Audit 355581

Special Tests and Provisions – Return to Title IV Student Financial Assistance Cluster – AL 84.007, 84,063 and 84.268 US Department of Education Significant Deficiency and Nonmaterial Noncompliance Criteria or specific requirements 34 CFR section 668.173(b) Returns of Title IV funds are required to be deposited or transferred into the SFA account or electronic fund transfers initiated to ED as soon as possible, but no later than 45 days after the date the institution determines that the student withdrew. Returns by check are late if the check is issued more than 45 days after the institution determined the student withdrew or the date on the canceled check shows the check was endorsed more than 60 days after the date the institution determined that the student withdrew. 34 CFR section 668.22(j)(2): An institution must determine the withdrawal date for a student who withdraws without providing notification to the institution no later than 30 days after the end of the earlier of the (1) payment period or period of enrollment, (2) academic year in which the student withdrew, or (3) educational program from which the student withdrew. 34 CFR section 668.22(c): If an institution is not required to take attendance, the withdrawal date is (1) the date, as determined by the institution, that the student began the withdrawal process prescribed by the institution; (2) the date, as determined by the institution, that the student otherwise provided official notification to the school, in writing or orally, of his or her intent to withdraw; (3) if the student ceases attendance without providing official notification to the institution of his or her withdrawal, the midpoint of the payment period or, if applicable, the period of enrollment; (4) if the institution determines that a student did not begin the withdrawal process or otherwise notify the school of the intent to withdraw due to illness, accident, grievous personal loss or other circumstances beyond the student’s control, the date the institution determines is related to that circumstance; (5) if a student does not return from an approved leave of absence, the date that the institution determines the student began the leave of absence; or (6) if the student takes an unapproved leave of absence, the date that the student began the leave of absence. Condition During our procedures over Return to Title IV requirements, the following deficiencies were noted:  7 of 13 Return to Title IV calculations were performed outside of the allowable time frame.  1 of 13 withdrawn students did not have a Return to Title IV calculation performed.  2 of 6 instances where funds were returned beyond the required time frame. Cause The College did not implement procedures to ensure that the Return to Title IV funds were performed accurately and returned in a timely manner. Effect Without proper monitoring of accuracy and student withdrawal, the College risks noncompliance with the above criteria. Questioned costs None identified. While the determinations were performed late, no unreturned funds were noted. Context The college did not perform R2T4 calculations for students under the Pell grant and Direct Loan Programs timely. A nonstatistical sample of 13 withdrawn students out of 40 selected from the College’s total population. Identification as a repeat finding Previously reported as finding 2023-004. Recommendation The College should implement procedures to ensure that the student withdrawal calculations are preformed timely and return funds within 30 days from the end of the student’s period of enrollment. View of responsible officials and corrective action plan Management agrees with the finding. Please see separate Corrective Action Plan for procedures to be implemented.

Reporting Student Financial Assistance Cluster – AL 84.007, 84.063 and 84.268 US Department of Education Significant Deficiency and Nonmaterial Noncompliance Criteria or specific requirements 34 CFR 673.3: To participate in the FWS, or FSEOG programs, an institution shall file an application before the deadline date established annually by the Secretary through publication of a notice in the Federal Register. ED Form 646-1, Fiscal Operations Report and Application to Participate (FISAP) (OMB No. 1845-0030) – This electronic report is submitted annually to receive funds for the campus-based programs. The data is used in conjunction with institutional program reviews to assess the administrative capability and compliance of the College. Condition The College did not retain supporting evidence utilized for reporting certain critical information within the FISAP including:  Total number of students  Total tuition and fees  Information on eligible applicants Cause The College did not have a process in place to retain supporting documentation of figures within the report nor evidence of review of these reports. Effect The College is not in compliance with the Federal requirement described in the OMB Compliance Supplement. Questioned costs None identified. Context The College lacked evidence to support figures reported in the FISAP. Auditor examined key line items listed in the Compliance Supplement and was unable to trace 3 of 6 applicable items to supporting records. Identification as a repeat finding Previously reported as finding 2023-005. Recommendation It is recommended the College should establish effective controls and processes to ensure that reporting of FISAP figures are properly supported and any evidence of review is maintained. View of responsible officials and corrective action plan Management agrees with the finding. Please see separate Corrective Action Plan for procedures to be implemented.

Special Tests and Provisions – Disbursements to or on Behalf of Students Student Financial Assistance Cluster – AL 84.007, 84.063 and 84.268 US Department of Education Significant Deficiency and Nonmaterial Noncompliance Criteria or specific requirements 34 CFR 668.164(h)(2): A Title IV, HEA credit balance must be paid directly to the student or parent as soon as possible, but no later than (i) Fourteen (14) days after the balance occurred if the credit balance occurred after the first day of class of a payment period; or (ii) Fourteen (14) days after the first day of class of a payment period if the credit balance occurred on or before the first day of class of that payment period. Condition During our testing over the return of credit balances, the following deficiencies were noted:  8 instances where credit balances were not refunded in the required time frame.  11 instances where refunds were due to students but none were posted in the ledger.  7 instances where the balances refunded to students could not be recalculated. Cause The College did not comply with Federal disbursement requirements for students under the Pell Grant and Direct Loan programs. Effect The College is not in compliance with the Federal requirement described in the OMB Compliance Supplement. Questioned costs None identified. Context The College contracts with a third-party servicer to perform one or more of the functions associated with disbursing Title IV funds on behalf of the school. A nonstatistical sample of 40 students out of 514 students were selected for disbursement testing. Identification as a repeat finding Previously reported as finding 2023-006. Recommendation It is recommended the College should establish effective controls and processes to ensure that accurate credit balances are refunded to students in a timely manner. View of responsible officials and corrective action plan Management agrees with the finding. Please see separate Corrective Action Plan for procedures to be implemented.

Special Tests and Provisions – Enrollment Reporting Student Financial Assistance Cluster – AL 84.007, 84.063 and 84.268 US Department of Education Significant Deficiency and Nonmaterial Noncompliance Criteria or specific requirements OMB Compliance Supplement, OMB No. 1845-0035 – Institutions are required to report enrollment information under the Pell grant and the Direct and FFEL loan programs via the National Student Loan Data System (NSLDS). Institutions must review, update, and verify student enrollment statuses, program information, and effective dates that appear on the Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS Professional Access (NSLDSFAP) website which the financial aid administrator can access for the auditor. The data on the institutions’ Enrollment Reporting Roster, or Enrollment Maintenance page, is what NSLDS has as the most recently certified enrollment information. There are two categories of enrollment information: “Campus Level” and “Program Level”, both of which need to be reported accurately and have separate record types. The NSLDS Enrollment Reporting Guide provides the requirements and guidance for reporting enrollment details using the NSLDS Enrollment Reporting Process. Condition During our testing over the NSLDS reporting requirements, the following deficiencies were noted:  3 of 50 program reporting details did not agree to enrollment details from the enrollment records per the College.  24 of 40 students did not have campus reporting completed within the required timeframe. Cause The College did not report enrollment information for students under the Pell Grant and Direct Loan Programs via NSLDS timely and accurately. Effect The College is not in compliance with the Federal enrollment reporting requirements described in the OMB Compliance Supplement. Questioned costs None identified. Context The College disbursed financial aid to approximately 514 students that required student enrollment and program enrollment reporting to NSLDS. A nonstatistical sample of 40 students out of 514 students were selected for enrollment reporting testing. Identification as a repeat finding Previously reported as 2023-007. Recommendation The College should implement a process to review, update, and verify student enrollment statuses, program information, and effective dates that appear on the Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS Professional Access (NSLDSFAP) website. View of responsible officials and corrective action plan Management agrees with the finding. Please see separate Corrective Action Plan for procedures to be implemented.

Cash Management – Monthly Reconciliations for Direct Loans Student Financial Assistance Cluster – AL 84.007, 84.063 and 84.268 US Department of Education Significant Deficiency and Nonmaterial Noncompliance Criteria or specific requirements Per 34 CFR 685.300(b)(5), on a monthly basis, the College must reconcile institutional records with the Direct Loan funds received from the Secretary and Direct Loan disbursement records submitted to and accepted by the Secretary. Each month, Common Origination and Disbursement (COD) sends the College a School Account Statement, which is ED’s official record of the College’s cash and disbursement records and identifies the difference between the net draws from G5 and the actual disbursement information reported to COD by the College. The College is required to account for any differences by reconciling ED’s records (School Account Statements) with the College’s financial and business records. Condition During our testing, the College was unable to provide evidence of these Direct Loan reconciliations being performed monthly. Cause The College did not have processes and procedures in place to adequately document the monthly Direct Loan reconciliations. Effect The College is not in compliance with the monthly reconciliation requirements described in 34 CFR 685.300 and the OMB Compliance Supplement. Questioned Costs None Context As part of our audit procedures, we requested all 12 monthly reconciliations for the year under audit. The College was unable to provide evidence of these reconciliations being performed or documented. Identification as a repeat finding This is a new finding for fiscal year 2024. Recommendation The College should implement a process for timely review and approval of monthly Direct Loan reconciliations using the statements provided by COD. View of responsible officials and corrective action plan Management agrees with the finding. Please see separate Corrective Action Plan for procedures to be implemented.

Special Tests and Provisions – Return to Title IV Student Financial Assistance Cluster – AL 84.007, 84,063 and 84.268 US Department of Education Significant Deficiency and Nonmaterial Noncompliance Criteria or specific requirements 34 CFR section 668.173(b) Returns of Title IV funds are required to be deposited or transferred into the SFA account or electronic fund transfers initiated to ED as soon as possible, but no later than 45 days after the date the institution determines that the student withdrew. Returns by check are late if the check is issued more than 45 days after the institution determined the student withdrew or the date on the canceled check shows the check was endorsed more than 60 days after the date the institution determined that the student withdrew. 34 CFR section 668.22(j)(2): An institution must determine the withdrawal date for a student who withdraws without providing notification to the institution no later than 30 days after the end of the earlier of the (1) payment period or period of enrollment, (2) academic year in which the student withdrew, or (3) educational program from which the student withdrew. 34 CFR section 668.22(c): If an institution is not required to take attendance, the withdrawal date is (1) the date, as determined by the institution, that the student began the withdrawal process prescribed by the institution; (2) the date, as determined by the institution, that the student otherwise provided official notification to the school, in writing or orally, of his or her intent to withdraw; (3) if the student ceases attendance without providing official notification to the institution of his or her withdrawal, the midpoint of the payment period or, if applicable, the period of enrollment; (4) if the institution determines that a student did not begin the withdrawal process or otherwise notify the school of the intent to withdraw due to illness, accident, grievous personal loss or other circumstances beyond the student’s control, the date the institution determines is related to that circumstance; (5) if a student does not return from an approved leave of absence, the date that the institution determines the student began the leave of absence; or (6) if the student takes an unapproved leave of absence, the date that the student began the leave of absence. Condition During our procedures over Return to Title IV requirements, the following deficiencies were noted:  7 of 13 Return to Title IV calculations were performed outside of the allowable time frame.  1 of 13 withdrawn students did not have a Return to Title IV calculation performed.  2 of 6 instances where funds were returned beyond the required time frame. Cause The College did not implement procedures to ensure that the Return to Title IV funds were performed accurately and returned in a timely manner. Effect Without proper monitoring of accuracy and student withdrawal, the College risks noncompliance with the above criteria. Questioned costs None identified. While the determinations were performed late, no unreturned funds were noted. Context The college did not perform R2T4 calculations for students under the Pell grant and Direct Loan Programs timely. A nonstatistical sample of 13 withdrawn students out of 40 selected from the College’s total population. Identification as a repeat finding Previously reported as finding 2023-004. Recommendation The College should implement procedures to ensure that the student withdrawal calculations are preformed timely and return funds within 30 days from the end of the student’s period of enrollment. View of responsible officials and corrective action plan Management agrees with the finding. Please see separate Corrective Action Plan for procedures to be implemented.

Reporting Student Financial Assistance Cluster – AL 84.007, 84.063 and 84.268 US Department of Education Significant Deficiency and Nonmaterial Noncompliance Criteria or specific requirements 34 CFR 673.3: To participate in the FWS, or FSEOG programs, an institution shall file an application before the deadline date established annually by the Secretary through publication of a notice in the Federal Register. ED Form 646-1, Fiscal Operations Report and Application to Participate (FISAP) (OMB No. 1845-0030) – This electronic report is submitted annually to receive funds for the campus-based programs. The data is used in conjunction with institutional program reviews to assess the administrative capability and compliance of the College. Condition The College did not retain supporting evidence utilized for reporting certain critical information within the FISAP including:  Total number of students  Total tuition and fees  Information on eligible applicants Cause The College did not have a process in place to retain supporting documentation of figures within the report nor evidence of review of these reports. Effect The College is not in compliance with the Federal requirement described in the OMB Compliance Supplement. Questioned costs None identified. Context The College lacked evidence to support figures reported in the FISAP. Auditor examined key line items listed in the Compliance Supplement and was unable to trace 3 of 6 applicable items to supporting records. Identification as a repeat finding Previously reported as finding 2023-005. Recommendation It is recommended the College should establish effective controls and processes to ensure that reporting of FISAP figures are properly supported and any evidence of review is maintained. View of responsible officials and corrective action plan Management agrees with the finding. Please see separate Corrective Action Plan for procedures to be implemented.

Special Tests and Provisions – Disbursements to or on Behalf of Students Student Financial Assistance Cluster – AL 84.007, 84.063 and 84.268 US Department of Education Significant Deficiency and Nonmaterial Noncompliance Criteria or specific requirements 34 CFR 668.164(h)(2): A Title IV, HEA credit balance must be paid directly to the student or parent as soon as possible, but no later than (i) Fourteen (14) days after the balance occurred if the credit balance occurred after the first day of class of a payment period; or (ii) Fourteen (14) days after the first day of class of a payment period if the credit balance occurred on or before the first day of class of that payment period. Condition During our testing over the return of credit balances, the following deficiencies were noted:  8 instances where credit balances were not refunded in the required time frame.  11 instances where refunds were due to students but none were posted in the ledger.  7 instances where the balances refunded to students could not be recalculated. Cause The College did not comply with Federal disbursement requirements for students under the Pell Grant and Direct Loan programs. Effect The College is not in compliance with the Federal requirement described in the OMB Compliance Supplement. Questioned costs None identified. Context The College contracts with a third-party servicer to perform one or more of the functions associated with disbursing Title IV funds on behalf of the school. A nonstatistical sample of 40 students out of 514 students were selected for disbursement testing. Identification as a repeat finding Previously reported as finding 2023-006. Recommendation It is recommended the College should establish effective controls and processes to ensure that accurate credit balances are refunded to students in a timely manner. View of responsible officials and corrective action plan Management agrees with the finding. Please see separate Corrective Action Plan for procedures to be implemented.

Special Tests and Provisions – Enrollment Reporting Student Financial Assistance Cluster – AL 84.007, 84.063 and 84.268 US Department of Education Significant Deficiency and Nonmaterial Noncompliance Criteria or specific requirements OMB Compliance Supplement, OMB No. 1845-0035 – Institutions are required to report enrollment information under the Pell grant and the Direct and FFEL loan programs via the National Student Loan Data System (NSLDS). Institutions must review, update, and verify student enrollment statuses, program information, and effective dates that appear on the Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS Professional Access (NSLDSFAP) website which the financial aid administrator can access for the auditor. The data on the institutions’ Enrollment Reporting Roster, or Enrollment Maintenance page, is what NSLDS has as the most recently certified enrollment information. There are two categories of enrollment information: “Campus Level” and “Program Level”, both of which need to be reported accurately and have separate record types. The NSLDS Enrollment Reporting Guide provides the requirements and guidance for reporting enrollment details using the NSLDS Enrollment Reporting Process. Condition During our testing over the NSLDS reporting requirements, the following deficiencies were noted:  3 of 50 program reporting details did not agree to enrollment details from the enrollment records per the College.  24 of 40 students did not have campus reporting completed within the required timeframe. Cause The College did not report enrollment information for students under the Pell Grant and Direct Loan Programs via NSLDS timely and accurately. Effect The College is not in compliance with the Federal enrollment reporting requirements described in the OMB Compliance Supplement. Questioned costs None identified. Context The College disbursed financial aid to approximately 514 students that required student enrollment and program enrollment reporting to NSLDS. A nonstatistical sample of 40 students out of 514 students were selected for enrollment reporting testing. Identification as a repeat finding Previously reported as 2023-007. Recommendation The College should implement a process to review, update, and verify student enrollment statuses, program information, and effective dates that appear on the Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS Professional Access (NSLDSFAP) website. View of responsible officials and corrective action plan Management agrees with the finding. Please see separate Corrective Action Plan for procedures to be implemented.

Cash Management – Monthly Reconciliations for Direct Loans Student Financial Assistance Cluster – AL 84.007, 84.063 and 84.268 US Department of Education Significant Deficiency and Nonmaterial Noncompliance Criteria or specific requirements Per 34 CFR 685.300(b)(5), on a monthly basis, the College must reconcile institutional records with the Direct Loan funds received from the Secretary and Direct Loan disbursement records submitted to and accepted by the Secretary. Each month, Common Origination and Disbursement (COD) sends the College a School Account Statement, which is ED’s official record of the College’s cash and disbursement records and identifies the difference between the net draws from G5 and the actual disbursement information reported to COD by the College. The College is required to account for any differences by reconciling ED’s records (School Account Statements) with the College’s financial and business records. Condition During our testing, the College was unable to provide evidence of these Direct Loan reconciliations being performed monthly. Cause The College did not have processes and procedures in place to adequately document the monthly Direct Loan reconciliations. Effect The College is not in compliance with the monthly reconciliation requirements described in 34 CFR 685.300 and the OMB Compliance Supplement. Questioned Costs None Context As part of our audit procedures, we requested all 12 monthly reconciliations for the year under audit. The College was unable to provide evidence of these reconciliations being performed or documented. Identification as a repeat finding This is a new finding for fiscal year 2024. Recommendation The College should implement a process for timely review and approval of monthly Direct Loan reconciliations using the statements provided by COD. View of responsible officials and corrective action plan Management agrees with the finding. Please see separate Corrective Action Plan for procedures to be implemented.

Special Tests and Provisions – Return to Title IV Student Financial Assistance Cluster – AL 84.007, 84,063 and 84.268 US Department of Education Significant Deficiency and Nonmaterial Noncompliance Criteria or specific requirements 34 CFR section 668.173(b) Returns of Title IV funds are required to be deposited or transferred into the SFA account or electronic fund transfers initiated to ED as soon as possible, but no later than 45 days after the date the institution determines that the student withdrew. Returns by check are late if the check is issued more than 45 days after the institution determined the student withdrew or the date on the canceled check shows the check was endorsed more than 60 days after the date the institution determined that the student withdrew. 34 CFR section 668.22(j)(2): An institution must determine the withdrawal date for a student who withdraws without providing notification to the institution no later than 30 days after the end of the earlier of the (1) payment period or period of enrollment, (2) academic year in which the student withdrew, or (3) educational program from which the student withdrew. 34 CFR section 668.22(c): If an institution is not required to take attendance, the withdrawal date is (1) the date, as determined by the institution, that the student began the withdrawal process prescribed by the institution; (2) the date, as determined by the institution, that the student otherwise provided official notification to the school, in writing or orally, of his or her intent to withdraw; (3) if the student ceases attendance without providing official notification to the institution of his or her withdrawal, the midpoint of the payment period or, if applicable, the period of enrollment; (4) if the institution determines that a student did not begin the withdrawal process or otherwise notify the school of the intent to withdraw due to illness, accident, grievous personal loss or other circumstances beyond the student’s control, the date the institution determines is related to that circumstance; (5) if a student does not return from an approved leave of absence, the date that the institution determines the student began the leave of absence; or (6) if the student takes an unapproved leave of absence, the date that the student began the leave of absence. Condition During our procedures over Return to Title IV requirements, the following deficiencies were noted:  7 of 13 Return to Title IV calculations were performed outside of the allowable time frame.  1 of 13 withdrawn students did not have a Return to Title IV calculation performed.  2 of 6 instances where funds were returned beyond the required time frame. Cause The College did not implement procedures to ensure that the Return to Title IV funds were performed accurately and returned in a timely manner. Effect Without proper monitoring of accuracy and student withdrawal, the College risks noncompliance with the above criteria. Questioned costs None identified. While the determinations were performed late, no unreturned funds were noted. Context The college did not perform R2T4 calculations for students under the Pell grant and Direct Loan Programs timely. A nonstatistical sample of 13 withdrawn students out of 40 selected from the College’s total population. Identification as a repeat finding Previously reported as finding 2023-004. Recommendation The College should implement procedures to ensure that the student withdrawal calculations are preformed timely and return funds within 30 days from the end of the student’s period of enrollment. View of responsible officials and corrective action plan Management agrees with the finding. Please see separate Corrective Action Plan for procedures to be implemented.

Reporting Student Financial Assistance Cluster – AL 84.007, 84.063 and 84.268 US Department of Education Significant Deficiency and Nonmaterial Noncompliance Criteria or specific requirements 34 CFR 673.3: To participate in the FWS, or FSEOG programs, an institution shall file an application before the deadline date established annually by the Secretary through publication of a notice in the Federal Register. ED Form 646-1, Fiscal Operations Report and Application to Participate (FISAP) (OMB No. 1845-0030) – This electronic report is submitted annually to receive funds for the campus-based programs. The data is used in conjunction with institutional program reviews to assess the administrative capability and compliance of the College. Condition The College did not retain supporting evidence utilized for reporting certain critical information within the FISAP including:  Total number of students  Total tuition and fees  Information on eligible applicants Cause The College did not have a process in place to retain supporting documentation of figures within the report nor evidence of review of these reports. Effect The College is not in compliance with the Federal requirement described in the OMB Compliance Supplement. Questioned costs None identified. Context The College lacked evidence to support figures reported in the FISAP. Auditor examined key line items listed in the Compliance Supplement and was unable to trace 3 of 6 applicable items to supporting records. Identification as a repeat finding Previously reported as finding 2023-005. Recommendation It is recommended the College should establish effective controls and processes to ensure that reporting of FISAP figures are properly supported and any evidence of review is maintained. View of responsible officials and corrective action plan Management agrees with the finding. Please see separate Corrective Action Plan for procedures to be implemented.

Special Tests and Provisions – Disbursements to or on Behalf of Students Student Financial Assistance Cluster – AL 84.007, 84.063 and 84.268 US Department of Education Significant Deficiency and Nonmaterial Noncompliance Criteria or specific requirements 34 CFR 668.164(h)(2): A Title IV, HEA credit balance must be paid directly to the student or parent as soon as possible, but no later than (i) Fourteen (14) days after the balance occurred if the credit balance occurred after the first day of class of a payment period; or (ii) Fourteen (14) days after the first day of class of a payment period if the credit balance occurred on or before the first day of class of that payment period. Condition During our testing over the return of credit balances, the following deficiencies were noted:  8 instances where credit balances were not refunded in the required time frame.  11 instances where refunds were due to students but none were posted in the ledger.  7 instances where the balances refunded to students could not be recalculated. Cause The College did not comply with Federal disbursement requirements for students under the Pell Grant and Direct Loan programs. Effect The College is not in compliance with the Federal requirement described in the OMB Compliance Supplement. Questioned costs None identified. Context The College contracts with a third-party servicer to perform one or more of the functions associated with disbursing Title IV funds on behalf of the school. A nonstatistical sample of 40 students out of 514 students were selected for disbursement testing. Identification as a repeat finding Previously reported as finding 2023-006. Recommendation It is recommended the College should establish effective controls and processes to ensure that accurate credit balances are refunded to students in a timely manner. View of responsible officials and corrective action plan Management agrees with the finding. Please see separate Corrective Action Plan for procedures to be implemented.

Special Tests and Provisions – Enrollment Reporting Student Financial Assistance Cluster – AL 84.007, 84.063 and 84.268 US Department of Education Significant Deficiency and Nonmaterial Noncompliance Criteria or specific requirements OMB Compliance Supplement, OMB No. 1845-0035 – Institutions are required to report enrollment information under the Pell grant and the Direct and FFEL loan programs via the National Student Loan Data System (NSLDS). Institutions must review, update, and verify student enrollment statuses, program information, and effective dates that appear on the Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS Professional Access (NSLDSFAP) website which the financial aid administrator can access for the auditor. The data on the institutions’ Enrollment Reporting Roster, or Enrollment Maintenance page, is what NSLDS has as the most recently certified enrollment information. There are two categories of enrollment information: “Campus Level” and “Program Level”, both of which need to be reported accurately and have separate record types. The NSLDS Enrollment Reporting Guide provides the requirements and guidance for reporting enrollment details using the NSLDS Enrollment Reporting Process. Condition During our testing over the NSLDS reporting requirements, the following deficiencies were noted:  3 of 50 program reporting details did not agree to enrollment details from the enrollment records per the College.  24 of 40 students did not have campus reporting completed within the required timeframe. Cause The College did not report enrollment information for students under the Pell Grant and Direct Loan Programs via NSLDS timely and accurately. Effect The College is not in compliance with the Federal enrollment reporting requirements described in the OMB Compliance Supplement. Questioned costs None identified. Context The College disbursed financial aid to approximately 514 students that required student enrollment and program enrollment reporting to NSLDS. A nonstatistical sample of 40 students out of 514 students were selected for enrollment reporting testing. Identification as a repeat finding Previously reported as 2023-007. Recommendation The College should implement a process to review, update, and verify student enrollment statuses, program information, and effective dates that appear on the Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS Professional Access (NSLDSFAP) website. View of responsible officials and corrective action plan Management agrees with the finding. Please see separate Corrective Action Plan for procedures to be implemented.

Cash Management – Monthly Reconciliations for Direct Loans Student Financial Assistance Cluster – AL 84.007, 84.063 and 84.268 US Department of Education Significant Deficiency and Nonmaterial Noncompliance Criteria or specific requirements Per 34 CFR 685.300(b)(5), on a monthly basis, the College must reconcile institutional records with the Direct Loan funds received from the Secretary and Direct Loan disbursement records submitted to and accepted by the Secretary. Each month, Common Origination and Disbursement (COD) sends the College a School Account Statement, which is ED’s official record of the College’s cash and disbursement records and identifies the difference between the net draws from G5 and the actual disbursement information reported to COD by the College. The College is required to account for any differences by reconciling ED’s records (School Account Statements) with the College’s financial and business records. Condition During our testing, the College was unable to provide evidence of these Direct Loan reconciliations being performed monthly. Cause The College did not have processes and procedures in place to adequately document the monthly Direct Loan reconciliations. Effect The College is not in compliance with the monthly reconciliation requirements described in 34 CFR 685.300 and the OMB Compliance Supplement. Questioned Costs None Context As part of our audit procedures, we requested all 12 monthly reconciliations for the year under audit. The College was unable to provide evidence of these reconciliations being performed or documented. Identification as a repeat finding This is a new finding for fiscal year 2024. Recommendation The College should implement a process for timely review and approval of monthly Direct Loan reconciliations using the statements provided by COD. View of responsible officials and corrective action plan Management agrees with the finding. Please see separate Corrective Action Plan for procedures to be implemented.

Special Tests and Provisions – Return to Title IV Student Financial Assistance Cluster – AL 84.007, 84,063 and 84.268 US Department of Education Significant Deficiency and Nonmaterial Noncompliance Criteria or specific requirements 34 CFR section 668.173(b) Returns of Title IV funds are required to be deposited or transferred into the SFA account or electronic fund transfers initiated to ED as soon as possible, but no later than 45 days after the date the institution determines that the student withdrew. Returns by check are late if the check is issued more than 45 days after the institution determined the student withdrew or the date on the canceled check shows the check was endorsed more than 60 days after the date the institution determined that the student withdrew. 34 CFR section 668.22(j)(2): An institution must determine the withdrawal date for a student who withdraws without providing notification to the institution no later than 30 days after the end of the earlier of the (1) payment period or period of enrollment, (2) academic year in which the student withdrew, or (3) educational program from which the student withdrew. 34 CFR section 668.22(c): If an institution is not required to take attendance, the withdrawal date is (1) the date, as determined by the institution, that the student began the withdrawal process prescribed by the institution; (2) the date, as determined by the institution, that the student otherwise provided official notification to the school, in writing or orally, of his or her intent to withdraw; (3) if the student ceases attendance without providing official notification to the institution of his or her withdrawal, the midpoint of the payment period or, if applicable, the period of enrollment; (4) if the institution determines that a student did not begin the withdrawal process or otherwise notify the school of the intent to withdraw due to illness, accident, grievous personal loss or other circumstances beyond the student’s control, the date the institution determines is related to that circumstance; (5) if a student does not return from an approved leave of absence, the date that the institution determines the student began the leave of absence; or (6) if the student takes an unapproved leave of absence, the date that the student began the leave of absence. Condition During our procedures over Return to Title IV requirements, the following deficiencies were noted:  7 of 13 Return to Title IV calculations were performed outside of the allowable time frame.  1 of 13 withdrawn students did not have a Return to Title IV calculation performed.  2 of 6 instances where funds were returned beyond the required time frame. Cause The College did not implement procedures to ensure that the Return to Title IV funds were performed accurately and returned in a timely manner. Effect Without proper monitoring of accuracy and student withdrawal, the College risks noncompliance with the above criteria. Questioned costs None identified. While the determinations were performed late, no unreturned funds were noted. Context The college did not perform R2T4 calculations for students under the Pell grant and Direct Loan Programs timely. A nonstatistical sample of 13 withdrawn students out of 40 selected from the College’s total population. Identification as a repeat finding Previously reported as finding 2023-004. Recommendation The College should implement procedures to ensure that the student withdrawal calculations are preformed timely and return funds within 30 days from the end of the student’s period of enrollment. View of responsible officials and corrective action plan Management agrees with the finding. Please see separate Corrective Action Plan for procedures to be implemented.

Reporting Student Financial Assistance Cluster – AL 84.007, 84.063 and 84.268 US Department of Education Significant Deficiency and Nonmaterial Noncompliance Criteria or specific requirements 34 CFR 673.3: To participate in the FWS, or FSEOG programs, an institution shall file an application before the deadline date established annually by the Secretary through publication of a notice in the Federal Register. ED Form 646-1, Fiscal Operations Report and Application to Participate (FISAP) (OMB No. 1845-0030) – This electronic report is submitted annually to receive funds for the campus-based programs. The data is used in conjunction with institutional program reviews to assess the administrative capability and compliance of the College. Condition The College did not retain supporting evidence utilized for reporting certain critical information within the FISAP including:  Total number of students  Total tuition and fees  Information on eligible applicants Cause The College did not have a process in place to retain supporting documentation of figures within the report nor evidence of review of these reports. Effect The College is not in compliance with the Federal requirement described in the OMB Compliance Supplement. Questioned costs None identified. Context The College lacked evidence to support figures reported in the FISAP. Auditor examined key line items listed in the Compliance Supplement and was unable to trace 3 of 6 applicable items to supporting records. Identification as a repeat finding Previously reported as finding 2023-005. Recommendation It is recommended the College should establish effective controls and processes to ensure that reporting of FISAP figures are properly supported and any evidence of review is maintained. View of responsible officials and corrective action plan Management agrees with the finding. Please see separate Corrective Action Plan for procedures to be implemented.

Special Tests and Provisions – Disbursements to or on Behalf of Students Student Financial Assistance Cluster – AL 84.007, 84.063 and 84.268 US Department of Education Significant Deficiency and Nonmaterial Noncompliance Criteria or specific requirements 34 CFR 668.164(h)(2): A Title IV, HEA credit balance must be paid directly to the student or parent as soon as possible, but no later than (i) Fourteen (14) days after the balance occurred if the credit balance occurred after the first day of class of a payment period; or (ii) Fourteen (14) days after the first day of class of a payment period if the credit balance occurred on or before the first day of class of that payment period. Condition During our testing over the return of credit balances, the following deficiencies were noted:  8 instances where credit balances were not refunded in the required time frame.  11 instances where refunds were due to students but none were posted in the ledger.  7 instances where the balances refunded to students could not be recalculated. Cause The College did not comply with Federal disbursement requirements for students under the Pell Grant and Direct Loan programs. Effect The College is not in compliance with the Federal requirement described in the OMB Compliance Supplement. Questioned costs None identified. Context The College contracts with a third-party servicer to perform one or more of the functions associated with disbursing Title IV funds on behalf of the school. A nonstatistical sample of 40 students out of 514 students were selected for disbursement testing. Identification as a repeat finding Previously reported as finding 2023-006. Recommendation It is recommended the College should establish effective controls and processes to ensure that accurate credit balances are refunded to students in a timely manner. View of responsible officials and corrective action plan Management agrees with the finding. Please see separate Corrective Action Plan for procedures to be implemented.

Special Tests and Provisions – Enrollment Reporting Student Financial Assistance Cluster – AL 84.007, 84.063 and 84.268 US Department of Education Significant Deficiency and Nonmaterial Noncompliance Criteria or specific requirements OMB Compliance Supplement, OMB No. 1845-0035 – Institutions are required to report enrollment information under the Pell grant and the Direct and FFEL loan programs via the National Student Loan Data System (NSLDS). Institutions must review, update, and verify student enrollment statuses, program information, and effective dates that appear on the Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS Professional Access (NSLDSFAP) website which the financial aid administrator can access for the auditor. The data on the institutions’ Enrollment Reporting Roster, or Enrollment Maintenance page, is what NSLDS has as the most recently certified enrollment information. There are two categories of enrollment information: “Campus Level” and “Program Level”, both of which need to be reported accurately and have separate record types. The NSLDS Enrollment Reporting Guide provides the requirements and guidance for reporting enrollment details using the NSLDS Enrollment Reporting Process. Condition During our testing over the NSLDS reporting requirements, the following deficiencies were noted:  3 of 50 program reporting details did not agree to enrollment details from the enrollment records per the College.  24 of 40 students did not have campus reporting completed within the required timeframe. Cause The College did not report enrollment information for students under the Pell Grant and Direct Loan Programs via NSLDS timely and accurately. Effect The College is not in compliance with the Federal enrollment reporting requirements described in the OMB Compliance Supplement. Questioned costs None identified. Context The College disbursed financial aid to approximately 514 students that required student enrollment and program enrollment reporting to NSLDS. A nonstatistical sample of 40 students out of 514 students were selected for enrollment reporting testing. Identification as a repeat finding Previously reported as 2023-007. Recommendation The College should implement a process to review, update, and verify student enrollment statuses, program information, and effective dates that appear on the Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS Professional Access (NSLDSFAP) website. View of responsible officials and corrective action plan Management agrees with the finding. Please see separate Corrective Action Plan for procedures to be implemented.

Cash Management – Monthly Reconciliations for Direct Loans Student Financial Assistance Cluster – AL 84.007, 84.063 and 84.268 US Department of Education Significant Deficiency and Nonmaterial Noncompliance Criteria or specific requirements Per 34 CFR 685.300(b)(5), on a monthly basis, the College must reconcile institutional records with the Direct Loan funds received from the Secretary and Direct Loan disbursement records submitted to and accepted by the Secretary. Each month, Common Origination and Disbursement (COD) sends the College a School Account Statement, which is ED’s official record of the College’s cash and disbursement records and identifies the difference between the net draws from G5 and the actual disbursement information reported to COD by the College. The College is required to account for any differences by reconciling ED’s records (School Account Statements) with the College’s financial and business records. Condition During our testing, the College was unable to provide evidence of these Direct Loan reconciliations being performed monthly. Cause The College did not have processes and procedures in place to adequately document the monthly Direct Loan reconciliations. Effect The College is not in compliance with the monthly reconciliation requirements described in 34 CFR 685.300 and the OMB Compliance Supplement. Questioned Costs None Context As part of our audit procedures, we requested all 12 monthly reconciliations for the year under audit. The College was unable to provide evidence of these reconciliations being performed or documented. Identification as a repeat finding This is a new finding for fiscal year 2024. Recommendation The College should implement a process for timely review and approval of monthly Direct Loan reconciliations using the statements provided by COD. View of responsible officials and corrective action plan Management agrees with the finding. Please see separate Corrective Action Plan for procedures to be implemented.

Special Tests and Provisions – Return to Title IV Student Financial Assistance Cluster – AL 84.007, 84,063 and 84.268 US Department of Education Significant Deficiency and Nonmaterial Noncompliance Criteria or specific requirements 34 CFR section 668.173(b) Returns of Title IV funds are required to be deposited or transferred into the SFA account or electronic fund transfers initiated to ED as soon as possible, but no later than 45 days after the date the institution determines that the student withdrew. Returns by check are late if the check is issued more than 45 days after the institution determined the student withdrew or the date on the canceled check shows the check was endorsed more than 60 days after the date the institution determined that the student withdrew. 34 CFR section 668.22(j)(2): An institution must determine the withdrawal date for a student who withdraws without providing notification to the institution no later than 30 days after the end of the earlier of the (1) payment period or period of enrollment, (2) academic year in which the student withdrew, or (3) educational program from which the student withdrew. 34 CFR section 668.22(c): If an institution is not required to take attendance, the withdrawal date is (1) the date, as determined by the institution, that the student began the withdrawal process prescribed by the institution; (2) the date, as determined by the institution, that the student otherwise provided official notification to the school, in writing or orally, of his or her intent to withdraw; (3) if the student ceases attendance without providing official notification to the institution of his or her withdrawal, the midpoint of the payment period or, if applicable, the period of enrollment; (4) if the institution determines that a student did not begin the withdrawal process or otherwise notify the school of the intent to withdraw due to illness, accident, grievous personal loss or other circumstances beyond the student’s control, the date the institution determines is related to that circumstance; (5) if a student does not return from an approved leave of absence, the date that the institution determines the student began the leave of absence; or (6) if the student takes an unapproved leave of absence, the date that the student began the leave of absence. Condition During our procedures over Return to Title IV requirements, the following deficiencies were noted:  7 of 13 Return to Title IV calculations were performed outside of the allowable time frame.  1 of 13 withdrawn students did not have a Return to Title IV calculation performed.  2 of 6 instances where funds were returned beyond the required time frame. Cause The College did not implement procedures to ensure that the Return to Title IV funds were performed accurately and returned in a timely manner. Effect Without proper monitoring of accuracy and student withdrawal, the College risks noncompliance with the above criteria. Questioned costs None identified. While the determinations were performed late, no unreturned funds were noted. Context The college did not perform R2T4 calculations for students under the Pell grant and Direct Loan Programs timely. A nonstatistical sample of 13 withdrawn students out of 40 selected from the College’s total population. Identification as a repeat finding Previously reported as finding 2023-004. Recommendation The College should implement procedures to ensure that the student withdrawal calculations are preformed timely and return funds within 30 days from the end of the student’s period of enrollment. View of responsible officials and corrective action plan Management agrees with the finding. Please see separate Corrective Action Plan for procedures to be implemented.

Reporting Student Financial Assistance Cluster – AL 84.007, 84.063 and 84.268 US Department of Education Significant Deficiency and Nonmaterial Noncompliance Criteria or specific requirements 34 CFR 673.3: To participate in the FWS, or FSEOG programs, an institution shall file an application before the deadline date established annually by the Secretary through publication of a notice in the Federal Register. ED Form 646-1, Fiscal Operations Report and Application to Participate (FISAP) (OMB No. 1845-0030) – This electronic report is submitted annually to receive funds for the campus-based programs. The data is used in conjunction with institutional program reviews to assess the administrative capability and compliance of the College. Condition The College did not retain supporting evidence utilized for reporting certain critical information within the FISAP including:  Total number of students  Total tuition and fees  Information on eligible applicants Cause The College did not have a process in place to retain supporting documentation of figures within the report nor evidence of review of these reports. Effect The College is not in compliance with the Federal requirement described in the OMB Compliance Supplement. Questioned costs None identified. Context The College lacked evidence to support figures reported in the FISAP. Auditor examined key line items listed in the Compliance Supplement and was unable to trace 3 of 6 applicable items to supporting records. Identification as a repeat finding Previously reported as finding 2023-005. Recommendation It is recommended the College should establish effective controls and processes to ensure that reporting of FISAP figures are properly supported and any evidence of review is maintained. View of responsible officials and corrective action plan Management agrees with the finding. Please see separate Corrective Action Plan for procedures to be implemented.

Special Tests and Provisions – Disbursements to or on Behalf of Students Student Financial Assistance Cluster – AL 84.007, 84.063 and 84.268 US Department of Education Significant Deficiency and Nonmaterial Noncompliance Criteria or specific requirements 34 CFR 668.164(h)(2): A Title IV, HEA credit balance must be paid directly to the student or parent as soon as possible, but no later than (i) Fourteen (14) days after the balance occurred if the credit balance occurred after the first day of class of a payment period; or (ii) Fourteen (14) days after the first day of class of a payment period if the credit balance occurred on or before the first day of class of that payment period. Condition During our testing over the return of credit balances, the following deficiencies were noted:  8 instances where credit balances were not refunded in the required time frame.  11 instances where refunds were due to students but none were posted in the ledger.  7 instances where the balances refunded to students could not be recalculated. Cause The College did not comply with Federal disbursement requirements for students under the Pell Grant and Direct Loan programs. Effect The College is not in compliance with the Federal requirement described in the OMB Compliance Supplement. Questioned costs None identified. Context The College contracts with a third-party servicer to perform one or more of the functions associated with disbursing Title IV funds on behalf of the school. A nonstatistical sample of 40 students out of 514 students were selected for disbursement testing. Identification as a repeat finding Previously reported as finding 2023-006. Recommendation It is recommended the College should establish effective controls and processes to ensure that accurate credit balances are refunded to students in a timely manner. View of responsible officials and corrective action plan Management agrees with the finding. Please see separate Corrective Action Plan for procedures to be implemented.

Special Tests and Provisions – Enrollment Reporting Student Financial Assistance Cluster – AL 84.007, 84.063 and 84.268 US Department of Education Significant Deficiency and Nonmaterial Noncompliance Criteria or specific requirements OMB Compliance Supplement, OMB No. 1845-0035 – Institutions are required to report enrollment information under the Pell grant and the Direct and FFEL loan programs via the National Student Loan Data System (NSLDS). Institutions must review, update, and verify student enrollment statuses, program information, and effective dates that appear on the Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS Professional Access (NSLDSFAP) website which the financial aid administrator can access for the auditor. The data on the institutions’ Enrollment Reporting Roster, or Enrollment Maintenance page, is what NSLDS has as the most recently certified enrollment information. There are two categories of enrollment information: “Campus Level” and “Program Level”, both of which need to be reported accurately and have separate record types. The NSLDS Enrollment Reporting Guide provides the requirements and guidance for reporting enrollment details using the NSLDS Enrollment Reporting Process. Condition During our testing over the NSLDS reporting requirements, the following deficiencies were noted:  3 of 50 program reporting details did not agree to enrollment details from the enrollment records per the College.  24 of 40 students did not have campus reporting completed within the required timeframe. Cause The College did not report enrollment information for students under the Pell Grant and Direct Loan Programs via NSLDS timely and accurately. Effect The College is not in compliance with the Federal enrollment reporting requirements described in the OMB Compliance Supplement. Questioned costs None identified. Context The College disbursed financial aid to approximately 514 students that required student enrollment and program enrollment reporting to NSLDS. A nonstatistical sample of 40 students out of 514 students were selected for enrollment reporting testing. Identification as a repeat finding Previously reported as 2023-007. Recommendation The College should implement a process to review, update, and verify student enrollment statuses, program information, and effective dates that appear on the Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS Professional Access (NSLDSFAP) website. View of responsible officials and corrective action plan Management agrees with the finding. Please see separate Corrective Action Plan for procedures to be implemented.

Cash Management – Monthly Reconciliations for Direct Loans Student Financial Assistance Cluster – AL 84.007, 84.063 and 84.268 US Department of Education Significant Deficiency and Nonmaterial Noncompliance Criteria or specific requirements Per 34 CFR 685.300(b)(5), on a monthly basis, the College must reconcile institutional records with the Direct Loan funds received from the Secretary and Direct Loan disbursement records submitted to and accepted by the Secretary. Each month, Common Origination and Disbursement (COD) sends the College a School Account Statement, which is ED’s official record of the College’s cash and disbursement records and identifies the difference between the net draws from G5 and the actual disbursement information reported to COD by the College. The College is required to account for any differences by reconciling ED’s records (School Account Statements) with the College’s financial and business records. Condition During our testing, the College was unable to provide evidence of these Direct Loan reconciliations being performed monthly. Cause The College did not have processes and procedures in place to adequately document the monthly Direct Loan reconciliations. Effect The College is not in compliance with the monthly reconciliation requirements described in 34 CFR 685.300 and the OMB Compliance Supplement. Questioned Costs None Context As part of our audit procedures, we requested all 12 monthly reconciliations for the year under audit. The College was unable to provide evidence of these reconciliations being performed or documented. Identification as a repeat finding This is a new finding for fiscal year 2024. Recommendation The College should implement a process for timely review and approval of monthly Direct Loan reconciliations using the statements provided by COD. View of responsible officials and corrective action plan Management agrees with the finding. Please see separate Corrective Action Plan for procedures to be implemented.

Special Tests and Provisions – Return to Title IV Student Financial Assistance Cluster – AL 84.007, 84,063 and 84.268 US Department of Education Significant Deficiency and Nonmaterial Noncompliance Criteria or specific requirements 34 CFR section 668.173(b) Returns of Title IV funds are required to be deposited or transferred into the SFA account or electronic fund transfers initiated to ED as soon as possible, but no later than 45 days after the date the institution determines that the student withdrew. Returns by check are late if the check is issued more than 45 days after the institution determined the student withdrew or the date on the canceled check shows the check was endorsed more than 60 days after the date the institution determined that the student withdrew. 34 CFR section 668.22(j)(2): An institution must determine the withdrawal date for a student who withdraws without providing notification to the institution no later than 30 days after the end of the earlier of the (1) payment period or period of enrollment, (2) academic year in which the student withdrew, or (3) educational program from which the student withdrew. 34 CFR section 668.22(c): If an institution is not required to take attendance, the withdrawal date is (1) the date, as determined by the institution, that the student began the withdrawal process prescribed by the institution; (2) the date, as determined by the institution, that the student otherwise provided official notification to the school, in writing or orally, of his or her intent to withdraw; (3) if the student ceases attendance without providing official notification to the institution of his or her withdrawal, the midpoint of the payment period or, if applicable, the period of enrollment; (4) if the institution determines that a student did not begin the withdrawal process or otherwise notify the school of the intent to withdraw due to illness, accident, grievous personal loss or other circumstances beyond the student’s control, the date the institution determines is related to that circumstance; (5) if a student does not return from an approved leave of absence, the date that the institution determines the student began the leave of absence; or (6) if the student takes an unapproved leave of absence, the date that the student began the leave of absence. Condition During our procedures over Return to Title IV requirements, the following deficiencies were noted:  7 of 13 Return to Title IV calculations were performed outside of the allowable time frame.  1 of 13 withdrawn students did not have a Return to Title IV calculation performed.  2 of 6 instances where funds were returned beyond the required time frame. Cause The College did not implement procedures to ensure that the Return to Title IV funds were performed accurately and returned in a timely manner. Effect Without proper monitoring of accuracy and student withdrawal, the College risks noncompliance with the above criteria. Questioned costs None identified. While the determinations were performed late, no unreturned funds were noted. Context The college did not perform R2T4 calculations for students under the Pell grant and Direct Loan Programs timely. A nonstatistical sample of 13 withdrawn students out of 40 selected from the College’s total population. Identification as a repeat finding Previously reported as finding 2023-004. Recommendation The College should implement procedures to ensure that the student withdrawal calculations are preformed timely and return funds within 30 days from the end of the student’s period of enrollment. View of responsible officials and corrective action plan Management agrees with the finding. Please see separate Corrective Action Plan for procedures to be implemented.

Reporting Student Financial Assistance Cluster – AL 84.007, 84.063 and 84.268 US Department of Education Significant Deficiency and Nonmaterial Noncompliance Criteria or specific requirements 34 CFR 673.3: To participate in the FWS, or FSEOG programs, an institution shall file an application before the deadline date established annually by the Secretary through publication of a notice in the Federal Register. ED Form 646-1, Fiscal Operations Report and Application to Participate (FISAP) (OMB No. 1845-0030) – This electronic report is submitted annually to receive funds for the campus-based programs. The data is used in conjunction with institutional program reviews to assess the administrative capability and compliance of the College. Condition The College did not retain supporting evidence utilized for reporting certain critical information within the FISAP including:  Total number of students  Total tuition and fees  Information on eligible applicants Cause The College did not have a process in place to retain supporting documentation of figures within the report nor evidence of review of these reports. Effect The College is not in compliance with the Federal requirement described in the OMB Compliance Supplement. Questioned costs None identified. Context The College lacked evidence to support figures reported in the FISAP. Auditor examined key line items listed in the Compliance Supplement and was unable to trace 3 of 6 applicable items to supporting records. Identification as a repeat finding Previously reported as finding 2023-005. Recommendation It is recommended the College should establish effective controls and processes to ensure that reporting of FISAP figures are properly supported and any evidence of review is maintained. View of responsible officials and corrective action plan Management agrees with the finding. Please see separate Corrective Action Plan for procedures to be implemented.

Special Tests and Provisions – Disbursements to or on Behalf of Students Student Financial Assistance Cluster – AL 84.007, 84.063 and 84.268 US Department of Education Significant Deficiency and Nonmaterial Noncompliance Criteria or specific requirements 34 CFR 668.164(h)(2): A Title IV, HEA credit balance must be paid directly to the student or parent as soon as possible, but no later than (i) Fourteen (14) days after the balance occurred if the credit balance occurred after the first day of class of a payment period; or (ii) Fourteen (14) days after the first day of class of a payment period if the credit balance occurred on or before the first day of class of that payment period. Condition During our testing over the return of credit balances, the following deficiencies were noted:  8 instances where credit balances were not refunded in the required time frame.  11 instances where refunds were due to students but none were posted in the ledger.  7 instances where the balances refunded to students could not be recalculated. Cause The College did not comply with Federal disbursement requirements for students under the Pell Grant and Direct Loan programs. Effect The College is not in compliance with the Federal requirement described in the OMB Compliance Supplement. Questioned costs None identified. Context The College contracts with a third-party servicer to perform one or more of the functions associated with disbursing Title IV funds on behalf of the school. A nonstatistical sample of 40 students out of 514 students were selected for disbursement testing. Identification as a repeat finding Previously reported as finding 2023-006. Recommendation It is recommended the College should establish effective controls and processes to ensure that accurate credit balances are refunded to students in a timely manner. View of responsible officials and corrective action plan Management agrees with the finding. Please see separate Corrective Action Plan for procedures to be implemented.

Special Tests and Provisions – Enrollment Reporting Student Financial Assistance Cluster – AL 84.007, 84.063 and 84.268 US Department of Education Significant Deficiency and Nonmaterial Noncompliance Criteria or specific requirements OMB Compliance Supplement, OMB No. 1845-0035 – Institutions are required to report enrollment information under the Pell grant and the Direct and FFEL loan programs via the National Student Loan Data System (NSLDS). Institutions must review, update, and verify student enrollment statuses, program information, and effective dates that appear on the Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS Professional Access (NSLDSFAP) website which the financial aid administrator can access for the auditor. The data on the institutions’ Enrollment Reporting Roster, or Enrollment Maintenance page, is what NSLDS has as the most recently certified enrollment information. There are two categories of enrollment information: “Campus Level” and “Program Level”, both of which need to be reported accurately and have separate record types. The NSLDS Enrollment Reporting Guide provides the requirements and guidance for reporting enrollment details using the NSLDS Enrollment Reporting Process. Condition During our testing over the NSLDS reporting requirements, the following deficiencies were noted:  3 of 50 program reporting details did not agree to enrollment details from the enrollment records per the College.  24 of 40 students did not have campus reporting completed within the required timeframe. Cause The College did not report enrollment information for students under the Pell Grant and Direct Loan Programs via NSLDS timely and accurately. Effect The College is not in compliance with the Federal enrollment reporting requirements described in the OMB Compliance Supplement. Questioned costs None identified. Context The College disbursed financial aid to approximately 514 students that required student enrollment and program enrollment reporting to NSLDS. A nonstatistical sample of 40 students out of 514 students were selected for enrollment reporting testing. Identification as a repeat finding Previously reported as 2023-007. Recommendation The College should implement a process to review, update, and verify student enrollment statuses, program information, and effective dates that appear on the Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS Professional Access (NSLDSFAP) website. View of responsible officials and corrective action plan Management agrees with the finding. Please see separate Corrective Action Plan for procedures to be implemented.

Cash Management – Monthly Reconciliations for Direct Loans Student Financial Assistance Cluster – AL 84.007, 84.063 and 84.268 US Department of Education Significant Deficiency and Nonmaterial Noncompliance Criteria or specific requirements Per 34 CFR 685.300(b)(5), on a monthly basis, the College must reconcile institutional records with the Direct Loan funds received from the Secretary and Direct Loan disbursement records submitted to and accepted by the Secretary. Each month, Common Origination and Disbursement (COD) sends the College a School Account Statement, which is ED’s official record of the College’s cash and disbursement records and identifies the difference between the net draws from G5 and the actual disbursement information reported to COD by the College. The College is required to account for any differences by reconciling ED’s records (School Account Statements) with the College’s financial and business records. Condition During our testing, the College was unable to provide evidence of these Direct Loan reconciliations being performed monthly. Cause The College did not have processes and procedures in place to adequately document the monthly Direct Loan reconciliations. Effect The College is not in compliance with the monthly reconciliation requirements described in 34 CFR 685.300 and the OMB Compliance Supplement. Questioned Costs None Context As part of our audit procedures, we requested all 12 monthly reconciliations for the year under audit. The College was unable to provide evidence of these reconciliations being performed or documented. Identification as a repeat finding This is a new finding for fiscal year 2024. Recommendation The College should implement a process for timely review and approval of monthly Direct Loan reconciliations using the statements provided by COD. View of responsible officials and corrective action plan Management agrees with the finding. Please see separate Corrective Action Plan for procedures to be implemented.