Audit 395206

2025-002 – Awarding of Direct Loans Federal Agency: U.S. Department of Education Federal Program Name: Federal Direct Student Loans Assistance Listing Number: 84.268 Federal Award Identification Number and Year: P268K241818; P268K251818 - 2025 Award Period: 7/1/2024 – 6/30/2025 Type of Finding: Significant Deficiency in Internal Control Over Compliance, Other Matters Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 685.203 specifies the annual and aggregate loan limits the Institutions may not exceed for an academic year of study under the Direct Loan program and also requires loans to be prorated for a program of student that is less than a full academic year in length. Condition: Testing identified that 1 out of 40 students was awarded and disbursed Direct Loans in excess of the annual loan limit applicable to the student’s grade level and dependency status. Questioned costs: $5,000 Context: During our testing, one student was awarded and disbursed $12,500 in direct loans, when they were only eligible for $7,500 based on their grade-level and dependency status. Cause: The University did not resolve an ISIR code that identified a direct loan over-award and did not effectively ensure loan limits were properly applied. Effect: The student received Direct Loan funds in excess of their eligible amount, resulting in noncompliance with federal program requirements. Repeat finding: No. Recommendation: We recommend the University strengthen its review procedures over student award packages, including a review at the start of each academic year, to ensure Direct Loans are awarded in accordance with grade level and dependency status limits. We also recommend the University review all ISIR codes and resolve any that are necessary. Views of responsible officials: There is no disagreement with the audit finding.

2025-003 – Common Origination and Disbursement (COD) Reporting Federal Agency: U.S. Department of Education Federal Program Name: Federal Pell Grant Program Assistance Listing Number: 84.063 Federal Award Identification Number and Year: P063P231818; P063P241818 - 2025 Award Period: 7/1/2024 – 6/30/2025 Type of Finding: Significant Deficiency in Internal Control Over Compliance, Other Matters Criteria or specific requirement: Department of Education regulations require institutions to report Pell Grant and Direct Loan disbursement dates and amounts to the Common Origination and Disbursement (COD) system within 15 days of disbursement (34 CFR 690.83(b)(2) and 34 CFR 685.309). Condition: During our testing, we noted the University did not have adequate internal controls to ensure timely reporting to the COD. Questioned costs: None. Context: During our testing, we noted 6 out of 18 Pell disbursements were not reported within the 15 days required to the COD. Cause: The University’s procedures for timely reporting Pell Grant disbursements to COD were not functioning effectively. Effect: The University is not in compliance with COD reporting requirements. Repeat finding: No. Recommendation: We recommend the University review and enhance its policies and procedures related to COD reporting to ensure all disbursement information is reported accurately and within required timeframes. Views of responsible officials: There is no disagreement with the audit finding.

2025-004 – Title IV Credit Balances Federal Agency: U.S. Department of Education Federal Program Name: Federal Pell Grant Program, Federal Direct Student Loans, Federal Supplemental Education Opportunity Grants, Federal Work-Study Program Assistance Listing Number: 84.063, 84.268, 84.007, 84.033 Federal Award Identification Number and Year: P268K241818; P268K251818; P063P231818; P063P241818; P007A232600; PA007A242600; P033A242600 - 2025 Award Period: 7/1/2024 – 6/30/2025 Type of Finding: Significant Deficiency in Internal Control Over Compliance, Other Matters Criteria or specific requirement: The Department of Education requires the University to obtain written authorization to hold a Title IV credit balance to apply to future charges within the same academic year. Condition: Testing identified that for 1 out of 40 students, a Title IV credit balance was applied to a subsequent academic term without obtaining written authorization from the student. Questioned costs: None. Context: During our testing, it was noted that a student had a Title IV credit balance and balance was applied to a subsequent term without obtaining written authorization from the student. Cause: The University did not have policies or procedures in place to ensure written authorization for holding Title IV credit balances was obtained and retained. Effect: The University did not comply with Title IV requirements related to the handling of student credit balances. Repeat finding: No. Recommendation: We recommend the University implement policies and monitoring procedures to ensure Title IV credit balances are either refunded to students in a timely manner or supported by documented written authorization. Views of responsible officials: There is no disagreement with the audit finding.

2025-005 – Return of Title IV (R2T4) Calculations Federal Agency: U.S. Department of Education Federal Program Name: Federal Pell Grant Program, Federal Direct Student Loans, Federal Supplemental Education Opportunity Grants Assistance Listing Number: 84.063, 84.268, 84.007 Federal Award Identification Number and Year: P268K241818; P268K251818; P063P231818; P063P241818; P007A232600; PA007A242600 - 2025 Award Period: 7/1/2024 – 6/30/2025 Type of Finding: Significant Deficiency in Internal Control Over Compliance, Other Matters Criteria or specific requirement: Federal regulations require institutions to determine a student’s withdrawal date and calculate the percentage of the payment period completed to determine the amount of Title IV aid earned. Institutionally scheduled breaks of five or more consecutive days must be excluded from the calculation (34 CFR 668.22(f)(2)(i)). Regulations also define withdrawal dates for institutions that are required to take attendance and those that are not (34 CFR 668.22). Condition: Testing disclosed that in 1 out of 12 R2T4 calculations, an incorrect withdrawal date was used. Questioned costs: $51. Context: During our testing, we noted 1 instance where an incorrect withdrawal date was used in the calculation. Cause: Human error resulted in incorrect data being used. Effect: An incorrect amount of Title IV funds was returned to the Department of Education. Repeat finding: No. Recommendation: We recommend the University review and strengthen its policies and procedures for completing R2T4 calculations to ensure accurate inputs. Views of responsible officials: There is no disagreement with the audit finding.

2025-006 – National Student Loan Data System Federal Agency: U.S. Department of Education Federal Program Name: Federal Pell Grant Program, Federal Direct Student Loans Assistance Listing Number: 84.063, 84.268 Federal Award Identification Number and Year: P268K241818; P268K251818; P063P231818; P063P241818; P063Q221818, P063Q231818, P063Q241818 - 2025 Award Period: 7/1/2024 – 6/30/2025 Type of Finding: Significant Deficiency in Internal Control Over Compliance, Other Matters Criteria or specific requirement: Per U.S. Department of Education (ED) regulations, all schools participating (or approved to participate) in the Federal Student Aid programs must have an arrangement to report student enrollment data to the NSLDS through a roster file. The school is required to report enrollment status at both the school and program level. The school is required to report changes in the student’s enrollment status, the effective date of the status and an anticipated completion date. An academic program is defined as the combination of the school’s Office of Postsecondary Education Identification (OPEID) number and the program’s Classification of Instructional Program (CIP) code, credential level, and published program length. ED requires the University to report changes in enrollment status and indicate the date that the changes occurred (34 CFR 685.309). Condition: Certain students' enrollment information was not reported accurately to NSLDS or no information was reported at all. Questioned costs: None. Context: Testing of 40 students identified that enrollment information for certain students was not reported accurately or was not reported at all. Specifically: • One student’s program-level effective date did not agree between University records and NSLDS. • One student was never reported to NSLDS. Cause: The University’s procedures for identifying and reporting enrollment status changes to NSLDS were not functioning effectively. Effect: Inaccurate reporting to the NSLDS can impact when students enter repayment periods or affect their interest rates. Repeat finding: No. Recommendation: We recommend the University evaluate its policies and procedures around reporting student status changes to the NSLDS to ensure that all relevant information is being captured and reported in accordance with applicable regulations. Views of responsible officials: There is no disagreement with the audit finding.