Audit 3911

Criteria According to 34 CFR 690.83(b) (1) An institution shall report to the Secretary any change for which a student qualifies including any related Payment Data changes by submitting to the Secretary the student’s Payment Data that discloses the basis and result of the change in award for each student. The institution shall submit the student’s Payment Data reporting to the Secretary by the reporting deadlines published by the Secretary in the Federal Register. (2) An institution shall submit, in accordance with the deadline dates established by the Secretary, through publication in the Federal Register, other reports and information the Secretary requires and shall comply with the procedures the Secretary finds necessary to ensure that the reports are correct. According to the Federal Register (Volume 83, Number 233): An institution must submit Pell Grant, Iraq and Afghanistan Service Grant, Direct Loan, and TEACH Grant disbursement records to COD, no later than 15 days after making the disbursement or becoming aware of the need to adjust a previously reported disbursement. In accordance with 34 CFR 668.164(a), title IV, Higher Education Act (“HEA”) program funds are disbursed on the date that the institution: (a) Credits those funds to a student’s account in the institution’s general ledger or any subledger of the general ledger; or (b) pays those funds to a student directly. Title IV, HEA program funds are disbursed even if an institution uses its own funds in advance of receiving program funds from the Department. Condition Federal regulations require the Colleges to report to the Federal Government’s Common Origination and Disbursement System (“COD”) Federal Pell Grant and Direct Loan disbursements made to students within 15 days of the funds being disbursed to the student. During our testing, we noted 3 students, out of a sample of 40, that were not reported within the required timeframe by 1 to 9 days. Cause The Colleges have policies and procedures in place to report the disbursement records to the Department of Education through the COD system within the required fifteen calendar days, however, in this case the procedures were not completed properly. Effect The Colleges did not report Pell Grant and Direct Loan disbursements to COD within the required time frame. Identification as a Repeat Finding, if applicable Not applicable Recommendation We recommend that management of the Colleges review, and if necessary, update the policies and procedures to ensure all Pell Grant and Direct Loan funds are reported within the required timeframe. View of Responsible Officials The Colleges agree with the finding. Questioned Costs Not applicable Perspective Our sample was not, and was not intended to be, statistically valid. Of the 40 students selected for testing, 3 students, or 7.5% of our sample, were determined to be reported late to the COD by 1 to 9 days. Identification as a Repeat Finding, if applicable Not applicable Recommendation We recommend that management of the Colleges review, and if necessary, update the policies and procedures to ensure all Pell Grant and Direct Loan funds are reported within the required timeframe. View of Responsible Officials The Colleges agree with the finding.

Criteria According to 34 CFR 690.83(b) (1) An institution shall report to the Secretary any change for which a student qualifies including any related Payment Data changes by submitting to the Secretary the student’s Payment Data that discloses the basis and result of the change in award for each student. The institution shall submit the student’s Payment Data reporting to the Secretary by the reporting deadlines published by the Secretary in the Federal Register. (2) An institution shall submit, in accordance with the deadline dates established by the Secretary, through publication in the Federal Register, other reports and information the Secretary requires and shall comply with the procedures the Secretary finds necessary to ensure that the reports are correct. According to the Federal Register (Volume 83, Number 233): An institution must submit Pell Grant, Iraq and Afghanistan Service Grant, Direct Loan, and TEACH Grant disbursement records to COD, no later than 15 days after making the disbursement or becoming aware of the need to adjust a previously reported disbursement. In accordance with 34 CFR 668.164(a), title IV, Higher Education Act (“HEA”) program funds are disbursed on the date that the institution: (a) Credits those funds to a student’s account in the institution’s general ledger or any subledger of the general ledger; or (b) pays those funds to a student directly. Title IV, HEA program funds are disbursed even if an institution uses its own funds in advance of receiving program funds from the Department. Condition Federal regulations require the Colleges to report to the Federal Government’s Common Origination and Disbursement System (“COD”) Federal Pell Grant and Direct Loan disbursements made to students within 15 days of the funds being disbursed to the student. During our testing, we noted 3 students, out of a sample of 40, that were not reported within the required timeframe by 1 to 9 days. Cause The Colleges have policies and procedures in place to report the disbursement records to the Department of Education through the COD system within the required fifteen calendar days, however, in this case the procedures were not completed properly. Effect The Colleges did not report Pell Grant and Direct Loan disbursements to COD within the required time frame. Identification as a Repeat Finding, if applicable Not applicable Recommendation We recommend that management of the Colleges review, and if necessary, update the policies and procedures to ensure all Pell Grant and Direct Loan funds are reported within the required timeframe. View of Responsible Officials The Colleges agree with the finding. Questioned Costs Not applicable Perspective Our sample was not, and was not intended to be, statistically valid. Of the 40 students selected for testing, 3 students, or 7.5% of our sample, were determined to be reported late to the COD by 1 to 9 days. Identification as a Repeat Finding, if applicable Not applicable Recommendation We recommend that management of the Colleges review, and if necessary, update the policies and procedures to ensure all Pell Grant and Direct Loan funds are reported within the required timeframe. View of Responsible Officials The Colleges agree with the finding.

Criteria According to 34 CFR 690.83(b) (1) An institution shall report to the Secretary any change for which a student qualifies including any related Payment Data changes by submitting to the Secretary the student’s Payment Data that discloses the basis and result of the change in award for each student. The institution shall submit the student’s Payment Data reporting to the Secretary by the reporting deadlines published by the Secretary in the Federal Register. (2) An institution shall submit, in accordance with the deadline dates established by the Secretary, through publication in the Federal Register, other reports and information the Secretary requires and shall comply with the procedures the Secretary finds necessary to ensure that the reports are correct. According to the Federal Register (Volume 83, Number 233): An institution must submit Pell Grant, Iraq and Afghanistan Service Grant, Direct Loan, and TEACH Grant disbursement records to COD, no later than 15 days after making the disbursement or becoming aware of the need to adjust a previously reported disbursement. In accordance with 34 CFR 668.164(a), title IV, Higher Education Act (“HEA”) program funds are disbursed on the date that the institution: (a) Credits those funds to a student’s account in the institution’s general ledger or any subledger of the general ledger; or (b) pays those funds to a student directly. Title IV, HEA program funds are disbursed even if an institution uses its own funds in advance of receiving program funds from the Department. Condition Federal regulations require the Colleges to report to the Federal Government’s Common Origination and Disbursement System (“COD”) Federal Pell Grant and Direct Loan disbursements made to students within 15 days of the funds being disbursed to the student. During our testing, we noted 3 students, out of a sample of 40, that were not reported within the required timeframe by 1 to 9 days. Cause The Colleges have policies and procedures in place to report the disbursement records to the Department of Education through the COD system within the required fifteen calendar days, however, in this case the procedures were not completed properly. Effect The Colleges did not report Pell Grant and Direct Loan disbursements to COD within the required time frame. Identification as a Repeat Finding, if applicable Not applicable Recommendation We recommend that management of the Colleges review, and if necessary, update the policies and procedures to ensure all Pell Grant and Direct Loan funds are reported within the required timeframe. View of Responsible Officials The Colleges agree with the finding. Questioned Costs Not applicable Perspective Our sample was not, and was not intended to be, statistically valid. Of the 40 students selected for testing, 3 students, or 7.5% of our sample, were determined to be reported late to the COD by 1 to 9 days. Identification as a Repeat Finding, if applicable Not applicable Recommendation We recommend that management of the Colleges review, and if necessary, update the policies and procedures to ensure all Pell Grant and Direct Loan funds are reported within the required timeframe. View of Responsible Officials The Colleges agree with the finding.

Criteria According to 34 CFR 690.83(b) (1) An institution shall report to the Secretary any change for which a student qualifies including any related Payment Data changes by submitting to the Secretary the student’s Payment Data that discloses the basis and result of the change in award for each student. The institution shall submit the student’s Payment Data reporting to the Secretary by the reporting deadlines published by the Secretary in the Federal Register. (2) An institution shall submit, in accordance with the deadline dates established by the Secretary, through publication in the Federal Register, other reports and information the Secretary requires and shall comply with the procedures the Secretary finds necessary to ensure that the reports are correct. According to the Federal Register (Volume 83, Number 233): An institution must submit Pell Grant, Iraq and Afghanistan Service Grant, Direct Loan, and TEACH Grant disbursement records to COD, no later than 15 days after making the disbursement or becoming aware of the need to adjust a previously reported disbursement. In accordance with 34 CFR 668.164(a), title IV, Higher Education Act (“HEA”) program funds are disbursed on the date that the institution: (a) Credits those funds to a student’s account in the institution’s general ledger or any subledger of the general ledger; or (b) pays those funds to a student directly. Title IV, HEA program funds are disbursed even if an institution uses its own funds in advance of receiving program funds from the Department. Condition Federal regulations require the Colleges to report to the Federal Government’s Common Origination and Disbursement System (“COD”) Federal Pell Grant and Direct Loan disbursements made to students within 15 days of the funds being disbursed to the student. During our testing, we noted 3 students, out of a sample of 40, that were not reported within the required timeframe by 1 to 9 days. Cause The Colleges have policies and procedures in place to report the disbursement records to the Department of Education through the COD system within the required fifteen calendar days, however, in this case the procedures were not completed properly. Effect The Colleges did not report Pell Grant and Direct Loan disbursements to COD within the required time frame. Identification as a Repeat Finding, if applicable Not applicable Recommendation We recommend that management of the Colleges review, and if necessary, update the policies and procedures to ensure all Pell Grant and Direct Loan funds are reported within the required timeframe. View of Responsible Officials The Colleges agree with the finding. Questioned Costs Not applicable Perspective Our sample was not, and was not intended to be, statistically valid. Of the 40 students selected for testing, 3 students, or 7.5% of our sample, were determined to be reported late to the COD by 1 to 9 days. Identification as a Repeat Finding, if applicable Not applicable Recommendation We recommend that management of the Colleges review, and if necessary, update the policies and procedures to ensure all Pell Grant and Direct Loan funds are reported within the required timeframe. View of Responsible Officials The Colleges agree with the finding.

Criteria According to 34 CFR 668.34: (a) An institution must establish a reasonable satisfactory academic progress policy for determining whether an otherwise eligible student is making satisfactory academic progress in his or her educational program and may receive assistance under the title IV, HEA programs. (9) If the institution permits a student to appeal a determination by the institution that he or she is not making satisfactory academic progress, the policy describes – (i) How the student may reestablish his or her eligibility to receive assistance under the title IV, HEA programs; (ii) The basis on which a student may file an appeal: The death of a relative, an injury or illness of the student, or other special circumstances; and (iii) Information the student must submit regarding why the student failed to make satisfactory academic progress, and what has changed in the student's situation that will allow the student to demonstrate satisfactory academic progress at the next evaluation. Condition The Colleges’ satisfactory academic progress policy (“SAP”) allows for a student who fails to meet the minimum standard to be provided one semester of academic warning. If the student does not improve, as described in the Colleges’ SAP, the student will be dismissed from the Colleges unless the student successfully appeals the dismissal. Our testing revealed that four students failed to meet the minimum standards established by the Colleges’ SAP. Of these four students, one student did not receive notification that they were out of compliance of the Colleges’ SAP. Cause The Colleges failed to have the proper review procedures in place to ensure that all students who did not meet the minimum SAP standards received proper notification. Effect Students did not receive notification of their current academic standing and as such were unable to submit an appeal. Questioned Costs Not applicable Perspective Our sample was not, and was not intended to be, statistically valid. Of the 40 students selected for testing, 1 student, or 2.5%, failed to meet the minimum standards established by the Colleges’ SAP. Identification as a Repeat Finding, if applicable Not applicable Recommendation The Colleges should continue to strengthen their controls surrounding notification to students who have failed to meet the minimum standards per the SAP. View of Responsible Officials The Colleges agree with the finding.

Criteria According to 34 CFR 668.34: (a) An institution must establish a reasonable satisfactory academic progress policy for determining whether an otherwise eligible student is making satisfactory academic progress in his or her educational program and may receive assistance under the title IV, HEA programs. (9) If the institution permits a student to appeal a determination by the institution that he or she is not making satisfactory academic progress, the policy describes – (i) How the student may reestablish his or her eligibility to receive assistance under the title IV, HEA programs; (ii) The basis on which a student may file an appeal: The death of a relative, an injury or illness of the student, or other special circumstances; and (iii) Information the student must submit regarding why the student failed to make satisfactory academic progress, and what has changed in the student's situation that will allow the student to demonstrate satisfactory academic progress at the next evaluation. Condition The Colleges’ satisfactory academic progress policy (“SAP”) allows for a student who fails to meet the minimum standard to be provided one semester of academic warning. If the student does not improve, as described in the Colleges’ SAP, the student will be dismissed from the Colleges unless the student successfully appeals the dismissal. Our testing revealed that four students failed to meet the minimum standards established by the Colleges’ SAP. Of these four students, one student did not receive notification that they were out of compliance of the Colleges’ SAP. Cause The Colleges failed to have the proper review procedures in place to ensure that all students who did not meet the minimum SAP standards received proper notification. Effect Students did not receive notification of their current academic standing and as such were unable to submit an appeal. Questioned Costs Not applicable Perspective Our sample was not, and was not intended to be, statistically valid. Of the 40 students selected for testing, 1 student, or 2.5%, failed to meet the minimum standards established by the Colleges’ SAP. Identification as a Repeat Finding, if applicable Not applicable Recommendation The Colleges should continue to strengthen their controls surrounding notification to students who have failed to meet the minimum standards per the SAP. View of Responsible Officials The Colleges agree with the finding.

Criteria According to 34 CFR 668.34: (a) An institution must establish a reasonable satisfactory academic progress policy for determining whether an otherwise eligible student is making satisfactory academic progress in his or her educational program and may receive assistance under the title IV, HEA programs. (9) If the institution permits a student to appeal a determination by the institution that he or she is not making satisfactory academic progress, the policy describes – (i) How the student may reestablish his or her eligibility to receive assistance under the title IV, HEA programs; (ii) The basis on which a student may file an appeal: The death of a relative, an injury or illness of the student, or other special circumstances; and (iii) Information the student must submit regarding why the student failed to make satisfactory academic progress, and what has changed in the student's situation that will allow the student to demonstrate satisfactory academic progress at the next evaluation. Condition The Colleges’ satisfactory academic progress policy (“SAP”) allows for a student who fails to meet the minimum standard to be provided one semester of academic warning. If the student does not improve, as described in the Colleges’ SAP, the student will be dismissed from the Colleges unless the student successfully appeals the dismissal. Our testing revealed that four students failed to meet the minimum standards established by the Colleges’ SAP. Of these four students, one student did not receive notification that they were out of compliance of the Colleges’ SAP. Cause The Colleges failed to have the proper review procedures in place to ensure that all students who did not meet the minimum SAP standards received proper notification. Effect Students did not receive notification of their current academic standing and as such were unable to submit an appeal. Questioned Costs Not applicable Perspective Our sample was not, and was not intended to be, statistically valid. Of the 40 students selected for testing, 1 student, or 2.5%, failed to meet the minimum standards established by the Colleges’ SAP. Identification as a Repeat Finding, if applicable Not applicable Recommendation The Colleges should continue to strengthen their controls surrounding notification to students who have failed to meet the minimum standards per the SAP. View of Responsible Officials The Colleges agree with the finding.

Criteria According to 34 CFR 668.34: (a) An institution must establish a reasonable satisfactory academic progress policy for determining whether an otherwise eligible student is making satisfactory academic progress in his or her educational program and may receive assistance under the title IV, HEA programs. (9) If the institution permits a student to appeal a determination by the institution that he or she is not making satisfactory academic progress, the policy describes – (i) How the student may reestablish his or her eligibility to receive assistance under the title IV, HEA programs; (ii) The basis on which a student may file an appeal: The death of a relative, an injury or illness of the student, or other special circumstances; and (iii) Information the student must submit regarding why the student failed to make satisfactory academic progress, and what has changed in the student's situation that will allow the student to demonstrate satisfactory academic progress at the next evaluation. Condition The Colleges’ satisfactory academic progress policy (“SAP”) allows for a student who fails to meet the minimum standard to be provided one semester of academic warning. If the student does not improve, as described in the Colleges’ SAP, the student will be dismissed from the Colleges unless the student successfully appeals the dismissal. Our testing revealed that four students failed to meet the minimum standards established by the Colleges’ SAP. Of these four students, one student did not receive notification that they were out of compliance of the Colleges’ SAP. Cause The Colleges failed to have the proper review procedures in place to ensure that all students who did not meet the minimum SAP standards received proper notification. Effect Students did not receive notification of their current academic standing and as such were unable to submit an appeal. Questioned Costs Not applicable Perspective Our sample was not, and was not intended to be, statistically valid. Of the 40 students selected for testing, 1 student, or 2.5%, failed to meet the minimum standards established by the Colleges’ SAP. Identification as a Repeat Finding, if applicable Not applicable Recommendation The Colleges should continue to strengthen their controls surrounding notification to students who have failed to meet the minimum standards per the SAP. View of Responsible Officials The Colleges agree with the finding.

Criteria According to 34 CFR 668.22(c): Withdrawal date for a student who withdraws from an institution that is not required to take attendance. For purposes of this section, for a student who ceases attendance at an institution that is not required to take attendance, the student’s withdrawal date is – (i) The date, as determined by the institution, that the student began the withdrawal process prescribed by the institution; (ii) The date, as determined by the institution, that the student otherwise provided official notification to the institution, in writing or orally, of his or her intent to withdraw; (iii) If the student ceases attendance without providing official notification to the institution of his or her withdrawal in accordance with paragraph (c)(1)(i) or (c)(1)(ii) of this section, the mid-point of the payment period (or period of enrollment, if applicable). Condition When a recipient of Title IV funds withdraws from an institution during a payment period or period of enrollment in which the recipient began attendance, the institution should determine the proper amount of Title IV funds to be refunded as of the recipient’s withdrawal date. Once a recipient’s withdrawal date is determined, an institution should complete a Return of Title IV (“R2T4”) calculation. The R2T4 is used to calculate the percentage of the payment period or period of enrollment completed, establish the amount of Title IV funds earned by the recipient, and determine the amount required to be returned to the Department of Education. During our testing, we noted 1 student, out of a sample of 40, where the Return of Title IV calculation was completed using incorrect withdrawal dates. Cause When completing the R2T4 calculation, the Colleges used the date the student’s withdrawal was processed by the Colleges instead of the actual date the student withdrew from the Colleges. Effect The Colleges calculated the student’s percentage of earned aid incorrectly which resulted in an incorrect amount of Title IV funds returned to the Department of Education. Questioned Costs Unknown Perspective Our sample was not, and was not intended to be, statistically valid. Of the 40 students selected for testing, 1 student, or 2.5% of our sample, used the incorrect withdrawal date when completing the Return of Title IV calculation. Identification as a Repeat Finding, if applicable Not applicable Recommendation The Colleges should implement a formal review process of the Return of Title IV calculations to ensure an accurate calculation is made. View of Responsible Officials The Colleges agree with the finding.

Criteria According to 34 CFR 668.22(c): Withdrawal date for a student who withdraws from an institution that is not required to take attendance. For purposes of this section, for a student who ceases attendance at an institution that is not required to take attendance, the student’s withdrawal date is – (i) The date, as determined by the institution, that the student began the withdrawal process prescribed by the institution; (ii) The date, as determined by the institution, that the student otherwise provided official notification to the institution, in writing or orally, of his or her intent to withdraw; (iii) If the student ceases attendance without providing official notification to the institution of his or her withdrawal in accordance with paragraph (c)(1)(i) or (c)(1)(ii) of this section, the mid-point of the payment period (or period of enrollment, if applicable). Condition When a recipient of Title IV funds withdraws from an institution during a payment period or period of enrollment in which the recipient began attendance, the institution should determine the proper amount of Title IV funds to be refunded as of the recipient’s withdrawal date. Once a recipient’s withdrawal date is determined, an institution should complete a Return of Title IV (“R2T4”) calculation. The R2T4 is used to calculate the percentage of the payment period or period of enrollment completed, establish the amount of Title IV funds earned by the recipient, and determine the amount required to be returned to the Department of Education. During our testing, we noted 1 student, out of a sample of 40, where the Return of Title IV calculation was completed using incorrect withdrawal dates. Cause When completing the R2T4 calculation, the Colleges used the date the student’s withdrawal was processed by the Colleges instead of the actual date the student withdrew from the Colleges. Effect The Colleges calculated the student’s percentage of earned aid incorrectly which resulted in an incorrect amount of Title IV funds returned to the Department of Education. Questioned Costs Unknown Perspective Our sample was not, and was not intended to be, statistically valid. Of the 40 students selected for testing, 1 student, or 2.5% of our sample, used the incorrect withdrawal date when completing the Return of Title IV calculation. Identification as a Repeat Finding, if applicable Not applicable Recommendation The Colleges should implement a formal review process of the Return of Title IV calculations to ensure an accurate calculation is made. View of Responsible Officials The Colleges agree with the finding.

Criteria According to 34 CFR 668.22(c): Withdrawal date for a student who withdraws from an institution that is not required to take attendance. For purposes of this section, for a student who ceases attendance at an institution that is not required to take attendance, the student’s withdrawal date is – (i) The date, as determined by the institution, that the student began the withdrawal process prescribed by the institution; (ii) The date, as determined by the institution, that the student otherwise provided official notification to the institution, in writing or orally, of his or her intent to withdraw; (iii) If the student ceases attendance without providing official notification to the institution of his or her withdrawal in accordance with paragraph (c)(1)(i) or (c)(1)(ii) of this section, the mid-point of the payment period (or period of enrollment, if applicable). Condition When a recipient of Title IV funds withdraws from an institution during a payment period or period of enrollment in which the recipient began attendance, the institution should determine the proper amount of Title IV funds to be refunded as of the recipient’s withdrawal date. Once a recipient’s withdrawal date is determined, an institution should complete a Return of Title IV (“R2T4”) calculation. The R2T4 is used to calculate the percentage of the payment period or period of enrollment completed, establish the amount of Title IV funds earned by the recipient, and determine the amount required to be returned to the Department of Education. During our testing, we noted 1 student, out of a sample of 40, where the Return of Title IV calculation was completed using incorrect withdrawal dates. Cause When completing the R2T4 calculation, the Colleges used the date the student’s withdrawal was processed by the Colleges instead of the actual date the student withdrew from the Colleges. Effect The Colleges calculated the student’s percentage of earned aid incorrectly which resulted in an incorrect amount of Title IV funds returned to the Department of Education. Questioned Costs Unknown Perspective Our sample was not, and was not intended to be, statistically valid. Of the 40 students selected for testing, 1 student, or 2.5% of our sample, used the incorrect withdrawal date when completing the Return of Title IV calculation. Identification as a Repeat Finding, if applicable Not applicable Recommendation The Colleges should implement a formal review process of the Return of Title IV calculations to ensure an accurate calculation is made. View of Responsible Officials The Colleges agree with the finding.

Criteria According to 34 CFR 668.22(c): Withdrawal date for a student who withdraws from an institution that is not required to take attendance. For purposes of this section, for a student who ceases attendance at an institution that is not required to take attendance, the student’s withdrawal date is – (i) The date, as determined by the institution, that the student began the withdrawal process prescribed by the institution; (ii) The date, as determined by the institution, that the student otherwise provided official notification to the institution, in writing or orally, of his or her intent to withdraw; (iii) If the student ceases attendance without providing official notification to the institution of his or her withdrawal in accordance with paragraph (c)(1)(i) or (c)(1)(ii) of this section, the mid-point of the payment period (or period of enrollment, if applicable). Condition When a recipient of Title IV funds withdraws from an institution during a payment period or period of enrollment in which the recipient began attendance, the institution should determine the proper amount of Title IV funds to be refunded as of the recipient’s withdrawal date. Once a recipient’s withdrawal date is determined, an institution should complete a Return of Title IV (“R2T4”) calculation. The R2T4 is used to calculate the percentage of the payment period or period of enrollment completed, establish the amount of Title IV funds earned by the recipient, and determine the amount required to be returned to the Department of Education. During our testing, we noted 1 student, out of a sample of 40, where the Return of Title IV calculation was completed using incorrect withdrawal dates. Cause When completing the R2T4 calculation, the Colleges used the date the student’s withdrawal was processed by the Colleges instead of the actual date the student withdrew from the Colleges. Effect The Colleges calculated the student’s percentage of earned aid incorrectly which resulted in an incorrect amount of Title IV funds returned to the Department of Education. Questioned Costs Unknown Perspective Our sample was not, and was not intended to be, statistically valid. Of the 40 students selected for testing, 1 student, or 2.5% of our sample, used the incorrect withdrawal date when completing the Return of Title IV calculation. Identification as a Repeat Finding, if applicable Not applicable Recommendation The Colleges should implement a formal review process of the Return of Title IV calculations to ensure an accurate calculation is made. View of Responsible Officials The Colleges agree with the finding.

Criteria According to 34 CFR 668.22(j)(1): Timeframe for the return of title IV funds. An institution must return the amount of title IV funds for which it is responsible under paragraph (g) of this section as soon as possible but no later than 45 days after the date of the institution's determination that the student withdrew as defined in paragraph (l)(3) of this section. According to 34 CFR 668.173(b): Timely return of Title IV, HEA program funds. In accordance with procedures established by the Secretary or Federal Family Education Loan (“FFEL”) program lender, an institution returns unearned Title IV, HEA program funds timely if – (1) The institution deposits or transfers the funds into the bank account it maintains under 34 CFR Sections 668.163 no later than 45 days after the date it determines the student withdrew; (2) The institution initiates an electronic funds transfer no later than 45 days after the date it determines that the student withdrew; (3) The institution initiates an electronic transaction no later than 45 days after the date it determines that the student withdrew, that informs a FFEL lender to adjust the borrower’s loan account for the amount returned; or (4) The institution issues a check no later than 45 days after the date it determines that the student withdrew. An institution does not satisfy this requirement if – (i) The institution’s records show that the check was issued more than 45 days after the date the institution determined the student withdrew; or (ii) The date on the cancelled check shows that the bank used by the Secretary or FFEL Program lender endorsed that check more than 60 days after the date the institution determined that the student withdrew. Condition Federal regulations state that any unearned Title IV grant or loan assistance received by a student must be refunded to the Title IV programs upon a student’s withdrawal from the institution. The Colleges have 45 days from the date they determined the student withdrew to return any unearned portions of Title IV funds. During our testing, we noted 3 students, out of a sample of 40, had unearned Title IV aid that was not returned to the Federal Government, within 45 days of the determined withdrawal date, by 20 to 74 days. Cause The Colleges did not consistently follow the procedures in place to monitor student withdrawals related to Title IV funds that must be returned to the Department of Education within 45 days. Effect The Colleges did not return unearned Title IV funds within the required 45-day time frame. Questioned Costs Not applicable Perspective Our sample was not, and was not intended to be, statistically valid. Of the 40 students selected for testing, 3 students, or 7.5% of our sample, had unearned Title IV funds that were not returned to the Department of Education within the 45-day required time frame. Identification as a Repeat Finding, if applicable Not applicable Recommendation The Colleges should strengthen their controls surrounding the review Return of Title IV calculations in a timely manner to ensure that all funds are returned to the Department of Education within the required time frame. View of Responsible Officials The Colleges agree with the finding.

Criteria According to 34 CFR 668.22(j)(1): Timeframe for the return of title IV funds. An institution must return the amount of title IV funds for which it is responsible under paragraph (g) of this section as soon as possible but no later than 45 days after the date of the institution's determination that the student withdrew as defined in paragraph (l)(3) of this section. According to 34 CFR 668.173(b): Timely return of Title IV, HEA program funds. In accordance with procedures established by the Secretary or Federal Family Education Loan (“FFEL”) program lender, an institution returns unearned Title IV, HEA program funds timely if – (1) The institution deposits or transfers the funds into the bank account it maintains under 34 CFR Sections 668.163 no later than 45 days after the date it determines the student withdrew; (2) The institution initiates an electronic funds transfer no later than 45 days after the date it determines that the student withdrew; (3) The institution initiates an electronic transaction no later than 45 days after the date it determines that the student withdrew, that informs a FFEL lender to adjust the borrower’s loan account for the amount returned; or (4) The institution issues a check no later than 45 days after the date it determines that the student withdrew. An institution does not satisfy this requirement if – (i) The institution’s records show that the check was issued more than 45 days after the date the institution determined the student withdrew; or (ii) The date on the cancelled check shows that the bank used by the Secretary or FFEL Program lender endorsed that check more than 60 days after the date the institution determined that the student withdrew. Condition Federal regulations state that any unearned Title IV grant or loan assistance received by a student must be refunded to the Title IV programs upon a student’s withdrawal from the institution. The Colleges have 45 days from the date they determined the student withdrew to return any unearned portions of Title IV funds. During our testing, we noted 3 students, out of a sample of 40, had unearned Title IV aid that was not returned to the Federal Government, within 45 days of the determined withdrawal date, by 20 to 74 days. Cause The Colleges did not consistently follow the procedures in place to monitor student withdrawals related to Title IV funds that must be returned to the Department of Education within 45 days. Effect The Colleges did not return unearned Title IV funds within the required 45-day time frame. Questioned Costs Not applicable Perspective Our sample was not, and was not intended to be, statistically valid. Of the 40 students selected for testing, 3 students, or 7.5% of our sample, had unearned Title IV funds that were not returned to the Department of Education within the 45-day required time frame. Identification as a Repeat Finding, if applicable Not applicable Recommendation The Colleges should strengthen their controls surrounding the review Return of Title IV calculations in a timely manner to ensure that all funds are returned to the Department of Education within the required time frame. View of Responsible Officials The Colleges agree with the finding.

Criteria According to 34 CFR 668.22(j)(1): Timeframe for the return of title IV funds. An institution must return the amount of title IV funds for which it is responsible under paragraph (g) of this section as soon as possible but no later than 45 days after the date of the institution's determination that the student withdrew as defined in paragraph (l)(3) of this section. According to 34 CFR 668.173(b): Timely return of Title IV, HEA program funds. In accordance with procedures established by the Secretary or Federal Family Education Loan (“FFEL”) program lender, an institution returns unearned Title IV, HEA program funds timely if – (1) The institution deposits or transfers the funds into the bank account it maintains under 34 CFR Sections 668.163 no later than 45 days after the date it determines the student withdrew; (2) The institution initiates an electronic funds transfer no later than 45 days after the date it determines that the student withdrew; (3) The institution initiates an electronic transaction no later than 45 days after the date it determines that the student withdrew, that informs a FFEL lender to adjust the borrower’s loan account for the amount returned; or (4) The institution issues a check no later than 45 days after the date it determines that the student withdrew. An institution does not satisfy this requirement if – (i) The institution’s records show that the check was issued more than 45 days after the date the institution determined the student withdrew; or (ii) The date on the cancelled check shows that the bank used by the Secretary or FFEL Program lender endorsed that check more than 60 days after the date the institution determined that the student withdrew. Condition Federal regulations state that any unearned Title IV grant or loan assistance received by a student must be refunded to the Title IV programs upon a student’s withdrawal from the institution. The Colleges have 45 days from the date they determined the student withdrew to return any unearned portions of Title IV funds. During our testing, we noted 3 students, out of a sample of 40, had unearned Title IV aid that was not returned to the Federal Government, within 45 days of the determined withdrawal date, by 20 to 74 days. Cause The Colleges did not consistently follow the procedures in place to monitor student withdrawals related to Title IV funds that must be returned to the Department of Education within 45 days. Effect The Colleges did not return unearned Title IV funds within the required 45-day time frame. Questioned Costs Not applicable Perspective Our sample was not, and was not intended to be, statistically valid. Of the 40 students selected for testing, 3 students, or 7.5% of our sample, had unearned Title IV funds that were not returned to the Department of Education within the 45-day required time frame. Identification as a Repeat Finding, if applicable Not applicable Recommendation The Colleges should strengthen their controls surrounding the review Return of Title IV calculations in a timely manner to ensure that all funds are returned to the Department of Education within the required time frame. View of Responsible Officials The Colleges agree with the finding.

Criteria According to 34 CFR 668.22(j)(1): Timeframe for the return of title IV funds. An institution must return the amount of title IV funds for which it is responsible under paragraph (g) of this section as soon as possible but no later than 45 days after the date of the institution's determination that the student withdrew as defined in paragraph (l)(3) of this section. According to 34 CFR 668.173(b): Timely return of Title IV, HEA program funds. In accordance with procedures established by the Secretary or Federal Family Education Loan (“FFEL”) program lender, an institution returns unearned Title IV, HEA program funds timely if – (1) The institution deposits or transfers the funds into the bank account it maintains under 34 CFR Sections 668.163 no later than 45 days after the date it determines the student withdrew; (2) The institution initiates an electronic funds transfer no later than 45 days after the date it determines that the student withdrew; (3) The institution initiates an electronic transaction no later than 45 days after the date it determines that the student withdrew, that informs a FFEL lender to adjust the borrower’s loan account for the amount returned; or (4) The institution issues a check no later than 45 days after the date it determines that the student withdrew. An institution does not satisfy this requirement if – (i) The institution’s records show that the check was issued more than 45 days after the date the institution determined the student withdrew; or (ii) The date on the cancelled check shows that the bank used by the Secretary or FFEL Program lender endorsed that check more than 60 days after the date the institution determined that the student withdrew. Condition Federal regulations state that any unearned Title IV grant or loan assistance received by a student must be refunded to the Title IV programs upon a student’s withdrawal from the institution. The Colleges have 45 days from the date they determined the student withdrew to return any unearned portions of Title IV funds. During our testing, we noted 3 students, out of a sample of 40, had unearned Title IV aid that was not returned to the Federal Government, within 45 days of the determined withdrawal date, by 20 to 74 days. Cause The Colleges did not consistently follow the procedures in place to monitor student withdrawals related to Title IV funds that must be returned to the Department of Education within 45 days. Effect The Colleges did not return unearned Title IV funds within the required 45-day time frame. Questioned Costs Not applicable Perspective Our sample was not, and was not intended to be, statistically valid. Of the 40 students selected for testing, 3 students, or 7.5% of our sample, had unearned Title IV funds that were not returned to the Department of Education within the 45-day required time frame. Identification as a Repeat Finding, if applicable Not applicable Recommendation The Colleges should strengthen their controls surrounding the review Return of Title IV calculations in a timely manner to ensure that all funds are returned to the Department of Education within the required time frame. View of Responsible Officials The Colleges agree with the finding.

Criteria According to 34 CFR 685.309(b)(2): Unless the Colleges expects to submit its next updated enrollment report to the Secretary within the next 60 days, a school must notify the Secretary within 30 days after the date the school 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 school, 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 school and who received a loan under Title IV of the Act has changed his or her permanent address. The Dear Colleague Letter GEN-12-6 issued by the U.S. Department of Education (“ED”) on March 30, 2012 states that in addition to student loan borrowers, Enrollment Reporting files will include two additional groups of students: Pell Grant and Perkins Loan recipients. According to 2 CFR Part 200, Appendix XI Compliance Supplement updated June 2019: Under the Pell Grant and loan programs, institutions must complete and return within 15 days the Enrollment Reporting roster file placed in their Student Aid Internet Gateway mailboxes sent by ED via the National Student Loan Data System (“NSLDS”). The institution determines how often it receives the Enrollment Reporting roster file with the default set at a minimum of every 60 days. Once received, the institution must update for changes in student status, report the date the enrollment status was effective, enter the new anticipated completion date, and submit the changes electronically through the batch method or the NSLDS website. Institutions are responsible for timely reporting, whether they report directly or via a third-party servicer. Condition The Federal Government requires the Colleges to report student enrollment changes to the National Student Loan Data System (“NSLDS”) within 60 days. During our testing, 5 out of 40 students were reported late to the NSLDS by 3 to 168 days. During our testing, 2 out of 40 students reported incorrect effective dates, and 1 out of 40 students had an incorrect status reported to the NSLDS. Cause The Colleges did not have the proper review procedures in place to ensure enrollment status changes were being reported to NSLDS timely and correctly. Effect The Colleges did not report the students' correct effective dates to NSLDS or were not reported within the required timeframe, which may impact the students’ loan grace periods. Questioned Costs Not applicable Perspective Our sample was not, and was not intended to be, statistically valid. Of the 40 students selected for testing, 7 students, or 17.5% of our sample, did not report the correct effective dates to NSLDS or were not reported within the required timeframe. Identification as a Repeat Finding, if applicable See prior year finding 2022-001 Recommendation The Colleges should strengthen their controls surrounding the review of the NSLDS reporting process to ensure they are in compliance with federal regulations. View of Responsible Officials The Colleges agree with the finding.

Criteria According to 34 CFR 685.309(b)(2): Unless the Colleges expects to submit its next updated enrollment report to the Secretary within the next 60 days, a school must notify the Secretary within 30 days after the date the school 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 school, 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 school and who received a loan under Title IV of the Act has changed his or her permanent address. The Dear Colleague Letter GEN-12-6 issued by the U.S. Department of Education (“ED”) on March 30, 2012 states that in addition to student loan borrowers, Enrollment Reporting files will include two additional groups of students: Pell Grant and Perkins Loan recipients. According to 2 CFR Part 200, Appendix XI Compliance Supplement updated June 2019: Under the Pell Grant and loan programs, institutions must complete and return within 15 days the Enrollment Reporting roster file placed in their Student Aid Internet Gateway mailboxes sent by ED via the National Student Loan Data System (“NSLDS”). The institution determines how often it receives the Enrollment Reporting roster file with the default set at a minimum of every 60 days. Once received, the institution must update for changes in student status, report the date the enrollment status was effective, enter the new anticipated completion date, and submit the changes electronically through the batch method or the NSLDS website. Institutions are responsible for timely reporting, whether they report directly or via a third-party servicer. Condition The Federal Government requires the Colleges to report student enrollment changes to the National Student Loan Data System (“NSLDS”) within 60 days. During our testing, 5 out of 40 students were reported late to the NSLDS by 3 to 168 days. During our testing, 2 out of 40 students reported incorrect effective dates, and 1 out of 40 students had an incorrect status reported to the NSLDS. Cause The Colleges did not have the proper review procedures in place to ensure enrollment status changes were being reported to NSLDS timely and correctly. Effect The Colleges did not report the students' correct effective dates to NSLDS or were not reported within the required timeframe, which may impact the students’ loan grace periods. Questioned Costs Not applicable Perspective Our sample was not, and was not intended to be, statistically valid. Of the 40 students selected for testing, 7 students, or 17.5% of our sample, did not report the correct effective dates to NSLDS or were not reported within the required timeframe. Identification as a Repeat Finding, if applicable See prior year finding 2022-001 Recommendation The Colleges should strengthen their controls surrounding the review of the NSLDS reporting process to ensure they are in compliance with federal regulations. View of Responsible Officials The Colleges agree with the finding.

Criteria According to 34 CFR 685.309(b)(2): Unless the Colleges expects to submit its next updated enrollment report to the Secretary within the next 60 days, a school must notify the Secretary within 30 days after the date the school 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 school, 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 school and who received a loan under Title IV of the Act has changed his or her permanent address. The Dear Colleague Letter GEN-12-6 issued by the U.S. Department of Education (“ED”) on March 30, 2012 states that in addition to student loan borrowers, Enrollment Reporting files will include two additional groups of students: Pell Grant and Perkins Loan recipients. According to 2 CFR Part 200, Appendix XI Compliance Supplement updated June 2019: Under the Pell Grant and loan programs, institutions must complete and return within 15 days the Enrollment Reporting roster file placed in their Student Aid Internet Gateway mailboxes sent by ED via the National Student Loan Data System (“NSLDS”). The institution determines how often it receives the Enrollment Reporting roster file with the default set at a minimum of every 60 days. Once received, the institution must update for changes in student status, report the date the enrollment status was effective, enter the new anticipated completion date, and submit the changes electronically through the batch method or the NSLDS website. Institutions are responsible for timely reporting, whether they report directly or via a third-party servicer. Condition The Federal Government requires the Colleges to report student enrollment changes to the National Student Loan Data System (“NSLDS”) within 60 days. During our testing, 5 out of 40 students were reported late to the NSLDS by 3 to 168 days. During our testing, 2 out of 40 students reported incorrect effective dates, and 1 out of 40 students had an incorrect status reported to the NSLDS. Cause The Colleges did not have the proper review procedures in place to ensure enrollment status changes were being reported to NSLDS timely and correctly. Effect The Colleges did not report the students' correct effective dates to NSLDS or were not reported within the required timeframe, which may impact the students’ loan grace periods. Questioned Costs Not applicable Perspective Our sample was not, and was not intended to be, statistically valid. Of the 40 students selected for testing, 7 students, or 17.5% of our sample, did not report the correct effective dates to NSLDS or were not reported within the required timeframe. Identification as a Repeat Finding, if applicable See prior year finding 2022-001 Recommendation The Colleges should strengthen their controls surrounding the review of the NSLDS reporting process to ensure they are in compliance with federal regulations. View of Responsible Officials The Colleges agree with the finding.

Criteria According to 34 CFR 685.309(b)(2): Unless the Colleges expects to submit its next updated enrollment report to the Secretary within the next 60 days, a school must notify the Secretary within 30 days after the date the school 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 school, 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 school and who received a loan under Title IV of the Act has changed his or her permanent address. The Dear Colleague Letter GEN-12-6 issued by the U.S. Department of Education (“ED”) on March 30, 2012 states that in addition to student loan borrowers, Enrollment Reporting files will include two additional groups of students: Pell Grant and Perkins Loan recipients. According to 2 CFR Part 200, Appendix XI Compliance Supplement updated June 2019: Under the Pell Grant and loan programs, institutions must complete and return within 15 days the Enrollment Reporting roster file placed in their Student Aid Internet Gateway mailboxes sent by ED via the National Student Loan Data System (“NSLDS”). The institution determines how often it receives the Enrollment Reporting roster file with the default set at a minimum of every 60 days. Once received, the institution must update for changes in student status, report the date the enrollment status was effective, enter the new anticipated completion date, and submit the changes electronically through the batch method or the NSLDS website. Institutions are responsible for timely reporting, whether they report directly or via a third-party servicer. Condition The Federal Government requires the Colleges to report student enrollment changes to the National Student Loan Data System (“NSLDS”) within 60 days. During our testing, 5 out of 40 students were reported late to the NSLDS by 3 to 168 days. During our testing, 2 out of 40 students reported incorrect effective dates, and 1 out of 40 students had an incorrect status reported to the NSLDS. Cause The Colleges did not have the proper review procedures in place to ensure enrollment status changes were being reported to NSLDS timely and correctly. Effect The Colleges did not report the students' correct effective dates to NSLDS or were not reported within the required timeframe, which may impact the students’ loan grace periods. Questioned Costs Not applicable Perspective Our sample was not, and was not intended to be, statistically valid. Of the 40 students selected for testing, 7 students, or 17.5% of our sample, did not report the correct effective dates to NSLDS or were not reported within the required timeframe. Identification as a Repeat Finding, if applicable See prior year finding 2022-001 Recommendation The Colleges should strengthen their controls surrounding the review of the NSLDS reporting process to ensure they are in compliance with federal regulations. View of Responsible Officials The Colleges agree with the finding.

Criteria According to 34 CFR 668.164(l): (1) Notwithstanding any State law (such as a law that allows funds to escheat to the State), an institution must return to the Secretary any title IV, Higher Education Act (“HEA”) program funds, except Federal Work Study (“FWS”) program funds, that it attempts to disburse directly to a student or parent that are not received by the student or parent. For FWS program funds, the institution is required to return only the Federal portion of the payroll disbursement. (2) If an EFT to a student's or parent's financial account is rejected, or a check to a student or parent is returned, the institution may make additional attempts to disburse the funds, provided that those attempts are made not later than 45 days after the EFT was rejected or the check returned. In cases where the institution does not make another attempt, the funds must be returned to the Secretary before the end of this 45-day period. (3) If a check sent to a student or parent is not returned to the institution but is not cashed, the institution must return the funds to the Secretary no later than 240 days after the date it issued the check. Condition Federal regulations require an institution to return unclaimed Title IV funds issued by check or EFT within 240 days. During our testing, we noted 3 students, out of a sample of 40, that had unclaimed funds exceeding the federal day limit by 27 to 224 days. Cause The Colleges did not have an effective procedures in place to monitor the outstanding check aging to ensure that the 240-day timeframe was met. Effect The Colleges did not return Title IV unclaimed funds to the Department of Education within the required 240-day time frame. Questioned Costs There were 3 outstanding checks totaling $4,729 which pertained specifically to federal-sourced funds. Perspective Our sample was not, and was not intended to be, statistically valid. Of the 40 students selected for testing, 3 students, or 7.5% of our sample, had unclaimed funds pertaining to federal sources that were not returned to the Department of Education within the 240-day required time frame. Recommendation The Colleges should examine its policies and procedures related to unclaimed funds including the process and time frame for identifying aged balances and the process for cancelling checks and returning funds to the Department of Education. View of Responsible Officials The Colleges agrees with the finding.

Criteria According to 34 CFR 668.164(l): (1) Notwithstanding any State law (such as a law that allows funds to escheat to the State), an institution must return to the Secretary any title IV, Higher Education Act (“HEA”) program funds, except Federal Work Study (“FWS”) program funds, that it attempts to disburse directly to a student or parent that are not received by the student or parent. For FWS program funds, the institution is required to return only the Federal portion of the payroll disbursement. (2) If an EFT to a student's or parent's financial account is rejected, or a check to a student or parent is returned, the institution may make additional attempts to disburse the funds, provided that those attempts are made not later than 45 days after the EFT was rejected or the check returned. In cases where the institution does not make another attempt, the funds must be returned to the Secretary before the end of this 45-day period. (3) If a check sent to a student or parent is not returned to the institution but is not cashed, the institution must return the funds to the Secretary no later than 240 days after the date it issued the check. Condition Federal regulations require an institution to return unclaimed Title IV funds issued by check or EFT within 240 days. During our testing, we noted 3 students, out of a sample of 40, that had unclaimed funds exceeding the federal day limit by 27 to 224 days. Cause The Colleges did not have an effective procedures in place to monitor the outstanding check aging to ensure that the 240-day timeframe was met. Effect The Colleges did not return Title IV unclaimed funds to the Department of Education within the required 240-day time frame. Questioned Costs There were 3 outstanding checks totaling $4,729 which pertained specifically to federal-sourced funds. Perspective Our sample was not, and was not intended to be, statistically valid. Of the 40 students selected for testing, 3 students, or 7.5% of our sample, had unclaimed funds pertaining to federal sources that were not returned to the Department of Education within the 240-day required time frame. Recommendation The Colleges should examine its policies and procedures related to unclaimed funds including the process and time frame for identifying aged balances and the process for cancelling checks and returning funds to the Department of Education. View of Responsible Officials The Colleges agrees with the finding.

Criteria According to 34 CFR 668.164(l): (1) Notwithstanding any State law (such as a law that allows funds to escheat to the State), an institution must return to the Secretary any title IV, Higher Education Act (“HEA”) program funds, except Federal Work Study (“FWS”) program funds, that it attempts to disburse directly to a student or parent that are not received by the student or parent. For FWS program funds, the institution is required to return only the Federal portion of the payroll disbursement. (2) If an EFT to a student's or parent's financial account is rejected, or a check to a student or parent is returned, the institution may make additional attempts to disburse the funds, provided that those attempts are made not later than 45 days after the EFT was rejected or the check returned. In cases where the institution does not make another attempt, the funds must be returned to the Secretary before the end of this 45-day period. (3) If a check sent to a student or parent is not returned to the institution but is not cashed, the institution must return the funds to the Secretary no later than 240 days after the date it issued the check. Condition Federal regulations require an institution to return unclaimed Title IV funds issued by check or EFT within 240 days. During our testing, we noted 3 students, out of a sample of 40, that had unclaimed funds exceeding the federal day limit by 27 to 224 days. Cause The Colleges did not have an effective procedures in place to monitor the outstanding check aging to ensure that the 240-day timeframe was met. Effect The Colleges did not return Title IV unclaimed funds to the Department of Education within the required 240-day time frame. Questioned Costs There were 3 outstanding checks totaling $4,729 which pertained specifically to federal-sourced funds. Perspective Our sample was not, and was not intended to be, statistically valid. Of the 40 students selected for testing, 3 students, or 7.5% of our sample, had unclaimed funds pertaining to federal sources that were not returned to the Department of Education within the 240-day required time frame. Recommendation The Colleges should examine its policies and procedures related to unclaimed funds including the process and time frame for identifying aged balances and the process for cancelling checks and returning funds to the Department of Education. View of Responsible Officials The Colleges agrees with the finding.

Criteria According to 34 CFR 668.164(l): (1) Notwithstanding any State law (such as a law that allows funds to escheat to the State), an institution must return to the Secretary any title IV, Higher Education Act (“HEA”) program funds, except Federal Work Study (“FWS”) program funds, that it attempts to disburse directly to a student or parent that are not received by the student or parent. For FWS program funds, the institution is required to return only the Federal portion of the payroll disbursement. (2) If an EFT to a student's or parent's financial account is rejected, or a check to a student or parent is returned, the institution may make additional attempts to disburse the funds, provided that those attempts are made not later than 45 days after the EFT was rejected or the check returned. In cases where the institution does not make another attempt, the funds must be returned to the Secretary before the end of this 45-day period. (3) If a check sent to a student or parent is not returned to the institution but is not cashed, the institution must return the funds to the Secretary no later than 240 days after the date it issued the check. Condition Federal regulations require an institution to return unclaimed Title IV funds issued by check or EFT within 240 days. During our testing, we noted 3 students, out of a sample of 40, that had unclaimed funds exceeding the federal day limit by 27 to 224 days. Cause The Colleges did not have an effective procedures in place to monitor the outstanding check aging to ensure that the 240-day timeframe was met. Effect The Colleges did not return Title IV unclaimed funds to the Department of Education within the required 240-day time frame. Questioned Costs There were 3 outstanding checks totaling $4,729 which pertained specifically to federal-sourced funds. Perspective Our sample was not, and was not intended to be, statistically valid. Of the 40 students selected for testing, 3 students, or 7.5% of our sample, had unclaimed funds pertaining to federal sources that were not returned to the Department of Education within the 240-day required time frame. Recommendation The Colleges should examine its policies and procedures related to unclaimed funds including the process and time frame for identifying aged balances and the process for cancelling checks and returning funds to the Department of Education. View of Responsible Officials The Colleges agrees with the finding.

Criteria According to 34 CFR 690.83(b) (1) An institution shall report to the Secretary any change for which a student qualifies including any related Payment Data changes by submitting to the Secretary the student’s Payment Data that discloses the basis and result of the change in award for each student. The institution shall submit the student’s Payment Data reporting to the Secretary by the reporting deadlines published by the Secretary in the Federal Register. (2) An institution shall submit, in accordance with the deadline dates established by the Secretary, through publication in the Federal Register, other reports and information the Secretary requires and shall comply with the procedures the Secretary finds necessary to ensure that the reports are correct. According to the Federal Register (Volume 83, Number 233): An institution must submit Pell Grant, Iraq and Afghanistan Service Grant, Direct Loan, and TEACH Grant disbursement records to COD, no later than 15 days after making the disbursement or becoming aware of the need to adjust a previously reported disbursement. In accordance with 34 CFR 668.164(a), title IV, Higher Education Act (“HEA”) program funds are disbursed on the date that the institution: (a) Credits those funds to a student’s account in the institution’s general ledger or any subledger of the general ledger; or (b) pays those funds to a student directly. Title IV, HEA program funds are disbursed even if an institution uses its own funds in advance of receiving program funds from the Department. Condition Federal regulations require the Colleges to report to the Federal Government’s Common Origination and Disbursement System (“COD”) Federal Pell Grant and Direct Loan disbursements made to students within 15 days of the funds being disbursed to the student. During our testing, we noted 3 students, out of a sample of 40, that were not reported within the required timeframe by 1 to 9 days. Cause The Colleges have policies and procedures in place to report the disbursement records to the Department of Education through the COD system within the required fifteen calendar days, however, in this case the procedures were not completed properly. Effect The Colleges did not report Pell Grant and Direct Loan disbursements to COD within the required time frame. Identification as a Repeat Finding, if applicable Not applicable Recommendation We recommend that management of the Colleges review, and if necessary, update the policies and procedures to ensure all Pell Grant and Direct Loan funds are reported within the required timeframe. View of Responsible Officials The Colleges agree with the finding. Questioned Costs Not applicable Perspective Our sample was not, and was not intended to be, statistically valid. Of the 40 students selected for testing, 3 students, or 7.5% of our sample, were determined to be reported late to the COD by 1 to 9 days. Identification as a Repeat Finding, if applicable Not applicable Recommendation We recommend that management of the Colleges review, and if necessary, update the policies and procedures to ensure all Pell Grant and Direct Loan funds are reported within the required timeframe. View of Responsible Officials The Colleges agree with the finding.

Criteria According to 34 CFR 690.83(b) (1) An institution shall report to the Secretary any change for which a student qualifies including any related Payment Data changes by submitting to the Secretary the student’s Payment Data that discloses the basis and result of the change in award for each student. The institution shall submit the student’s Payment Data reporting to the Secretary by the reporting deadlines published by the Secretary in the Federal Register. (2) An institution shall submit, in accordance with the deadline dates established by the Secretary, through publication in the Federal Register, other reports and information the Secretary requires and shall comply with the procedures the Secretary finds necessary to ensure that the reports are correct. According to the Federal Register (Volume 83, Number 233): An institution must submit Pell Grant, Iraq and Afghanistan Service Grant, Direct Loan, and TEACH Grant disbursement records to COD, no later than 15 days after making the disbursement or becoming aware of the need to adjust a previously reported disbursement. In accordance with 34 CFR 668.164(a), title IV, Higher Education Act (“HEA”) program funds are disbursed on the date that the institution: (a) Credits those funds to a student’s account in the institution’s general ledger or any subledger of the general ledger; or (b) pays those funds to a student directly. Title IV, HEA program funds are disbursed even if an institution uses its own funds in advance of receiving program funds from the Department. Condition Federal regulations require the Colleges to report to the Federal Government’s Common Origination and Disbursement System (“COD”) Federal Pell Grant and Direct Loan disbursements made to students within 15 days of the funds being disbursed to the student. During our testing, we noted 3 students, out of a sample of 40, that were not reported within the required timeframe by 1 to 9 days. Cause The Colleges have policies and procedures in place to report the disbursement records to the Department of Education through the COD system within the required fifteen calendar days, however, in this case the procedures were not completed properly. Effect The Colleges did not report Pell Grant and Direct Loan disbursements to COD within the required time frame. Identification as a Repeat Finding, if applicable Not applicable Recommendation We recommend that management of the Colleges review, and if necessary, update the policies and procedures to ensure all Pell Grant and Direct Loan funds are reported within the required timeframe. View of Responsible Officials The Colleges agree with the finding. Questioned Costs Not applicable Perspective Our sample was not, and was not intended to be, statistically valid. Of the 40 students selected for testing, 3 students, or 7.5% of our sample, were determined to be reported late to the COD by 1 to 9 days. Identification as a Repeat Finding, if applicable Not applicable Recommendation We recommend that management of the Colleges review, and if necessary, update the policies and procedures to ensure all Pell Grant and Direct Loan funds are reported within the required timeframe. View of Responsible Officials The Colleges agree with the finding.

Criteria According to 34 CFR 690.83(b) (1) An institution shall report to the Secretary any change for which a student qualifies including any related Payment Data changes by submitting to the Secretary the student’s Payment Data that discloses the basis and result of the change in award for each student. The institution shall submit the student’s Payment Data reporting to the Secretary by the reporting deadlines published by the Secretary in the Federal Register. (2) An institution shall submit, in accordance with the deadline dates established by the Secretary, through publication in the Federal Register, other reports and information the Secretary requires and shall comply with the procedures the Secretary finds necessary to ensure that the reports are correct. According to the Federal Register (Volume 83, Number 233): An institution must submit Pell Grant, Iraq and Afghanistan Service Grant, Direct Loan, and TEACH Grant disbursement records to COD, no later than 15 days after making the disbursement or becoming aware of the need to adjust a previously reported disbursement. In accordance with 34 CFR 668.164(a), title IV, Higher Education Act (“HEA”) program funds are disbursed on the date that the institution: (a) Credits those funds to a student’s account in the institution’s general ledger or any subledger of the general ledger; or (b) pays those funds to a student directly. Title IV, HEA program funds are disbursed even if an institution uses its own funds in advance of receiving program funds from the Department. Condition Federal regulations require the Colleges to report to the Federal Government’s Common Origination and Disbursement System (“COD”) Federal Pell Grant and Direct Loan disbursements made to students within 15 days of the funds being disbursed to the student. During our testing, we noted 3 students, out of a sample of 40, that were not reported within the required timeframe by 1 to 9 days. Cause The Colleges have policies and procedures in place to report the disbursement records to the Department of Education through the COD system within the required fifteen calendar days, however, in this case the procedures were not completed properly. Effect The Colleges did not report Pell Grant and Direct Loan disbursements to COD within the required time frame. Identification as a Repeat Finding, if applicable Not applicable Recommendation We recommend that management of the Colleges review, and if necessary, update the policies and procedures to ensure all Pell Grant and Direct Loan funds are reported within the required timeframe. View of Responsible Officials The Colleges agree with the finding. Questioned Costs Not applicable Perspective Our sample was not, and was not intended to be, statistically valid. Of the 40 students selected for testing, 3 students, or 7.5% of our sample, were determined to be reported late to the COD by 1 to 9 days. Identification as a Repeat Finding, if applicable Not applicable Recommendation We recommend that management of the Colleges review, and if necessary, update the policies and procedures to ensure all Pell Grant and Direct Loan funds are reported within the required timeframe. View of Responsible Officials The Colleges agree with the finding.

Criteria According to 34 CFR 690.83(b) (1) An institution shall report to the Secretary any change for which a student qualifies including any related Payment Data changes by submitting to the Secretary the student’s Payment Data that discloses the basis and result of the change in award for each student. The institution shall submit the student’s Payment Data reporting to the Secretary by the reporting deadlines published by the Secretary in the Federal Register. (2) An institution shall submit, in accordance with the deadline dates established by the Secretary, through publication in the Federal Register, other reports and information the Secretary requires and shall comply with the procedures the Secretary finds necessary to ensure that the reports are correct. According to the Federal Register (Volume 83, Number 233): An institution must submit Pell Grant, Iraq and Afghanistan Service Grant, Direct Loan, and TEACH Grant disbursement records to COD, no later than 15 days after making the disbursement or becoming aware of the need to adjust a previously reported disbursement. In accordance with 34 CFR 668.164(a), title IV, Higher Education Act (“HEA”) program funds are disbursed on the date that the institution: (a) Credits those funds to a student’s account in the institution’s general ledger or any subledger of the general ledger; or (b) pays those funds to a student directly. Title IV, HEA program funds are disbursed even if an institution uses its own funds in advance of receiving program funds from the Department. Condition Federal regulations require the Colleges to report to the Federal Government’s Common Origination and Disbursement System (“COD”) Federal Pell Grant and Direct Loan disbursements made to students within 15 days of the funds being disbursed to the student. During our testing, we noted 3 students, out of a sample of 40, that were not reported within the required timeframe by 1 to 9 days. Cause The Colleges have policies and procedures in place to report the disbursement records to the Department of Education through the COD system within the required fifteen calendar days, however, in this case the procedures were not completed properly. Effect The Colleges did not report Pell Grant and Direct Loan disbursements to COD within the required time frame. Identification as a Repeat Finding, if applicable Not applicable Recommendation We recommend that management of the Colleges review, and if necessary, update the policies and procedures to ensure all Pell Grant and Direct Loan funds are reported within the required timeframe. View of Responsible Officials The Colleges agree with the finding. Questioned Costs Not applicable Perspective Our sample was not, and was not intended to be, statistically valid. Of the 40 students selected for testing, 3 students, or 7.5% of our sample, were determined to be reported late to the COD by 1 to 9 days. Identification as a Repeat Finding, if applicable Not applicable Recommendation We recommend that management of the Colleges review, and if necessary, update the policies and procedures to ensure all Pell Grant and Direct Loan funds are reported within the required timeframe. View of Responsible Officials The Colleges agree with the finding.

Criteria According to 34 CFR 668.34: (a) An institution must establish a reasonable satisfactory academic progress policy for determining whether an otherwise eligible student is making satisfactory academic progress in his or her educational program and may receive assistance under the title IV, HEA programs. (9) If the institution permits a student to appeal a determination by the institution that he or she is not making satisfactory academic progress, the policy describes – (i) How the student may reestablish his or her eligibility to receive assistance under the title IV, HEA programs; (ii) The basis on which a student may file an appeal: The death of a relative, an injury or illness of the student, or other special circumstances; and (iii) Information the student must submit regarding why the student failed to make satisfactory academic progress, and what has changed in the student's situation that will allow the student to demonstrate satisfactory academic progress at the next evaluation. Condition The Colleges’ satisfactory academic progress policy (“SAP”) allows for a student who fails to meet the minimum standard to be provided one semester of academic warning. If the student does not improve, as described in the Colleges’ SAP, the student will be dismissed from the Colleges unless the student successfully appeals the dismissal. Our testing revealed that four students failed to meet the minimum standards established by the Colleges’ SAP. Of these four students, one student did not receive notification that they were out of compliance of the Colleges’ SAP. Cause The Colleges failed to have the proper review procedures in place to ensure that all students who did not meet the minimum SAP standards received proper notification. Effect Students did not receive notification of their current academic standing and as such were unable to submit an appeal. Questioned Costs Not applicable Perspective Our sample was not, and was not intended to be, statistically valid. Of the 40 students selected for testing, 1 student, or 2.5%, failed to meet the minimum standards established by the Colleges’ SAP. Identification as a Repeat Finding, if applicable Not applicable Recommendation The Colleges should continue to strengthen their controls surrounding notification to students who have failed to meet the minimum standards per the SAP. View of Responsible Officials The Colleges agree with the finding.

Criteria According to 34 CFR 668.34: (a) An institution must establish a reasonable satisfactory academic progress policy for determining whether an otherwise eligible student is making satisfactory academic progress in his or her educational program and may receive assistance under the title IV, HEA programs. (9) If the institution permits a student to appeal a determination by the institution that he or she is not making satisfactory academic progress, the policy describes – (i) How the student may reestablish his or her eligibility to receive assistance under the title IV, HEA programs; (ii) The basis on which a student may file an appeal: The death of a relative, an injury or illness of the student, or other special circumstances; and (iii) Information the student must submit regarding why the student failed to make satisfactory academic progress, and what has changed in the student's situation that will allow the student to demonstrate satisfactory academic progress at the next evaluation. Condition The Colleges’ satisfactory academic progress policy (“SAP”) allows for a student who fails to meet the minimum standard to be provided one semester of academic warning. If the student does not improve, as described in the Colleges’ SAP, the student will be dismissed from the Colleges unless the student successfully appeals the dismissal. Our testing revealed that four students failed to meet the minimum standards established by the Colleges’ SAP. Of these four students, one student did not receive notification that they were out of compliance of the Colleges’ SAP. Cause The Colleges failed to have the proper review procedures in place to ensure that all students who did not meet the minimum SAP standards received proper notification. Effect Students did not receive notification of their current academic standing and as such were unable to submit an appeal. Questioned Costs Not applicable Perspective Our sample was not, and was not intended to be, statistically valid. Of the 40 students selected for testing, 1 student, or 2.5%, failed to meet the minimum standards established by the Colleges’ SAP. Identification as a Repeat Finding, if applicable Not applicable Recommendation The Colleges should continue to strengthen their controls surrounding notification to students who have failed to meet the minimum standards per the SAP. View of Responsible Officials The Colleges agree with the finding.

Criteria According to 34 CFR 668.34: (a) An institution must establish a reasonable satisfactory academic progress policy for determining whether an otherwise eligible student is making satisfactory academic progress in his or her educational program and may receive assistance under the title IV, HEA programs. (9) If the institution permits a student to appeal a determination by the institution that he or she is not making satisfactory academic progress, the policy describes – (i) How the student may reestablish his or her eligibility to receive assistance under the title IV, HEA programs; (ii) The basis on which a student may file an appeal: The death of a relative, an injury or illness of the student, or other special circumstances; and (iii) Information the student must submit regarding why the student failed to make satisfactory academic progress, and what has changed in the student's situation that will allow the student to demonstrate satisfactory academic progress at the next evaluation. Condition The Colleges’ satisfactory academic progress policy (“SAP”) allows for a student who fails to meet the minimum standard to be provided one semester of academic warning. If the student does not improve, as described in the Colleges’ SAP, the student will be dismissed from the Colleges unless the student successfully appeals the dismissal. Our testing revealed that four students failed to meet the minimum standards established by the Colleges’ SAP. Of these four students, one student did not receive notification that they were out of compliance of the Colleges’ SAP. Cause The Colleges failed to have the proper review procedures in place to ensure that all students who did not meet the minimum SAP standards received proper notification. Effect Students did not receive notification of their current academic standing and as such were unable to submit an appeal. Questioned Costs Not applicable Perspective Our sample was not, and was not intended to be, statistically valid. Of the 40 students selected for testing, 1 student, or 2.5%, failed to meet the minimum standards established by the Colleges’ SAP. Identification as a Repeat Finding, if applicable Not applicable Recommendation The Colleges should continue to strengthen their controls surrounding notification to students who have failed to meet the minimum standards per the SAP. View of Responsible Officials The Colleges agree with the finding.

Criteria According to 34 CFR 668.34: (a) An institution must establish a reasonable satisfactory academic progress policy for determining whether an otherwise eligible student is making satisfactory academic progress in his or her educational program and may receive assistance under the title IV, HEA programs. (9) If the institution permits a student to appeal a determination by the institution that he or she is not making satisfactory academic progress, the policy describes – (i) How the student may reestablish his or her eligibility to receive assistance under the title IV, HEA programs; (ii) The basis on which a student may file an appeal: The death of a relative, an injury or illness of the student, or other special circumstances; and (iii) Information the student must submit regarding why the student failed to make satisfactory academic progress, and what has changed in the student's situation that will allow the student to demonstrate satisfactory academic progress at the next evaluation. Condition The Colleges’ satisfactory academic progress policy (“SAP”) allows for a student who fails to meet the minimum standard to be provided one semester of academic warning. If the student does not improve, as described in the Colleges’ SAP, the student will be dismissed from the Colleges unless the student successfully appeals the dismissal. Our testing revealed that four students failed to meet the minimum standards established by the Colleges’ SAP. Of these four students, one student did not receive notification that they were out of compliance of the Colleges’ SAP. Cause The Colleges failed to have the proper review procedures in place to ensure that all students who did not meet the minimum SAP standards received proper notification. Effect Students did not receive notification of their current academic standing and as such were unable to submit an appeal. Questioned Costs Not applicable Perspective Our sample was not, and was not intended to be, statistically valid. Of the 40 students selected for testing, 1 student, or 2.5%, failed to meet the minimum standards established by the Colleges’ SAP. Identification as a Repeat Finding, if applicable Not applicable Recommendation The Colleges should continue to strengthen their controls surrounding notification to students who have failed to meet the minimum standards per the SAP. View of Responsible Officials The Colleges agree with the finding.

Criteria According to 34 CFR 668.22(c): Withdrawal date for a student who withdraws from an institution that is not required to take attendance. For purposes of this section, for a student who ceases attendance at an institution that is not required to take attendance, the student’s withdrawal date is – (i) The date, as determined by the institution, that the student began the withdrawal process prescribed by the institution; (ii) The date, as determined by the institution, that the student otherwise provided official notification to the institution, in writing or orally, of his or her intent to withdraw; (iii) If the student ceases attendance without providing official notification to the institution of his or her withdrawal in accordance with paragraph (c)(1)(i) or (c)(1)(ii) of this section, the mid-point of the payment period (or period of enrollment, if applicable). Condition When a recipient of Title IV funds withdraws from an institution during a payment period or period of enrollment in which the recipient began attendance, the institution should determine the proper amount of Title IV funds to be refunded as of the recipient’s withdrawal date. Once a recipient’s withdrawal date is determined, an institution should complete a Return of Title IV (“R2T4”) calculation. The R2T4 is used to calculate the percentage of the payment period or period of enrollment completed, establish the amount of Title IV funds earned by the recipient, and determine the amount required to be returned to the Department of Education. During our testing, we noted 1 student, out of a sample of 40, where the Return of Title IV calculation was completed using incorrect withdrawal dates. Cause When completing the R2T4 calculation, the Colleges used the date the student’s withdrawal was processed by the Colleges instead of the actual date the student withdrew from the Colleges. Effect The Colleges calculated the student’s percentage of earned aid incorrectly which resulted in an incorrect amount of Title IV funds returned to the Department of Education. Questioned Costs Unknown Perspective Our sample was not, and was not intended to be, statistically valid. Of the 40 students selected for testing, 1 student, or 2.5% of our sample, used the incorrect withdrawal date when completing the Return of Title IV calculation. Identification as a Repeat Finding, if applicable Not applicable Recommendation The Colleges should implement a formal review process of the Return of Title IV calculations to ensure an accurate calculation is made. View of Responsible Officials The Colleges agree with the finding.

Criteria According to 34 CFR 668.22(c): Withdrawal date for a student who withdraws from an institution that is not required to take attendance. For purposes of this section, for a student who ceases attendance at an institution that is not required to take attendance, the student’s withdrawal date is – (i) The date, as determined by the institution, that the student began the withdrawal process prescribed by the institution; (ii) The date, as determined by the institution, that the student otherwise provided official notification to the institution, in writing or orally, of his or her intent to withdraw; (iii) If the student ceases attendance without providing official notification to the institution of his or her withdrawal in accordance with paragraph (c)(1)(i) or (c)(1)(ii) of this section, the mid-point of the payment period (or period of enrollment, if applicable). Condition When a recipient of Title IV funds withdraws from an institution during a payment period or period of enrollment in which the recipient began attendance, the institution should determine the proper amount of Title IV funds to be refunded as of the recipient’s withdrawal date. Once a recipient’s withdrawal date is determined, an institution should complete a Return of Title IV (“R2T4”) calculation. The R2T4 is used to calculate the percentage of the payment period or period of enrollment completed, establish the amount of Title IV funds earned by the recipient, and determine the amount required to be returned to the Department of Education. During our testing, we noted 1 student, out of a sample of 40, where the Return of Title IV calculation was completed using incorrect withdrawal dates. Cause When completing the R2T4 calculation, the Colleges used the date the student’s withdrawal was processed by the Colleges instead of the actual date the student withdrew from the Colleges. Effect The Colleges calculated the student’s percentage of earned aid incorrectly which resulted in an incorrect amount of Title IV funds returned to the Department of Education. Questioned Costs Unknown Perspective Our sample was not, and was not intended to be, statistically valid. Of the 40 students selected for testing, 1 student, or 2.5% of our sample, used the incorrect withdrawal date when completing the Return of Title IV calculation. Identification as a Repeat Finding, if applicable Not applicable Recommendation The Colleges should implement a formal review process of the Return of Title IV calculations to ensure an accurate calculation is made. View of Responsible Officials The Colleges agree with the finding.

Criteria According to 34 CFR 668.22(c): Withdrawal date for a student who withdraws from an institution that is not required to take attendance. For purposes of this section, for a student who ceases attendance at an institution that is not required to take attendance, the student’s withdrawal date is – (i) The date, as determined by the institution, that the student began the withdrawal process prescribed by the institution; (ii) The date, as determined by the institution, that the student otherwise provided official notification to the institution, in writing or orally, of his or her intent to withdraw; (iii) If the student ceases attendance without providing official notification to the institution of his or her withdrawal in accordance with paragraph (c)(1)(i) or (c)(1)(ii) of this section, the mid-point of the payment period (or period of enrollment, if applicable). Condition When a recipient of Title IV funds withdraws from an institution during a payment period or period of enrollment in which the recipient began attendance, the institution should determine the proper amount of Title IV funds to be refunded as of the recipient’s withdrawal date. Once a recipient’s withdrawal date is determined, an institution should complete a Return of Title IV (“R2T4”) calculation. The R2T4 is used to calculate the percentage of the payment period or period of enrollment completed, establish the amount of Title IV funds earned by the recipient, and determine the amount required to be returned to the Department of Education. During our testing, we noted 1 student, out of a sample of 40, where the Return of Title IV calculation was completed using incorrect withdrawal dates. Cause When completing the R2T4 calculation, the Colleges used the date the student’s withdrawal was processed by the Colleges instead of the actual date the student withdrew from the Colleges. Effect The Colleges calculated the student’s percentage of earned aid incorrectly which resulted in an incorrect amount of Title IV funds returned to the Department of Education. Questioned Costs Unknown Perspective Our sample was not, and was not intended to be, statistically valid. Of the 40 students selected for testing, 1 student, or 2.5% of our sample, used the incorrect withdrawal date when completing the Return of Title IV calculation. Identification as a Repeat Finding, if applicable Not applicable Recommendation The Colleges should implement a formal review process of the Return of Title IV calculations to ensure an accurate calculation is made. View of Responsible Officials The Colleges agree with the finding.

Criteria According to 34 CFR 668.22(c): Withdrawal date for a student who withdraws from an institution that is not required to take attendance. For purposes of this section, for a student who ceases attendance at an institution that is not required to take attendance, the student’s withdrawal date is – (i) The date, as determined by the institution, that the student began the withdrawal process prescribed by the institution; (ii) The date, as determined by the institution, that the student otherwise provided official notification to the institution, in writing or orally, of his or her intent to withdraw; (iii) If the student ceases attendance without providing official notification to the institution of his or her withdrawal in accordance with paragraph (c)(1)(i) or (c)(1)(ii) of this section, the mid-point of the payment period (or period of enrollment, if applicable). Condition When a recipient of Title IV funds withdraws from an institution during a payment period or period of enrollment in which the recipient began attendance, the institution should determine the proper amount of Title IV funds to be refunded as of the recipient’s withdrawal date. Once a recipient’s withdrawal date is determined, an institution should complete a Return of Title IV (“R2T4”) calculation. The R2T4 is used to calculate the percentage of the payment period or period of enrollment completed, establish the amount of Title IV funds earned by the recipient, and determine the amount required to be returned to the Department of Education. During our testing, we noted 1 student, out of a sample of 40, where the Return of Title IV calculation was completed using incorrect withdrawal dates. Cause When completing the R2T4 calculation, the Colleges used the date the student’s withdrawal was processed by the Colleges instead of the actual date the student withdrew from the Colleges. Effect The Colleges calculated the student’s percentage of earned aid incorrectly which resulted in an incorrect amount of Title IV funds returned to the Department of Education. Questioned Costs Unknown Perspective Our sample was not, and was not intended to be, statistically valid. Of the 40 students selected for testing, 1 student, or 2.5% of our sample, used the incorrect withdrawal date when completing the Return of Title IV calculation. Identification as a Repeat Finding, if applicable Not applicable Recommendation The Colleges should implement a formal review process of the Return of Title IV calculations to ensure an accurate calculation is made. View of Responsible Officials The Colleges agree with the finding.

Criteria According to 34 CFR 668.22(j)(1): Timeframe for the return of title IV funds. An institution must return the amount of title IV funds for which it is responsible under paragraph (g) of this section as soon as possible but no later than 45 days after the date of the institution's determination that the student withdrew as defined in paragraph (l)(3) of this section. According to 34 CFR 668.173(b): Timely return of Title IV, HEA program funds. In accordance with procedures established by the Secretary or Federal Family Education Loan (“FFEL”) program lender, an institution returns unearned Title IV, HEA program funds timely if – (1) The institution deposits or transfers the funds into the bank account it maintains under 34 CFR Sections 668.163 no later than 45 days after the date it determines the student withdrew; (2) The institution initiates an electronic funds transfer no later than 45 days after the date it determines that the student withdrew; (3) The institution initiates an electronic transaction no later than 45 days after the date it determines that the student withdrew, that informs a FFEL lender to adjust the borrower’s loan account for the amount returned; or (4) The institution issues a check no later than 45 days after the date it determines that the student withdrew. An institution does not satisfy this requirement if – (i) The institution’s records show that the check was issued more than 45 days after the date the institution determined the student withdrew; or (ii) The date on the cancelled check shows that the bank used by the Secretary or FFEL Program lender endorsed that check more than 60 days after the date the institution determined that the student withdrew. Condition Federal regulations state that any unearned Title IV grant or loan assistance received by a student must be refunded to the Title IV programs upon a student’s withdrawal from the institution. The Colleges have 45 days from the date they determined the student withdrew to return any unearned portions of Title IV funds. During our testing, we noted 3 students, out of a sample of 40, had unearned Title IV aid that was not returned to the Federal Government, within 45 days of the determined withdrawal date, by 20 to 74 days. Cause The Colleges did not consistently follow the procedures in place to monitor student withdrawals related to Title IV funds that must be returned to the Department of Education within 45 days. Effect The Colleges did not return unearned Title IV funds within the required 45-day time frame. Questioned Costs Not applicable Perspective Our sample was not, and was not intended to be, statistically valid. Of the 40 students selected for testing, 3 students, or 7.5% of our sample, had unearned Title IV funds that were not returned to the Department of Education within the 45-day required time frame. Identification as a Repeat Finding, if applicable Not applicable Recommendation The Colleges should strengthen their controls surrounding the review Return of Title IV calculations in a timely manner to ensure that all funds are returned to the Department of Education within the required time frame. View of Responsible Officials The Colleges agree with the finding.

Criteria According to 34 CFR 668.22(j)(1): Timeframe for the return of title IV funds. An institution must return the amount of title IV funds for which it is responsible under paragraph (g) of this section as soon as possible but no later than 45 days after the date of the institution's determination that the student withdrew as defined in paragraph (l)(3) of this section. According to 34 CFR 668.173(b): Timely return of Title IV, HEA program funds. In accordance with procedures established by the Secretary or Federal Family Education Loan (“FFEL”) program lender, an institution returns unearned Title IV, HEA program funds timely if – (1) The institution deposits or transfers the funds into the bank account it maintains under 34 CFR Sections 668.163 no later than 45 days after the date it determines the student withdrew; (2) The institution initiates an electronic funds transfer no later than 45 days after the date it determines that the student withdrew; (3) The institution initiates an electronic transaction no later than 45 days after the date it determines that the student withdrew, that informs a FFEL lender to adjust the borrower’s loan account for the amount returned; or (4) The institution issues a check no later than 45 days after the date it determines that the student withdrew. An institution does not satisfy this requirement if – (i) The institution’s records show that the check was issued more than 45 days after the date the institution determined the student withdrew; or (ii) The date on the cancelled check shows that the bank used by the Secretary or FFEL Program lender endorsed that check more than 60 days after the date the institution determined that the student withdrew. Condition Federal regulations state that any unearned Title IV grant or loan assistance received by a student must be refunded to the Title IV programs upon a student’s withdrawal from the institution. The Colleges have 45 days from the date they determined the student withdrew to return any unearned portions of Title IV funds. During our testing, we noted 3 students, out of a sample of 40, had unearned Title IV aid that was not returned to the Federal Government, within 45 days of the determined withdrawal date, by 20 to 74 days. Cause The Colleges did not consistently follow the procedures in place to monitor student withdrawals related to Title IV funds that must be returned to the Department of Education within 45 days. Effect The Colleges did not return unearned Title IV funds within the required 45-day time frame. Questioned Costs Not applicable Perspective Our sample was not, and was not intended to be, statistically valid. Of the 40 students selected for testing, 3 students, or 7.5% of our sample, had unearned Title IV funds that were not returned to the Department of Education within the 45-day required time frame. Identification as a Repeat Finding, if applicable Not applicable Recommendation The Colleges should strengthen their controls surrounding the review Return of Title IV calculations in a timely manner to ensure that all funds are returned to the Department of Education within the required time frame. View of Responsible Officials The Colleges agree with the finding.

Criteria According to 34 CFR 668.22(j)(1): Timeframe for the return of title IV funds. An institution must return the amount of title IV funds for which it is responsible under paragraph (g) of this section as soon as possible but no later than 45 days after the date of the institution's determination that the student withdrew as defined in paragraph (l)(3) of this section. According to 34 CFR 668.173(b): Timely return of Title IV, HEA program funds. In accordance with procedures established by the Secretary or Federal Family Education Loan (“FFEL”) program lender, an institution returns unearned Title IV, HEA program funds timely if – (1) The institution deposits or transfers the funds into the bank account it maintains under 34 CFR Sections 668.163 no later than 45 days after the date it determines the student withdrew; (2) The institution initiates an electronic funds transfer no later than 45 days after the date it determines that the student withdrew; (3) The institution initiates an electronic transaction no later than 45 days after the date it determines that the student withdrew, that informs a FFEL lender to adjust the borrower’s loan account for the amount returned; or (4) The institution issues a check no later than 45 days after the date it determines that the student withdrew. An institution does not satisfy this requirement if – (i) The institution’s records show that the check was issued more than 45 days after the date the institution determined the student withdrew; or (ii) The date on the cancelled check shows that the bank used by the Secretary or FFEL Program lender endorsed that check more than 60 days after the date the institution determined that the student withdrew. Condition Federal regulations state that any unearned Title IV grant or loan assistance received by a student must be refunded to the Title IV programs upon a student’s withdrawal from the institution. The Colleges have 45 days from the date they determined the student withdrew to return any unearned portions of Title IV funds. During our testing, we noted 3 students, out of a sample of 40, had unearned Title IV aid that was not returned to the Federal Government, within 45 days of the determined withdrawal date, by 20 to 74 days. Cause The Colleges did not consistently follow the procedures in place to monitor student withdrawals related to Title IV funds that must be returned to the Department of Education within 45 days. Effect The Colleges did not return unearned Title IV funds within the required 45-day time frame. Questioned Costs Not applicable Perspective Our sample was not, and was not intended to be, statistically valid. Of the 40 students selected for testing, 3 students, or 7.5% of our sample, had unearned Title IV funds that were not returned to the Department of Education within the 45-day required time frame. Identification as a Repeat Finding, if applicable Not applicable Recommendation The Colleges should strengthen their controls surrounding the review Return of Title IV calculations in a timely manner to ensure that all funds are returned to the Department of Education within the required time frame. View of Responsible Officials The Colleges agree with the finding.

Criteria According to 34 CFR 668.22(j)(1): Timeframe for the return of title IV funds. An institution must return the amount of title IV funds for which it is responsible under paragraph (g) of this section as soon as possible but no later than 45 days after the date of the institution's determination that the student withdrew as defined in paragraph (l)(3) of this section. According to 34 CFR 668.173(b): Timely return of Title IV, HEA program funds. In accordance with procedures established by the Secretary or Federal Family Education Loan (“FFEL”) program lender, an institution returns unearned Title IV, HEA program funds timely if – (1) The institution deposits or transfers the funds into the bank account it maintains under 34 CFR Sections 668.163 no later than 45 days after the date it determines the student withdrew; (2) The institution initiates an electronic funds transfer no later than 45 days after the date it determines that the student withdrew; (3) The institution initiates an electronic transaction no later than 45 days after the date it determines that the student withdrew, that informs a FFEL lender to adjust the borrower’s loan account for the amount returned; or (4) The institution issues a check no later than 45 days after the date it determines that the student withdrew. An institution does not satisfy this requirement if – (i) The institution’s records show that the check was issued more than 45 days after the date the institution determined the student withdrew; or (ii) The date on the cancelled check shows that the bank used by the Secretary or FFEL Program lender endorsed that check more than 60 days after the date the institution determined that the student withdrew. Condition Federal regulations state that any unearned Title IV grant or loan assistance received by a student must be refunded to the Title IV programs upon a student’s withdrawal from the institution. The Colleges have 45 days from the date they determined the student withdrew to return any unearned portions of Title IV funds. During our testing, we noted 3 students, out of a sample of 40, had unearned Title IV aid that was not returned to the Federal Government, within 45 days of the determined withdrawal date, by 20 to 74 days. Cause The Colleges did not consistently follow the procedures in place to monitor student withdrawals related to Title IV funds that must be returned to the Department of Education within 45 days. Effect The Colleges did not return unearned Title IV funds within the required 45-day time frame. Questioned Costs Not applicable Perspective Our sample was not, and was not intended to be, statistically valid. Of the 40 students selected for testing, 3 students, or 7.5% of our sample, had unearned Title IV funds that were not returned to the Department of Education within the 45-day required time frame. Identification as a Repeat Finding, if applicable Not applicable Recommendation The Colleges should strengthen their controls surrounding the review Return of Title IV calculations in a timely manner to ensure that all funds are returned to the Department of Education within the required time frame. View of Responsible Officials The Colleges agree with the finding.

Criteria According to 34 CFR 685.309(b)(2): Unless the Colleges expects to submit its next updated enrollment report to the Secretary within the next 60 days, a school must notify the Secretary within 30 days after the date the school 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 school, 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 school and who received a loan under Title IV of the Act has changed his or her permanent address. The Dear Colleague Letter GEN-12-6 issued by the U.S. Department of Education (“ED”) on March 30, 2012 states that in addition to student loan borrowers, Enrollment Reporting files will include two additional groups of students: Pell Grant and Perkins Loan recipients. According to 2 CFR Part 200, Appendix XI Compliance Supplement updated June 2019: Under the Pell Grant and loan programs, institutions must complete and return within 15 days the Enrollment Reporting roster file placed in their Student Aid Internet Gateway mailboxes sent by ED via the National Student Loan Data System (“NSLDS”). The institution determines how often it receives the Enrollment Reporting roster file with the default set at a minimum of every 60 days. Once received, the institution must update for changes in student status, report the date the enrollment status was effective, enter the new anticipated completion date, and submit the changes electronically through the batch method or the NSLDS website. Institutions are responsible for timely reporting, whether they report directly or via a third-party servicer. Condition The Federal Government requires the Colleges to report student enrollment changes to the National Student Loan Data System (“NSLDS”) within 60 days. During our testing, 5 out of 40 students were reported late to the NSLDS by 3 to 168 days. During our testing, 2 out of 40 students reported incorrect effective dates, and 1 out of 40 students had an incorrect status reported to the NSLDS. Cause The Colleges did not have the proper review procedures in place to ensure enrollment status changes were being reported to NSLDS timely and correctly. Effect The Colleges did not report the students' correct effective dates to NSLDS or were not reported within the required timeframe, which may impact the students’ loan grace periods. Questioned Costs Not applicable Perspective Our sample was not, and was not intended to be, statistically valid. Of the 40 students selected for testing, 7 students, or 17.5% of our sample, did not report the correct effective dates to NSLDS or were not reported within the required timeframe. Identification as a Repeat Finding, if applicable See prior year finding 2022-001 Recommendation The Colleges should strengthen their controls surrounding the review of the NSLDS reporting process to ensure they are in compliance with federal regulations. View of Responsible Officials The Colleges agree with the finding.

Criteria According to 34 CFR 685.309(b)(2): Unless the Colleges expects to submit its next updated enrollment report to the Secretary within the next 60 days, a school must notify the Secretary within 30 days after the date the school 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 school, 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 school and who received a loan under Title IV of the Act has changed his or her permanent address. The Dear Colleague Letter GEN-12-6 issued by the U.S. Department of Education (“ED”) on March 30, 2012 states that in addition to student loan borrowers, Enrollment Reporting files will include two additional groups of students: Pell Grant and Perkins Loan recipients. According to 2 CFR Part 200, Appendix XI Compliance Supplement updated June 2019: Under the Pell Grant and loan programs, institutions must complete and return within 15 days the Enrollment Reporting roster file placed in their Student Aid Internet Gateway mailboxes sent by ED via the National Student Loan Data System (“NSLDS”). The institution determines how often it receives the Enrollment Reporting roster file with the default set at a minimum of every 60 days. Once received, the institution must update for changes in student status, report the date the enrollment status was effective, enter the new anticipated completion date, and submit the changes electronically through the batch method or the NSLDS website. Institutions are responsible for timely reporting, whether they report directly or via a third-party servicer. Condition The Federal Government requires the Colleges to report student enrollment changes to the National Student Loan Data System (“NSLDS”) within 60 days. During our testing, 5 out of 40 students were reported late to the NSLDS by 3 to 168 days. During our testing, 2 out of 40 students reported incorrect effective dates, and 1 out of 40 students had an incorrect status reported to the NSLDS. Cause The Colleges did not have the proper review procedures in place to ensure enrollment status changes were being reported to NSLDS timely and correctly. Effect The Colleges did not report the students' correct effective dates to NSLDS or were not reported within the required timeframe, which may impact the students’ loan grace periods. Questioned Costs Not applicable Perspective Our sample was not, and was not intended to be, statistically valid. Of the 40 students selected for testing, 7 students, or 17.5% of our sample, did not report the correct effective dates to NSLDS or were not reported within the required timeframe. Identification as a Repeat Finding, if applicable See prior year finding 2022-001 Recommendation The Colleges should strengthen their controls surrounding the review of the NSLDS reporting process to ensure they are in compliance with federal regulations. View of Responsible Officials The Colleges agree with the finding.

Criteria According to 34 CFR 685.309(b)(2): Unless the Colleges expects to submit its next updated enrollment report to the Secretary within the next 60 days, a school must notify the Secretary within 30 days after the date the school 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 school, 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 school and who received a loan under Title IV of the Act has changed his or her permanent address. The Dear Colleague Letter GEN-12-6 issued by the U.S. Department of Education (“ED”) on March 30, 2012 states that in addition to student loan borrowers, Enrollment Reporting files will include two additional groups of students: Pell Grant and Perkins Loan recipients. According to 2 CFR Part 200, Appendix XI Compliance Supplement updated June 2019: Under the Pell Grant and loan programs, institutions must complete and return within 15 days the Enrollment Reporting roster file placed in their Student Aid Internet Gateway mailboxes sent by ED via the National Student Loan Data System (“NSLDS”). The institution determines how often it receives the Enrollment Reporting roster file with the default set at a minimum of every 60 days. Once received, the institution must update for changes in student status, report the date the enrollment status was effective, enter the new anticipated completion date, and submit the changes electronically through the batch method or the NSLDS website. Institutions are responsible for timely reporting, whether they report directly or via a third-party servicer. Condition The Federal Government requires the Colleges to report student enrollment changes to the National Student Loan Data System (“NSLDS”) within 60 days. During our testing, 5 out of 40 students were reported late to the NSLDS by 3 to 168 days. During our testing, 2 out of 40 students reported incorrect effective dates, and 1 out of 40 students had an incorrect status reported to the NSLDS. Cause The Colleges did not have the proper review procedures in place to ensure enrollment status changes were being reported to NSLDS timely and correctly. Effect The Colleges did not report the students' correct effective dates to NSLDS or were not reported within the required timeframe, which may impact the students’ loan grace periods. Questioned Costs Not applicable Perspective Our sample was not, and was not intended to be, statistically valid. Of the 40 students selected for testing, 7 students, or 17.5% of our sample, did not report the correct effective dates to NSLDS or were not reported within the required timeframe. Identification as a Repeat Finding, if applicable See prior year finding 2022-001 Recommendation The Colleges should strengthen their controls surrounding the review of the NSLDS reporting process to ensure they are in compliance with federal regulations. View of Responsible Officials The Colleges agree with the finding.

Criteria According to 34 CFR 685.309(b)(2): Unless the Colleges expects to submit its next updated enrollment report to the Secretary within the next 60 days, a school must notify the Secretary within 30 days after the date the school 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 school, 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 school and who received a loan under Title IV of the Act has changed his or her permanent address. The Dear Colleague Letter GEN-12-6 issued by the U.S. Department of Education (“ED”) on March 30, 2012 states that in addition to student loan borrowers, Enrollment Reporting files will include two additional groups of students: Pell Grant and Perkins Loan recipients. According to 2 CFR Part 200, Appendix XI Compliance Supplement updated June 2019: Under the Pell Grant and loan programs, institutions must complete and return within 15 days the Enrollment Reporting roster file placed in their Student Aid Internet Gateway mailboxes sent by ED via the National Student Loan Data System (“NSLDS”). The institution determines how often it receives the Enrollment Reporting roster file with the default set at a minimum of every 60 days. Once received, the institution must update for changes in student status, report the date the enrollment status was effective, enter the new anticipated completion date, and submit the changes electronically through the batch method or the NSLDS website. Institutions are responsible for timely reporting, whether they report directly or via a third-party servicer. Condition The Federal Government requires the Colleges to report student enrollment changes to the National Student Loan Data System (“NSLDS”) within 60 days. During our testing, 5 out of 40 students were reported late to the NSLDS by 3 to 168 days. During our testing, 2 out of 40 students reported incorrect effective dates, and 1 out of 40 students had an incorrect status reported to the NSLDS. Cause The Colleges did not have the proper review procedures in place to ensure enrollment status changes were being reported to NSLDS timely and correctly. Effect The Colleges did not report the students' correct effective dates to NSLDS or were not reported within the required timeframe, which may impact the students’ loan grace periods. Questioned Costs Not applicable Perspective Our sample was not, and was not intended to be, statistically valid. Of the 40 students selected for testing, 7 students, or 17.5% of our sample, did not report the correct effective dates to NSLDS or were not reported within the required timeframe. Identification as a Repeat Finding, if applicable See prior year finding 2022-001 Recommendation The Colleges should strengthen their controls surrounding the review of the NSLDS reporting process to ensure they are in compliance with federal regulations. View of Responsible Officials The Colleges agree with the finding.

Criteria According to 34 CFR 668.164(l): (1) Notwithstanding any State law (such as a law that allows funds to escheat to the State), an institution must return to the Secretary any title IV, Higher Education Act (“HEA”) program funds, except Federal Work Study (“FWS”) program funds, that it attempts to disburse directly to a student or parent that are not received by the student or parent. For FWS program funds, the institution is required to return only the Federal portion of the payroll disbursement. (2) If an EFT to a student's or parent's financial account is rejected, or a check to a student or parent is returned, the institution may make additional attempts to disburse the funds, provided that those attempts are made not later than 45 days after the EFT was rejected or the check returned. In cases where the institution does not make another attempt, the funds must be returned to the Secretary before the end of this 45-day period. (3) If a check sent to a student or parent is not returned to the institution but is not cashed, the institution must return the funds to the Secretary no later than 240 days after the date it issued the check. Condition Federal regulations require an institution to return unclaimed Title IV funds issued by check or EFT within 240 days. During our testing, we noted 3 students, out of a sample of 40, that had unclaimed funds exceeding the federal day limit by 27 to 224 days. Cause The Colleges did not have an effective procedures in place to monitor the outstanding check aging to ensure that the 240-day timeframe was met. Effect The Colleges did not return Title IV unclaimed funds to the Department of Education within the required 240-day time frame. Questioned Costs There were 3 outstanding checks totaling $4,729 which pertained specifically to federal-sourced funds. Perspective Our sample was not, and was not intended to be, statistically valid. Of the 40 students selected for testing, 3 students, or 7.5% of our sample, had unclaimed funds pertaining to federal sources that were not returned to the Department of Education within the 240-day required time frame. Recommendation The Colleges should examine its policies and procedures related to unclaimed funds including the process and time frame for identifying aged balances and the process for cancelling checks and returning funds to the Department of Education. View of Responsible Officials The Colleges agrees with the finding.

Criteria According to 34 CFR 668.164(l): (1) Notwithstanding any State law (such as a law that allows funds to escheat to the State), an institution must return to the Secretary any title IV, Higher Education Act (“HEA”) program funds, except Federal Work Study (“FWS”) program funds, that it attempts to disburse directly to a student or parent that are not received by the student or parent. For FWS program funds, the institution is required to return only the Federal portion of the payroll disbursement. (2) If an EFT to a student's or parent's financial account is rejected, or a check to a student or parent is returned, the institution may make additional attempts to disburse the funds, provided that those attempts are made not later than 45 days after the EFT was rejected or the check returned. In cases where the institution does not make another attempt, the funds must be returned to the Secretary before the end of this 45-day period. (3) If a check sent to a student or parent is not returned to the institution but is not cashed, the institution must return the funds to the Secretary no later than 240 days after the date it issued the check. Condition Federal regulations require an institution to return unclaimed Title IV funds issued by check or EFT within 240 days. During our testing, we noted 3 students, out of a sample of 40, that had unclaimed funds exceeding the federal day limit by 27 to 224 days. Cause The Colleges did not have an effective procedures in place to monitor the outstanding check aging to ensure that the 240-day timeframe was met. Effect The Colleges did not return Title IV unclaimed funds to the Department of Education within the required 240-day time frame. Questioned Costs There were 3 outstanding checks totaling $4,729 which pertained specifically to federal-sourced funds. Perspective Our sample was not, and was not intended to be, statistically valid. Of the 40 students selected for testing, 3 students, or 7.5% of our sample, had unclaimed funds pertaining to federal sources that were not returned to the Department of Education within the 240-day required time frame. Recommendation The Colleges should examine its policies and procedures related to unclaimed funds including the process and time frame for identifying aged balances and the process for cancelling checks and returning funds to the Department of Education. View of Responsible Officials The Colleges agrees with the finding.

Criteria According to 34 CFR 668.164(l): (1) Notwithstanding any State law (such as a law that allows funds to escheat to the State), an institution must return to the Secretary any title IV, Higher Education Act (“HEA”) program funds, except Federal Work Study (“FWS”) program funds, that it attempts to disburse directly to a student or parent that are not received by the student or parent. For FWS program funds, the institution is required to return only the Federal portion of the payroll disbursement. (2) If an EFT to a student's or parent's financial account is rejected, or a check to a student or parent is returned, the institution may make additional attempts to disburse the funds, provided that those attempts are made not later than 45 days after the EFT was rejected or the check returned. In cases where the institution does not make another attempt, the funds must be returned to the Secretary before the end of this 45-day period. (3) If a check sent to a student or parent is not returned to the institution but is not cashed, the institution must return the funds to the Secretary no later than 240 days after the date it issued the check. Condition Federal regulations require an institution to return unclaimed Title IV funds issued by check or EFT within 240 days. During our testing, we noted 3 students, out of a sample of 40, that had unclaimed funds exceeding the federal day limit by 27 to 224 days. Cause The Colleges did not have an effective procedures in place to monitor the outstanding check aging to ensure that the 240-day timeframe was met. Effect The Colleges did not return Title IV unclaimed funds to the Department of Education within the required 240-day time frame. Questioned Costs There were 3 outstanding checks totaling $4,729 which pertained specifically to federal-sourced funds. Perspective Our sample was not, and was not intended to be, statistically valid. Of the 40 students selected for testing, 3 students, or 7.5% of our sample, had unclaimed funds pertaining to federal sources that were not returned to the Department of Education within the 240-day required time frame. Recommendation The Colleges should examine its policies and procedures related to unclaimed funds including the process and time frame for identifying aged balances and the process for cancelling checks and returning funds to the Department of Education. View of Responsible Officials The Colleges agrees with the finding.

Criteria According to 34 CFR 668.164(l): (1) Notwithstanding any State law (such as a law that allows funds to escheat to the State), an institution must return to the Secretary any title IV, Higher Education Act (“HEA”) program funds, except Federal Work Study (“FWS”) program funds, that it attempts to disburse directly to a student or parent that are not received by the student or parent. For FWS program funds, the institution is required to return only the Federal portion of the payroll disbursement. (2) If an EFT to a student's or parent's financial account is rejected, or a check to a student or parent is returned, the institution may make additional attempts to disburse the funds, provided that those attempts are made not later than 45 days after the EFT was rejected or the check returned. In cases where the institution does not make another attempt, the funds must be returned to the Secretary before the end of this 45-day period. (3) If a check sent to a student or parent is not returned to the institution but is not cashed, the institution must return the funds to the Secretary no later than 240 days after the date it issued the check. Condition Federal regulations require an institution to return unclaimed Title IV funds issued by check or EFT within 240 days. During our testing, we noted 3 students, out of a sample of 40, that had unclaimed funds exceeding the federal day limit by 27 to 224 days. Cause The Colleges did not have an effective procedures in place to monitor the outstanding check aging to ensure that the 240-day timeframe was met. Effect The Colleges did not return Title IV unclaimed funds to the Department of Education within the required 240-day time frame. Questioned Costs There were 3 outstanding checks totaling $4,729 which pertained specifically to federal-sourced funds. Perspective Our sample was not, and was not intended to be, statistically valid. Of the 40 students selected for testing, 3 students, or 7.5% of our sample, had unclaimed funds pertaining to federal sources that were not returned to the Department of Education within the 240-day required time frame. Recommendation The Colleges should examine its policies and procedures related to unclaimed funds including the process and time frame for identifying aged balances and the process for cancelling checks and returning funds to the Department of Education. View of Responsible Officials The Colleges agrees with the finding.