Audit 375536

Federal Program - Federal Direct Student Loans Federal Agency - U.S. Department of Education Pass-Through Entity - Not Applicable Assistance Listing Number - 84.268 Federal Award Number - P268K251776 Federal Award Year - June 30, 2025 Repeat Finding: 2024-001 Criteria: Title IV regulations (34 CFR 668.22) require the University to return the unearned portion of grants or loans to the Title IV program within 45 days after a student withdraws. The Uniform Guidance requires recipients of federal awards to administer its federal programs with an adequate system of internal controls over applicable compliance requirements. Condition/Context: During the year, there was no documented internal controls in place over the Title IV refund calculations. In the sample of 5 students that withdrew from the University, there was one student for which the return was calculated incorrectly. The result was too much aid being refunded. The sample was not a statistically valid sample. Questioned Costs: A total of $251 of subsidized direct loans for one student Cause: The University’s financial aid department has a limited number of individuals, and they experienced turnover during the year. Effect: The University returned incorrect amount to the US Department of Education. Recommendation: The University should document controls in place to ensure R2T4 calculations are complete and accurate. This should include a review of the calculations by someone other than the preparer prior to the refund being issued. Management Response: Due to staff turnover the change as noted in the FY2024 audit was not implemented. Management has now automated and implemented changes in systems controls for all Title IV refund calculations.

Federal Program - Federal Direct Student Loans Federal Agency - U.S. Department of Education Pass-Through Entity - Not Applicable Assistance Listing Number - 84.268 Federal Award Number - P268K251776 Federal Award Year - June 30, 2025 Criteria: Title IV regulations (34 CFR 685.309(b)) require that upon receipt of an enrollment report from the Secretary, institutions must update all information included in the report and return the report to the Secretary: (i) in the manner and format prescribed by the Secretary; and (ii) within the timeframe prescribed by the Secretary. Unless it expects to submit its next updated enrollment report to the Secretary within the next 60 days, an institution must notify the Secretary within 30 days after the date the institution discovers that: (i) a loan under Title IV of the Act was made to or on behalf of a student who was enrolled or accepted for enrollment at the institution, and the student has ceased to be enrolled on at least a half-time basis or failed to enroll on at least a half-time basis for the period for which the loan was intended; or (ii) a student who is enrolled at the institution and who received a loan under Title IV of the Act has changed his or her permanent address. Condition/Context: Of 25 students tested, the status date for one student selected was not reported timely on the campus level reporting in National Student Loan Data System (NSLDS). The sample was not a statistically valid sample. Cause: The University noted the reporting was completed timely to the servicer National Student Clearinghouse (NSC) however was not reflected in NSLDS. Effect: The accuracy of Title IV student loan records depends heavily on the accuracy of the enrollment information reported by schools. If an Institution does not review, update, and verify student enrollment statuses, effective dates of the enrollment status, and the anticipated completion dates, then the Title IV student loan records will be inaccurate. Questions Costs: Not applicable Recommendation: It is recommended that the University review policies and procedures in place to resolve reporting issues in a timely manner to facilitate compliance with Title IV regulations. Management Response: Management has adjusted processes to ensure all student updates are correctly captured.

Federal Program - Federal Direct Student Loans Federal Agency - U.S. Department of Education Pass-Through Entity - Not Applicable Assistance Listing Number - 84.268 Federal Award Number - P268K251776 Federal Award Year - June 30, 2025 Criteria: Prior to making a disbursement, the school must notify students of the amount and type of Title IV funds they are expected to receive, and how and when those disbursements will be made (often referred to as an award letter or college financing plan) (34 CFR 668.165(a)(1)). Additionally, when Direct Loans or TEACH funds are being credited to a student’s account, the institution must notify the student, or parent, in writing of (1) the date and amount of the disbursement; (2) the student’s right, or parent’s right, to cancel all or a portion of that loan or loan disbursement and have the loan proceeds returned to the holder of that loan or the TEACH Grant payments returned to ED; and (3) the procedure and time by which the student or parent must notify the institution that he or she wishes to cancel the loan, TEACH Grant, or TEACH Grant disbursement (a minimum of 14 or 30 days depending on confirmation process). The notification requirement for loan funds applies only if the funds are disbursed by EFT payment or master check (34 CFR 668.165). Condition/Context: Of the sample of 25 disbursements in the sample, seven students tested did not receive proper notification of the student's right, or parent's right to cancel any portion of the loans to be distributed. The sample was not a statistically valid sample. Cause: The University's controls surrounding notification of Title IV disbursements did not appropriately ensure the communications sent to students and parents contained all of the required information. Effect: Students were not properly notified of their student’s right, or their parent’s right, to cancel all or a portion of that loan or loan disbursement and have the loan proceeds returned to the holder of that loan payments returned to ED. Questions Costs: Not applicable Recommendation: The University should revise its procedures to ensure that notifications of Title IV fund disbursements contain all the information required by CFR 668.165. Management Response: Management has updated notification processes to ensure appropriate and timely notifications are sent to students.