Audit 384186

2025-001: Enrollment Reporting Controls– Student Financial Aid Special Test Material Weakness Federal Program: Student Financial Assistance Cluster Federal Agency: Department of Education Federal Award Year: July 1, 2024 - June 30, 2025 Assistance Listing Number(s): Student Financial Assistance Cluster • 84.007 • 84.033 • 84.038 • 84.063 • 84.268 • 84.379 • 93.925 Criteria: To comply with enrollment reporting requirements, institutions must accurately and timely report student enrollment status changes to the National Student Loan Data System (NSLDS) within 60 days of determining the change, as outlined in Federal Regulations 34 CFR 682.610 and 685.309. Auditee requirements contained in Title 2 U.S. Code of Federal Regulations (2 CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, Subpart D – Post Federal Award Requirements, Section 200.303 – Internal Controls, requires the auditee to establish and maintain effective internal control over the Federal award that provides reasonable assurance that the nonfederal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with a framework such as the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: There is no control in place by the College to review information submitted to the NSLDS for student enrollment status changes. The individual performing the submission is able to complete and transmit the data without an independent review or verification by another person, increasing the risk of inaccurate or incomplete information being reported. Cause: Lack of control in place over enrollment status changes reported to the NSLDS. Effect or Potential Effect: Lack of controls in place could result in instances of noncompliance with Department of Education and Federal regulations. Questioned Costs: None Context: While the College ensures accurate status change data is sent to the National Student Clearinghouse (third party who submits enrollment status changes to the NSLDS), the College does not have controls in place to ensure information was submitted to the NSLDS accurately and timely. Repeat Finding: Yes Recommendation: We recommend the College implement controls where there is an independent review of the submissions received by NSLDS to ensure enrollment status changes are reported accurately and timely. Views of Responsible Officials: Management agrees with the finding. See corrective action plan.

2025-002: Return of Title IV Funds Controls Significant Deficiency Federal Program: Student Financial Assistance Cluster Federal Agency: Department of Education Federal Award Year: July 1, 2024 - June 30, 2025 Assistance Listing Number(s): Student Financial Assistance Cluster • 84.007 • 84.033 • 84.038 • 84.063 • 84.268 • 84.379 • 93.925 Criteria: When a student withdraws, institutions must comply with the "Return of Title IV Funds" requirements outlined in 34 CFR 668.22, ensuring any unearned funds are returned to the Department of Education within 45 days of determining the student's withdrawal. Auditee requirements contained in Title 2 U.S. Code of Federal Regulations (2 CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, Subpart D – Post Federal Award Requirements, Section 200.303 – Internal Controls, requires the auditee to establish and maintain effective internal control over the Federal award that provides reasonable assurance that the nonfederal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with a framework such as the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: There is no evidence of a control in place by the College to review Return of Title IV Fund calculations. Cause: Lack of control in place over returns of Title IV funding. Effect or Potential Effect: Returns of Title IV Funds may not be refunded within the 45-day requirement and result in instances of noncompliance with the Department of Education. Questioned Costs: None Context: The College claims to review these calculations; however, there is no evidence that such reviews were conducted or effective. Additionally, there is no retention of documentation demonstrating that an approval or review occurred, making it impossible to verify that the process was properly performed. Repeat Finding: Yes Recommendation: We recommend the College review its process and controls in place for calculating refunds from Title IV and include an independent review and sufficient documentation to support the application of the control. Views of Responsible Officials: Management agrees with the finding. See corrective action plan.