Audit 351293

Criteria According to 34 CFR 668.164(h): Title IV, Higher Education Act (“HEA”) credit balances. (1) A title IV, HEA credit balance occurs whenever the amount of title IV, HEA program funds credited to a student's ledger account for a payment period exceeds the amount assessed the student for allowable charges associated with that payment period. (2) A title IV, HEA credit balance must be paid directly to the student or parent as soon as possible, but – (i) No later than 14 days after the balance occurred if the balance occurred after the first day of class of a payment period; or (ii) No later than 14 days after the first day of class of a payment period if the credit balance occurred on or before the first day of that payment period. Condition The Federal Government requires that whenever Title IV aid is disbursed on a student’s account, the account must be reviewed to determine if the disbursement caused a credit balance. If the credit balance was caused by Title IV funds, the College must refund the balance directly to the student within 14 days of the disbursement of funds. During our testing, we noted 29 students, out of a sample of 60, that were not refunded credit balances within the required timeframe by 8-251 days. Cause The College failed to identify and return Title IV credit balances within required timeframe due to lack of procedures and knowledge of compliance requirements over Student Financial Assistance requirements within business office. Effect The College did not refund Title IV credit balances within the required 14-day time frame and therefore was not in compliance with federal requirements. Questioned Costs Not applicable Perspective Our sample was not, and was not intended to be, statistically valid. Of the 60 students selected for testing, 44 students, or 73% of our sample, had credit balances caused by financial aid. Of these 44 students, 29 students’ credit balances caused by Title IV funds were not refunded within the required time frame (65.9% of students who had credit balances). The remaining 15 students had credit balances as a result of Title IV aid, which were returned within the required time frame. Identification as a Repeat Finding, if applicable See finding 2023-001 included in the summary schedule of prior year findings. Recommendation The Business Office should continue to develop their procedures to identify credit balances caused by changes on students’ accounts as well as disbursements. This includes reviewing accounts after late disbursement of Title IV aid as well as tuition and fee adjustments, health insurance waivers and bookstore credits. Moreover, the College should provide training to employees responsible for processing such information over student accounts to ensure personnel have adequate knowledge in the related rules and regulations. 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.

Criteria According to 34 CFR 668.164(h): Title IV, Higher Education Act (“HEA”) credit balances. (1) A title IV, HEA credit balance occurs whenever the amount of title IV, HEA program funds credited to a student's ledger account for a payment period exceeds the amount assessed the student for allowable charges associated with that payment period. (2) A title IV, HEA credit balance must be paid directly to the student or parent as soon as possible, but – (i) No later than 14 days after the balance occurred if the balance occurred after the first day of class of a payment period; or (ii) No later than 14 days after the first day of class of a payment period if the credit balance occurred on or before the first day of that payment period. Condition The Federal Government requires that whenever Title IV aid is disbursed on a student’s account, the account must be reviewed to determine if the disbursement caused a credit balance. If the credit balance was caused by Title IV funds, the College must refund the balance directly to the student within 14 days of the disbursement of funds. During our testing, we noted 29 students, out of a sample of 60, that were not refunded credit balances within the required timeframe by 8-251 days. Cause The College failed to identify and return Title IV credit balances within required timeframe due to lack of procedures and knowledge of compliance requirements over Student Financial Assistance requirements within business office. Effect The College did not refund Title IV credit balances within the required 14-day time frame and therefore was not in compliance with federal requirements. Questioned Costs Not applicable Perspective Our sample was not, and was not intended to be, statistically valid. Of the 60 students selected for testing, 44 students, or 73% of our sample, had credit balances caused by financial aid. Of these 44 students, 29 students’ credit balances caused by Title IV funds were not refunded within the required time frame (65.9% of students who had credit balances). The remaining 15 students had credit balances as a result of Title IV aid, which were returned within the required time frame. Identification as a Repeat Finding, if applicable See finding 2023-001 included in the summary schedule of prior year findings. Recommendation The Business Office should continue to develop their procedures to identify credit balances caused by changes on students’ accounts as well as disbursements. This includes reviewing accounts after late disbursement of Title IV aid as well as tuition and fee adjustments, health insurance waivers and bookstore credits. Moreover, the College should provide training to employees responsible for processing such information over student accounts to ensure personnel have adequate knowledge in the related rules and regulations. 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.

Criteria According to 34 CFR 668.164(h): Title IV, Higher Education Act (“HEA”) credit balances. (1) A title IV, HEA credit balance occurs whenever the amount of title IV, HEA program funds credited to a student's ledger account for a payment period exceeds the amount assessed the student for allowable charges associated with that payment period. (2) A title IV, HEA credit balance must be paid directly to the student or parent as soon as possible, but – (i) No later than 14 days after the balance occurred if the balance occurred after the first day of class of a payment period; or (ii) No later than 14 days after the first day of class of a payment period if the credit balance occurred on or before the first day of that payment period. Condition The Federal Government requires that whenever Title IV aid is disbursed on a student’s account, the account must be reviewed to determine if the disbursement caused a credit balance. If the credit balance was caused by Title IV funds, the College must refund the balance directly to the student within 14 days of the disbursement of funds. During our testing, we noted 29 students, out of a sample of 60, that were not refunded credit balances within the required timeframe by 8-251 days. Cause The College failed to identify and return Title IV credit balances within required timeframe due to lack of procedures and knowledge of compliance requirements over Student Financial Assistance requirements within business office. Effect The College did not refund Title IV credit balances within the required 14-day time frame and therefore was not in compliance with federal requirements. Questioned Costs Not applicable Perspective Our sample was not, and was not intended to be, statistically valid. Of the 60 students selected for testing, 44 students, or 73% of our sample, had credit balances caused by financial aid. Of these 44 students, 29 students’ credit balances caused by Title IV funds were not refunded within the required time frame (65.9% of students who had credit balances). The remaining 15 students had credit balances as a result of Title IV aid, which were returned within the required time frame. Identification as a Repeat Finding, if applicable See finding 2023-001 included in the summary schedule of prior year findings. Recommendation The Business Office should continue to develop their procedures to identify credit balances caused by changes on students’ accounts as well as disbursements. This includes reviewing accounts after late disbursement of Title IV aid as well as tuition and fee adjustments, health insurance waivers and bookstore credits. Moreover, the College should provide training to employees responsible for processing such information over student accounts to ensure personnel have adequate knowledge in the related rules and regulations. 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.

Criteria According to 34 CFR 690.83(b) (1) An institution shall report to the Secretary any change for which a student qualifies including any related Payment Data changes by submitting to the Secretary the student’s Payment Data that discloses the basis and result of the change in award for each student. The institution shall submit the student’s Payment Data reporting any to the Secretary by the reporting deadlines published by the Secretary in the Federal Register. (2) An institution shall submit, in accordance with the deadline dates established by the Secretary, through publication in the Federal Register, other reports and information the Secretary requires and shall comply with the procedures the Secretary finds necessary to ensure that the reports are correct. According to the Federal Register (Volume 88, Number 120): An institution must submit Pell Grant, Iraq and Afghanistan Service Grant, Direct Loan, and TEACH Grant disbursement records to COD, no later than 15 days after making the disbursement or becoming aware of the need to adjust a previously reported disbursement. In accordance with 34 CFR 668.164(a), title IV, Higher Education Act (“HEA”) program funds are disbursed on the date that the institution: (a) Credits those funds to a student’s account in the institution’s general ledger or any subledger of the general ledger; or (b) pays those funds to a student directly. Title IV, HEA program funds are disbursed even if an institution uses its own funds in advance of receiving program funds from the Department. Condition Federal regulations require the College to report to the Federal Government’s Common Origination and Disbursement System (“COD”) disbursements made to students accurately based on date award was credited to student directly. During our testing, we noted 51 students, out of a sample of 60, was not reported accurately to Common Origination System based on disbursement date per College records. Cause The College has policies and procedures in place to report the disbursement records to the Department of Education through the COD are recorded accurately, however, in this case the procedures were not completed properly. Cause due to transition and change in processes as the College has contracted service organization to assist in cash management. The College was not aware that there was a +1 day needed to be added to student accounts from check register provided by service organization, causing variance between actual disbursement date and disbursement date per COD. Effect The College did not report Pell disbursements to COD accurately based on College records. Questioned Costs Not applicable Perspective Our sample was not, and was not intended to be, statistically valid. Of the 60 students selected for testing, 51 students, or 85% of our sample, had disbursement information not recorded. Identification as a Repeat Finding, if applicable See finding 2023-002 included in the summary schedule of prior year findings. Recommendation We recommend that management of the College review, and if necessary, update the policies and procedures to ensure all Direct Loan funds disbursed are reported accurately based on when awards were credited to student account. View of Responsible Officials The College agrees with the finding and has implemented the corrective action plan within the management corrective action plan section of this report.

Criteria According to 34 CFR 690.83(b) (1) An institution shall report to the Secretary any change for which a student qualifies including any related Payment Data changes by submitting to the Secretary the student’s Payment Data that discloses the basis and result of the change in award for each student. The institution shall submit the student’s Payment Data reporting any to the Secretary by the reporting deadlines published by the Secretary in the Federal Register. (2) An institution shall submit, in accordance with the deadline dates established by the Secretary, through publication in the Federal Register, other reports and information the Secretary requires and shall comply with the procedures the Secretary finds necessary to ensure that the reports are correct. According to the Federal Register (Volume 88, Number 120): An institution must submit Pell Grant, Iraq and Afghanistan Service Grant, Direct Loan, and TEACH Grant disbursement records to COD, no later than 15 days after making the disbursement or becoming aware of the need to adjust a previously reported disbursement. In accordance with 34 CFR 668.164(a), title IV, Higher Education Act (“HEA”) program funds are disbursed on the date that the institution: (a) Credits those funds to a student’s account in the institution’s general ledger or any subledger of the general ledger; or (b) pays those funds to a student directly. Title IV, HEA program funds are disbursed even if an institution uses its own funds in advance of receiving program funds from the Department. Condition Federal regulations require the College to report to the Federal Government’s Common Origination and Disbursement System (“COD”) disbursements made to students accurately based on date award was credited to student directly. During our testing, we noted 51 students, out of a sample of 60, was not reported accurately to Common Origination System based on disbursement date per College records. Cause The College has policies and procedures in place to report the disbursement records to the Department of Education through the COD are recorded accurately, however, in this case the procedures were not completed properly. Cause due to transition and change in processes as the College has contracted service organization to assist in cash management. The College was not aware that there was a +1 day needed to be added to student accounts from check register provided by service organization, causing variance between actual disbursement date and disbursement date per COD. Effect The College did not report Pell disbursements to COD accurately based on College records. Questioned Costs Not applicable Perspective Our sample was not, and was not intended to be, statistically valid. Of the 60 students selected for testing, 51 students, or 85% of our sample, had disbursement information not recorded. Identification as a Repeat Finding, if applicable See finding 2023-002 included in the summary schedule of prior year findings. Recommendation We recommend that management of the College review, and if necessary, update the policies and procedures to ensure all Direct Loan funds disbursed are reported accurately based on when awards were credited to student account. View of Responsible Officials The College agrees with the finding and has implemented the corrective action plan within the management corrective action plan section of this report.

Criteria According to 34 CFR 668.164(l): (1) Notwithstanding any State law (such as a law that allows funds to escheat to the State), an institution must return to the Secretary any title IV, Higher Education Act (“HEA”) program funds, except Federal Work Study (“FWS”) program funds, that it attempts to disburse directly to a student or parent that are not received by the student or parent. For FWS program funds, the institution is required to return only the Federal portion of the payroll disbursement. (2) If an EFT to a student's or parent's financial account is rejected, or a check to a student or parent is returned, the institution may make additional attempts to disburse the funds, provided that those attempts are made not later than 45 days after the EFT was rejected or the check returned. In cases where the institution does not make another attempt, the funds must be returned to the Secretary before the end of this 45-day period. (3) If a check sent to a student or parent is not returned to the institution but is not cashed, the institution must return the funds to the Secretary no later than 240 days after the date it issued the check. Condition Federal regulations require an institution to return unclaimed Title IV funds issued by check or EFT within 240 days. During our testing, we noted 9 students, out of a sample of 13, that had unclaimed funds exceeding the federal day limit by 64-717 days. Cause Accounts are reviewed and reconciled routinely. However, the College did not monitor outstanding checks or unclaimed funds over 240-days due to Title IV as the business office was not aware of 240-day timeframe to require unclaimed Title IV funds. Effect The College did not return Title IV unclaimed funds to the Department of Education within the required 240-day time frame. Questioned Costs There were 9 outstanding checks totaling $986, which pertained specifically to federal-sourced funds. Perspective Our sample was not, and was not intended to be, statistically valid. Of the 13 students selected for testing, 9 students, or 69.23% of our sample, had unclaimed funds pertaining to federal sources that were not returned to the Department of Education within the 240-day required time frame. Identification as a Repeat Finding, if applicable See finding 2023-003 included in the summary schedule of prior year findings. Recommendation The College should examine its policies and procedures related to unclaimed funds including the process and time frame for identifying aged balances and the process for cancelling checks and returning funds to the Department of Education. Moreover, the College should provide training to employees responsible for reviewing and processing information to ensure that they have adequate knowledge in the related rules and regulations. 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.

Criteria According to 34 CFR 668.164(l): (1) Notwithstanding any State law (such as a law that allows funds to escheat to the State), an institution must return to the Secretary any title IV, Higher Education Act (“HEA”) program funds, except Federal Work Study (“FWS”) program funds, that it attempts to disburse directly to a student or parent that are not received by the student or parent. For FWS program funds, the institution is required to return only the Federal portion of the payroll disbursement. (2) If an EFT to a student's or parent's financial account is rejected, or a check to a student or parent is returned, the institution may make additional attempts to disburse the funds, provided that those attempts are made not later than 45 days after the EFT was rejected or the check returned. In cases where the institution does not make another attempt, the funds must be returned to the Secretary before the end of this 45-day period. (3) If a check sent to a student or parent is not returned to the institution but is not cashed, the institution must return the funds to the Secretary no later than 240 days after the date it issued the check. Condition Federal regulations require an institution to return unclaimed Title IV funds issued by check or EFT within 240 days. During our testing, we noted 9 students, out of a sample of 13, that had unclaimed funds exceeding the federal day limit by 64-717 days. Cause Accounts are reviewed and reconciled routinely. However, the College did not monitor outstanding checks or unclaimed funds over 240-days due to Title IV as the business office was not aware of 240-day timeframe to require unclaimed Title IV funds. Effect The College did not return Title IV unclaimed funds to the Department of Education within the required 240-day time frame. Questioned Costs There were 9 outstanding checks totaling $986, which pertained specifically to federal-sourced funds. Perspective Our sample was not, and was not intended to be, statistically valid. Of the 13 students selected for testing, 9 students, or 69.23% of our sample, had unclaimed funds pertaining to federal sources that were not returned to the Department of Education within the 240-day required time frame. Identification as a Repeat Finding, if applicable See finding 2023-003 included in the summary schedule of prior year findings. Recommendation The College should examine its policies and procedures related to unclaimed funds including the process and time frame for identifying aged balances and the process for cancelling checks and returning funds to the Department of Education. Moreover, the College should provide training to employees responsible for reviewing and processing information to ensure that they have adequate knowledge in the related rules and regulations. 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.

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 2 students, out of a sample of 10, 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. Effect The College did not return the correct amount of Title IV funds to the Department of Education. Questioned Costs $16.18 Perspective Our sample was not, and was not intended to be, statistically valid. Of the 10 students selected for testing, 2 students, or 20% 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

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 2 students, out of a sample of 10, 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. Effect The College did not return the correct amount of Title IV funds to the Department of Education. Questioned Costs $16.18 Perspective Our sample was not, and was not intended to be, statistically valid. Of the 10 students selected for testing, 2 students, or 20% 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

Criteria According to 34 CFR 668.22(j)(1): Timeframe for the return of title IV funds. An institution must return the amount of title IV funds for which it is responsible under paragraph (g) of this section as soon as possible but no later than 45 days after the date of the institution's determination that the student withdrew as defined in paragraph (l)(3) of this section. According to 34 CFR 668.173(b): Timely return of Title IV, HEA program funds. In accordance with procedures established by the Secretary or Federal Family Education Loan (“FFEL”) program lender, an institution returns unearned Title IV, HEA program funds timely if – (1) The institution deposits or transfers the funds into the bank account it maintains under 34 CFR Sections 668.163 no later than 45 days after the date it determines the student withdrew; (2) The institution initiates an electronic funds transfer no later than 45 days after the date it determines that the student withdrew; (3) The institution initiates an electronic transaction no later than 45 days after the date it determines that the student withdrew, that informs a FFEL lender to adjust the borrower’s loan account for the amount returned; or (4) The institution issues a check no later than 45 days after the date it determines that the student withdrew. An institution does not satisfy this requirement if – (i) The institution’s records show that the check was issued more than 45 days after the date the institution determined the student withdrew; or (ii) The date on the cancelled check shows that the bank used by the Secretary or FFEL Program lender endorsed that check more than 60 days after the date the institution determined that the student withdrew. Condition Federal regulations state that any unearned Title IV grant or loan assistance received by a student must be refunded to the Title IV programs upon a student’s withdrawal from the institution. 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 5 students, out of a sample of 10, had unearned Title IV aid that was not returned to the Federal Government, within 45 days of the determined withdrawal date, by 99-235 days. Cause The College did not consistently follow the procedures in place to monitor student withdrawals related to Title IV funds that must be returned to the Department of Education within 45 days due to delay between student’s withdrawal date and the date in which return was moved to financing department. Effect The College did not return unearned Title IV funds within the required 45-day time frame. Questioned Costs Not applicable Perspective Our sample was not, and was not intended to be, statistically valid. Of the 10 students selected for testing, 5 students, or 50% of our sample, had unearned Title IV funds that were not returned to the Department of Education within the 45-day required time frame. Identification as a Repeat Finding, if applicable See finding 2023-005 included in the summary schedule of prior year findings. Recommendation The College should strengthen their controls surrounding the review Return of Title IV calculations in a timely manner to ensure that all funds are returned to the Department of Education within the required time frame. 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.

Criteria According to 34 CFR 668.22(j)(1): Timeframe for the return of title IV funds. An institution must return the amount of title IV funds for which it is responsible under paragraph (g) of this section as soon as possible but no later than 45 days after the date of the institution's determination that the student withdrew as defined in paragraph (l)(3) of this section. According to 34 CFR 668.173(b): Timely return of Title IV, HEA program funds. In accordance with procedures established by the Secretary or Federal Family Education Loan (“FFEL”) program lender, an institution returns unearned Title IV, HEA program funds timely if – (1) The institution deposits or transfers the funds into the bank account it maintains under 34 CFR Sections 668.163 no later than 45 days after the date it determines the student withdrew; (2) The institution initiates an electronic funds transfer no later than 45 days after the date it determines that the student withdrew; (3) The institution initiates an electronic transaction no later than 45 days after the date it determines that the student withdrew, that informs a FFEL lender to adjust the borrower’s loan account for the amount returned; or (4) The institution issues a check no later than 45 days after the date it determines that the student withdrew. An institution does not satisfy this requirement if – (i) The institution’s records show that the check was issued more than 45 days after the date the institution determined the student withdrew; or (ii) The date on the cancelled check shows that the bank used by the Secretary or FFEL Program lender endorsed that check more than 60 days after the date the institution determined that the student withdrew. Condition Federal regulations state that any unearned Title IV grant or loan assistance received by a student must be refunded to the Title IV programs upon a student’s withdrawal from the institution. 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 5 students, out of a sample of 10, had unearned Title IV aid that was not returned to the Federal Government, within 45 days of the determined withdrawal date, by 99-235 days. Cause The College did not consistently follow the procedures in place to monitor student withdrawals related to Title IV funds that must be returned to the Department of Education within 45 days due to delay between student’s withdrawal date and the date in which return was moved to financing department. Effect The College did not return unearned Title IV funds within the required 45-day time frame. Questioned Costs Not applicable Perspective Our sample was not, and was not intended to be, statistically valid. Of the 10 students selected for testing, 5 students, or 50% of our sample, had unearned Title IV funds that were not returned to the Department of Education within the 45-day required time frame. Identification as a Repeat Finding, if applicable See finding 2023-005 included in the summary schedule of prior year findings. Recommendation The College should strengthen their controls surrounding the review Return of Title IV calculations in a timely manner to ensure that all funds are returned to the Department of Education within the required time frame. 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.

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 April 2018: 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 5 students, out of a sample of 10, that had incorrect effective dates reported to NSLDS. We noted 5 students, out of a sample of 10, were not reported to NSLDS within the required timeframe, and 2 out of a sample of 10, that were not reported at all to NSLDS. Cause The College did not have adequate procedures in place to ensure that students with status changes had their effective date correctly reported to NSLDS. For unofficial withdrawals, an administrative withdrawal form is completed once determined by the College. As the College is an attendance-taking institution, the College should have reported the students’ last date of attendance as the effective date, but instead used the date that the College completed withdrawal form as the effective date. Effect The College did not report the students’ correct status changes to NSLDS, which may impact the students’ loan grace periods and enrollment reporting statistics collected by the Department of Education. Questioned Costs Not applicable Perspective Our sample was not, and was not intended to be, statistically valid. Of the 10 students selected for testing, 5 students, or 50% of our sample, had incorrect effective dates reported to NSLDS. We also noted 5 students, were not reported within required timeframe of 60 days and 2 students, were not reported at all to NSLDS. Such instances reflect 50% and 20% of our population, respective Identification as a Repeat Finding, if applicable See finding 2023-007, 2023-008, and 2023-009 included in the summary schedule of prior year findings. 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 effective date of a student’s withdrawal, the importance of reporting the correct effective date and the consequences of incorrect reporting. Moreover, the College should emphasize the importance of distinguishing the last date of attendance (Activity Date) and completion date of Administrative Withdrawal Form (Date Completed). This oversight should also ensure that the effective date reported to NSLDS is consistent with the date the student separated from the College. 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.

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 April 2018: 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 5 students, out of a sample of 10, that had incorrect effective dates reported to NSLDS. We noted 5 students, out of a sample of 10, were not reported to NSLDS within the required timeframe, and 2 out of a sample of 10, that were not reported at all to NSLDS. Cause The College did not have adequate procedures in place to ensure that students with status changes had their effective date correctly reported to NSLDS. For unofficial withdrawals, an administrative withdrawal form is completed once determined by the College. As the College is an attendance-taking institution, the College should have reported the students’ last date of attendance as the effective date, but instead used the date that the College completed withdrawal form as the effective date. Effect The College did not report the students’ correct status changes to NSLDS, which may impact the students’ loan grace periods and enrollment reporting statistics collected by the Department of Education. Questioned Costs Not applicable Perspective Our sample was not, and was not intended to be, statistically valid. Of the 10 students selected for testing, 5 students, or 50% of our sample, had incorrect effective dates reported to NSLDS. We also noted 5 students, were not reported within required timeframe of 60 days and 2 students, were not reported at all to NSLDS. Such instances reflect 50% and 20% of our population, respective Identification as a Repeat Finding, if applicable See finding 2023-007, 2023-008, and 2023-009 included in the summary schedule of prior year findings. 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 effective date of a student’s withdrawal, the importance of reporting the correct effective date and the consequences of incorrect reporting. Moreover, the College should emphasize the importance of distinguishing the last date of attendance (Activity Date) and completion date of Administrative Withdrawal Form (Date Completed). This oversight should also ensure that the effective date reported to NSLDS is consistent with the date the student separated from the College. 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.

Criteria According to 34 CFR 668.164(h): Title IV, Higher Education Act (“HEA”) credit balances. (1) A title IV, HEA credit balance occurs whenever the amount of title IV, HEA program funds credited to a student's ledger account for a payment period exceeds the amount assessed the student for allowable charges associated with that payment period. (2) A title IV, HEA credit balance must be paid directly to the student or parent as soon as possible, but – (i) No later than 14 days after the balance occurred if the balance occurred after the first day of class of a payment period; or (ii) No later than 14 days after the first day of class of a payment period if the credit balance occurred on or before the first day of that payment period. Condition The Federal Government requires that whenever Title IV aid is disbursed on a student’s account, the account must be reviewed to determine if the disbursement caused a credit balance. If the credit balance was caused by Title IV funds, the College must refund the balance directly to the student within 14 days of the disbursement of funds. During our testing, we noted 29 students, out of a sample of 60, that were not refunded credit balances within the required timeframe by 8-251 days. Cause The College failed to identify and return Title IV credit balances within required timeframe due to lack of procedures and knowledge of compliance requirements over Student Financial Assistance requirements within business office. Effect The College did not refund Title IV credit balances within the required 14-day time frame and therefore was not in compliance with federal requirements. Questioned Costs Not applicable Perspective Our sample was not, and was not intended to be, statistically valid. Of the 60 students selected for testing, 44 students, or 73% of our sample, had credit balances caused by financial aid. Of these 44 students, 29 students’ credit balances caused by Title IV funds were not refunded within the required time frame (65.9% of students who had credit balances). The remaining 15 students had credit balances as a result of Title IV aid, which were returned within the required time frame. Identification as a Repeat Finding, if applicable See finding 2023-001 included in the summary schedule of prior year findings. Recommendation The Business Office should continue to develop their procedures to identify credit balances caused by changes on students’ accounts as well as disbursements. This includes reviewing accounts after late disbursement of Title IV aid as well as tuition and fee adjustments, health insurance waivers and bookstore credits. Moreover, the College should provide training to employees responsible for processing such information over student accounts to ensure personnel have adequate knowledge in the related rules and regulations. 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.

Criteria According to 34 CFR 668.164(h): Title IV, Higher Education Act (“HEA”) credit balances. (1) A title IV, HEA credit balance occurs whenever the amount of title IV, HEA program funds credited to a student's ledger account for a payment period exceeds the amount assessed the student for allowable charges associated with that payment period. (2) A title IV, HEA credit balance must be paid directly to the student or parent as soon as possible, but – (i) No later than 14 days after the balance occurred if the balance occurred after the first day of class of a payment period; or (ii) No later than 14 days after the first day of class of a payment period if the credit balance occurred on or before the first day of that payment period. Condition The Federal Government requires that whenever Title IV aid is disbursed on a student’s account, the account must be reviewed to determine if the disbursement caused a credit balance. If the credit balance was caused by Title IV funds, the College must refund the balance directly to the student within 14 days of the disbursement of funds. During our testing, we noted 29 students, out of a sample of 60, that were not refunded credit balances within the required timeframe by 8-251 days. Cause The College failed to identify and return Title IV credit balances within required timeframe due to lack of procedures and knowledge of compliance requirements over Student Financial Assistance requirements within business office. Effect The College did not refund Title IV credit balances within the required 14-day time frame and therefore was not in compliance with federal requirements. Questioned Costs Not applicable Perspective Our sample was not, and was not intended to be, statistically valid. Of the 60 students selected for testing, 44 students, or 73% of our sample, had credit balances caused by financial aid. Of these 44 students, 29 students’ credit balances caused by Title IV funds were not refunded within the required time frame (65.9% of students who had credit balances). The remaining 15 students had credit balances as a result of Title IV aid, which were returned within the required time frame. Identification as a Repeat Finding, if applicable See finding 2023-001 included in the summary schedule of prior year findings. Recommendation The Business Office should continue to develop their procedures to identify credit balances caused by changes on students’ accounts as well as disbursements. This includes reviewing accounts after late disbursement of Title IV aid as well as tuition and fee adjustments, health insurance waivers and bookstore credits. Moreover, the College should provide training to employees responsible for processing such information over student accounts to ensure personnel have adequate knowledge in the related rules and regulations. 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.

Criteria According to 34 CFR 668.164(h): Title IV, Higher Education Act (“HEA”) credit balances. (1) A title IV, HEA credit balance occurs whenever the amount of title IV, HEA program funds credited to a student's ledger account for a payment period exceeds the amount assessed the student for allowable charges associated with that payment period. (2) A title IV, HEA credit balance must be paid directly to the student or parent as soon as possible, but – (i) No later than 14 days after the balance occurred if the balance occurred after the first day of class of a payment period; or (ii) No later than 14 days after the first day of class of a payment period if the credit balance occurred on or before the first day of that payment period. Condition The Federal Government requires that whenever Title IV aid is disbursed on a student’s account, the account must be reviewed to determine if the disbursement caused a credit balance. If the credit balance was caused by Title IV funds, the College must refund the balance directly to the student within 14 days of the disbursement of funds. During our testing, we noted 29 students, out of a sample of 60, that were not refunded credit balances within the required timeframe by 8-251 days. Cause The College failed to identify and return Title IV credit balances within required timeframe due to lack of procedures and knowledge of compliance requirements over Student Financial Assistance requirements within business office. Effect The College did not refund Title IV credit balances within the required 14-day time frame and therefore was not in compliance with federal requirements. Questioned Costs Not applicable Perspective Our sample was not, and was not intended to be, statistically valid. Of the 60 students selected for testing, 44 students, or 73% of our sample, had credit balances caused by financial aid. Of these 44 students, 29 students’ credit balances caused by Title IV funds were not refunded within the required time frame (65.9% of students who had credit balances). The remaining 15 students had credit balances as a result of Title IV aid, which were returned within the required time frame. Identification as a Repeat Finding, if applicable See finding 2023-001 included in the summary schedule of prior year findings. Recommendation The Business Office should continue to develop their procedures to identify credit balances caused by changes on students’ accounts as well as disbursements. This includes reviewing accounts after late disbursement of Title IV aid as well as tuition and fee adjustments, health insurance waivers and bookstore credits. Moreover, the College should provide training to employees responsible for processing such information over student accounts to ensure personnel have adequate knowledge in the related rules and regulations. 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.

Criteria According to 34 CFR 690.83(b) (1) An institution shall report to the Secretary any change for which a student qualifies including any related Payment Data changes by submitting to the Secretary the student’s Payment Data that discloses the basis and result of the change in award for each student. The institution shall submit the student’s Payment Data reporting any to the Secretary by the reporting deadlines published by the Secretary in the Federal Register. (2) An institution shall submit, in accordance with the deadline dates established by the Secretary, through publication in the Federal Register, other reports and information the Secretary requires and shall comply with the procedures the Secretary finds necessary to ensure that the reports are correct. According to the Federal Register (Volume 88, Number 120): An institution must submit Pell Grant, Iraq and Afghanistan Service Grant, Direct Loan, and TEACH Grant disbursement records to COD, no later than 15 days after making the disbursement or becoming aware of the need to adjust a previously reported disbursement. In accordance with 34 CFR 668.164(a), title IV, Higher Education Act (“HEA”) program funds are disbursed on the date that the institution: (a) Credits those funds to a student’s account in the institution’s general ledger or any subledger of the general ledger; or (b) pays those funds to a student directly. Title IV, HEA program funds are disbursed even if an institution uses its own funds in advance of receiving program funds from the Department. Condition Federal regulations require the College to report to the Federal Government’s Common Origination and Disbursement System (“COD”) disbursements made to students accurately based on date award was credited to student directly. During our testing, we noted 51 students, out of a sample of 60, was not reported accurately to Common Origination System based on disbursement date per College records. Cause The College has policies and procedures in place to report the disbursement records to the Department of Education through the COD are recorded accurately, however, in this case the procedures were not completed properly. Cause due to transition and change in processes as the College has contracted service organization to assist in cash management. The College was not aware that there was a +1 day needed to be added to student accounts from check register provided by service organization, causing variance between actual disbursement date and disbursement date per COD. Effect The College did not report Pell disbursements to COD accurately based on College records. Questioned Costs Not applicable Perspective Our sample was not, and was not intended to be, statistically valid. Of the 60 students selected for testing, 51 students, or 85% of our sample, had disbursement information not recorded. Identification as a Repeat Finding, if applicable See finding 2023-002 included in the summary schedule of prior year findings. Recommendation We recommend that management of the College review, and if necessary, update the policies and procedures to ensure all Direct Loan funds disbursed are reported accurately based on when awards were credited to student account. View of Responsible Officials The College agrees with the finding and has implemented the corrective action plan within the management corrective action plan section of this report.

Criteria According to 34 CFR 690.83(b) (1) An institution shall report to the Secretary any change for which a student qualifies including any related Payment Data changes by submitting to the Secretary the student’s Payment Data that discloses the basis and result of the change in award for each student. The institution shall submit the student’s Payment Data reporting any to the Secretary by the reporting deadlines published by the Secretary in the Federal Register. (2) An institution shall submit, in accordance with the deadline dates established by the Secretary, through publication in the Federal Register, other reports and information the Secretary requires and shall comply with the procedures the Secretary finds necessary to ensure that the reports are correct. According to the Federal Register (Volume 88, Number 120): An institution must submit Pell Grant, Iraq and Afghanistan Service Grant, Direct Loan, and TEACH Grant disbursement records to COD, no later than 15 days after making the disbursement or becoming aware of the need to adjust a previously reported disbursement. In accordance with 34 CFR 668.164(a), title IV, Higher Education Act (“HEA”) program funds are disbursed on the date that the institution: (a) Credits those funds to a student’s account in the institution’s general ledger or any subledger of the general ledger; or (b) pays those funds to a student directly. Title IV, HEA program funds are disbursed even if an institution uses its own funds in advance of receiving program funds from the Department. Condition Federal regulations require the College to report to the Federal Government’s Common Origination and Disbursement System (“COD”) disbursements made to students accurately based on date award was credited to student directly. During our testing, we noted 51 students, out of a sample of 60, was not reported accurately to Common Origination System based on disbursement date per College records. Cause The College has policies and procedures in place to report the disbursement records to the Department of Education through the COD are recorded accurately, however, in this case the procedures were not completed properly. Cause due to transition and change in processes as the College has contracted service organization to assist in cash management. The College was not aware that there was a +1 day needed to be added to student accounts from check register provided by service organization, causing variance between actual disbursement date and disbursement date per COD. Effect The College did not report Pell disbursements to COD accurately based on College records. Questioned Costs Not applicable Perspective Our sample was not, and was not intended to be, statistically valid. Of the 60 students selected for testing, 51 students, or 85% of our sample, had disbursement information not recorded. Identification as a Repeat Finding, if applicable See finding 2023-002 included in the summary schedule of prior year findings. Recommendation We recommend that management of the College review, and if necessary, update the policies and procedures to ensure all Direct Loan funds disbursed are reported accurately based on when awards were credited to student account. View of Responsible Officials The College agrees with the finding and has implemented the corrective action plan within the management corrective action plan section of this report.

Criteria According to 34 CFR 668.164(l): (1) Notwithstanding any State law (such as a law that allows funds to escheat to the State), an institution must return to the Secretary any title IV, Higher Education Act (“HEA”) program funds, except Federal Work Study (“FWS”) program funds, that it attempts to disburse directly to a student or parent that are not received by the student or parent. For FWS program funds, the institution is required to return only the Federal portion of the payroll disbursement. (2) If an EFT to a student's or parent's financial account is rejected, or a check to a student or parent is returned, the institution may make additional attempts to disburse the funds, provided that those attempts are made not later than 45 days after the EFT was rejected or the check returned. In cases where the institution does not make another attempt, the funds must be returned to the Secretary before the end of this 45-day period. (3) If a check sent to a student or parent is not returned to the institution but is not cashed, the institution must return the funds to the Secretary no later than 240 days after the date it issued the check. Condition Federal regulations require an institution to return unclaimed Title IV funds issued by check or EFT within 240 days. During our testing, we noted 9 students, out of a sample of 13, that had unclaimed funds exceeding the federal day limit by 64-717 days. Cause Accounts are reviewed and reconciled routinely. However, the College did not monitor outstanding checks or unclaimed funds over 240-days due to Title IV as the business office was not aware of 240-day timeframe to require unclaimed Title IV funds. Effect The College did not return Title IV unclaimed funds to the Department of Education within the required 240-day time frame. Questioned Costs There were 9 outstanding checks totaling $986, which pertained specifically to federal-sourced funds. Perspective Our sample was not, and was not intended to be, statistically valid. Of the 13 students selected for testing, 9 students, or 69.23% of our sample, had unclaimed funds pertaining to federal sources that were not returned to the Department of Education within the 240-day required time frame. Identification as a Repeat Finding, if applicable See finding 2023-003 included in the summary schedule of prior year findings. Recommendation The College should examine its policies and procedures related to unclaimed funds including the process and time frame for identifying aged balances and the process for cancelling checks and returning funds to the Department of Education. Moreover, the College should provide training to employees responsible for reviewing and processing information to ensure that they have adequate knowledge in the related rules and regulations. 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.

Criteria According to 34 CFR 668.164(l): (1) Notwithstanding any State law (such as a law that allows funds to escheat to the State), an institution must return to the Secretary any title IV, Higher Education Act (“HEA”) program funds, except Federal Work Study (“FWS”) program funds, that it attempts to disburse directly to a student or parent that are not received by the student or parent. For FWS program funds, the institution is required to return only the Federal portion of the payroll disbursement. (2) If an EFT to a student's or parent's financial account is rejected, or a check to a student or parent is returned, the institution may make additional attempts to disburse the funds, provided that those attempts are made not later than 45 days after the EFT was rejected or the check returned. In cases where the institution does not make another attempt, the funds must be returned to the Secretary before the end of this 45-day period. (3) If a check sent to a student or parent is not returned to the institution but is not cashed, the institution must return the funds to the Secretary no later than 240 days after the date it issued the check. Condition Federal regulations require an institution to return unclaimed Title IV funds issued by check or EFT within 240 days. During our testing, we noted 9 students, out of a sample of 13, that had unclaimed funds exceeding the federal day limit by 64-717 days. Cause Accounts are reviewed and reconciled routinely. However, the College did not monitor outstanding checks or unclaimed funds over 240-days due to Title IV as the business office was not aware of 240-day timeframe to require unclaimed Title IV funds. Effect The College did not return Title IV unclaimed funds to the Department of Education within the required 240-day time frame. Questioned Costs There were 9 outstanding checks totaling $986, which pertained specifically to federal-sourced funds. Perspective Our sample was not, and was not intended to be, statistically valid. Of the 13 students selected for testing, 9 students, or 69.23% of our sample, had unclaimed funds pertaining to federal sources that were not returned to the Department of Education within the 240-day required time frame. Identification as a Repeat Finding, if applicable See finding 2023-003 included in the summary schedule of prior year findings. Recommendation The College should examine its policies and procedures related to unclaimed funds including the process and time frame for identifying aged balances and the process for cancelling checks and returning funds to the Department of Education. Moreover, the College should provide training to employees responsible for reviewing and processing information to ensure that they have adequate knowledge in the related rules and regulations. 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.

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 2 students, out of a sample of 10, 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. Effect The College did not return the correct amount of Title IV funds to the Department of Education. Questioned Costs $16.18 Perspective Our sample was not, and was not intended to be, statistically valid. Of the 10 students selected for testing, 2 students, or 20% 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

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 2 students, out of a sample of 10, 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. Effect The College did not return the correct amount of Title IV funds to the Department of Education. Questioned Costs $16.18 Perspective Our sample was not, and was not intended to be, statistically valid. Of the 10 students selected for testing, 2 students, or 20% 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

Criteria According to 34 CFR 668.22(j)(1): Timeframe for the return of title IV funds. An institution must return the amount of title IV funds for which it is responsible under paragraph (g) of this section as soon as possible but no later than 45 days after the date of the institution's determination that the student withdrew as defined in paragraph (l)(3) of this section. According to 34 CFR 668.173(b): Timely return of Title IV, HEA program funds. In accordance with procedures established by the Secretary or Federal Family Education Loan (“FFEL”) program lender, an institution returns unearned Title IV, HEA program funds timely if – (1) The institution deposits or transfers the funds into the bank account it maintains under 34 CFR Sections 668.163 no later than 45 days after the date it determines the student withdrew; (2) The institution initiates an electronic funds transfer no later than 45 days after the date it determines that the student withdrew; (3) The institution initiates an electronic transaction no later than 45 days after the date it determines that the student withdrew, that informs a FFEL lender to adjust the borrower’s loan account for the amount returned; or (4) The institution issues a check no later than 45 days after the date it determines that the student withdrew. An institution does not satisfy this requirement if – (i) The institution’s records show that the check was issued more than 45 days after the date the institution determined the student withdrew; or (ii) The date on the cancelled check shows that the bank used by the Secretary or FFEL Program lender endorsed that check more than 60 days after the date the institution determined that the student withdrew. Condition Federal regulations state that any unearned Title IV grant or loan assistance received by a student must be refunded to the Title IV programs upon a student’s withdrawal from the institution. 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 5 students, out of a sample of 10, had unearned Title IV aid that was not returned to the Federal Government, within 45 days of the determined withdrawal date, by 99-235 days. Cause The College did not consistently follow the procedures in place to monitor student withdrawals related to Title IV funds that must be returned to the Department of Education within 45 days due to delay between student’s withdrawal date and the date in which return was moved to financing department. Effect The College did not return unearned Title IV funds within the required 45-day time frame. Questioned Costs Not applicable Perspective Our sample was not, and was not intended to be, statistically valid. Of the 10 students selected for testing, 5 students, or 50% of our sample, had unearned Title IV funds that were not returned to the Department of Education within the 45-day required time frame. Identification as a Repeat Finding, if applicable See finding 2023-005 included in the summary schedule of prior year findings. Recommendation The College should strengthen their controls surrounding the review Return of Title IV calculations in a timely manner to ensure that all funds are returned to the Department of Education within the required time frame. 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.

Criteria According to 34 CFR 668.22(j)(1): Timeframe for the return of title IV funds. An institution must return the amount of title IV funds for which it is responsible under paragraph (g) of this section as soon as possible but no later than 45 days after the date of the institution's determination that the student withdrew as defined in paragraph (l)(3) of this section. According to 34 CFR 668.173(b): Timely return of Title IV, HEA program funds. In accordance with procedures established by the Secretary or Federal Family Education Loan (“FFEL”) program lender, an institution returns unearned Title IV, HEA program funds timely if – (1) The institution deposits or transfers the funds into the bank account it maintains under 34 CFR Sections 668.163 no later than 45 days after the date it determines the student withdrew; (2) The institution initiates an electronic funds transfer no later than 45 days after the date it determines that the student withdrew; (3) The institution initiates an electronic transaction no later than 45 days after the date it determines that the student withdrew, that informs a FFEL lender to adjust the borrower’s loan account for the amount returned; or (4) The institution issues a check no later than 45 days after the date it determines that the student withdrew. An institution does not satisfy this requirement if – (i) The institution’s records show that the check was issued more than 45 days after the date the institution determined the student withdrew; or (ii) The date on the cancelled check shows that the bank used by the Secretary or FFEL Program lender endorsed that check more than 60 days after the date the institution determined that the student withdrew. Condition Federal regulations state that any unearned Title IV grant or loan assistance received by a student must be refunded to the Title IV programs upon a student’s withdrawal from the institution. 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 5 students, out of a sample of 10, had unearned Title IV aid that was not returned to the Federal Government, within 45 days of the determined withdrawal date, by 99-235 days. Cause The College did not consistently follow the procedures in place to monitor student withdrawals related to Title IV funds that must be returned to the Department of Education within 45 days due to delay between student’s withdrawal date and the date in which return was moved to financing department. Effect The College did not return unearned Title IV funds within the required 45-day time frame. Questioned Costs Not applicable Perspective Our sample was not, and was not intended to be, statistically valid. Of the 10 students selected for testing, 5 students, or 50% of our sample, had unearned Title IV funds that were not returned to the Department of Education within the 45-day required time frame. Identification as a Repeat Finding, if applicable See finding 2023-005 included in the summary schedule of prior year findings. Recommendation The College should strengthen their controls surrounding the review Return of Title IV calculations in a timely manner to ensure that all funds are returned to the Department of Education within the required time frame. 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.

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 April 2018: 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 5 students, out of a sample of 10, that had incorrect effective dates reported to NSLDS. We noted 5 students, out of a sample of 10, were not reported to NSLDS within the required timeframe, and 2 out of a sample of 10, that were not reported at all to NSLDS. Cause The College did not have adequate procedures in place to ensure that students with status changes had their effective date correctly reported to NSLDS. For unofficial withdrawals, an administrative withdrawal form is completed once determined by the College. As the College is an attendance-taking institution, the College should have reported the students’ last date of attendance as the effective date, but instead used the date that the College completed withdrawal form as the effective date. Effect The College did not report the students’ correct status changes to NSLDS, which may impact the students’ loan grace periods and enrollment reporting statistics collected by the Department of Education. Questioned Costs Not applicable Perspective Our sample was not, and was not intended to be, statistically valid. Of the 10 students selected for testing, 5 students, or 50% of our sample, had incorrect effective dates reported to NSLDS. We also noted 5 students, were not reported within required timeframe of 60 days and 2 students, were not reported at all to NSLDS. Such instances reflect 50% and 20% of our population, respective Identification as a Repeat Finding, if applicable See finding 2023-007, 2023-008, and 2023-009 included in the summary schedule of prior year findings. 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 effective date of a student’s withdrawal, the importance of reporting the correct effective date and the consequences of incorrect reporting. Moreover, the College should emphasize the importance of distinguishing the last date of attendance (Activity Date) and completion date of Administrative Withdrawal Form (Date Completed). This oversight should also ensure that the effective date reported to NSLDS is consistent with the date the student separated from the College. 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.

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 April 2018: 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 5 students, out of a sample of 10, that had incorrect effective dates reported to NSLDS. We noted 5 students, out of a sample of 10, were not reported to NSLDS within the required timeframe, and 2 out of a sample of 10, that were not reported at all to NSLDS. Cause The College did not have adequate procedures in place to ensure that students with status changes had their effective date correctly reported to NSLDS. For unofficial withdrawals, an administrative withdrawal form is completed once determined by the College. As the College is an attendance-taking institution, the College should have reported the students’ last date of attendance as the effective date, but instead used the date that the College completed withdrawal form as the effective date. Effect The College did not report the students’ correct status changes to NSLDS, which may impact the students’ loan grace periods and enrollment reporting statistics collected by the Department of Education. Questioned Costs Not applicable Perspective Our sample was not, and was not intended to be, statistically valid. Of the 10 students selected for testing, 5 students, or 50% of our sample, had incorrect effective dates reported to NSLDS. We also noted 5 students, were not reported within required timeframe of 60 days and 2 students, were not reported at all to NSLDS. Such instances reflect 50% and 20% of our population, respective Identification as a Repeat Finding, if applicable See finding 2023-007, 2023-008, and 2023-009 included in the summary schedule of prior year findings. 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 effective date of a student’s withdrawal, the importance of reporting the correct effective date and the consequences of incorrect reporting. Moreover, the College should emphasize the importance of distinguishing the last date of attendance (Activity Date) and completion date of Administrative Withdrawal Form (Date Completed). This oversight should also ensure that the effective date reported to NSLDS is consistent with the date the student separated from the College. 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.