Audit 371188

2025‐002 Significant Deficiency: Working During Scheduled Class Time (U.S. Department of Education - Federal Work Study Program, ALN #84.033) Criteria: In accordance with the 2024-2025 Federal Student Aid Handbook, in general, students are not permitted to work in Federal Work Study positions during scheduled class times. Exceptions are permitted if an individual class is cancelled, if the instructor has excused the student from attending for a particular day, and if the student is receiving credit for employment in an internship, externship, or community work-study experience. Any such exemptions must be documented. Statement of Condition: During the audit, it was noted that multiples students appear to have been paid for Federal Work Study hours logged and submitted for time the student was scheduled to be in class. The reasons for overlap vary, but no reasonable exemption could be verified. Questioned Costs: The known monetary error is an over-payment of $99. Extrapolation of the error across all students and pay periods that may have been affected estimates total possible monetary error of $3,115. Therefore, the monetary impact of this deficiency does not exceed the reporting threshold of $25,000. Perspective Information: The audit included a detailed testing of 9 files for students participating in the Federal Work Study program during the 2024-2025 award year, and limited detail testing of an additional 22 students’ Federal Work Study documents pertaining to this specific attribute. For the 31 students tested, auditors vouched class schedules, timecards, and paystubs for two specific pay periods, one in each semester. Of these students for the specific pay periods tested, overlap between submitted work study hours paid and classes scheduled without reasonable exception was identified in the records for five students. Therefore, we consider the error rate as 16.13%. Cause and Effect: In certain cases of conflicting times, class took place as scheduled, but the student was not present, choosing to work instead; other cases appear to be related to students being present in class, but also clocked into their work study position, resulting in payment for hours not worked at all. In all instances, supervisors did not identify the conflicts when reviewing and submitting timesheets for payroll processing and funds were paid to the students for the overlapping times, which is prohibited without an adequate exemption that has been appropriately documented. Recommendation: The University should ensure that proper safeguards, in both software and personnel, are in place to prevent, identify, and remediate such errors to prevent over-payment of federal aid funds. View of Responsible Officials: The University concurs with the finding. The University provided a reminder via email to all students and supervisors each pay period throughout the year that students are not allowed to work during scheduled class times without documentation. Supervisor training was required of all FWS supervisors in August 2025 to emphasize the importance of compliance with this specific aspect of FWS as well as all other federal requirements governing the FWS program. Supervisors are expected to monitor when their students are beginning work and request documentation if clock-in, or any period of their work, falls within a scheduled class period.

2025‐001 Significant Deficiency: Return to Title IV Funds (U.S. Department of Education - William D. Ford Direct Loan Program, ALN #84.268; Federal Pell Grant Program, ALN #84.063; Federal Supplemental Educational Opportunity Grant, ALN #84.007; Teacher Education Assistance for College and Higher Education Grant, ALN #84.379) Criteria: In accordance with the 2024-2025 Federal Student Aid Handbook and 34 CFR 668.22, a school must calculate the amount of earned Title IV funds by applying a percentage to the total amount of Title IV program assistance that was disbursed and that could have been disbursed. Aid included in this calculation to be prorated includes assistance from the Direct Loan, Federal Pell Grant, Iraq and Afghanistan Service Grant, TEACH Grant, and FSEOG programs. Statement of Condition: During the audit, the Return to Title IV calculation for one student failed to include all aid disbursed or able to be disbursed in step one. Therefore, the calculated percentage of aid earned was applied a limited portion of the student’s federal aid, resulting in incorrect fund totals being returned. Questioned Costs: The known monetary error is $220 excess Federal Pell Grant funds being retained on the student’s behalf. During the audit, all students meeting the criteria to warrant a Return to Title IV calculation were tested, so no extrapolation of the monetary error is necessary beyond the identified error. The monetary impact of this deficiency does not exceed the reporting threshold of $25,000. Perspective Information: The audit included a detailed testing of 9 files for students who withdrew mid-term during the 2024-2025 award year who had received Title IV awards, requiring the University to complete a Return to Title IV calculation. Of these students, this mistake was identified in one instance. Therefore, we consider the error rate as 1 out of the 9 total applicable students, which is 11.11%. Cause and Effect: This error was caused by an oversight by the personnel completing the Return to Title IV calculation, resulting in miscalculation of total Title IV aid earned. Recommendation: The director of financial aid completing any Return to Title IV calculations should ensure that all applicable aid is included in step one of the worksheet. Proper measures may be put into place to verify information input and review the calculation as a whole. View of Responsible Officials: The University concurs with the finding and has provided education and training for the staff responsible for refund calculations. The University will strengthen review procedures of refund calculations in the next award year to ensure compliance with federal guidelines.