Audit 374299

Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Aid FALN Number: Student Financial Aid Cluster Award Period: June 01, 2024 through May 31, 2025 Type of Finding: • Significant Deficiency in Internal Control Over Compliance • Other Matters Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 685.309(b), states schools must have some arrangement to report student enrollment data to the National Student Loan Data System (NSLDS) through an enrollment roster file. The school is required to report changes in the student’s enrollment status, the effective date of the status, and an anticipated completion date as well as program enrollment effective date. In addition, at a minimum, schools are required to certify enrollment every 60 days, and respond within 15 days of the date that NSLDS sends a Roster file to the school or its third-party servicer. Condition: During our testing, we noted 40 out of the 40 students tested where the student was not reported in a timely manner after the school determined the students change in status. In addition, we noted for 1 out of the 40 students tested, the enrollment effective date per NSLDS did not match the enrollment effective date per the University’s records. Questioned costs: None Context: During our testing, it was noted the University does not have a process in place to ensure timeliness and accuracy of NSLDS reporting. Cause: The University did not have a process in place to ensure the effective dates reported matched the University’s records as well as that these changes were reported timely. Effect: The enrollment effective date reported to NSLDS is used to determine when the student’s grace period should begin. By not reporting an incorrect effective date, the grace period begin date for the student will be incorrect. In addition, the University did not comply with Department of Education (ED) regulations by reporting student enrollment status changes timely. Repeat finding: Yes, see finding 2024-002 Recommendation: We recommend the University reevaluate its procedures and review policies surrounding reporting status changes to NSLDS to put a process in place to ensure the enrollment effective date reported to NSLDS on the campus and program level is aligning with the University. Views of responsible officials: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Aid FALN Number: Student Financial Aid Cluster Award Period: June 01, 2024 through May 31, 2025 Type of Finding: • Significant Deficiency in Internal Control Over Compliance • Other Matters Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 674.16 states that before an institution makes its first disbursement to a student, the student shall sign the promissory note and the institution shall provide the student with certain repayment information. Condition: During our testing of the Student Financial Aid Cluster, we noted that 1 student out of 30 tested in the Perkins loan program could not be supported as having completed a promissory note or entrance counseling. Questioned costs: None Context: During our testing, it was noted the University does not have a process in place to ensure MPN’s are retained. Cause: The University did not have a process in place to ensure they retained a copy of the MPN for at least three years after the loans were satisfied. Effect: The University was not in compliance with the Perkins recordkeeping regulations. Repeat finding: No Recommendation: We recommend the University implements procedures moving forward to ensure that all necessary MPN’s are retained in accordance with the Perkins recordkeeping regulations. Views of responsible officials: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Aid FALN Number: Student Financial Aid Cluster Award Period: June 01, 2024 through May 31, 2025 Type of Finding: • Material Weakness in Internal Control Over Compliance • Other Matters Criteria or specific requirement: Federal regulations require institutions to award and disburse Title IV aid accurately and in accordance with student eligibility: Pell Grant: 34 CFR § 690.75 – Payment determination based on enrollment status and cost of attendance. FSEOG: 34 CFR § 676.10 – Must be awarded to students with exceptional financial need. Subsidized and Unsubsidized Stafford Loans: 34 CFR § 685.301 – Loan amounts must be based on grade level, dependency status, and cost of attendance. General Disbursement Requirements: 34 CFR § 668.164 – Institutions must disburse funds for the correct amount and payment period. Condition: A review of student financial aid records revealed that although students were accurately awarded federal financial aid—including Pell Grants, FSEOG, Subsidized Stafford Loans, and Unsubsidized Stafford Loans—based on documented eligibility and financial need, the actual disbursements were less than the awarded amounts. In several cases, students did not receive the full aid they were eligible for during the designated payment period, resulting in underdisbursement of funds. Questioned costs: $49,565 Context: During our testing, it was noted that 4 of 40 students were underdisbursed Pell, 12 of 40 students were underdisbursed SEOG, 7 of 40 students were underdisbursed Subsidized Stafford Loans, and 5 of 40 students were underdisbursed Unsubsidized Stafford Loans. Cause: The University did not have a process in place to ensure the student were disbursed in accordance with their federal awards. Effect: The University was not in compliance with Title IV aid regulations. Repeat finding: No Recommendation: We recommend the University enhance system controls to ensure disbursements match awards. Views of responsible officials: There is no disagreement with the audit finding.