Audit 359094

Section III - Federal Awards Findings and Questioned Costs Finding 2024-001 - Special Tests and Provisions - Exit Counseling - Significant Deficiency Name of Federal Agency: U.S. Department of Education Federal Program Name: Federal Direct Student Loans Assistance Listing Number: 84.268 Federal Award Identification Number and Year: P268K243382 2024 Name of Pass-through Entity: N/A Criteria According to the Federal Register (34 CFR 685.304 (b) (1)), an institution must ensure exit counseling is conducted with each Federal Direct Loans Program borrower and the institution must maintain in the student borrower's file documents substantiating compliance with these requirements (34 CFR 685.304 (b)(7)). Condition We noted 1 instance where the Institute failed to document exit counseling which should have been conducted with a participating student during the award year. Cause There was an administrative oversight that caused the above mentioned condition. Effect or Potential Effect The Institute was not in compliance with federal regulations regarding special tests and provisions for the year ended September 30, 2024. Questioned Costs None Context A total of 36 students who were credited with Federal Direct Loan Program proceeds during the year were included in the haphazardly selected sample of 40 participating students. Our testing noted that 1 of the students with Federal Direct Loan Program proceeds credited to their account did not have the required exit counseling documented. Identification as a repeat finding This finding is not a repeat finding. Recommendation We recommend the Institute continue its efforts to ensure all required exit counseling procedures are conducted and documented in compliance with U.S. Department of Education regulations. Views of Responsible Officials The failure to document the exit conference of one student borrower in the Federal Direct Loans Program, as noted in the auditor’s findings, was an administrative oversight. In May 2025, the Institute reviewed and revised its current procedures to ensure that all exit conferences are documented. Under the revised procedures, an employee independent from the exit conference process is to review that any student that has not enrolled in a new semester or that is enrolled at less than half time status has received proper exit conferencing and that the exit conferencing has been properly documented.

Finding 2024-002 - Special Tests and Provisions - Federal Direct Loan Program Student Notification - Significant Deficiency Name of Federal Agency: U.S. Department of Education Federal Program Name: Federal Direct Student Loans Assistance Listing Number: 84.268 Federal Award Identification Number and Year: P268K243382 2024 Name of Pass-through Entity: N/A Criteria According to the Federal Register (34 CFR 668.165 (a)(3)), an institution must provide notice to a participating student no earlier than 30 days before, and no later than seven days after, crediting the student's account with Federal Direct Loan Program proceeds at the institution, if the institution does not receive affirmative confirmation from the student. Condition We noted 1 instance where the Institute did not send out the required notifications regarding Federal Direct Student Loan Program proceeds that had been credited to participating student's accounts within prescribed timeframes in accordance with U.S. Department of Education regulations. Cause There was an administrative oversight that caused the above mentioned condition. Effect or Potential Effect The effect of these findings is noncompliance with U.S. Department of Education regulations regarding special tests and provisions. Questioned Costs None Context A total of 36 students who were credited with Federal Direct Loan Program proceeds during the year were included in the randomly selected sample of 40 participating students. Our testing noted that 1 of the students with Federal Direct Loan Program proceeds credited to their account were not provided with the required notifications. Identification as a repeat finding Yes 2022-005 Recommendation We recommend the Institute review and revise, its current procedures and have controls in place to ensure required notifications regarding Federal Direct Loan Program proceeds are provided to participating students. Views of Responsible Officials The failure to timely send out the required notification of Federal Direct Student Loan Program proceeds credited to one student’s account, as noted in the auditor’s findings, was an administrative oversight. In May 2025, the Institute reviewed and revised its current procedures to ensure that all required notifications are made. Under the revised procedures, an employee independent from the student loan proceed crediting notification process is to review that notifications are sent out within prescribed time frames in accordance with U.S. Department of Education regulations to all students receiving and being credited with Federal Direct Loan Program amounts and that copies of the notifications are maintained in each applicable student’s file.

Section III - Federal Awards Findings and Questioned Costs Finding 2024-001 - Special Tests and Provisions - Exit Counseling - Significant Deficiency Name of Federal Agency: U.S. Department of Education Federal Program Name: Federal Direct Student Loans Assistance Listing Number: 84.268 Federal Award Identification Number and Year: P268K243382 2024 Name of Pass-through Entity: N/A Criteria According to the Federal Register (34 CFR 685.304 (b) (1)), an institution must ensure exit counseling is conducted with each Federal Direct Loans Program borrower and the institution must maintain in the student borrower's file documents substantiating compliance with these requirements (34 CFR 685.304 (b)(7)). Condition We noted 1 instance where the Institute failed to document exit counseling which should have been conducted with a participating student during the award year. Cause There was an administrative oversight that caused the above mentioned condition. Effect or Potential Effect The Institute was not in compliance with federal regulations regarding special tests and provisions for the year ended September 30, 2024. Questioned Costs None Context A total of 36 students who were credited with Federal Direct Loan Program proceeds during the year were included in the haphazardly selected sample of 40 participating students. Our testing noted that 1 of the students with Federal Direct Loan Program proceeds credited to their account did not have the required exit counseling documented. Identification as a repeat finding This finding is not a repeat finding. Recommendation We recommend the Institute continue its efforts to ensure all required exit counseling procedures are conducted and documented in compliance with U.S. Department of Education regulations. Views of Responsible Officials The failure to document the exit conference of one student borrower in the Federal Direct Loans Program, as noted in the auditor’s findings, was an administrative oversight. In May 2025, the Institute reviewed and revised its current procedures to ensure that all exit conferences are documented. Under the revised procedures, an employee independent from the exit conference process is to review that any student that has not enrolled in a new semester or that is enrolled at less than half time status has received proper exit conferencing and that the exit conferencing has been properly documented.

Finding 2024-002 - Special Tests and Provisions - Federal Direct Loan Program Student Notification - Significant Deficiency Name of Federal Agency: U.S. Department of Education Federal Program Name: Federal Direct Student Loans Assistance Listing Number: 84.268 Federal Award Identification Number and Year: P268K243382 2024 Name of Pass-through Entity: N/A Criteria According to the Federal Register (34 CFR 668.165 (a)(3)), an institution must provide notice to a participating student no earlier than 30 days before, and no later than seven days after, crediting the student's account with Federal Direct Loan Program proceeds at the institution, if the institution does not receive affirmative confirmation from the student. Condition We noted 1 instance where the Institute did not send out the required notifications regarding Federal Direct Student Loan Program proceeds that had been credited to participating student's accounts within prescribed timeframes in accordance with U.S. Department of Education regulations. Cause There was an administrative oversight that caused the above mentioned condition. Effect or Potential Effect The effect of these findings is noncompliance with U.S. Department of Education regulations regarding special tests and provisions. Questioned Costs None Context A total of 36 students who were credited with Federal Direct Loan Program proceeds during the year were included in the randomly selected sample of 40 participating students. Our testing noted that 1 of the students with Federal Direct Loan Program proceeds credited to their account were not provided with the required notifications. Identification as a repeat finding Yes 2022-005 Recommendation We recommend the Institute review and revise, its current procedures and have controls in place to ensure required notifications regarding Federal Direct Loan Program proceeds are provided to participating students. Views of Responsible Officials The failure to timely send out the required notification of Federal Direct Student Loan Program proceeds credited to one student’s account, as noted in the auditor’s findings, was an administrative oversight. In May 2025, the Institute reviewed and revised its current procedures to ensure that all required notifications are made. Under the revised procedures, an employee independent from the student loan proceed crediting notification process is to review that notifications are sent out within prescribed time frames in accordance with U.S. Department of Education regulations to all students receiving and being credited with Federal Direct Loan Program amounts and that copies of the notifications are maintained in each applicable student’s file.