Audit 389443

2025 - 001 – Common Origination and Disbursement (COD) Reporting Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Assistance Cluster Federal Assistance Listing Number: 84.063 Award Period: 7/1/24-6/30/25 Type of Finding: Significant Deficiency in Internal Control Over Compliance, Other Matters Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 690.83(b)(2) and 34 CFR 685.309 states institutions must report the disbursement dates and amounts to the COD within 15 days of disbursing Pell and Direct Loan funds to students. Condition: One disbursement was not reported to COD within the required timeframe. Questioned Costs: None. Context: During our testing, 1 student out of a sample of 40 had a disbursement that was not reported to COD within the required 15-day timeframe. Cause: The University's process to ensure timely COD reporting was not functioning properly. Effect: The University did not report to the COD within the required timeframe. Repeat Finding: No. Auditors’ Recommendation: We recommend the University evaluate its procedures and review policies in overseeing COD reporting to ensure timely reporting. Views of Responsible Officials: There is no disagreement with the audit finding.

2025 – 002 – National Student Loan Data System (NSLDS) Reporting Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Assistance Cluster Federal Assistance Listing Number: 84.268, 84.063 Award Period: 7/1/24-6/30/25 Type of Finding: Material Weakness in Internal Control over Compliance, Material Noncompliance (Modified Opinion) Criteria or specific requirement: Per U.S. Department of Education (ED) regulations, all schools participating (or approved to participate) in the Federal Student Aid programs must have an arrangement to report student enrollment data to the NSLDS through a roster file. The school is required to report enrollment status at both the school and program level. The school is required to report changes in the student’s enrollment status, the effective date of the status and an anticipated completion date. An academic program is defined as the combination of the school’s Office of Postsecondary Education Identification (OPEID) number and the program’s Classification of Instructional Program (CIP) code, credential level, and published program length. ED requires the University to report changes in enrollment status and indicate the date that the changes occurred (34 CFR 685.309). Changes in enrollment status must be reported within 30 days. However, if a roster file is expected within 60 days, you may provide the date on that roster file. In addition, regulations require that an institution make necessary corrections and return the records within 10 days for any roster files that don’t pass the NSLDS enrollment reporting edits. ED requires the University to report changes in enrollment status within 30 or 60 days that the University determined the changes occurred (34 CFR 682.610). Condition: Certain students’ enrollment information was not reported accurately or timely to the NSLDS. Questioned costs: None. Context: During our testing, we noted the following out of our sample of 40 students tested: • 22 students had effective dates at the campus and program level that did not agree between the University’s records and NSLDS. • 3 students were not reported to the campus level record in NSLDS in a timely manner. At a minimum, schools are required to certify enrollment every 60 days. • 1 student had an effective status at the campus and program level that did not agree between the University records and NSLDS. • 2 students had a program begin date at the program level that did not agree between the University records and NSLDS. Cause: The University’s process in place for timely reporting and updating effective dates within the Banner system were not functioning properly. Effect: Inaccurate reporting to NSLDS can impact when students enter repayment periods or affect their interest rates. Repeat Finding: The finding is a repeat of a finding in the immediately prior year. Prior year finding number was 2024-002. Recommendation: We recommend the University evaluate its policies and procedures around reporting student status changes to NSLDS to ensure that all relevant information is being captured and reported timely in accordance with applicable regulations. Views of responsible officials: There is no disagreement with the audit finding.

2025 - 003 – Return of Title IV Funds Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Assistance Cluster Federal Assistance Listing Number: 84.007, 84.063, 84.268 Award Period: 7/1/24-6/30/25 Type of Finding: Significant Deficiency in Internal Control Over Compliance, Other Matters Criteria or specific requirement: Once a student’s withdrawal date is determined, a school needs to calculate the percentage of the payment period of enrollment completed. Institutionally scheduled breaks of five or more consecutive days are excluded from the R2T4 calculation as periods of nonattendance and, therefore, do not affect the calculation of the amount of Federal Student Aid earned (34 CFR 668.22(f)(2)(i)). The Code of Federal Regulations, 34 CFR 668.22 defines the last date of attendance for schools that are required to take attendance and those that are not required. Condition: The incorrect semester end date was used in the calculation. Questioned costs: $67 Context: During our testing, we noted 4 students out of 12 students tested where the wrong date was used for the last day of the fall semester in the R2T4 calculation. Cause: The University's process in place for identifying semester end dates for R2T4 calculations was not functioning properly. Effect: Inaccurate calculation affects the amount of funds to be returned. Repeat finding: No. Recommendation: We recommend the University evaluate its procedures and policies to ensure correct dates are being used in the calculation and that it is reviewed for accuracy. Views of responsible officials: There is no disagreement with the audit finding.

2025 - 004 – Title IV Outstanding Checks Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Assistance Cluster Federal Assistance Listing Number: 84.007, 84.033, 84.063, 84.268 Award Period: 7/1/24-6/30/25 Type of Finding: Significant Deficiency in Internal Control Over Compliance, Other Matters Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 668.164(l)(3) states that an institution that attempts to disburse funds by check and the check is not cashed, the institution must return the funds to the Secretary no later than 240 days after the date it issued that check. Condition: During our testing of Title IV checks, we noted refunds of Title IV financial aid outstanding more than 240 days not returned to the Department of Ed. Questioned costs: $2,304 Context: During our testing, we noted 14 Title IV checks outstanding over 240 days that were not returned to the Department of Education. Cause: The University did not have a process in place to ensure Title IV checks outstanding more than 240 days were returned within the required timeframe. Effect: The University is not in compliance with Department of Education requirements that all student refund checks that are outstanding for more than 240 days be returned to the Department of Education. Repeat finding: The finding is a repeat of a finding in the immediately prior year. Prior year finding number was 2024-004 Recommendation: We recommend the University review its policies and procedures related to outstanding Title IV checks to ensure they are being returned to the Department of Education after being outstanding more than 240 days. Views of responsible officials: There is no disagreement with the audit finding.