Audit 357504

2024-001 Reporting (Financial) Student Financial Assistance Cluster: U.S. Department of Education Federal Direct Student Loans (ALN 84.268) Federal Grant Numbers and Years: P268K240460 (9/1/2023-8/31/2024) Statistically Valid Sample: No, and it was not intended to bePrior Year Finding: Not a repeat finding. Finding Type: Material Weakness and Noncompliance Criteria: SFA – Title IV Programs Institutions submit Direct Loan, Pell Grant, TEACH Grant, and IASG origination records and disbursement records to the Common Origination and Disbursement (COD) system. Origination records can be sent well in advance of any disbursements, as early as the institution chooses to submit them for any student the institution reasonably believes will be eligible for a payment. An institution follows up with a disbursement record for that student no earlier than (1) seven calendar days prior to the disbursement date under the Advance or Heightened Cash Monitoring 1 payment methods, or (2) the date of the disbursement under the Reimbursement or Heightened Cash Monitoring 2 Payment Method (see Federal Register, Volume 86, Number 119, June 24, 2021). The disbursement record reports the actual disbursement date and the amount of the disbursement. ED processes origination and/or disbursement records and returns acknowledgments to the institution. The acknowledgments identify the processing status of each record: Rejected, Accepted with Corrections, or Accepted. In testing the origination and disbursement data, the auditor should be most concerned with the data ED has categorized as accepted or accepted with corrections. Institutions must report student disbursement data within 15 calendar days after the institution makes a disbursement or becomes aware of the need to make an adjustment to previously reported student disbursement data or expected student disbursement data. Institutions may do this by reporting once every 15 calendar days, bi-weekly or weekly, or may set up their own system to ensure that changes are reported in a timely manner. Key items to test on origination records, if applicable, are: Social Security number, award amount, enrollment date, verification status code (when the applicant is selected for verification), transaction number, cost of attendance, and the “Academic Start Date” and “Academic End Date”. Key items to test on disbursement records are disbursement date and amount. Further, the College must establish and maintain effective internal controls over federal programs designed to provide reasonable assurance that transactions are executed in compliance with federal statutes, regulations, and the terms and conditions of the federal award that could have a direct and material effect on a federal program. Condition and Context: During our testing of the timeliness of reporting of disbursement data, we noted the following: For 5 out of 40 students selected for testwork, the College did not report student disbursement data within the required 15 days after making a disbursement to the student’s account. For each of the students selected for testwork above, the students’ institutional records information agreed to the COD system. Upon further review of the root cause for the late reporting, the College determined that a total 785 student disbursement data records were reported late to COD (2 students – 1 day late, 5 students – 2 days late, 22 students – 4 days late, 740 students – 5 days late; 14 students – 11 days late, 1 student – 12 days late, and 1 student – 43 days late). We did not note any discrepancies with the key line items noted above related to the origination and disbursement records, respectively, with our sample subjected to testwork. Cause: Certain student disbursement data records were not reported and/ or updated in COD and the College’s processes and procedures did not identify the issue until after the required 15 calendar days review period had passed. Effect: The College did not report student disbursement data within the required 15 calendar days after the College made a disbursement. Questioned Costs: No questioned costs were noted as a result of the audit procedures performed. Recommendation: We recommend that the College review and enhance its current policies and proceduers to ensure that all students’ disbursement data is reported to COD within the 15 calendar day required deadline. Views of Responsible Officials: Management agrees with the finding.

2024-002 Special Tests (Enrollment Reporting) Student Financial Assistance Cluster: U.S. Department of Education Federal Direct Student Loans (ALN 84.268) Federal Grant Numbers and Years: P268K240460 (9/1/2023-8/31/2024) Statistically Valid Sample: No, and it was not intended to be Prior Year Finding: No Finding Type: Significant Deficiency and Noncompliance Criteria: Under the Pell grant and the Direct and Federal Family Education Loan programs, institutions are required to report enrollment information via the National Student Loan Data System (NSLDS) (OMB No. 1845-0035). The administration of the Title IV programs depends heavily on the accuracy and timeliness of the enrollment information reported by institutions. Institutions must review, update and certify 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. The data on the institution’s 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. Institutions are responsible for accurately reporting all Campus-Level Record data elements. The Department of Education (ED) considers the following data elements to be high risk: • OPEID number, enrollment effective date, enrollment status and certification date Institutions are responsible for accurately reporting all Program-Level Record data elements. The Department of Education (ED) considers the following data elements to be high risk: • OPEID number, CIP code, CIP year, credential level, published program length measurement, published program length, program begin date, program enrollment status and program enrollment effective date Institutions are responsible for timely reporting, whether they report directly or via a third-party servicer. Institutions must complete and return within 15 days the Enrollment Reporting roster file placed in their Student Aid Internet Gateway (SAIG) (OMB No. 1845-0002) mailboxes sent by ED via NSLDS. An 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 the data elements for the Campus Record and the Program Record identified above, and submit the changes electronically through the batch method, spreadsheet submittal, or the NSLDS website (Pell, 34 CFR 690.83(b)(2); FFEL, 34 CFR 682.610; Direct Loan, 34 CFR 685.309: Perkins 34 CFR 674.19(f)). Additionally, in accordance with federal requirements, the College shall maintain internal controls over federal programs designed to provide reasonable assurance that transactions are executed in compliance with federal statutes, regulations, and the terms and conditions of the federal award that could have a direct and material effect on a federal program. Condition and Context: The College utilizes the National Student Clearinghouse (the Clearinghouse) as a service provider for transmission of its enrollment reporting changes including, but not limited to withdrawals and graduate status to the National Student Loan Data System (NSLDS). The College receives the Enrollment Reporting Roster and makes necessary updates for changes in student status. A final file is then sent to the Clearinghouse who transmits information or corrections to NSLDS. For 4 out of the 26 students selected for testwork, the enrollment status did not match between the institutions records, NSLDS Campus-Level Records, and NSLDS Program Level Records due to a DegreeVerify service limitation within the National Student Clearinghouse and two of the four students also were certified by NSLDS 82 days after the 60 day certification requirement past the status effective date. In addition to the 4 students previously discussed, one additional student’s status was certified 16 days beyond the 60 day certification day requirement. Cause: The College’s processes and procedures did not ensure that the Clearinghouse transmitted the change in status certification dates by the required 60 day reporting period and was properly reflected in NSLDS. Effect: Student status changes not reported in a timely or accurate manner may cause the student to not enter into repayment status for Federal Direct Student Loans on a timely basis. Questioned Costs: No questioned costs were noted as a result of the audit procedures performed. Recommendation: We recommend the College review and enhance its current policies and procedures to ensure that all status changes are reported to NSLDS timely and that all student statuses match between the College records, Campus-Level Records and Program-Level Records. Views of Responsible Officials: Management agrees with the finding.

2024-001 Reporting (Financial) Student Financial Assistance Cluster: U.S. Department of Education Federal Direct Student Loans (ALN 84.268) Federal Grant Numbers and Years: P268K240460 (9/1/2023-8/31/2024) Statistically Valid Sample: No, and it was not intended to bePrior Year Finding: Not a repeat finding. Finding Type: Material Weakness and Noncompliance Criteria: SFA – Title IV Programs Institutions submit Direct Loan, Pell Grant, TEACH Grant, and IASG origination records and disbursement records to the Common Origination and Disbursement (COD) system. Origination records can be sent well in advance of any disbursements, as early as the institution chooses to submit them for any student the institution reasonably believes will be eligible for a payment. An institution follows up with a disbursement record for that student no earlier than (1) seven calendar days prior to the disbursement date under the Advance or Heightened Cash Monitoring 1 payment methods, or (2) the date of the disbursement under the Reimbursement or Heightened Cash Monitoring 2 Payment Method (see Federal Register, Volume 86, Number 119, June 24, 2021). The disbursement record reports the actual disbursement date and the amount of the disbursement. ED processes origination and/or disbursement records and returns acknowledgments to the institution. The acknowledgments identify the processing status of each record: Rejected, Accepted with Corrections, or Accepted. In testing the origination and disbursement data, the auditor should be most concerned with the data ED has categorized as accepted or accepted with corrections. Institutions must report student disbursement data within 15 calendar days after the institution makes a disbursement or becomes aware of the need to make an adjustment to previously reported student disbursement data or expected student disbursement data. Institutions may do this by reporting once every 15 calendar days, bi-weekly or weekly, or may set up their own system to ensure that changes are reported in a timely manner. Key items to test on origination records, if applicable, are: Social Security number, award amount, enrollment date, verification status code (when the applicant is selected for verification), transaction number, cost of attendance, and the “Academic Start Date” and “Academic End Date”. Key items to test on disbursement records are disbursement date and amount. Further, the College must establish and maintain effective internal controls over federal programs designed to provide reasonable assurance that transactions are executed in compliance with federal statutes, regulations, and the terms and conditions of the federal award that could have a direct and material effect on a federal program. Condition and Context: During our testing of the timeliness of reporting of disbursement data, we noted the following: For 5 out of 40 students selected for testwork, the College did not report student disbursement data within the required 15 days after making a disbursement to the student’s account. For each of the students selected for testwork above, the students’ institutional records information agreed to the COD system. Upon further review of the root cause for the late reporting, the College determined that a total 785 student disbursement data records were reported late to COD (2 students – 1 day late, 5 students – 2 days late, 22 students – 4 days late, 740 students – 5 days late; 14 students – 11 days late, 1 student – 12 days late, and 1 student – 43 days late). We did not note any discrepancies with the key line items noted above related to the origination and disbursement records, respectively, with our sample subjected to testwork. Cause: Certain student disbursement data records were not reported and/ or updated in COD and the College’s processes and procedures did not identify the issue until after the required 15 calendar days review period had passed. Effect: The College did not report student disbursement data within the required 15 calendar days after the College made a disbursement. Questioned Costs: No questioned costs were noted as a result of the audit procedures performed. Recommendation: We recommend that the College review and enhance its current policies and proceduers to ensure that all students’ disbursement data is reported to COD within the 15 calendar day required deadline. Views of Responsible Officials: Management agrees with the finding.

2024-002 Special Tests (Enrollment Reporting) Student Financial Assistance Cluster: U.S. Department of Education Federal Direct Student Loans (ALN 84.268) Federal Grant Numbers and Years: P268K240460 (9/1/2023-8/31/2024) Statistically Valid Sample: No, and it was not intended to be Prior Year Finding: No Finding Type: Significant Deficiency and Noncompliance Criteria: Under the Pell grant and the Direct and Federal Family Education Loan programs, institutions are required to report enrollment information via the National Student Loan Data System (NSLDS) (OMB No. 1845-0035). The administration of the Title IV programs depends heavily on the accuracy and timeliness of the enrollment information reported by institutions. Institutions must review, update and certify 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. The data on the institution’s 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. Institutions are responsible for accurately reporting all Campus-Level Record data elements. The Department of Education (ED) considers the following data elements to be high risk: • OPEID number, enrollment effective date, enrollment status and certification date Institutions are responsible for accurately reporting all Program-Level Record data elements. The Department of Education (ED) considers the following data elements to be high risk: • OPEID number, CIP code, CIP year, credential level, published program length measurement, published program length, program begin date, program enrollment status and program enrollment effective date Institutions are responsible for timely reporting, whether they report directly or via a third-party servicer. Institutions must complete and return within 15 days the Enrollment Reporting roster file placed in their Student Aid Internet Gateway (SAIG) (OMB No. 1845-0002) mailboxes sent by ED via NSLDS. An 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 the data elements for the Campus Record and the Program Record identified above, and submit the changes electronically through the batch method, spreadsheet submittal, or the NSLDS website (Pell, 34 CFR 690.83(b)(2); FFEL, 34 CFR 682.610; Direct Loan, 34 CFR 685.309: Perkins 34 CFR 674.19(f)). Additionally, in accordance with federal requirements, the College shall maintain internal controls over federal programs designed to provide reasonable assurance that transactions are executed in compliance with federal statutes, regulations, and the terms and conditions of the federal award that could have a direct and material effect on a federal program. Condition and Context: The College utilizes the National Student Clearinghouse (the Clearinghouse) as a service provider for transmission of its enrollment reporting changes including, but not limited to withdrawals and graduate status to the National Student Loan Data System (NSLDS). The College receives the Enrollment Reporting Roster and makes necessary updates for changes in student status. A final file is then sent to the Clearinghouse who transmits information or corrections to NSLDS. For 4 out of the 26 students selected for testwork, the enrollment status did not match between the institutions records, NSLDS Campus-Level Records, and NSLDS Program Level Records due to a DegreeVerify service limitation within the National Student Clearinghouse and two of the four students also were certified by NSLDS 82 days after the 60 day certification requirement past the status effective date. In addition to the 4 students previously discussed, one additional student’s status was certified 16 days beyond the 60 day certification day requirement. Cause: The College’s processes and procedures did not ensure that the Clearinghouse transmitted the change in status certification dates by the required 60 day reporting period and was properly reflected in NSLDS. Effect: Student status changes not reported in a timely or accurate manner may cause the student to not enter into repayment status for Federal Direct Student Loans on a timely basis. Questioned Costs: No questioned costs were noted as a result of the audit procedures performed. Recommendation: We recommend the College review and enhance its current policies and procedures to ensure that all status changes are reported to NSLDS timely and that all student statuses match between the College records, Campus-Level Records and Program-Level Records. Views of Responsible Officials: Management agrees with the finding.