Audit 412928

Federal Program: Student Financial Assistance Cluster • Federal Direct Student Loans (ALN 84.268) • Federal Pell Grant Program (ALN 84.063) Federal Agency: U.S. Department of Education Pass Through Entity: None Federal Award Year: January 1, 2025 to December 31, 2025 Compliance Requirement: Special Tests and Provisions – Enrollment Reporting Criteria Requirement: Under the Pell grant and the Direct and Federal Family Education Loan programs, institutions are required to report enrollment information via the National Student Loan Data System (NSLDS) (OMB No. 1845-0035). The administration of the Title IV programs depends heavily on the accuracy and timeliness of the enrollment information reported by institutions. Institutions must review, update and verify student enrollment statuses, program information and effective dates that appear on the Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS Professional Access (NSLDSFAP) website. The data on the institution’s Enrollment Reporting Roster, or Enrollment Maintenance page, is what NSLDS has as the most recently certified enrollment information. There are two categories of enrollment information; “Campus Level” and “Program Level,” both of which need to be reported accurately and have separate record types. Institutions are responsible for accurately reporting the following significant data elements under the Campus-Level Record that the Department of Education (ED) considers high risk: • OPEID number, enrollment effective date, enrollment status and certification date Institutions are responsible for accurately reporting the following significant data elements under the Program-Level Record that ED considers high risk: • OPEID number, CIP code, CIP year, credential level, published program length measurement, published program length, program begin date, program enrollment status and program enrollment effective date Institutions are responsible for timely reporting, whether they report directly or via a third-party servicer. Institutions must complete and return the Enrollment Reporting Roster file placed in their Student Aid Internet Gateway (SAIG) (OMB No. 1845-0002) mailboxes sent by ED via NSLDS within 15 days. An 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 the data elements for the Campus Record and Program Record identified above, and submit the changes electronically through the batch method, spreadsheet submittal or the NSLDS website. Additionally, in accordance with Federal requirements, the College shall maintain internal controls over Federal programs designed to provide reasonable assurance that transactions are executed in compliance with Federal statutes, regulations, and terms and conditions of the Federal award that could have a direct and material effect on a Federal program. Condition Found: The Institution utilizes the National Student Clearinghouse (the Clearinghouse) as a service provider for transmissions of its enrollment reporting changes to the NSLDS. The College receives the Enrollment Reporting Roster and updates it for changes in student status. The file is sent to the Clearinghouse who transmits the updated information to NSLDS. For a sample of 60 students who were recipients of Direct Loans or Pell Grants who had been identified as having withdrawn, graduated, or modified their enrollment status as defined by the College’s Satisfactory Academic Progress Policy through a change in course load, the following were noted: • For 5 of the 60 students selected for enrollment reporting testing, management did not report the status change to NSLDS within the required timeframe of 60 days from the date they became aware of the change. • For 8 of the 60 students selected for enrollment reporting testing, the Program Level status was not updated to reflect the appropriate status, therefore management did not report the status change to NSLDS within the required timeframe of 60 days from the date they became aware of the change. Cause and Possible Asserted Effect: The Institution’s controls over the review of the recording and communication of these status changes is not designed effectively to ensure that individuals’ enrollment statuses are completely and accurately communicated to NSLDS on a timely basis. Identification of Questioned Costs: There are no questioned costs related to this finding. Sampling: The sample was not intended to be and was not a statistically valid sample. Identification of Repeat Finding: This audit finding is a repeat of Finding 2024-002 in the immediately prior year. Recommendation: Our recommendation is for management to design and implement a control in order to ensure the compliance requirement objectives are met. In particular, it is advised to implement a system of control within the institution related to the review of enrollment statuses to ensure information is transmitted to NSLDS accurately and timely. Further, management should reinforce and provide training to individuals responsible for compliance control ownership. This will help ensure that there are controls in place to ensure compliance and control ownership is established, thereby preventing or promptly identifying and rectifying instances of noncompliance and ensuring the controls operate as designed. Views of Responsible Officials: The College agrees with the recommendation provided. The College has initiated immediate corrective actions including implementation of proactive controls designed to prevent noncompliance.

Federal Program: Student Financial Assistance Cluster • Federal Direct Student Loans (ALN 84.268) • Federal Pell Grant Program (ALN 84.063) Federal Agency: U.S. Department of Education Pass Through Entity: None Federal Award Year: January 1, 2025 to December 31, 2025 Compliance Requirement: Special Tests and Provisions – Disbursements to or on behalf of students Criteria Requirement: Per the Uniform Guidance, when Title IV funds are credited to a student account and they exceed the amount of tuition and fees, room and board, and other authorized charges assessed the student, a credit balance is created. The institution must pay the resulting credit balance directly to the student or parent borrower within 14 days after: (i) the first day of class of a payment period if the credit balance occurred on or before that day, or (ii) the balance occurred if that was after the first day of class An institution is permitted to hold credit balances if it obtains a voluntary authorization from the student. Regardless of any authorization obtained by the institution, the institution must pay any remaining loan balance by the end of the loan period and any other remaining Title IV funds by the end of the last payment period in the award year for which the funds were awarded. Conditions Found: For a sample of 39 students who received Title IV funds credited to student, the following were noted: • For 3 of the 39 students selected for testing, the institution did not refund the credit balances back to the student within 14 days and did not obtain authorization from the student to retain the balance. Cause and Possible Asserted Effect: This resulted in a control failure by the institution to make payments to students within the 14-day timeframe required by the Department of Education and did not obtain voluntary authorization from the student to retain credit balances. Therefore, this evidenced the lack of an appropriately designed control by the institution to ensure credit balances are refunded to students within the timeframe requirements. Identification of Questioned Costs: There are no questioned costs related to this finding. All credit balances were appropriately refunded by the end of the semester and therefore there were no questioned costs or misstatements that occurred as it related to the SEFA or financial statements. Sampling: This sample was not intended to be and was not a statistically valid sample. Identification of Repeat Finding: This audit finding is a repeat of finding 2024-003 in the immediately prior year. Recommendation: Our recommendation is for management to design and implement a control in order to ensure the compliance requirement objectives are met. In particular, it is advised to implement a system of control within the institutions for refunds of credit balances to be paid to students within the 14-day timeframe. Further, management should reinforce and provide training to individuals responsible for compliance control ownership. This will help ensure that there are controls in place to ensure compliance and control ownership is established, thereby preventing or promptly identifying and rectifying instances of noncompliance and ensuring the controls operate as designed. Views of Responsible Officials: The College agrees with the recommendation provided. The College will establish and implement a formal credit balance monitoring process to ensure that Title IV credit balances are identified, monitored, and refunded within the required 14-day timeframe.

Federal Program: Student Financial Assistance Cluster • Federal Direct Student Loans (ALN 84.268) • Federal Pell Grant Program (ALN 84.063) Federal Agency: U.S. Department of Education Pass Through Entity: None Federal Award Year: January 1, 2025 to December 31, 2025 Compliance Requirement: Reporting Criteria Requirement: Per the Uniform Guidance, institutions submit Direct Loan, Pell Grant, and TEACH Grant origination records and disbursement records to the COD system. Origination records can be sent well in advance of any disbursements, as early as the institution chooses to submit them for any student the institution reasonably believes will be eligible for a payment. Key items to test on origination records for the fiscal year are: award amount, enrollment date, verification status code (when the applicant is selected for verification), transaction number, cost of attendance, Academic Start Date, and Academic End Date. Conditions Found: For a sample of 60 students whose records were reported to the COD system, 5 of the 60 students had key items incorrectly reported to the COD. The key items identified as reported incorrectly included Academic End Date and Transaction Number. Cause and Possible Asserted Effect: This resulted in a control failure by the institution to report key items accurately to the COD system. Therefore, this evidenced the lack of an appropriately designed control by the institution to ensure key items are completely and accurately reported to the COD system. Identification of Questioned Costs: There are no questioned costs related to this finding. Sampling: This sample was not intended to be and was not a statistically valid sample. Identification of Repeat Finding: This audit finding is not a repeat finding in the prior year. Recommendation: Our recommendation is for management to design and implement a control in order to ensure the compliance requirement objectives are met. In particular, it is advised to implement a system of control within the institution to ensure key items reported to the COD system are complete and accurate. This will help ensure that there are controls in place to ensure compliance and control ownership is established, thereby preventing or promptly identifying and rectifying instances of noncompliance and ensuring the controls operate as designed. Views of Responsible Officials: The College agrees with the recommendation provided. The College has established a framework of controls and quality assurance testing to ensure complete and accurate reporting to the COD system.