Audit 349777

Finding number: 2024-001 Federal agency: U.S. Department of Education Programs: Student Financial Assistance Cluster Assistance Listing #: 84.007, 84.063, 84.268 Award year: 2024 Criteria According to 34 CFR 685.309(b)(2): Unless [the institution] it expects to submit its next updated enrollment report to the Secretary within the next 60 days, a school must notify the Secretary within 30 days after the date the school discovers that – (i) A loan under title IV of the Act was made to or on behalf of a student who was enrolled or accepted for enrollment at the school, and the student has ceased to be enrolled on at least a half-time basis or failed to enroll on at least a half-time basis for the period for which the loan was intended; or (ii) A student who is enrolled at the school and who received a loan under title IV of the Act has changed his or her permanent address. The Dear Colleague Letter GEN-12-6 issued by the U.S. Department of Education (“ED”) on March 30, 2012 states that in addition to student loan borrowers, Enrollment Reporting files will include two additional groups of students: Pell Grant and Perkins Loan recipients. According to 2 CFR Part 200, Appendix XI Compliance Supplement updated August 2020: Under the Pell Grant and loan programs, institutions must complete and return within 15 days the Enrollment Reporting roster file placed in their Student Aid Internet Gateway mailboxes sent by ED via the National Student Loan Data System (“NSLDS”). The institution determines how often it receives the Enrollment Reporting roster file with the default set at a minimum of every 60 days. Once received, the institution must update for changes in student status, report the date the enrollment status was effective, enter the new anticipated completion date, and submit the changes electronically through the batch method or the NSLDS website. Institutions are responsible for timely reporting, whether they report directly or via a third-party servicer. Condition The Federal Government requires the College to report student enrollment changes to the National Student Loan Data System (“NSLDS”) within 60 days. During our testing, we noted 10 students, out of a sample of 40, were not reported to NSLDS within the required timeframe. Cause The College did not have adequate procedures in place to ensure that students with enrollment status changes were reported to NSLDS within the required timeframe. The College uses the National Student Clearinghouse (“NSC”) to process student enrollment change submissions to NSLDS. There were discrepancies on the roster file submitted by the College to NSC in January 2024, which caused a delay in the enrollment changes from that file being processed and submitted to NSLDS. The delay in January 2024 also resulted in a delay to subsequent enrollment roster files submitted because roster files are processed in order of their certification dates. These subsequent delays caused several enrollment status changes to submitted late to NSLDS, which is ultimately the responsibility of the College. Effect The College did not report the students’ status changes to NSLDS within the required timeframe, which may impact the students’ loan grace periods. Questioned Costs Not applicable Perspective Our sample was not, and was not intended to be, statistically valid. Of the 40 students selected for testing, 10 students, or 25% of our sample, had status changes that were not reported to NSLDS within the required timeframe. The 10 students were submitted between 6 and 209 days late. Identification as a Repeat Finding, if applicable Not applicable Recommendation The College should provide training to employees responsible for processing information for the NSLDS and ensure that they have adequate knowledge in the related rules and regulations. This training should include an explanation of the College’s date of determination of withdrawal, the importance of reporting the timely and the consequences of late reporting. Additionally, submission of additional rosters and routine review of enrollment reporting submissions may reduce the likelihood of the finding in the future. View of Responsible Officials The College agrees with the finding and has implemented the corrective action plan listed within the management corrective action plan section of this report.

Finding number: 2024-001 Federal agency: U.S. Department of Education Programs: Student Financial Assistance Cluster Assistance Listing #: 84.007, 84.063, 84.268 Award year: 2024 Criteria According to 34 CFR 685.309(b)(2): Unless [the institution] it expects to submit its next updated enrollment report to the Secretary within the next 60 days, a school must notify the Secretary within 30 days after the date the school discovers that – (i) A loan under title IV of the Act was made to or on behalf of a student who was enrolled or accepted for enrollment at the school, and the student has ceased to be enrolled on at least a half-time basis or failed to enroll on at least a half-time basis for the period for which the loan was intended; or (ii) A student who is enrolled at the school and who received a loan under title IV of the Act has changed his or her permanent address. The Dear Colleague Letter GEN-12-6 issued by the U.S. Department of Education (“ED”) on March 30, 2012 states that in addition to student loan borrowers, Enrollment Reporting files will include two additional groups of students: Pell Grant and Perkins Loan recipients. According to 2 CFR Part 200, Appendix XI Compliance Supplement updated August 2020: Under the Pell Grant and loan programs, institutions must complete and return within 15 days the Enrollment Reporting roster file placed in their Student Aid Internet Gateway mailboxes sent by ED via the National Student Loan Data System (“NSLDS”). The institution determines how often it receives the Enrollment Reporting roster file with the default set at a minimum of every 60 days. Once received, the institution must update for changes in student status, report the date the enrollment status was effective, enter the new anticipated completion date, and submit the changes electronically through the batch method or the NSLDS website. Institutions are responsible for timely reporting, whether they report directly or via a third-party servicer. Condition The Federal Government requires the College to report student enrollment changes to the National Student Loan Data System (“NSLDS”) within 60 days. During our testing, we noted 10 students, out of a sample of 40, were not reported to NSLDS within the required timeframe. Cause The College did not have adequate procedures in place to ensure that students with enrollment status changes were reported to NSLDS within the required timeframe. The College uses the National Student Clearinghouse (“NSC”) to process student enrollment change submissions to NSLDS. There were discrepancies on the roster file submitted by the College to NSC in January 2024, which caused a delay in the enrollment changes from that file being processed and submitted to NSLDS. The delay in January 2024 also resulted in a delay to subsequent enrollment roster files submitted because roster files are processed in order of their certification dates. These subsequent delays caused several enrollment status changes to submitted late to NSLDS, which is ultimately the responsibility of the College. Effect The College did not report the students’ status changes to NSLDS within the required timeframe, which may impact the students’ loan grace periods. Questioned Costs Not applicable Perspective Our sample was not, and was not intended to be, statistically valid. Of the 40 students selected for testing, 10 students, or 25% of our sample, had status changes that were not reported to NSLDS within the required timeframe. The 10 students were submitted between 6 and 209 days late. Identification as a Repeat Finding, if applicable Not applicable Recommendation The College should provide training to employees responsible for processing information for the NSLDS and ensure that they have adequate knowledge in the related rules and regulations. This training should include an explanation of the College’s date of determination of withdrawal, the importance of reporting the timely and the consequences of late reporting. Additionally, submission of additional rosters and routine review of enrollment reporting submissions may reduce the likelihood of the finding in the future. View of Responsible Officials The College agrees with the finding and has implemented the corrective action plan listed within the management corrective action plan section of this report.

Finding number: 2024-001 Federal agency: U.S. Department of Education Programs: Student Financial Assistance Cluster Assistance Listing #: 84.007, 84.063, 84.268 Award year: 2024 Criteria According to 34 CFR 685.309(b)(2): Unless [the institution] it expects to submit its next updated enrollment report to the Secretary within the next 60 days, a school must notify the Secretary within 30 days after the date the school discovers that – (i) A loan under title IV of the Act was made to or on behalf of a student who was enrolled or accepted for enrollment at the school, and the student has ceased to be enrolled on at least a half-time basis or failed to enroll on at least a half-time basis for the period for which the loan was intended; or (ii) A student who is enrolled at the school and who received a loan under title IV of the Act has changed his or her permanent address. The Dear Colleague Letter GEN-12-6 issued by the U.S. Department of Education (“ED”) on March 30, 2012 states that in addition to student loan borrowers, Enrollment Reporting files will include two additional groups of students: Pell Grant and Perkins Loan recipients. According to 2 CFR Part 200, Appendix XI Compliance Supplement updated August 2020: Under the Pell Grant and loan programs, institutions must complete and return within 15 days the Enrollment Reporting roster file placed in their Student Aid Internet Gateway mailboxes sent by ED via the National Student Loan Data System (“NSLDS”). The institution determines how often it receives the Enrollment Reporting roster file with the default set at a minimum of every 60 days. Once received, the institution must update for changes in student status, report the date the enrollment status was effective, enter the new anticipated completion date, and submit the changes electronically through the batch method or the NSLDS website. Institutions are responsible for timely reporting, whether they report directly or via a third-party servicer. Condition The Federal Government requires the College to report student enrollment changes to the National Student Loan Data System (“NSLDS”) within 60 days. During our testing, we noted 10 students, out of a sample of 40, were not reported to NSLDS within the required timeframe. Cause The College did not have adequate procedures in place to ensure that students with enrollment status changes were reported to NSLDS within the required timeframe. The College uses the National Student Clearinghouse (“NSC”) to process student enrollment change submissions to NSLDS. There were discrepancies on the roster file submitted by the College to NSC in January 2024, which caused a delay in the enrollment changes from that file being processed and submitted to NSLDS. The delay in January 2024 also resulted in a delay to subsequent enrollment roster files submitted because roster files are processed in order of their certification dates. These subsequent delays caused several enrollment status changes to submitted late to NSLDS, which is ultimately the responsibility of the College. Effect The College did not report the students’ status changes to NSLDS within the required timeframe, which may impact the students’ loan grace periods. Questioned Costs Not applicable Perspective Our sample was not, and was not intended to be, statistically valid. Of the 40 students selected for testing, 10 students, or 25% of our sample, had status changes that were not reported to NSLDS within the required timeframe. The 10 students were submitted between 6 and 209 days late. Identification as a Repeat Finding, if applicable Not applicable Recommendation The College should provide training to employees responsible for processing information for the NSLDS and ensure that they have adequate knowledge in the related rules and regulations. This training should include an explanation of the College’s date of determination of withdrawal, the importance of reporting the timely and the consequences of late reporting. Additionally, submission of additional rosters and routine review of enrollment reporting submissions may reduce the likelihood of the finding in the future. View of Responsible Officials The College agrees with the finding and has implemented the corrective action plan listed within the management corrective action plan section of this report.

Finding number: 2024-002 Federal agency: U.S. Department of Education Programs: Student Financial Assistance Cluster Assistance Listing #: 84.268 Award year: 2024 Criteria According to 34 CFR 668.22(e)(4): Total amount of unearned title IV assistance to be returned. The unearned amount of title IV assistance to be returned is calculated by subtracting the amount of title IV assistance earned by the student as calculated under paragraph (e)(1) of this section from the amount of title IV aid that was disbursed to the student as of the date of the institution's determination that the student withdrew. Condition The Financial Aid Office is responsible for completing the Return of Title IV calculation to determine how much Title IV aid the student earned and how much must be returned to the Department of Education. Once the Return of Title IV calculation is completed, the College is responsible for adjusting the student’s billing statement and returning unearned Title IV funds through the U.S. Department of Education’s Grant Management System (“G5”). The College has 45 days from the date they determined the student withdrew to return any unearned portions of Title IV funds. During our testing, we noted 1 student, out of a sample of 9, where the aid returned was different than the amount correctly calculated on the Return to Title IV (“R2T4”) form. Cause The College did not ensure that the regulations were met in regard to refunding Title IV funds when calculating the amount of aid to be returned. While the college correctly calculated the student’s earned and unearned amounts, the College debited the student’s account in amount of $1,943, which represented the amount earned by student. The debit to the student’s account should have been $1,769, representing the amount to return to the Department of Education per the R2T4 form. This resulted in an under awarding of aid that the student earned. Effect The College did not return the correct amount of Title IV funds to the Department of Education. Questioned Costs $174 Perspective Our sample was not, and was not intended to be, statistically valid. Of the 9 students selected for testing, 1 student, or 11% of our sample, had the incorrect amount of Title IV funds returned. Identification as a Repeat Finding, if applicable Not applicable Recommendation The College should review their current policies and procedures to ensure the amount of federal aid returned agrees with the amount calculated on the R2T4 form. View of Responsible Officials The College agrees with the finding and has implemented the corrective action plan listed within the management corrective action plan section of this report.

Finding number: 2024-003 Federal agency: U.S. Department of Education Programs: Federal Work-Study (“FWS”) Assistance Listing #: 84.033 Award year: 2024-003 Criteria According to 34 CFR 675.19(a): The institution must establish and maintain program and fiscal records that include a certification by the student's supervisor, an official of the institution, or off-campus agency, that each student has worked and earned the amount being paid. The certification must include or be supported by, for the students paid on an hourly basis, a time record showing the hours each student worked in clock time sequence, or the total hours worked per day. The 2023-2024 Federal Student Aid Handbook (Vol. 6, Pg. 33) states: In general, students are not permitted to work in Federal Work-Study positions during scheduled class times. Exceptions are permitted if the individual class is cancelled, if the instructor has excused the student from attending for a particular day, and if the student is receiving credit for employment in an internship, externship, or community work- study experience. Any such exemptions must be documented. Condition Federal regulations require an institution to monitor and ensure that a work-study student is not working during his/her designated class time. Out of a sample of 3 students, we noted 2 students who worked during class time. Cause The College did not have adequate procedures in place to ensure that students did not work during class time. Effect Two students reported work-study time sheets conflicted with their respective class schedules. As a result of this scheduling conflict, the students either did not attend class or were not present during the documented time period for which they were paid Federal Work-Study wages. Questioned Costs Not applicable Perspective Our sample was not, and was not intended to be, statistically valid. Of the 3 students selected for testing, 2 students, or 66% of our sample, were determined to have worked during class time. Identification as a Repeat Finding, if applicable Not applicable Recommendation We recommend that the College review, and if necessary, update the policies and procedures to ensure all Federal Work-Study supervisors are monitoring students' work time to ensure that it does not conflict with their class schedules. These policies should also be revisited and reinforced with those in charge of monitoring the students' federal work-study time. View of Responsible Officials The College agrees with the finding and has implemented the corrective action plan listed within the management corrective action plan section of this report.

Finding number: 2024-001 Federal agency: U.S. Department of Education Programs: Student Financial Assistance Cluster Assistance Listing #: 84.007, 84.063, 84.268 Award year: 2024 Criteria According to 34 CFR 685.309(b)(2): Unless [the institution] it expects to submit its next updated enrollment report to the Secretary within the next 60 days, a school must notify the Secretary within 30 days after the date the school discovers that – (i) A loan under title IV of the Act was made to or on behalf of a student who was enrolled or accepted for enrollment at the school, and the student has ceased to be enrolled on at least a half-time basis or failed to enroll on at least a half-time basis for the period for which the loan was intended; or (ii) A student who is enrolled at the school and who received a loan under title IV of the Act has changed his or her permanent address. The Dear Colleague Letter GEN-12-6 issued by the U.S. Department of Education (“ED”) on March 30, 2012 states that in addition to student loan borrowers, Enrollment Reporting files will include two additional groups of students: Pell Grant and Perkins Loan recipients. According to 2 CFR Part 200, Appendix XI Compliance Supplement updated August 2020: Under the Pell Grant and loan programs, institutions must complete and return within 15 days the Enrollment Reporting roster file placed in their Student Aid Internet Gateway mailboxes sent by ED via the National Student Loan Data System (“NSLDS”). The institution determines how often it receives the Enrollment Reporting roster file with the default set at a minimum of every 60 days. Once received, the institution must update for changes in student status, report the date the enrollment status was effective, enter the new anticipated completion date, and submit the changes electronically through the batch method or the NSLDS website. Institutions are responsible for timely reporting, whether they report directly or via a third-party servicer. Condition The Federal Government requires the College to report student enrollment changes to the National Student Loan Data System (“NSLDS”) within 60 days. During our testing, we noted 10 students, out of a sample of 40, were not reported to NSLDS within the required timeframe. Cause The College did not have adequate procedures in place to ensure that students with enrollment status changes were reported to NSLDS within the required timeframe. The College uses the National Student Clearinghouse (“NSC”) to process student enrollment change submissions to NSLDS. There were discrepancies on the roster file submitted by the College to NSC in January 2024, which caused a delay in the enrollment changes from that file being processed and submitted to NSLDS. The delay in January 2024 also resulted in a delay to subsequent enrollment roster files submitted because roster files are processed in order of their certification dates. These subsequent delays caused several enrollment status changes to submitted late to NSLDS, which is ultimately the responsibility of the College. Effect The College did not report the students’ status changes to NSLDS within the required timeframe, which may impact the students’ loan grace periods. Questioned Costs Not applicable Perspective Our sample was not, and was not intended to be, statistically valid. Of the 40 students selected for testing, 10 students, or 25% of our sample, had status changes that were not reported to NSLDS within the required timeframe. The 10 students were submitted between 6 and 209 days late. Identification as a Repeat Finding, if applicable Not applicable Recommendation The College should provide training to employees responsible for processing information for the NSLDS and ensure that they have adequate knowledge in the related rules and regulations. This training should include an explanation of the College’s date of determination of withdrawal, the importance of reporting the timely and the consequences of late reporting. Additionally, submission of additional rosters and routine review of enrollment reporting submissions may reduce the likelihood of the finding in the future. View of Responsible Officials The College agrees with the finding and has implemented the corrective action plan listed within the management corrective action plan section of this report.

Finding number: 2024-001 Federal agency: U.S. Department of Education Programs: Student Financial Assistance Cluster Assistance Listing #: 84.007, 84.063, 84.268 Award year: 2024 Criteria According to 34 CFR 685.309(b)(2): Unless [the institution] it expects to submit its next updated enrollment report to the Secretary within the next 60 days, a school must notify the Secretary within 30 days after the date the school discovers that – (i) A loan under title IV of the Act was made to or on behalf of a student who was enrolled or accepted for enrollment at the school, and the student has ceased to be enrolled on at least a half-time basis or failed to enroll on at least a half-time basis for the period for which the loan was intended; or (ii) A student who is enrolled at the school and who received a loan under title IV of the Act has changed his or her permanent address. The Dear Colleague Letter GEN-12-6 issued by the U.S. Department of Education (“ED”) on March 30, 2012 states that in addition to student loan borrowers, Enrollment Reporting files will include two additional groups of students: Pell Grant and Perkins Loan recipients. According to 2 CFR Part 200, Appendix XI Compliance Supplement updated August 2020: Under the Pell Grant and loan programs, institutions must complete and return within 15 days the Enrollment Reporting roster file placed in their Student Aid Internet Gateway mailboxes sent by ED via the National Student Loan Data System (“NSLDS”). The institution determines how often it receives the Enrollment Reporting roster file with the default set at a minimum of every 60 days. Once received, the institution must update for changes in student status, report the date the enrollment status was effective, enter the new anticipated completion date, and submit the changes electronically through the batch method or the NSLDS website. Institutions are responsible for timely reporting, whether they report directly or via a third-party servicer. Condition The Federal Government requires the College to report student enrollment changes to the National Student Loan Data System (“NSLDS”) within 60 days. During our testing, we noted 10 students, out of a sample of 40, were not reported to NSLDS within the required timeframe. Cause The College did not have adequate procedures in place to ensure that students with enrollment status changes were reported to NSLDS within the required timeframe. The College uses the National Student Clearinghouse (“NSC”) to process student enrollment change submissions to NSLDS. There were discrepancies on the roster file submitted by the College to NSC in January 2024, which caused a delay in the enrollment changes from that file being processed and submitted to NSLDS. The delay in January 2024 also resulted in a delay to subsequent enrollment roster files submitted because roster files are processed in order of their certification dates. These subsequent delays caused several enrollment status changes to submitted late to NSLDS, which is ultimately the responsibility of the College. Effect The College did not report the students’ status changes to NSLDS within the required timeframe, which may impact the students’ loan grace periods. Questioned Costs Not applicable Perspective Our sample was not, and was not intended to be, statistically valid. Of the 40 students selected for testing, 10 students, or 25% of our sample, had status changes that were not reported to NSLDS within the required timeframe. The 10 students were submitted between 6 and 209 days late. Identification as a Repeat Finding, if applicable Not applicable Recommendation The College should provide training to employees responsible for processing information for the NSLDS and ensure that they have adequate knowledge in the related rules and regulations. This training should include an explanation of the College’s date of determination of withdrawal, the importance of reporting the timely and the consequences of late reporting. Additionally, submission of additional rosters and routine review of enrollment reporting submissions may reduce the likelihood of the finding in the future. View of Responsible Officials The College agrees with the finding and has implemented the corrective action plan listed within the management corrective action plan section of this report.

Finding number: 2024-001 Federal agency: U.S. Department of Education Programs: Student Financial Assistance Cluster Assistance Listing #: 84.007, 84.063, 84.268 Award year: 2024 Criteria According to 34 CFR 685.309(b)(2): Unless [the institution] it expects to submit its next updated enrollment report to the Secretary within the next 60 days, a school must notify the Secretary within 30 days after the date the school discovers that – (i) A loan under title IV of the Act was made to or on behalf of a student who was enrolled or accepted for enrollment at the school, and the student has ceased to be enrolled on at least a half-time basis or failed to enroll on at least a half-time basis for the period for which the loan was intended; or (ii) A student who is enrolled at the school and who received a loan under title IV of the Act has changed his or her permanent address. The Dear Colleague Letter GEN-12-6 issued by the U.S. Department of Education (“ED”) on March 30, 2012 states that in addition to student loan borrowers, Enrollment Reporting files will include two additional groups of students: Pell Grant and Perkins Loan recipients. According to 2 CFR Part 200, Appendix XI Compliance Supplement updated August 2020: Under the Pell Grant and loan programs, institutions must complete and return within 15 days the Enrollment Reporting roster file placed in their Student Aid Internet Gateway mailboxes sent by ED via the National Student Loan Data System (“NSLDS”). The institution determines how often it receives the Enrollment Reporting roster file with the default set at a minimum of every 60 days. Once received, the institution must update for changes in student status, report the date the enrollment status was effective, enter the new anticipated completion date, and submit the changes electronically through the batch method or the NSLDS website. Institutions are responsible for timely reporting, whether they report directly or via a third-party servicer. Condition The Federal Government requires the College to report student enrollment changes to the National Student Loan Data System (“NSLDS”) within 60 days. During our testing, we noted 10 students, out of a sample of 40, were not reported to NSLDS within the required timeframe. Cause The College did not have adequate procedures in place to ensure that students with enrollment status changes were reported to NSLDS within the required timeframe. The College uses the National Student Clearinghouse (“NSC”) to process student enrollment change submissions to NSLDS. There were discrepancies on the roster file submitted by the College to NSC in January 2024, which caused a delay in the enrollment changes from that file being processed and submitted to NSLDS. The delay in January 2024 also resulted in a delay to subsequent enrollment roster files submitted because roster files are processed in order of their certification dates. These subsequent delays caused several enrollment status changes to submitted late to NSLDS, which is ultimately the responsibility of the College. Effect The College did not report the students’ status changes to NSLDS within the required timeframe, which may impact the students’ loan grace periods. Questioned Costs Not applicable Perspective Our sample was not, and was not intended to be, statistically valid. Of the 40 students selected for testing, 10 students, or 25% of our sample, had status changes that were not reported to NSLDS within the required timeframe. The 10 students were submitted between 6 and 209 days late. Identification as a Repeat Finding, if applicable Not applicable Recommendation The College should provide training to employees responsible for processing information for the NSLDS and ensure that they have adequate knowledge in the related rules and regulations. This training should include an explanation of the College’s date of determination of withdrawal, the importance of reporting the timely and the consequences of late reporting. Additionally, submission of additional rosters and routine review of enrollment reporting submissions may reduce the likelihood of the finding in the future. View of Responsible Officials The College agrees with the finding and has implemented the corrective action plan listed within the management corrective action plan section of this report.

Finding number: 2024-002 Federal agency: U.S. Department of Education Programs: Student Financial Assistance Cluster Assistance Listing #: 84.268 Award year: 2024 Criteria According to 34 CFR 668.22(e)(4): Total amount of unearned title IV assistance to be returned. The unearned amount of title IV assistance to be returned is calculated by subtracting the amount of title IV assistance earned by the student as calculated under paragraph (e)(1) of this section from the amount of title IV aid that was disbursed to the student as of the date of the institution's determination that the student withdrew. Condition The Financial Aid Office is responsible for completing the Return of Title IV calculation to determine how much Title IV aid the student earned and how much must be returned to the Department of Education. Once the Return of Title IV calculation is completed, the College is responsible for adjusting the student’s billing statement and returning unearned Title IV funds through the U.S. Department of Education’s Grant Management System (“G5”). The College has 45 days from the date they determined the student withdrew to return any unearned portions of Title IV funds. During our testing, we noted 1 student, out of a sample of 9, where the aid returned was different than the amount correctly calculated on the Return to Title IV (“R2T4”) form. Cause The College did not ensure that the regulations were met in regard to refunding Title IV funds when calculating the amount of aid to be returned. While the college correctly calculated the student’s earned and unearned amounts, the College debited the student’s account in amount of $1,943, which represented the amount earned by student. The debit to the student’s account should have been $1,769, representing the amount to return to the Department of Education per the R2T4 form. This resulted in an under awarding of aid that the student earned. Effect The College did not return the correct amount of Title IV funds to the Department of Education. Questioned Costs $174 Perspective Our sample was not, and was not intended to be, statistically valid. Of the 9 students selected for testing, 1 student, or 11% of our sample, had the incorrect amount of Title IV funds returned. Identification as a Repeat Finding, if applicable Not applicable Recommendation The College should review their current policies and procedures to ensure the amount of federal aid returned agrees with the amount calculated on the R2T4 form. View of Responsible Officials The College agrees with the finding and has implemented the corrective action plan listed within the management corrective action plan section of this report.

Finding number: 2024-003 Federal agency: U.S. Department of Education Programs: Federal Work-Study (“FWS”) Assistance Listing #: 84.033 Award year: 2024-003 Criteria According to 34 CFR 675.19(a): The institution must establish and maintain program and fiscal records that include a certification by the student's supervisor, an official of the institution, or off-campus agency, that each student has worked and earned the amount being paid. The certification must include or be supported by, for the students paid on an hourly basis, a time record showing the hours each student worked in clock time sequence, or the total hours worked per day. The 2023-2024 Federal Student Aid Handbook (Vol. 6, Pg. 33) states: In general, students are not permitted to work in Federal Work-Study positions during scheduled class times. Exceptions are permitted if the individual class is cancelled, if the instructor has excused the student from attending for a particular day, and if the student is receiving credit for employment in an internship, externship, or community work- study experience. Any such exemptions must be documented. Condition Federal regulations require an institution to monitor and ensure that a work-study student is not working during his/her designated class time. Out of a sample of 3 students, we noted 2 students who worked during class time. Cause The College did not have adequate procedures in place to ensure that students did not work during class time. Effect Two students reported work-study time sheets conflicted with their respective class schedules. As a result of this scheduling conflict, the students either did not attend class or were not present during the documented time period for which they were paid Federal Work-Study wages. Questioned Costs Not applicable Perspective Our sample was not, and was not intended to be, statistically valid. Of the 3 students selected for testing, 2 students, or 66% of our sample, were determined to have worked during class time. Identification as a Repeat Finding, if applicable Not applicable Recommendation We recommend that the College review, and if necessary, update the policies and procedures to ensure all Federal Work-Study supervisors are monitoring students' work time to ensure that it does not conflict with their class schedules. These policies should also be revisited and reinforced with those in charge of monitoring the students' federal work-study time. View of Responsible Officials The College agrees with the finding and has implemented the corrective action plan listed within the management corrective action plan section of this report.