Audit 343204

Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Aid Cluster ALN Numbers: Multiple Award Period: September 1, 2023 through August 31, 2024 Type of Finding: • Significant Deficiency in Internal Control Over Compliance • Other Matters Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 685.309 requires that enrollment status changes for students be reported to NSLDS within 30 days or within 60 days if the student with the status change will be reported on a scheduled transmission within 60 days of the change in status. Regulations require the status include an accurate effective date. In addition, regulations require that an institution make necessary corrections and return the records within 10 days for any roster files that don’t pass the NSLDS enrollment reporting edits. Condition: During our testing, it was noted the effective date reported on the “Campus Level” and “Program Level” report in NSLDS did not match the University records for 6 of the 60 students tested. It was also noted that the effective date on the “Campus Level” and “Program Level” did not match for one the 1 out of the 60 students. Questioned Costs: None. Context: There were discrepancies between the effective dates reported to NSLDS and the University’s records. Cause: The University’s processes and controls did not ensure that student effective dates were properly reported to NSLDS. The effective date should be the student’s last date of attendance and academically related activity. Effect: The NSLDS system is not updated with the correct student information which can cause a student to not properly enter the repayment period. Repeat Finding: Yes, 2023-001 Recommendation: We recommend reviewing the components of the enrollment roster file to ensure the correct effective date is reported correctly for both the “Campus Level” and “Program Level”. Views of Responsible Officials: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Aid Cluster ALN Numbers: Multiple Award Period: September 1, 2023 through August 31, 2024 Type of Finding: • Significant Deficiency in Internal Control Over Compliance • Other Matters Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 685.309 requires that enrollment status changes for students be reported to NSLDS within 30 days or within 60 days if the student with the status change will be reported on a scheduled transmission within 60 days of the change in status. Regulations require the status include an accurate effective date. In addition, regulations require that an institution make necessary corrections and return the records within 10 days for any roster files that don’t pass the NSLDS enrollment reporting edits. Condition: During our testing, it was noted the effective date reported on the “Campus Level” and “Program Level” report in NSLDS did not match the University records for 6 of the 60 students tested. It was also noted that the effective date on the “Campus Level” and “Program Level” did not match for one the 1 out of the 60 students. Questioned Costs: None. Context: There were discrepancies between the effective dates reported to NSLDS and the University’s records. Cause: The University’s processes and controls did not ensure that student effective dates were properly reported to NSLDS. The effective date should be the student’s last date of attendance and academically related activity. Effect: The NSLDS system is not updated with the correct student information which can cause a student to not properly enter the repayment period. Repeat Finding: Yes, 2023-001 Recommendation: We recommend reviewing the components of the enrollment roster file to ensure the correct effective date is reported correctly for both the “Campus Level” and “Program Level”. Views of Responsible Officials: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Aid Cluster ALN Numbers: Multiple Award Period: September 1, 2023 through August 31, 2024 Type of Finding: • Significant Deficiency in Internal Control Over Compliance • Other Matters Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 685.309 requires that enrollment status changes for students be reported to NSLDS within 30 days or within 60 days if the student with the status change will be reported on a scheduled transmission within 60 days of the change in status. Regulations require the status include an accurate effective date. In addition, regulations require that an institution make necessary corrections and return the records within 10 days for any roster files that don’t pass the NSLDS enrollment reporting edits. Condition: During our testing, it was noted the effective date reported on the “Campus Level” and “Program Level” report in NSLDS did not match the University records for 6 of the 60 students tested. It was also noted that the effective date on the “Campus Level” and “Program Level” did not match for one the 1 out of the 60 students. Questioned Costs: None. Context: There were discrepancies between the effective dates reported to NSLDS and the University’s records. Cause: The University’s processes and controls did not ensure that student effective dates were properly reported to NSLDS. The effective date should be the student’s last date of attendance and academically related activity. Effect: The NSLDS system is not updated with the correct student information which can cause a student to not properly enter the repayment period. Repeat Finding: Yes, 2023-001 Recommendation: We recommend reviewing the components of the enrollment roster file to ensure the correct effective date is reported correctly for both the “Campus Level” and “Program Level”. Views of Responsible Officials: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Aid Cluster ALN Numbers: Multiple Award Period: September 1, 2023 through August 31, 2024 Type of Finding: • Significant Deficiency in Internal Control Over Compliance • Other Matters Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 685.309 requires that enrollment status changes for students be reported to NSLDS within 30 days or within 60 days if the student with the status change will be reported on a scheduled transmission within 60 days of the change in status. Regulations require the status include an accurate effective date. In addition, regulations require that an institution make necessary corrections and return the records within 10 days for any roster files that don’t pass the NSLDS enrollment reporting edits. Condition: During our testing, it was noted the effective date reported on the “Campus Level” and “Program Level” report in NSLDS did not match the University records for 6 of the 60 students tested. It was also noted that the effective date on the “Campus Level” and “Program Level” did not match for one the 1 out of the 60 students. Questioned Costs: None. Context: There were discrepancies between the effective dates reported to NSLDS and the University’s records. Cause: The University’s processes and controls did not ensure that student effective dates were properly reported to NSLDS. The effective date should be the student’s last date of attendance and academically related activity. Effect: The NSLDS system is not updated with the correct student information which can cause a student to not properly enter the repayment period. Repeat Finding: Yes, 2023-001 Recommendation: We recommend reviewing the components of the enrollment roster file to ensure the correct effective date is reported correctly for both the “Campus Level” and “Program Level”. Views of Responsible Officials: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Aid Cluster ALN Numbers: Multiple Award Period: September 1, 2023 through August 31, 2024 Type of Finding: • Significant Deficiency in Internal Control Over Compliance • Other Matters Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 685.309 requires that enrollment status changes for students be reported to NSLDS within 30 days or within 60 days if the student with the status change will be reported on a scheduled transmission within 60 days of the change in status. Regulations require the status include an accurate effective date. In addition, regulations require that an institution make necessary corrections and return the records within 10 days for any roster files that don’t pass the NSLDS enrollment reporting edits. Condition: During our testing, it was noted the effective date reported on the “Campus Level” and “Program Level” report in NSLDS did not match the University records for 6 of the 60 students tested. It was also noted that the effective date on the “Campus Level” and “Program Level” did not match for one the 1 out of the 60 students. Questioned Costs: None. Context: There were discrepancies between the effective dates reported to NSLDS and the University’s records. Cause: The University’s processes and controls did not ensure that student effective dates were properly reported to NSLDS. The effective date should be the student’s last date of attendance and academically related activity. Effect: The NSLDS system is not updated with the correct student information which can cause a student to not properly enter the repayment period. Repeat Finding: Yes, 2023-001 Recommendation: We recommend reviewing the components of the enrollment roster file to ensure the correct effective date is reported correctly for both the “Campus Level” and “Program Level”. Views of Responsible Officials: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Aid Cluster ALN Numbers: 84.038 Award Period: September 1, 2023 through August 31, 2024 Type of Finding: • Significant Deficiency in Internal Control Over Compliance • Other Matters Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 674-19(e) states that Institutions must retain original, true and exact copies of promissory and master promissory notes (MPN), repayment records, and cancellation and deferment requests for each Perkins loan made. Condition: During our testing, we noted that 5 out of 40 Perkins files tested, the MPN was not retained on file. Questioned Costs: None. Context: The MPNs for the five students were not kept for at least three years as required by the regulation. Cause: The loans were old and as such the records were not able to be found. Effect: The University was not in compliance with the Perkins recordkeeping regulation as it relates to MPNs. Repeat Finding: Yes, 2023-003 Recommendation: We recommend that the University implement a procedure to ensure that all necessary MPNs are retained in accordance with the federal regulation. Views of Responsible Officials: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Aid Cluster ALN Numbers: Multiple Award Period: September 1, 2023 through August 31, 2024 Type of Finding: • Significant Deficiency in Internal Control Over Compliance • Other Matters Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 685.309(b) and 34 CFR 682.610(c) states that because a student begins earning Title IV funds on the first day of attendance, even if the student withdraws before a school’s census date, the school must perform an R2T4 calculation using the number of days or the number of scheduled clock hours the student attended class. The school must include in the R2T4 calculation all forms of Title IV aid that were disbursed or that could have been disbursed, even if the student receives a full tuition refund. Condition: During our testing, we noted that 1 out of the 12 students had the incorrect term end date used in their return calculation. Questioned Costs: $88.00. Context: The University did not correctly assess the number of term days in the R2T4 calculation. Due to this one of the summer calculations was done incorrectly. CLA then tested all the R2T4 calculations in the summer term. Noted one student was affected by the calculation. Cause: The University incorrectly assessed the number of days in the summer semester. Effect: One student was incorrectly calculated. Repeat Finding: No Recommendation: We recommend the University review the R2T4 calculations and the term dates used. Views of Responsible Officials: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Aid Cluster ALN Numbers: Multiple Award Period: September 1, 2023 through August 31, 2024 Type of Finding: • Significant Deficiency in Internal Control Over Compliance • Other Matters Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 685.309(b) and 34 CFR 682.610(c) states that because a student begins earning Title IV funds on the first day of attendance, even if the student withdraws before a school’s census date, the school must perform an R2T4 calculation using the number of days or the number of scheduled clock hours the student attended class. The school must include in the R2T4 calculation all forms of Title IV aid that were disbursed or that could have been disbursed, even if the student receives a full tuition refund. Condition: During our testing, we noted that 1 out of the 12 students had the incorrect term end date used in their return calculation. Questioned Costs: $88.00. Context: The University did not correctly assess the number of term days in the R2T4 calculation. Due to this one of the summer calculations was done incorrectly. CLA then tested all the R2T4 calculations in the summer term. Noted one student was affected by the calculation. Cause: The University incorrectly assessed the number of days in the summer semester. Effect: One student was incorrectly calculated. Repeat Finding: No Recommendation: We recommend the University review the R2T4 calculations and the term dates used. Views of Responsible Officials: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Aid Cluster ALN Numbers: Multiple Award Period: September 1, 2023 through August 31, 2024 Type of Finding: • Significant Deficiency in Internal Control Over Compliance • Other Matters Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 685.309(b) and 34 CFR 682.610(c) states that because a student begins earning Title IV funds on the first day of attendance, even if the student withdraws before a school’s census date, the school must perform an R2T4 calculation using the number of days or the number of scheduled clock hours the student attended class. The school must include in the R2T4 calculation all forms of Title IV aid that were disbursed or that could have been disbursed, even if the student receives a full tuition refund. Condition: During our testing, we noted that 1 out of the 12 students had the incorrect term end date used in their return calculation. Questioned Costs: $88.00. Context: The University did not correctly assess the number of term days in the R2T4 calculation. Due to this one of the summer calculations was done incorrectly. CLA then tested all the R2T4 calculations in the summer term. Noted one student was affected by the calculation. Cause: The University incorrectly assessed the number of days in the summer semester. Effect: One student was incorrectly calculated. Repeat Finding: No Recommendation: We recommend the University review the R2T4 calculations and the term dates used. Views of Responsible Officials: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Aid Cluster ALN Numbers: Multiple Award Period: September 1, 2023 through August 31, 2024 Type of Finding: • Significant Deficiency in Internal Control Over Compliance • Other Matters Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 685.309(b) and 34 CFR 682.610(c) states that because a student begins earning Title IV funds on the first day of attendance, even if the student withdraws before a school’s census date, the school must perform an R2T4 calculation using the number of days or the number of scheduled clock hours the student attended class. The school must include in the R2T4 calculation all forms of Title IV aid that were disbursed or that could have been disbursed, even if the student receives a full tuition refund. Condition: During our testing, we noted that 1 out of the 12 students had the incorrect term end date used in their return calculation. Questioned Costs: $88.00. Context: The University did not correctly assess the number of term days in the R2T4 calculation. Due to this one of the summer calculations was done incorrectly. CLA then tested all the R2T4 calculations in the summer term. Noted one student was affected by the calculation. Cause: The University incorrectly assessed the number of days in the summer semester. Effect: One student was incorrectly calculated. Repeat Finding: No Recommendation: We recommend the University review the R2T4 calculations and the term dates used. Views of Responsible Officials: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Aid Cluster ALN Numbers: Multiple Award Period: September 1, 2023 through August 31, 2024 Type of Finding: • Significant Deficiency in Internal Control Over Compliance • Other Matters Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 685.309(b) and 34 CFR 682.610(c) states that because a student begins earning Title IV funds on the first day of attendance, even if the student withdraws before a school’s census date, the school must perform an R2T4 calculation using the number of days or the number of scheduled clock hours the student attended class. The school must include in the R2T4 calculation all forms of Title IV aid that were disbursed or that could have been disbursed, even if the student receives a full tuition refund. Condition: During our testing, we noted that 1 out of the 12 students had the incorrect term end date used in their return calculation. Questioned Costs: $88.00. Context: The University did not correctly assess the number of term days in the R2T4 calculation. Due to this one of the summer calculations was done incorrectly. CLA then tested all the R2T4 calculations in the summer term. Noted one student was affected by the calculation. Cause: The University incorrectly assessed the number of days in the summer semester. Effect: One student was incorrectly calculated. Repeat Finding: No Recommendation: We recommend the University review the R2T4 calculations and the term dates used. Views of Responsible Officials: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Aid Cluster ALN Numbers: Multiple Award Period: September 1, 2023 through August 31, 2024 Type of Finding: • Significant Deficiency in Internal Control Over Compliance • Other Matters Criteria or Specific Requirement: The 2 CFR Section 200.303 require that nonfederal entities receiving federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal Statues, regulations, and the term and conditions of the federal awards. Condition: During our testing of Common Origination and Disbursement (COD), Return of Title IV Funds (R2T4) and National Student Loan Data System (NSLDS), we noted there was a review process implemented; however, there was no process in place to retain the review being performed as to provide evidence to ensure the controls are being performed effectively. Questioned Costs: None. Context: During our testing, it was noted the University does not have a process in place to ensure controls are being performed effectively. Cause: The University did not have a process in place to ensure controls implemented are being performed effectively Effect: There is no way to determine who was involved in the process should an error be present. Repeat Finding: No Recommendation: We recommend the University reevaluate its procedures and review policies surrounding controls implemented for Title IV Aid. Views of Responsible Officials: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Aid Cluster ALN Numbers: Multiple Award Period: September 1, 2023 through August 31, 2024 Type of Finding: • Significant Deficiency in Internal Control Over Compliance • Other Matters Criteria or Specific Requirement: The 2 CFR Section 200.303 require that nonfederal entities receiving federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal Statues, regulations, and the term and conditions of the federal awards. Condition: During our testing of Common Origination and Disbursement (COD), Return of Title IV Funds (R2T4) and National Student Loan Data System (NSLDS), we noted there was a review process implemented; however, there was no process in place to retain the review being performed as to provide evidence to ensure the controls are being performed effectively. Questioned Costs: None. Context: During our testing, it was noted the University does not have a process in place to ensure controls are being performed effectively. Cause: The University did not have a process in place to ensure controls implemented are being performed effectively Effect: There is no way to determine who was involved in the process should an error be present. Repeat Finding: No Recommendation: We recommend the University reevaluate its procedures and review policies surrounding controls implemented for Title IV Aid. Views of Responsible Officials: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Aid Cluster ALN Numbers: Multiple Award Period: September 1, 2023 through August 31, 2024 Type of Finding: • Significant Deficiency in Internal Control Over Compliance • Other Matters Criteria or Specific Requirement: The 2 CFR Section 200.303 require that nonfederal entities receiving federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal Statues, regulations, and the term and conditions of the federal awards. Condition: During our testing of Common Origination and Disbursement (COD), Return of Title IV Funds (R2T4) and National Student Loan Data System (NSLDS), we noted there was a review process implemented; however, there was no process in place to retain the review being performed as to provide evidence to ensure the controls are being performed effectively. Questioned Costs: None. Context: During our testing, it was noted the University does not have a process in place to ensure controls are being performed effectively. Cause: The University did not have a process in place to ensure controls implemented are being performed effectively Effect: There is no way to determine who was involved in the process should an error be present. Repeat Finding: No Recommendation: We recommend the University reevaluate its procedures and review policies surrounding controls implemented for Title IV Aid. Views of Responsible Officials: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Aid Cluster ALN Numbers: Multiple Award Period: September 1, 2023 through August 31, 2024 Type of Finding: • Significant Deficiency in Internal Control Over Compliance • Other Matters Criteria or Specific Requirement: The 2 CFR Section 200.303 require that nonfederal entities receiving federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal Statues, regulations, and the term and conditions of the federal awards. Condition: During our testing of Common Origination and Disbursement (COD), Return of Title IV Funds (R2T4) and National Student Loan Data System (NSLDS), we noted there was a review process implemented; however, there was no process in place to retain the review being performed as to provide evidence to ensure the controls are being performed effectively. Questioned Costs: None. Context: During our testing, it was noted the University does not have a process in place to ensure controls are being performed effectively. Cause: The University did not have a process in place to ensure controls implemented are being performed effectively Effect: There is no way to determine who was involved in the process should an error be present. Repeat Finding: No Recommendation: We recommend the University reevaluate its procedures and review policies surrounding controls implemented for Title IV Aid. Views of Responsible Officials: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Aid Cluster ALN Numbers: Multiple Award Period: September 1, 2023 through August 31, 2024 Type of Finding: • Significant Deficiency in Internal Control Over Compliance • Other Matters Criteria or Specific Requirement: The 2 CFR Section 200.303 require that nonfederal entities receiving federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal Statues, regulations, and the term and conditions of the federal awards. Condition: During our testing of Common Origination and Disbursement (COD), Return of Title IV Funds (R2T4) and National Student Loan Data System (NSLDS), we noted there was a review process implemented; however, there was no process in place to retain the review being performed as to provide evidence to ensure the controls are being performed effectively. Questioned Costs: None. Context: During our testing, it was noted the University does not have a process in place to ensure controls are being performed effectively. Cause: The University did not have a process in place to ensure controls implemented are being performed effectively Effect: There is no way to determine who was involved in the process should an error be present. Repeat Finding: No Recommendation: We recommend the University reevaluate its procedures and review policies surrounding controls implemented for Title IV Aid. Views of Responsible Officials: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Aid Cluster ALN Numbers: Multiple Award Period: September 1, 2023 through August 31, 2024 Type of Finding: • Significant Deficiency in Internal Control Over Compliance • Other Matters Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 685.309 requires that enrollment status changes for students be reported to NSLDS within 30 days or within 60 days if the student with the status change will be reported on a scheduled transmission within 60 days of the change in status. Regulations require the status include an accurate effective date. In addition, regulations require that an institution make necessary corrections and return the records within 10 days for any roster files that don’t pass the NSLDS enrollment reporting edits. Condition: During our testing, it was noted the effective date reported on the “Campus Level” and “Program Level” report in NSLDS did not match the University records for 6 of the 60 students tested. It was also noted that the effective date on the “Campus Level” and “Program Level” did not match for one the 1 out of the 60 students. Questioned Costs: None. Context: There were discrepancies between the effective dates reported to NSLDS and the University’s records. Cause: The University’s processes and controls did not ensure that student effective dates were properly reported to NSLDS. The effective date should be the student’s last date of attendance and academically related activity. Effect: The NSLDS system is not updated with the correct student information which can cause a student to not properly enter the repayment period. Repeat Finding: Yes, 2023-001 Recommendation: We recommend reviewing the components of the enrollment roster file to ensure the correct effective date is reported correctly for both the “Campus Level” and “Program Level”. Views of Responsible Officials: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Aid Cluster ALN Numbers: Multiple Award Period: September 1, 2023 through August 31, 2024 Type of Finding: • Significant Deficiency in Internal Control Over Compliance • Other Matters Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 685.309 requires that enrollment status changes for students be reported to NSLDS within 30 days or within 60 days if the student with the status change will be reported on a scheduled transmission within 60 days of the change in status. Regulations require the status include an accurate effective date. In addition, regulations require that an institution make necessary corrections and return the records within 10 days for any roster files that don’t pass the NSLDS enrollment reporting edits. Condition: During our testing, it was noted the effective date reported on the “Campus Level” and “Program Level” report in NSLDS did not match the University records for 6 of the 60 students tested. It was also noted that the effective date on the “Campus Level” and “Program Level” did not match for one the 1 out of the 60 students. Questioned Costs: None. Context: There were discrepancies between the effective dates reported to NSLDS and the University’s records. Cause: The University’s processes and controls did not ensure that student effective dates were properly reported to NSLDS. The effective date should be the student’s last date of attendance and academically related activity. Effect: The NSLDS system is not updated with the correct student information which can cause a student to not properly enter the repayment period. Repeat Finding: Yes, 2023-001 Recommendation: We recommend reviewing the components of the enrollment roster file to ensure the correct effective date is reported correctly for both the “Campus Level” and “Program Level”. Views of Responsible Officials: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Aid Cluster ALN Numbers: Multiple Award Period: September 1, 2023 through August 31, 2024 Type of Finding: • Significant Deficiency in Internal Control Over Compliance • Other Matters Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 685.309 requires that enrollment status changes for students be reported to NSLDS within 30 days or within 60 days if the student with the status change will be reported on a scheduled transmission within 60 days of the change in status. Regulations require the status include an accurate effective date. In addition, regulations require that an institution make necessary corrections and return the records within 10 days for any roster files that don’t pass the NSLDS enrollment reporting edits. Condition: During our testing, it was noted the effective date reported on the “Campus Level” and “Program Level” report in NSLDS did not match the University records for 6 of the 60 students tested. It was also noted that the effective date on the “Campus Level” and “Program Level” did not match for one the 1 out of the 60 students. Questioned Costs: None. Context: There were discrepancies between the effective dates reported to NSLDS and the University’s records. Cause: The University’s processes and controls did not ensure that student effective dates were properly reported to NSLDS. The effective date should be the student’s last date of attendance and academically related activity. Effect: The NSLDS system is not updated with the correct student information which can cause a student to not properly enter the repayment period. Repeat Finding: Yes, 2023-001 Recommendation: We recommend reviewing the components of the enrollment roster file to ensure the correct effective date is reported correctly for both the “Campus Level” and “Program Level”. Views of Responsible Officials: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Aid Cluster ALN Numbers: Multiple Award Period: September 1, 2023 through August 31, 2024 Type of Finding: • Significant Deficiency in Internal Control Over Compliance • Other Matters Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 685.309 requires that enrollment status changes for students be reported to NSLDS within 30 days or within 60 days if the student with the status change will be reported on a scheduled transmission within 60 days of the change in status. Regulations require the status include an accurate effective date. In addition, regulations require that an institution make necessary corrections and return the records within 10 days for any roster files that don’t pass the NSLDS enrollment reporting edits. Condition: During our testing, it was noted the effective date reported on the “Campus Level” and “Program Level” report in NSLDS did not match the University records for 6 of the 60 students tested. It was also noted that the effective date on the “Campus Level” and “Program Level” did not match for one the 1 out of the 60 students. Questioned Costs: None. Context: There were discrepancies between the effective dates reported to NSLDS and the University’s records. Cause: The University’s processes and controls did not ensure that student effective dates were properly reported to NSLDS. The effective date should be the student’s last date of attendance and academically related activity. Effect: The NSLDS system is not updated with the correct student information which can cause a student to not properly enter the repayment period. Repeat Finding: Yes, 2023-001 Recommendation: We recommend reviewing the components of the enrollment roster file to ensure the correct effective date is reported correctly for both the “Campus Level” and “Program Level”. Views of Responsible Officials: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Aid Cluster ALN Numbers: Multiple Award Period: September 1, 2023 through August 31, 2024 Type of Finding: • Significant Deficiency in Internal Control Over Compliance • Other Matters Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 685.309 requires that enrollment status changes for students be reported to NSLDS within 30 days or within 60 days if the student with the status change will be reported on a scheduled transmission within 60 days of the change in status. Regulations require the status include an accurate effective date. In addition, regulations require that an institution make necessary corrections and return the records within 10 days for any roster files that don’t pass the NSLDS enrollment reporting edits. Condition: During our testing, it was noted the effective date reported on the “Campus Level” and “Program Level” report in NSLDS did not match the University records for 6 of the 60 students tested. It was also noted that the effective date on the “Campus Level” and “Program Level” did not match for one the 1 out of the 60 students. Questioned Costs: None. Context: There were discrepancies between the effective dates reported to NSLDS and the University’s records. Cause: The University’s processes and controls did not ensure that student effective dates were properly reported to NSLDS. The effective date should be the student’s last date of attendance and academically related activity. Effect: The NSLDS system is not updated with the correct student information which can cause a student to not properly enter the repayment period. Repeat Finding: Yes, 2023-001 Recommendation: We recommend reviewing the components of the enrollment roster file to ensure the correct effective date is reported correctly for both the “Campus Level” and “Program Level”. Views of Responsible Officials: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Aid Cluster ALN Numbers: 84.038 Award Period: September 1, 2023 through August 31, 2024 Type of Finding: • Significant Deficiency in Internal Control Over Compliance • Other Matters Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 674-19(e) states that Institutions must retain original, true and exact copies of promissory and master promissory notes (MPN), repayment records, and cancellation and deferment requests for each Perkins loan made. Condition: During our testing, we noted that 5 out of 40 Perkins files tested, the MPN was not retained on file. Questioned Costs: None. Context: The MPNs for the five students were not kept for at least three years as required by the regulation. Cause: The loans were old and as such the records were not able to be found. Effect: The University was not in compliance with the Perkins recordkeeping regulation as it relates to MPNs. Repeat Finding: Yes, 2023-003 Recommendation: We recommend that the University implement a procedure to ensure that all necessary MPNs are retained in accordance with the federal regulation. Views of Responsible Officials: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Aid Cluster ALN Numbers: Multiple Award Period: September 1, 2023 through August 31, 2024 Type of Finding: • Significant Deficiency in Internal Control Over Compliance • Other Matters Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 685.309(b) and 34 CFR 682.610(c) states that because a student begins earning Title IV funds on the first day of attendance, even if the student withdraws before a school’s census date, the school must perform an R2T4 calculation using the number of days or the number of scheduled clock hours the student attended class. The school must include in the R2T4 calculation all forms of Title IV aid that were disbursed or that could have been disbursed, even if the student receives a full tuition refund. Condition: During our testing, we noted that 1 out of the 12 students had the incorrect term end date used in their return calculation. Questioned Costs: $88.00. Context: The University did not correctly assess the number of term days in the R2T4 calculation. Due to this one of the summer calculations was done incorrectly. CLA then tested all the R2T4 calculations in the summer term. Noted one student was affected by the calculation. Cause: The University incorrectly assessed the number of days in the summer semester. Effect: One student was incorrectly calculated. Repeat Finding: No Recommendation: We recommend the University review the R2T4 calculations and the term dates used. Views of Responsible Officials: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Aid Cluster ALN Numbers: Multiple Award Period: September 1, 2023 through August 31, 2024 Type of Finding: • Significant Deficiency in Internal Control Over Compliance • Other Matters Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 685.309(b) and 34 CFR 682.610(c) states that because a student begins earning Title IV funds on the first day of attendance, even if the student withdraws before a school’s census date, the school must perform an R2T4 calculation using the number of days or the number of scheduled clock hours the student attended class. The school must include in the R2T4 calculation all forms of Title IV aid that were disbursed or that could have been disbursed, even if the student receives a full tuition refund. Condition: During our testing, we noted that 1 out of the 12 students had the incorrect term end date used in their return calculation. Questioned Costs: $88.00. Context: The University did not correctly assess the number of term days in the R2T4 calculation. Due to this one of the summer calculations was done incorrectly. CLA then tested all the R2T4 calculations in the summer term. Noted one student was affected by the calculation. Cause: The University incorrectly assessed the number of days in the summer semester. Effect: One student was incorrectly calculated. Repeat Finding: No Recommendation: We recommend the University review the R2T4 calculations and the term dates used. Views of Responsible Officials: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Aid Cluster ALN Numbers: Multiple Award Period: September 1, 2023 through August 31, 2024 Type of Finding: • Significant Deficiency in Internal Control Over Compliance • Other Matters Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 685.309(b) and 34 CFR 682.610(c) states that because a student begins earning Title IV funds on the first day of attendance, even if the student withdraws before a school’s census date, the school must perform an R2T4 calculation using the number of days or the number of scheduled clock hours the student attended class. The school must include in the R2T4 calculation all forms of Title IV aid that were disbursed or that could have been disbursed, even if the student receives a full tuition refund. Condition: During our testing, we noted that 1 out of the 12 students had the incorrect term end date used in their return calculation. Questioned Costs: $88.00. Context: The University did not correctly assess the number of term days in the R2T4 calculation. Due to this one of the summer calculations was done incorrectly. CLA then tested all the R2T4 calculations in the summer term. Noted one student was affected by the calculation. Cause: The University incorrectly assessed the number of days in the summer semester. Effect: One student was incorrectly calculated. Repeat Finding: No Recommendation: We recommend the University review the R2T4 calculations and the term dates used. Views of Responsible Officials: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Aid Cluster ALN Numbers: Multiple Award Period: September 1, 2023 through August 31, 2024 Type of Finding: • Significant Deficiency in Internal Control Over Compliance • Other Matters Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 685.309(b) and 34 CFR 682.610(c) states that because a student begins earning Title IV funds on the first day of attendance, even if the student withdraws before a school’s census date, the school must perform an R2T4 calculation using the number of days or the number of scheduled clock hours the student attended class. The school must include in the R2T4 calculation all forms of Title IV aid that were disbursed or that could have been disbursed, even if the student receives a full tuition refund. Condition: During our testing, we noted that 1 out of the 12 students had the incorrect term end date used in their return calculation. Questioned Costs: $88.00. Context: The University did not correctly assess the number of term days in the R2T4 calculation. Due to this one of the summer calculations was done incorrectly. CLA then tested all the R2T4 calculations in the summer term. Noted one student was affected by the calculation. Cause: The University incorrectly assessed the number of days in the summer semester. Effect: One student was incorrectly calculated. Repeat Finding: No Recommendation: We recommend the University review the R2T4 calculations and the term dates used. Views of Responsible Officials: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Aid Cluster ALN Numbers: Multiple Award Period: September 1, 2023 through August 31, 2024 Type of Finding: • Significant Deficiency in Internal Control Over Compliance • Other Matters Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 685.309(b) and 34 CFR 682.610(c) states that because a student begins earning Title IV funds on the first day of attendance, even if the student withdraws before a school’s census date, the school must perform an R2T4 calculation using the number of days or the number of scheduled clock hours the student attended class. The school must include in the R2T4 calculation all forms of Title IV aid that were disbursed or that could have been disbursed, even if the student receives a full tuition refund. Condition: During our testing, we noted that 1 out of the 12 students had the incorrect term end date used in their return calculation. Questioned Costs: $88.00. Context: The University did not correctly assess the number of term days in the R2T4 calculation. Due to this one of the summer calculations was done incorrectly. CLA then tested all the R2T4 calculations in the summer term. Noted one student was affected by the calculation. Cause: The University incorrectly assessed the number of days in the summer semester. Effect: One student was incorrectly calculated. Repeat Finding: No Recommendation: We recommend the University review the R2T4 calculations and the term dates used. Views of Responsible Officials: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Aid Cluster ALN Numbers: Multiple Award Period: September 1, 2023 through August 31, 2024 Type of Finding: • Significant Deficiency in Internal Control Over Compliance • Other Matters Criteria or Specific Requirement: The 2 CFR Section 200.303 require that nonfederal entities receiving federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal Statues, regulations, and the term and conditions of the federal awards. Condition: During our testing of Common Origination and Disbursement (COD), Return of Title IV Funds (R2T4) and National Student Loan Data System (NSLDS), we noted there was a review process implemented; however, there was no process in place to retain the review being performed as to provide evidence to ensure the controls are being performed effectively. Questioned Costs: None. Context: During our testing, it was noted the University does not have a process in place to ensure controls are being performed effectively. Cause: The University did not have a process in place to ensure controls implemented are being performed effectively Effect: There is no way to determine who was involved in the process should an error be present. Repeat Finding: No Recommendation: We recommend the University reevaluate its procedures and review policies surrounding controls implemented for Title IV Aid. Views of Responsible Officials: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Aid Cluster ALN Numbers: Multiple Award Period: September 1, 2023 through August 31, 2024 Type of Finding: • Significant Deficiency in Internal Control Over Compliance • Other Matters Criteria or Specific Requirement: The 2 CFR Section 200.303 require that nonfederal entities receiving federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal Statues, regulations, and the term and conditions of the federal awards. Condition: During our testing of Common Origination and Disbursement (COD), Return of Title IV Funds (R2T4) and National Student Loan Data System (NSLDS), we noted there was a review process implemented; however, there was no process in place to retain the review being performed as to provide evidence to ensure the controls are being performed effectively. Questioned Costs: None. Context: During our testing, it was noted the University does not have a process in place to ensure controls are being performed effectively. Cause: The University did not have a process in place to ensure controls implemented are being performed effectively Effect: There is no way to determine who was involved in the process should an error be present. Repeat Finding: No Recommendation: We recommend the University reevaluate its procedures and review policies surrounding controls implemented for Title IV Aid. Views of Responsible Officials: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Aid Cluster ALN Numbers: Multiple Award Period: September 1, 2023 through August 31, 2024 Type of Finding: • Significant Deficiency in Internal Control Over Compliance • Other Matters Criteria or Specific Requirement: The 2 CFR Section 200.303 require that nonfederal entities receiving federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal Statues, regulations, and the term and conditions of the federal awards. Condition: During our testing of Common Origination and Disbursement (COD), Return of Title IV Funds (R2T4) and National Student Loan Data System (NSLDS), we noted there was a review process implemented; however, there was no process in place to retain the review being performed as to provide evidence to ensure the controls are being performed effectively. Questioned Costs: None. Context: During our testing, it was noted the University does not have a process in place to ensure controls are being performed effectively. Cause: The University did not have a process in place to ensure controls implemented are being performed effectively Effect: There is no way to determine who was involved in the process should an error be present. Repeat Finding: No Recommendation: We recommend the University reevaluate its procedures and review policies surrounding controls implemented for Title IV Aid. Views of Responsible Officials: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Aid Cluster ALN Numbers: Multiple Award Period: September 1, 2023 through August 31, 2024 Type of Finding: • Significant Deficiency in Internal Control Over Compliance • Other Matters Criteria or Specific Requirement: The 2 CFR Section 200.303 require that nonfederal entities receiving federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal Statues, regulations, and the term and conditions of the federal awards. Condition: During our testing of Common Origination and Disbursement (COD), Return of Title IV Funds (R2T4) and National Student Loan Data System (NSLDS), we noted there was a review process implemented; however, there was no process in place to retain the review being performed as to provide evidence to ensure the controls are being performed effectively. Questioned Costs: None. Context: During our testing, it was noted the University does not have a process in place to ensure controls are being performed effectively. Cause: The University did not have a process in place to ensure controls implemented are being performed effectively Effect: There is no way to determine who was involved in the process should an error be present. Repeat Finding: No Recommendation: We recommend the University reevaluate its procedures and review policies surrounding controls implemented for Title IV Aid. Views of Responsible Officials: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Aid Cluster ALN Numbers: Multiple Award Period: September 1, 2023 through August 31, 2024 Type of Finding: • Significant Deficiency in Internal Control Over Compliance • Other Matters Criteria or Specific Requirement: The 2 CFR Section 200.303 require that nonfederal entities receiving federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal Statues, regulations, and the term and conditions of the federal awards. Condition: During our testing of Common Origination and Disbursement (COD), Return of Title IV Funds (R2T4) and National Student Loan Data System (NSLDS), we noted there was a review process implemented; however, there was no process in place to retain the review being performed as to provide evidence to ensure the controls are being performed effectively. Questioned Costs: None. Context: During our testing, it was noted the University does not have a process in place to ensure controls are being performed effectively. Cause: The University did not have a process in place to ensure controls implemented are being performed effectively Effect: There is no way to determine who was involved in the process should an error be present. Repeat Finding: No Recommendation: We recommend the University reevaluate its procedures and review policies surrounding controls implemented for Title IV Aid. Views of Responsible Officials: There is no disagreement with the audit finding.