be eligible for a payment. 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 school. Institutions must report student payment data within 15 calendar days after the school makes a payment, or becomes aware of the need to make an adjustment to previously reported student payment data or expected student payment data. Condition Significant Deficiency in Internal Control over Compliance – The District inaccurately reported the disbursement date for one of sixty disbursements tested during the course of our audit. Cause The District’s internal controls over COD Reporting were not performed as prescribed to prevent erroneous reporting. Effect The District is not in compliance with the aforementioned criteria. Context During the 2023-2024 fiscal year, the District distributed student financial aid to approximately 9,260 students. Questioned Costs There are no questioned costs associated with this finding. Repeat Finding (Yes or No) No. Recommendation The District should continue to monitor and review their policies and control procedures in place over COD reporting to confirm they operate as intended to ensure compliance with Federal requirements.

Criteria or Specific Requirements Common Origination and Disbursement (COD) System (OMB No. 1845-0039) – Institutions submit Direct Loan and Pell Grant origination records and disbursement records to Department of Education through the COD system. Origination records can be sent well in advance of any disbursements, as early as the school chooses to submit them for any student the school reasonably believes will be eligible for a payment. 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 school. Institutions must report student payment data within 15 calendar days after the school makes a payment, or becomes aware of the need to make an adjustment to previously reported student payment data or expected student payment data. Condition Significant Deficiency in Internal Control over Compliance – The District inaccurately reported the disbursement date for one of sixty disbursements tested during the course of our audit. Cause The District’s internal controls over COD Reporting were not performed as prescribed to prevent erroneous reporting. Effect The District is not in compliance with the aforementioned criteria. Context During the 2023-2024 fiscal year, the District distributed student financial aid to approximately 9,260 students. Questioned Costs There are no questioned costs associated with this finding. Repeat Finding (Yes or No) No. Recommendation The District should continue to monitor and review their policies and control procedures in place over COD reporting to confirm they operate as intended to ensure compliance with Federal requirements.

Criteria or Specific Requirements 34 CFR 668.173(b): Return of Title IV funds are required to be deposited or transferred into the Student Financial Assistance (SFA) account or electronic funds transfer initiated to ED as soon as possible, but no later than 45 days after the date the institution determines that the student withdrew. Returns by check are late if the check is issued more than 45 days after the institution determined the student withdrew, or the date on the cancelled check shows the check was endorsed more than 60 days after the date the institution determined that the student withdrew. OMB Compliance Supplement, 34 CFR section 668.22(e)(f): The amount of Title IV assistance earned by the student is calculated by dividing the number of days completed by the student within the period of enrollment by the total number of days in the enrollment period. The enrollment period includes all days within the period that the student was scheduled to complete, except that scheduled breaks of at least five consecutive days are excluded from the total number of calendar days in the period of enrollment and the number of calendar days completed in that period. Condition Significant Deficiency in Internal Control over Compliance – We noted the following instances of noncompliance: - For one of the sixty students tested, the District did not return the required funds to the Department of Education within the 45-day requirement. - For three of the sixty students tested, the District inaccurately calculated the Return to Title IV funds. Cause The District’s internal controls over Return to Title IV calculations were not sufficient to ensure compliance with relevant requirements. Effect The District is not in compliance with the aforementioned criteria. Questioned Costs There are no questioned costs associated with this finding. Context The District performed 541 Return to Title IV calculations during the year ended June 30, 2024. Repeat Finding (Yes or No) No. Recommendation The District should review policies and procedures over the Return to Title IV calculations to ensure that the procedures are in line with the compliance requirements of the program. The District should strengthen internal controls over the review of the Return to Title IV calculations to ensure that the data utilized in preparing the calculation is accurate and that required funds are returned in a timely manner.

Criteria or Specific Requirements 34 CFR 668.173(b): Return of Title IV funds are required to be deposited or transferred into the Student Financial Assistance (SFA) account or electronic funds transfer initiated to ED as soon as possible, but no later than 45 days after the date the institution determines that the student withdrew. Returns by check are late if the check is issued more than 45 days after the institution determined the student withdrew, or the date on the cancelled check shows the check was endorsed more than 60 days after the date the institution determined that the student withdrew. OMB Compliance Supplement, 34 CFR section 668.22(e)(f): The amount of Title IV assistance earned by the student is calculated by dividing the number of days completed by the student within the period of enrollment by the total number of days in the enrollment period. The enrollment period includes all days within the period that the student was scheduled to complete, except that scheduled breaks of at least five consecutive days are excluded from the total number of calendar days in the period of enrollment and the number of calendar days completed in that period. Condition Significant Deficiency in Internal Control over Compliance – We noted the following instances of noncompliance: - For one of the sixty students tested, the District did not return the required funds to the Department of Education within the 45-day requirement. - For three of the sixty students tested, the District inaccurately calculated the Return to Title IV funds. Cause The District’s internal controls over Return to Title IV calculations were not sufficient to ensure compliance with relevant requirements. Effect The District is not in compliance with the aforementioned criteria. Questioned Costs There are no questioned costs associated with this finding. Context The District performed 541 Return to Title IV calculations during the year ended June 30, 2024. Repeat Finding (Yes or No) No. Recommendation The District should review policies and procedures over the Return to Title IV calculations to ensure that the procedures are in line with the compliance requirements of the program. The District should strengthen internal controls over the review of the Return to Title IV calculations to ensure that the data utilized in preparing the calculation is accurate and that required funds are returned in a timely manner.

Criteria or Specific Requirements 34 CFR 668.173(b): Return of Title IV funds are required to be deposited or transferred into the Student Financial Assistance (SFA) account or electronic funds transfer initiated to ED as soon as possible, but no later than 45 days after the date the institution determines that the student withdrew. Returns by check are late if the check is issued more than 45 days after the institution determined the student withdrew, or the date on the cancelled check shows the check was endorsed more than 60 days after the date the institution determined that the student withdrew. OMB Compliance Supplement, 34 CFR section 668.22(e)(f): The amount of Title IV assistance earned by the student is calculated by dividing the number of days completed by the student within the period of enrollment by the total number of days in the enrollment period. The enrollment period includes all days within the period that the student was scheduled to complete, except that scheduled breaks of at least five consecutive days are excluded from the total number of calendar days in the period of enrollment and the number of calendar days completed in that period. Condition Significant Deficiency in Internal Control over Compliance – We noted the following instances of noncompliance: - For one of the sixty students tested, the District did not return the required funds to the Department of Education within the 45-day requirement. - For three of the sixty students tested, the District inaccurately calculated the Return to Title IV funds. Cause The District’s internal controls over Return to Title IV calculations were not sufficient to ensure compliance with relevant requirements. Effect The District is not in compliance with the aforementioned criteria. Questioned Costs There are no questioned costs associated with this finding. Context The District performed 541 Return to Title IV calculations during the year ended June 30, 2024. Repeat Finding (Yes or No) No. Recommendation The District should review policies and procedures over the Return to Title IV calculations to ensure that the procedures are in line with the compliance requirements of the program. The District should strengthen internal controls over the review of the Return to Title IV calculations to ensure that the data utilized in preparing the calculation is accurate and that required funds are returned in a timely manner.

Criteria or Specific Requirements 34 CFR 668.173(b): Return of Title IV funds are required to be deposited or transferred into the Student Financial Assistance (SFA) account or electronic funds transfer initiated to ED as soon as possible, but no later than 45 days after the date the institution determines that the student withdrew. Returns by check are late if the check is issued more than 45 days after the institution determined the student withdrew, or the date on the cancelled check shows the check was endorsed more than 60 days after the date the institution determined that the student withdrew. OMB Compliance Supplement, 34 CFR section 668.22(e)(f): The amount of Title IV assistance earned by the student is calculated by dividing the number of days completed by the student within the period of enrollment by the total number of days in the enrollment period. The enrollment period includes all days within the period that the student was scheduled to complete, except that scheduled breaks of at least five consecutive days are excluded from the total number of calendar days in the period of enrollment and the number of calendar days completed in that period. Condition Significant Deficiency in Internal Control over Compliance – We noted the following instances of noncompliance: - For one of the sixty students tested, the District did not return the required funds to the Department of Education within the 45-day requirement. - For three of the sixty students tested, the District inaccurately calculated the Return to Title IV funds. Cause The District’s internal controls over Return to Title IV calculations were not sufficient to ensure compliance with relevant requirements. Effect The District is not in compliance with the aforementioned criteria. Questioned Costs There are no questioned costs associated with this finding. Context The District performed 541 Return to Title IV calculations during the year ended June 30, 2024. Repeat Finding (Yes or No) No. Recommendation The District should review policies and procedures over the Return to Title IV calculations to ensure that the procedures are in line with the compliance requirements of the program. The District should strengthen internal controls over the review of the Return to Title IV calculations to ensure that the data utilized in preparing the calculation is accurate and that required funds are returned in a timely manner.

Criteria or Specific Requirements 34 CFR 668.173(b): Return of Title IV funds are required to be deposited or transferred into the Student Financial Assistance (SFA) account or electronic funds transfer initiated to ED as soon as possible, but no later than 45 days after the date the institution determines that the student withdrew. Returns by check are late if the check is issued more than 45 days after the institution determined the student withdrew, or the date on the cancelled check shows the check was endorsed more than 60 days after the date the institution determined that the student withdrew. OMB Compliance Supplement, 34 CFR section 668.22(e)(f): The amount of Title IV assistance earned by the student is calculated by dividing the number of days completed by the student within the period of enrollment by the total number of days in the enrollment period. The enrollment period includes all days within the period that the student was scheduled to complete, except that scheduled breaks of at least five consecutive days are excluded from the total number of calendar days in the period of enrollment and the number of calendar days completed in that period. Condition Significant Deficiency in Internal Control over Compliance – We noted the following instances of noncompliance: - For one of the sixty students tested, the District did not return the required funds to the Department of Education within the 45-day requirement. - For three of the sixty students tested, the District inaccurately calculated the Return to Title IV funds. Cause The District’s internal controls over Return to Title IV calculations were not sufficient to ensure compliance with relevant requirements. Effect The District is not in compliance with the aforementioned criteria. Questioned Costs There are no questioned costs associated with this finding. Context The District performed 541 Return to Title IV calculations during the year ended June 30, 2024. Repeat Finding (Yes or No) No. Recommendation The District should review policies and procedures over the Return to Title IV calculations to ensure that the procedures are in line with the compliance requirements of the program. The District should strengthen internal controls over the review of the Return to Title IV calculations to ensure that the data utilized in preparing the calculation is accurate and that required funds are returned in a timely manner.

Criteria or Specific Requirements 34 CFR 668.173(b): Return of Title IV funds are required to be deposited or transferred into the Student Financial Assistance (SFA) account or electronic funds transfer initiated to ED as soon as possible, but no later than 45 days after the date the institution determines that the student withdrew. Returns by check are late if the check is issued more than 45 days after the institution determined the student withdrew, or the date on the cancelled check shows the check was endorsed more than 60 days after the date the institution determined that the student withdrew. OMB Compliance Supplement, 34 CFR section 668.22(e)(f): The amount of Title IV assistance earned by the student is calculated by dividing the number of days completed by the student within the period of enrollment by the total number of days in the enrollment period. The enrollment period includes all days within the period that the student was scheduled to complete, except that scheduled breaks of at least five consecutive days are excluded from the total number of calendar days in the period of enrollment and the number of calendar days completed in that period. Condition Significant Deficiency in Internal Control over Compliance – We noted the following instances of noncompliance: - For one of the sixty students tested, the District did not return the required funds to the Department of Education within the 45-day requirement. - For three of the sixty students tested, the District inaccurately calculated the Return to Title IV funds. Cause The District’s internal controls over Return to Title IV calculations were not sufficient to ensure compliance with relevant requirements. Effect The District is not in compliance with the aforementioned criteria. Questioned Costs There are no questioned costs associated with this finding. Context The District performed 541 Return to Title IV calculations during the year ended June 30, 2024. Repeat Finding (Yes or No) No. Recommendation The District should review policies and procedures over the Return to Title IV calculations to ensure that the procedures are in line with the compliance requirements of the program. The District should strengthen internal controls over the review of the Return to Title IV calculations to ensure that the data utilized in preparing the calculation is accurate and that required funds are returned in a timely manner.

Criteria or Specific Requirements 34 CFR 668.173(b): Return of Title IV funds are required to be deposited or transferred into the Student Financial Assistance (SFA) account or electronic funds transfer initiated to ED as soon as possible, but no later than 45 days after the date the institution determines that the student withdrew. Returns by check are late if the check is issued more than 45 days after the institution determined the student withdrew, or the date on the cancelled check shows the check was endorsed more than 60 days after the date the institution determined that the student withdrew. OMB Compliance Supplement, 34 CFR section 668.22(e)(f): The amount of Title IV assistance earned by the student is calculated by dividing the number of days completed by the student within the period of enrollment by the total number of days in the enrollment period. The enrollment period includes all days within the period that the student was scheduled to complete, except that scheduled breaks of at least five consecutive days are excluded from the total number of calendar days in the period of enrollment and the number of calendar days completed in that period. Condition Significant Deficiency in Internal Control over Compliance – We noted the following instances of noncompliance: - For one of the sixty students tested, the District did not return the required funds to the Department of Education within the 45-day requirement. - For three of the sixty students tested, the District inaccurately calculated the Return to Title IV funds. Cause The District’s internal controls over Return to Title IV calculations were not sufficient to ensure compliance with relevant requirements. Effect The District is not in compliance with the aforementioned criteria. Questioned Costs There are no questioned costs associated with this finding. Context The District performed 541 Return to Title IV calculations during the year ended June 30, 2024. Repeat Finding (Yes or No) No. Recommendation The District should review policies and procedures over the Return to Title IV calculations to ensure that the procedures are in line with the compliance requirements of the program. The District should strengthen internal controls over the review of the Return to Title IV calculations to ensure that the data utilized in preparing the calculation is accurate and that required funds are returned in a timely manner.

Criteria or Specific Requirements OMB Compliance Supplement, OMB No. 1845-0035 – Institutions are required to report enrollment information under the Pell grant and the Direct Loan and Federal Family Educational Loan (FFEL) programs via the National Student Loan Data System (NSLDS). Institutions are responsible for accurately reporting the following significant data elements under the Campus-Level Record that ED considers high risk: - OPEID Number – This is the OPEID for the location that the student is attending. - Enrollment Effective Date – The date that the current enrollment status reported for a student was first effective. - Enrollment Status – The student’s enrollment status as of the reporting date; full-time (F), three-quarter time (Q), half-time (H), less than half-time (L), leave of absence (A), graduated (G), withdrawn (W), deceased (D), never attended (X) and record not found (Z) - Certification Date – The date enrollment was certified by the District. At a minimum, schools are required to certify enrollment every 60 days. Institutions are responsible for accurately reporting the following significant data elements under the Program-Level Record that ED considers high risk: - OPEID Number – This is the OPEID for the location that the student is attending. - CIP Code – The code that defines the student’s field of study. - CIP Year – The year that corresponds with the CIP Code. - Credential Level – The level of a credential the student will receive for the program the student is attending. - Published Program Length Measurement – How the program length is measured by the institution whether it be in days, weeks, or years. - Published Program Length – The time it takes to complete a program as determined by the College. - Program Begin Date – The date the student first began attending the program being reported. - Program Enrollment Status – The student’s enrollment status as of the reporting date; full-time (F), three-quarter time (Q), half-time (H), less than half-time (L), leave of absence (A), graduated (G), withdrawn (W), deceased (D), never attended (X) and record not found (Z) - Program Enrollment Effective Date – The date when the student’s current program status first took effect. Institutions are responsible for timely and accurate reporting, whether they report directly or through a third-party servicer. Condition Significant Deficiency in Internal Control over Compliance – During our review of the enrollment reporting requirements we observed the following: - For one of sixty students who had a change in their enrollment status during the period subject to audit, the District did not accurately report the effective date of the change. - For four of sixty students tested, there was no enrollment information reported to NSLDS during the period under audit. - For one of sixty students tested, the student’s field of study was not correctly reported to NSLDS. Cause The District did not accurately report enrollment information for students under the Pell grant and Direct loan programs via NSLDS. The administration of the Title IV programs depends heavily on the accuracy and timeliness of the enrollment information reported by institutions. Effect The District is not in compliance with the aforementioned criteria. Questioned Costs There are no questioned costs associated with this finding. Context During the 2023-2024 fiscal year, the District distributed student financial aid to approximately 9,260 students. Repeat Finding (Yes or No) No. Recommendation The District should implement a process to review, update, and verify student enrollment information that appear on the Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS Professional Access (NSLDSFAP) website.

Criteria or Specific Requirements OMB Compliance Supplement, OMB No. 1845-0035 – Institutions are required to report enrollment information under the Pell grant and the Direct Loan and Federal Family Educational Loan (FFEL) programs via the National Student Loan Data System (NSLDS). Institutions are responsible for accurately reporting the following significant data elements under the Campus-Level Record that ED considers high risk: - OPEID Number – This is the OPEID for the location that the student is attending. - Enrollment Effective Date – The date that the current enrollment status reported for a student was first effective. - Enrollment Status – The student’s enrollment status as of the reporting date; full-time (F), three-quarter time (Q), half-time (H), less than half-time (L), leave of absence (A), graduated (G), withdrawn (W), deceased (D), never attended (X) and record not found (Z) - Certification Date – The date enrollment was certified by the District. At a minimum, schools are required to certify enrollment every 60 days. Institutions are responsible for accurately reporting the following significant data elements under the Program-Level Record that ED considers high risk: - OPEID Number – This is the OPEID for the location that the student is attending. - CIP Code – The code that defines the student’s field of study. - CIP Year – The year that corresponds with the CIP Code. - Credential Level – The level of a credential the student will receive for the program the student is attending. - Published Program Length Measurement – How the program length is measured by the institution whether it be in days, weeks, or years. - Published Program Length – The time it takes to complete a program as determined by the College. - Program Begin Date – The date the student first began attending the program being reported. - Program Enrollment Status – The student’s enrollment status as of the reporting date; full-time (F), three-quarter time (Q), half-time (H), less than half-time (L), leave of absence (A), graduated (G), withdrawn (W), deceased (D), never attended (X) and record not found (Z) - Program Enrollment Effective Date – The date when the student’s current program status first took effect. Institutions are responsible for timely and accurate reporting, whether they report directly or through a third-party servicer. Condition Significant Deficiency in Internal Control over Compliance – During our review of the enrollment reporting requirements we observed the following: - For one of sixty students who had a change in their enrollment status during the period subject to audit, the District did not accurately report the effective date of the change. - For four of sixty students tested, there was no enrollment information reported to NSLDS during the period under audit. - For one of sixty students tested, the student’s field of study was not correctly reported to NSLDS. Cause The District did not accurately report enrollment information for students under the Pell grant and Direct loan programs via NSLDS. The administration of the Title IV programs depends heavily on the accuracy and timeliness of the enrollment information reported by institutions. Effect The District is not in compliance with the aforementioned criteria. Questioned Costs There are no questioned costs associated with this finding. Context During the 2023-2024 fiscal year, the District distributed student financial aid to approximately 9,260 students. Repeat Finding (Yes or No) No. Recommendation The District should implement a process to review, update, and verify student enrollment information that appear on the Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS Professional Access (NSLDSFAP) website.

Criteria or Specific Requirements OMB Compliance Supplement, OMB No. 1845-0035 – Institutions are required to report enrollment information under the Pell grant and the Direct Loan and Federal Family Educational Loan (FFEL) programs via the National Student Loan Data System (NSLDS). Institutions are responsible for accurately reporting the following significant data elements under the Campus-Level Record that ED considers high risk: - OPEID Number – This is the OPEID for the location that the student is attending. - Enrollment Effective Date – The date that the current enrollment status reported for a student was first effective. - Enrollment Status – The student’s enrollment status as of the reporting date; full-time (F), three-quarter time (Q), half-time (H), less than half-time (L), leave of absence (A), graduated (G), withdrawn (W), deceased (D), never attended (X) and record not found (Z) - Certification Date – The date enrollment was certified by the District. At a minimum, schools are required to certify enrollment every 60 days. Institutions are responsible for accurately reporting the following significant data elements under the Program-Level Record that ED considers high risk: - OPEID Number – This is the OPEID for the location that the student is attending. - CIP Code – The code that defines the student’s field of study. - CIP Year – The year that corresponds with the CIP Code. - Credential Level – The level of a credential the student will receive for the program the student is attending. - Published Program Length Measurement – How the program length is measured by the institution whether it be in days, weeks, or years. - Published Program Length – The time it takes to complete a program as determined by the College. - Program Begin Date – The date the student first began attending the program being reported. - Program Enrollment Status – The student’s enrollment status as of the reporting date; full-time (F), three-quarter time (Q), half-time (H), less than half-time (L), leave of absence (A), graduated (G), withdrawn (W), deceased (D), never attended (X) and record not found (Z) - Program Enrollment Effective Date – The date when the student’s current program status first took effect. Institutions are responsible for timely and accurate reporting, whether they report directly or through a third-party servicer. Condition Significant Deficiency in Internal Control over Compliance – During our review of the enrollment reporting requirements we observed the following: - For one of sixty students who had a change in their enrollment status during the period subject to audit, the District did not accurately report the effective date of the change. - For four of sixty students tested, there was no enrollment information reported to NSLDS during the period under audit. - For one of sixty students tested, the student’s field of study was not correctly reported to NSLDS. Cause The District did not accurately report enrollment information for students under the Pell grant and Direct loan programs via NSLDS. The administration of the Title IV programs depends heavily on the accuracy and timeliness of the enrollment information reported by institutions. Effect The District is not in compliance with the aforementioned criteria. Questioned Costs There are no questioned costs associated with this finding. Context During the 2023-2024 fiscal year, the District distributed student financial aid to approximately 9,260 students. Repeat Finding (Yes or No) No. Recommendation The District should implement a process to review, update, and verify student enrollment information that appear on the Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS Professional Access (NSLDSFAP) website.

Criteria or Specific Requirements OMB Compliance Supplement, OMB No. 1845-0035 – Institutions are required to report enrollment information under the Pell grant and the Direct Loan and Federal Family Educational Loan (FFEL) programs via the National Student Loan Data System (NSLDS). Institutions are responsible for accurately reporting the following significant data elements under the Campus-Level Record that ED considers high risk: - OPEID Number – This is the OPEID for the location that the student is attending. - Enrollment Effective Date – The date that the current enrollment status reported for a student was first effective. - Enrollment Status – The student’s enrollment status as of the reporting date; full-time (F), three-quarter time (Q), half-time (H), less than half-time (L), leave of absence (A), graduated (G), withdrawn (W), deceased (D), never attended (X) and record not found (Z) - Certification Date – The date enrollment was certified by the District. At a minimum, schools are required to certify enrollment every 60 days. Institutions are responsible for accurately reporting the following significant data elements under the Program-Level Record that ED considers high risk: - OPEID Number – This is the OPEID for the location that the student is attending. - CIP Code – The code that defines the student’s field of study. - CIP Year – The year that corresponds with the CIP Code. - Credential Level – The level of a credential the student will receive for the program the student is attending. - Published Program Length Measurement – How the program length is measured by the institution whether it be in days, weeks, or years. - Published Program Length – The time it takes to complete a program as determined by the College. - Program Begin Date – The date the student first began attending the program being reported. - Program Enrollment Status – The student’s enrollment status as of the reporting date; full-time (F), three-quarter time (Q), half-time (H), less than half-time (L), leave of absence (A), graduated (G), withdrawn (W), deceased (D), never attended (X) and record not found (Z) - Program Enrollment Effective Date – The date when the student’s current program status first took effect. Institutions are responsible for timely and accurate reporting, whether they report directly or through a third-party servicer. Condition Significant Deficiency in Internal Control over Compliance – During our review of the enrollment reporting requirements we observed the following: - For one of sixty students who had a change in their enrollment status during the period subject to audit, the District did not accurately report the effective date of the change. - For four of sixty students tested, there was no enrollment information reported to NSLDS during the period under audit. - For one of sixty students tested, the student’s field of study was not correctly reported to NSLDS. Cause The District did not accurately report enrollment information for students under the Pell grant and Direct loan programs via NSLDS. The administration of the Title IV programs depends heavily on the accuracy and timeliness of the enrollment information reported by institutions. Effect The District is not in compliance with the aforementioned criteria. Questioned Costs There are no questioned costs associated with this finding. Context During the 2023-2024 fiscal year, the District distributed student financial aid to approximately 9,260 students. Repeat Finding (Yes or No) No. Recommendation The District should implement a process to review, update, and verify student enrollment information that appear on the Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS Professional Access (NSLDSFAP) website.

Criteria or Specific Requirements OMB Compliance Supplement, OMB No. 1845-0035 – Institutions are required to report enrollment information under the Pell grant and the Direct Loan and Federal Family Educational Loan (FFEL) programs via the National Student Loan Data System (NSLDS). Institutions are responsible for accurately reporting the following significant data elements under the Campus-Level Record that ED considers high risk: - OPEID Number – This is the OPEID for the location that the student is attending. - Enrollment Effective Date – The date that the current enrollment status reported for a student was first effective. - Enrollment Status – The student’s enrollment status as of the reporting date; full-time (F), three-quarter time (Q), half-time (H), less than half-time (L), leave of absence (A), graduated (G), withdrawn (W), deceased (D), never attended (X) and record not found (Z) - Certification Date – The date enrollment was certified by the District. At a minimum, schools are required to certify enrollment every 60 days. Institutions are responsible for accurately reporting the following significant data elements under the Program-Level Record that ED considers high risk: - OPEID Number – This is the OPEID for the location that the student is attending. - CIP Code – The code that defines the student’s field of study. - CIP Year – The year that corresponds with the CIP Code. - Credential Level – The level of a credential the student will receive for the program the student is attending. - Published Program Length Measurement – How the program length is measured by the institution whether it be in days, weeks, or years. - Published Program Length – The time it takes to complete a program as determined by the College. - Program Begin Date – The date the student first began attending the program being reported. - Program Enrollment Status – The student’s enrollment status as of the reporting date; full-time (F), three-quarter time (Q), half-time (H), less than half-time (L), leave of absence (A), graduated (G), withdrawn (W), deceased (D), never attended (X) and record not found (Z) - Program Enrollment Effective Date – The date when the student’s current program status first took effect. Institutions are responsible for timely and accurate reporting, whether they report directly or through a third-party servicer. Condition Significant Deficiency in Internal Control over Compliance – During our review of the enrollment reporting requirements we observed the following: - For one of sixty students who had a change in their enrollment status during the period subject to audit, the District did not accurately report the effective date of the change. - For four of sixty students tested, there was no enrollment information reported to NSLDS during the period under audit. - For one of sixty students tested, the student’s field of study was not correctly reported to NSLDS. Cause The District did not accurately report enrollment information for students under the Pell grant and Direct loan programs via NSLDS. The administration of the Title IV programs depends heavily on the accuracy and timeliness of the enrollment information reported by institutions. Effect The District is not in compliance with the aforementioned criteria. Questioned Costs There are no questioned costs associated with this finding. Context During the 2023-2024 fiscal year, the District distributed student financial aid to approximately 9,260 students. Repeat Finding (Yes or No) No. Recommendation The District should implement a process to review, update, and verify student enrollment information that appear on the Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS Professional Access (NSLDSFAP) website.

Criteria or Specific Requirements OMB Compliance Supplement, OMB No. 1845-0035 – Institutions are required to report enrollment information under the Pell grant and the Direct Loan and Federal Family Educational Loan (FFEL) programs via the National Student Loan Data System (NSLDS). Institutions are responsible for accurately reporting the following significant data elements under the Campus-Level Record that ED considers high risk: - OPEID Number – This is the OPEID for the location that the student is attending. - Enrollment Effective Date – The date that the current enrollment status reported for a student was first effective. - Enrollment Status – The student’s enrollment status as of the reporting date; full-time (F), three-quarter time (Q), half-time (H), less than half-time (L), leave of absence (A), graduated (G), withdrawn (W), deceased (D), never attended (X) and record not found (Z) - Certification Date – The date enrollment was certified by the District. At a minimum, schools are required to certify enrollment every 60 days. Institutions are responsible for accurately reporting the following significant data elements under the Program-Level Record that ED considers high risk: - OPEID Number – This is the OPEID for the location that the student is attending. - CIP Code – The code that defines the student’s field of study. - CIP Year – The year that corresponds with the CIP Code. - Credential Level – The level of a credential the student will receive for the program the student is attending. - Published Program Length Measurement – How the program length is measured by the institution whether it be in days, weeks, or years. - Published Program Length – The time it takes to complete a program as determined by the College. - Program Begin Date – The date the student first began attending the program being reported. - Program Enrollment Status – The student’s enrollment status as of the reporting date; full-time (F), three-quarter time (Q), half-time (H), less than half-time (L), leave of absence (A), graduated (G), withdrawn (W), deceased (D), never attended (X) and record not found (Z) - Program Enrollment Effective Date – The date when the student’s current program status first took effect. Institutions are responsible for timely and accurate reporting, whether they report directly or through a third-party servicer. Condition Significant Deficiency in Internal Control over Compliance – During our review of the enrollment reporting requirements we observed the following: - For one of sixty students who had a change in their enrollment status during the period subject to audit, the District did not accurately report the effective date of the change. - For four of sixty students tested, there was no enrollment information reported to NSLDS during the period under audit. - For one of sixty students tested, the student’s field of study was not correctly reported to NSLDS. Cause The District did not accurately report enrollment information for students under the Pell grant and Direct loan programs via NSLDS. The administration of the Title IV programs depends heavily on the accuracy and timeliness of the enrollment information reported by institutions. Effect The District is not in compliance with the aforementioned criteria. Questioned Costs There are no questioned costs associated with this finding. Context During the 2023-2024 fiscal year, the District distributed student financial aid to approximately 9,260 students. Repeat Finding (Yes or No) No. Recommendation The District should implement a process to review, update, and verify student enrollment information that appear on the Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS Professional Access (NSLDSFAP) website.

Criteria or Specific Requirements OMB Compliance Supplement, OMB No. 1845-0035 – Institutions are required to report enrollment information under the Pell grant and the Direct Loan and Federal Family Educational Loan (FFEL) programs via the National Student Loan Data System (NSLDS). Institutions are responsible for accurately reporting the following significant data elements under the Campus-Level Record that ED considers high risk: - OPEID Number – This is the OPEID for the location that the student is attending. - Enrollment Effective Date – The date that the current enrollment status reported for a student was first effective. - Enrollment Status – The student’s enrollment status as of the reporting date; full-time (F), three-quarter time (Q), half-time (H), less than half-time (L), leave of absence (A), graduated (G), withdrawn (W), deceased (D), never attended (X) and record not found (Z) - Certification Date – The date enrollment was certified by the District. At a minimum, schools are required to certify enrollment every 60 days. Institutions are responsible for accurately reporting the following significant data elements under the Program-Level Record that ED considers high risk: - OPEID Number – This is the OPEID for the location that the student is attending. - CIP Code – The code that defines the student’s field of study. - CIP Year – The year that corresponds with the CIP Code. - Credential Level – The level of a credential the student will receive for the program the student is attending. - Published Program Length Measurement – How the program length is measured by the institution whether it be in days, weeks, or years. - Published Program Length – The time it takes to complete a program as determined by the College. - Program Begin Date – The date the student first began attending the program being reported. - Program Enrollment Status – The student’s enrollment status as of the reporting date; full-time (F), three-quarter time (Q), half-time (H), less than half-time (L), leave of absence (A), graduated (G), withdrawn (W), deceased (D), never attended (X) and record not found (Z) - Program Enrollment Effective Date – The date when the student’s current program status first took effect. Institutions are responsible for timely and accurate reporting, whether they report directly or through a third-party servicer. Condition Significant Deficiency in Internal Control over Compliance – During our review of the enrollment reporting requirements we observed the following: - For one of sixty students who had a change in their enrollment status during the period subject to audit, the District did not accurately report the effective date of the change. - For four of sixty students tested, there was no enrollment information reported to NSLDS during the period under audit. - For one of sixty students tested, the student’s field of study was not correctly reported to NSLDS. Cause The District did not accurately report enrollment information for students under the Pell grant and Direct loan programs via NSLDS. The administration of the Title IV programs depends heavily on the accuracy and timeliness of the enrollment information reported by institutions. Effect The District is not in compliance with the aforementioned criteria. Questioned Costs There are no questioned costs associated with this finding. Context During the 2023-2024 fiscal year, the District distributed student financial aid to approximately 9,260 students. Repeat Finding (Yes or No) No. Recommendation The District should implement a process to review, update, and verify student enrollment information that appear on the Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS Professional Access (NSLDSFAP) website.

Criteria or Specific Requirements Common Origination and Disbursement (COD) System (OMB No. 1845-0039) – Institutions submit Direct Loan and Pell Grant origination records and disbursement records to Department of Education through the COD system. Origination records can be sent well in advance of any disbursements, as early as the school chooses to submit them for any student the school reasonably believes will be eligible for a payment. 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 school. Institutions must report student payment data within 15 calendar days after the school makes a payment, or becomes aware of the need to make an adjustment to previously reported student payment data or expected student payment data. Condition Significant Deficiency in Internal Control over Compliance – The District inaccurately reported the disbursement date for one of sixty disbursements tested during the course of our audit. Cause The District’s internal controls over COD Reporting were not performed as prescribed to prevent erroneous reporting. Effect The District is not in compliance with the aforementioned criteria. Context During the 2023-2024 fiscal year, the District distributed student financial aid to approximately 9,260 students. Questioned Costs There are no questioned costs associated with this finding. Repeat Finding (Yes or No) No. Recommendation The District should continue to monitor and review their policies and control procedures in place over COD reporting to confirm they operate as intended to ensure compliance with Federal requirements.

Criteria or Specific Requirements Common Origination and Disbursement (COD) System (OMB No. 1845-0039) – Institutions submit Direct Loan and Pell Grant origination records and disbursement records to Department of Education through the COD system. Origination records can be sent well in advance of any disbursements, as early as the school chooses to submit them for any student the school reasonably believes will be eligible for a payment. 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 school. Institutions must report student payment data within 15 calendar days after the school makes a payment, or becomes aware of the need to make an adjustment to previously reported student payment data or expected student payment data. Condition Significant Deficiency in Internal Control over Compliance – The District inaccurately reported the disbursement date for one of sixty disbursements tested during the course of our audit. Cause The District’s internal controls over COD Reporting were not performed as prescribed to prevent erroneous reporting. Effect The District is not in compliance with the aforementioned criteria. Context During the 2023-2024 fiscal year, the District distributed student financial aid to approximately 9,260 students. Questioned Costs There are no questioned costs associated with this finding. Repeat Finding (Yes or No) No. Recommendation The District should continue to monitor and review their policies and control procedures in place over COD reporting to confirm they operate as intended to ensure compliance with Federal requirements.

Criteria or Specific Requirements Common Origination and Disbursement (COD) System (OMB No. 1845-0039) – Institutions submit Direct Loan and Pell Grant origination records and disbursement records to Department of Education through the COD system. Origination records can be sent well in advance of any disbursements, as early as the school chooses to submit them for any student the school reasonably believes will be eligible for a payment. 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 school. Institutions must report student payment data within 15 calendar days after the school makes a payment, or becomes aware of the need to make an adjustment to previously reported student payment data or expected student payment data. Condition Significant Deficiency in Internal Control over Compliance – The District inaccurately reported the disbursement date for one of sixty disbursements tested during the course of our audit. Cause The District’s internal controls over COD Reporting were not performed as prescribed to prevent erroneous reporting. Effect The District is not in compliance with the aforementioned criteria. Context During the 2023-2024 fiscal year, the District distributed student financial aid to approximately 9,260 students. Questioned Costs There are no questioned costs associated with this finding. Repeat Finding (Yes or No) No. Recommendation The District should continue to monitor and review their policies and control procedures in place over COD reporting to confirm they operate as intended to ensure compliance with Federal requirements.

Criteria or Specific Requirements Common Origination and Disbursement (COD) System (OMB No. 1845-0039) – Institutions submit Direct Loan and Pell Grant origination records and disbursement records to Department of Education through the COD system. Origination records can be sent well in advance of any disbursements, as early as the school chooses to submit them for any student the school reasonably believes will be eligible for a payment. 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 school. Institutions must report student payment data within 15 calendar days after the school makes a payment, or becomes aware of the need to make an adjustment to previously reported student payment data or expected student payment data. Condition Significant Deficiency in Internal Control over Compliance – The District inaccurately reported the disbursement date for one of sixty disbursements tested during the course of our audit. Cause The District’s internal controls over COD Reporting were not performed as prescribed to prevent erroneous reporting. Effect The District is not in compliance with the aforementioned criteria. Context During the 2023-2024 fiscal year, the District distributed student financial aid to approximately 9,260 students. Questioned Costs There are no questioned costs associated with this finding. Repeat Finding (Yes or No) No. Recommendation The District should continue to monitor and review their policies and control procedures in place over COD reporting to confirm they operate as intended to ensure compliance with Federal requirements.

Criteria or Specific Requirements Common Origination and Disbursement (COD) System (OMB No. 1845-0039) – Institutions submit Direct Loan and Pell Grant origination records and disbursement records to Department of Education through the COD system. Origination records can be sent well in advance of any disbursements, as early as the school chooses to submit them for any student the school reasonably believes will be eligible for a payment. 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 school. Institutions must report student payment data within 15 calendar days after the school makes a payment, or becomes aware of the need to make an adjustment to previously reported student payment data or expected student payment data. Condition Significant Deficiency in Internal Control over Compliance – The District inaccurately reported the disbursement date for one of sixty disbursements tested during the course of our audit. Cause The District’s internal controls over COD Reporting were not performed as prescribed to prevent erroneous reporting. Effect The District is not in compliance with the aforementioned criteria. Context During the 2023-2024 fiscal year, the District distributed student financial aid to approximately 9,260 students. Questioned Costs There are no questioned costs associated with this finding. Repeat Finding (Yes or No) No. Recommendation The District should continue to monitor and review their policies and control procedures in place over COD reporting to confirm they operate as intended to ensure compliance with Federal requirements.

Criteria or Specific Requirements Common Origination and Disbursement (COD) System (OMB No. 1845-0039) – Institutions submit Direct Loan and Pell Grant origination records and disbursement records to Department of Education through the COD system. Origination records can be sent well in advance of any disbursements, as early as the school chooses to submit them for any student the school reasonably believes will be eligible for a payment. 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 school. Institutions must report student payment data within 15 calendar days after the school makes a payment, or becomes aware of the need to make an adjustment to previously reported student payment data or expected student payment data. Condition Significant Deficiency in Internal Control over Compliance – The District inaccurately reported the disbursement date for one of sixty disbursements tested during the course of our audit. Cause The District’s internal controls over COD Reporting were not performed as prescribed to prevent erroneous reporting. Effect The District is not in compliance with the aforementioned criteria. Context During the 2023-2024 fiscal year, the District distributed student financial aid to approximately 9,260 students. Questioned Costs There are no questioned costs associated with this finding. Repeat Finding (Yes or No) No. Recommendation The District should continue to monitor and review their policies and control procedures in place over COD reporting to confirm they operate as intended to ensure compliance with Federal requirements.

Criteria or Specific Requirements Common Origination and Disbursement (COD) System (OMB No. 1845-0039) – Institutions submit Direct Loan and Pell Grant origination records and disbursement records to Department of Education through the COD system. Origination records can be sent well in advance of any disbursements, as early as the school chooses to submit them for any student the school reasonably believes will be eligible for a payment. 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 school. Institutions must report student payment data within 15 calendar days after the school makes a payment, or becomes aware of the need to make an adjustment to previously reported student payment data or expected student payment data. Condition Significant Deficiency in Internal Control over Compliance – The District inaccurately reported the disbursement date for one of sixty disbursements tested during the course of our audit. Cause The District’s internal controls over COD Reporting were not performed as prescribed to prevent erroneous reporting. Effect The District is not in compliance with the aforementioned criteria. Context During the 2023-2024 fiscal year, the District distributed student financial aid to approximately 9,260 students. Questioned Costs There are no questioned costs associated with this finding. Repeat Finding (Yes or No) No. Recommendation The District should continue to monitor and review their policies and control procedures in place over COD reporting to confirm they operate as intended to ensure compliance with Federal requirements.