Audit 394070

Federal Agency: US Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Number: 84.063, 84.007, 84.033, 84.268 Federal Award Identification Number and Year: P063P242037 - 2025, P007A243429 - 2025, P033A243429 - 2025, P268K252037 - 2025 Award Period: July 1, 2024 to June 30, 2025 Type of Finding: • Compliance, Other Matter • Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: 34 CFR 682.604, states that a school must ensure that exit counseling is conducted with each Stafford Loan borrower and graduate or professional student PLUS Loan borrower either in person, by audiovisual presentation, or by interactive electronic means. In each case, the school must ensure that this counseling is conducted shortly before the student borrower ceases at least half-time study at the school. Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Condition: The College did not properly have documentation of exit counseling notification. Questioned costs: None. Context: During our testing of 40 students, we identified 7 students that did not have documentation of exit counseling notification. Cause: The College did not have proper procedures in place to ensure that notification of required exit counseling was sent to applicable students. Effect: Exit counseling helps federal student loan borrowers understand how to repay their loans and reviews deferment and repayment plans options. If students are not notified of exit counseling, they could be at risk of not understanding their rights and responsibilities regarding loan repayment. Repeat Finding: No Recommendation: We recommend the College review reporting processes to ensure all students that require exit counseling receive it in a timely manner. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.

Federal Agency: US Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Number: 84.063, 84.007, 84.033, 84.268 Federal Award Identification Number and Year: P063P242037 - 2025, P007A243429 - 2025, P033A243429 - 2025, P268K252037 - 2025 Award Period: July 1, 2024 to June 30, 2025 Type of Finding: • Compliance, Other Matter • Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: Per 34 CFR 668.22(f)(2)(i), the total number of calendar days in a payment period or period of enrollment includes all days within the period that the student was scheduled to complete, except that scheduled breaks of at least five consecutive days are excluded from the total number of calendar days in a payment period or period of enrollment and the number of calendar days completed in that period. The Code of Federal Regulations, 34 CFR 668.22(j)(1), states that an institution must return the amount of title IV funds for which it is responsible as soon as possible but no later than 45 days after the date of the institution's determination that the student withdrew. Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Condition: The College incorrectly calculated Return to Title IV (R2T4) calculations and did not return Title IV funds within 45-days. Questioned costs: None. Context: During our testing of 40 R2T4 calculations, we identified that 15 had mechanically incorrect calculations by using the incorrect number of scheduled break days in the Spring term. Additionally, we identified 1 student with Title IV refund that was not returned within the 45-day requirement. Cause: The College was using the incorrect number of scheduled break days for Spring Term. Effect: The College could return incorrect amounts based off of their calculations, which could effect student repayment amounts based off of amount earned. Repeat Finding: Yes, 2024-003 Recommendation: We recommend that the College review policies and procedures related to R2T4 calculations to ensure calculations are performed correctly and timely. We also recommend the College implement formal review procedures to document the Return of Title IV calculations are being performed to minimize the likelihood that errors may go undetected and not be corrected in a timely manner. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.

Federal Agency: US Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Number: 84.063, 84.007, 84.033, 84.268 Federal Award Identification Number and Year: P063P242037 - 2025, P007A243429 - 2025, P033A243429 - 2025, P268K252037 - 2025 Award Period: July 1, 2024 to June 30, 2025 Type of Finding: • Compliance, Other Matter • Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless of if they receive aid from the institution or not. Changes to said status are required to be reported within 30 days of becoming aware of the status change, or with the next scheduled transmission of statuses if the scheduled transmission is within 60 days. Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Condition: The College did not properly report student enrollment changes for students who received federal student aid to the National Student Loan Data System (NSLDS). Questioned costs: None. Context: During our testing of 40 students, we identified 7 students with an effective date reported to NSLDS that did not align with institutional records and 6 students that were reported after the 60 day requirement. Cause: The College did not have proper procedures in place to verify students' status in NSLDS matched the institutions records accurately and reported timely. Effect: The College was not in compliance with the requirements to properly report student enrollment data correctly. Incorrect dates submitted to NSLDS may be used to determine the grace period for the repayment and interest of outstanding Title IV student loans. Repeat Finding: Yes, 2024-002 Recommendation: We recommend the College review current processes for reporting to NSLDS and implement procedures to ensure submissions are reported accurately and timely. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.