Audit 9367

Award Information Cluster: Student Financial Assistance Grantor: Department of Education Award Name: Federal Supplemental Educational Opportunity Grant, Federal Work-Study, Federal Pell Grant, Federal Direct Student Loan, Primary Care Loan, Loan for Disadvantaged Students, Health Professions Student Loans, Nursing Student Loan Award Year: FY2023 CFDA Number: 84.007, 84.033, 84.063, 84.268, 93.342, 93.342, 93.342, 93.364 Criteria The University has a centralized office of student financial assistance, as well as individual offices at various schools within the University. Through testing of various compliance requirements, PwC noted improvements are needed to the documentation and execution of certain student financial aid requirements throughout the University. Specific criteria related to areas that need improvement are as follows: • An institution is required to establish written policies and procedures that incorporate the provisions of 34 CFR 668.51 through 668.61 for verifying applicant information for those applicants selected for verification by the Department of Education (ED). The institution shall require each applicant whose application is selected by ED to verify the information required for the Verification Tracking Group to which the applicant is assigned. • The Electronic Signatures in Global and National Commerce Act (“E-Sign Act”) states that a school must obtain a student’s voluntary consent to participate in electronic transactions. • University policy is to maintain a formal Title IV calculation form when a student withdraws or takes a leave of absence from the University. • An institution must communicate Campus-Level and Program-Level enrollment data when there is a student status change (34 CFR 674.19). • 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 (CFR 668.34). Condition As part of PwC’s testing over the student financial assistance cluster, they noted the following: • PwC selected 25 students who were selected by the Department of Education for verification. For six out of the 25 students selected, the University was required to obtain a statement of identity. The University could not provide documentation that evidenced a statement of identity was obtained. In examining 25 student records, the University did not receive a student's consent to participate in electronic transactions for one of the selections. After further investigation by the University, it was determined there were a total of 361 students that did not sign the voluntary consent, inclusive of the one PwC selected. • PwC selected 16 students that required a Return of Title IV calculation. For two of the selected students, the University did not formally document the refund calculation performed. For one student, a return of Title IV funds was not needed and for the other student, the required return of Title IV funds was appropriately made within the required timeframe. • PwC selected 25 students that had a student status change. For two of the selections, the University enrollment change was communicated to the NSLDS accurately and timely, however the program level data was not communicated as required by the regulations. • PwC reviewed the University’s policies over satisfactory academic progress. There were four schools within the University that did not document procedures for disbursements to students on financial aid warning status or financial aid probation status. Additionally, there was one school that did not document policies stating that students who (1) have not achieved the required GPA, (2) are not successfully completing their program of study at the required pace (if required), or (3) have not completed the program within the maximum time frame will no longer be eligible for Title IV aid. Questioned Costs None noted. Cause The University does not have consistent policies and procedures in place that require the appropriate documentation to be maintained to support compliance with the regulatory requirements. Effect Failure to maintain, distribute and enforce uniform policies and procedures across the University may result in appropriate documentation not being maintained for compliance purposes. Recommendation PwC recommends the University establish consistent policies and procedures for all compliance areas and hold trainings to ensure that student financial aid staff are aware of the required policies. Management’s Views and Corrective Action Plan Management's views and corrective action plan is included in Section V.

Award Information Cluster: Student Financial Assistance Grantor: Department of Education Award Name: Federal Supplemental Educational Opportunity Grant, Federal Work-Study, Federal Pell Grant, Federal Direct Student Loan, Primary Care Loan, Loan for Disadvantaged Students, Health Professions Student Loans, Nursing Student Loan Award Year: FY2023 CFDA Number: 84.007, 84.033, 84.063, 84.268, 93.342, 93.342, 93.342, 93.364 Criteria The University has a centralized office of student financial assistance, as well as individual offices at various schools within the University. Through testing of various compliance requirements, PwC noted improvements are needed to the documentation and execution of certain student financial aid requirements throughout the University. Specific criteria related to areas that need improvement are as follows: • An institution is required to establish written policies and procedures that incorporate the provisions of 34 CFR 668.51 through 668.61 for verifying applicant information for those applicants selected for verification by the Department of Education (ED). The institution shall require each applicant whose application is selected by ED to verify the information required for the Verification Tracking Group to which the applicant is assigned. • The Electronic Signatures in Global and National Commerce Act (“E-Sign Act”) states that a school must obtain a student’s voluntary consent to participate in electronic transactions. • University policy is to maintain a formal Title IV calculation form when a student withdraws or takes a leave of absence from the University. • An institution must communicate Campus-Level and Program-Level enrollment data when there is a student status change (34 CFR 674.19). • 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 (CFR 668.34). Condition As part of PwC’s testing over the student financial assistance cluster, they noted the following: • PwC selected 25 students who were selected by the Department of Education for verification. For six out of the 25 students selected, the University was required to obtain a statement of identity. The University could not provide documentation that evidenced a statement of identity was obtained. In examining 25 student records, the University did not receive a student's consent to participate in electronic transactions for one of the selections. After further investigation by the University, it was determined there were a total of 361 students that did not sign the voluntary consent, inclusive of the one PwC selected. • PwC selected 16 students that required a Return of Title IV calculation. For two of the selected students, the University did not formally document the refund calculation performed. For one student, a return of Title IV funds was not needed and for the other student, the required return of Title IV funds was appropriately made within the required timeframe. • PwC selected 25 students that had a student status change. For two of the selections, the University enrollment change was communicated to the NSLDS accurately and timely, however the program level data was not communicated as required by the regulations. • PwC reviewed the University’s policies over satisfactory academic progress. There were four schools within the University that did not document procedures for disbursements to students on financial aid warning status or financial aid probation status. Additionally, there was one school that did not document policies stating that students who (1) have not achieved the required GPA, (2) are not successfully completing their program of study at the required pace (if required), or (3) have not completed the program within the maximum time frame will no longer be eligible for Title IV aid. Questioned Costs None noted. Cause The University does not have consistent policies and procedures in place that require the appropriate documentation to be maintained to support compliance with the regulatory requirements. Effect Failure to maintain, distribute and enforce uniform policies and procedures across the University may result in appropriate documentation not being maintained for compliance purposes. Recommendation PwC recommends the University establish consistent policies and procedures for all compliance areas and hold trainings to ensure that student financial aid staff are aware of the required policies. Management’s Views and Corrective Action Plan Management's views and corrective action plan is included in Section V.

Award Information Cluster: Student Financial Assistance Grantor: Department of Education Award Name: Federal Supplemental Educational Opportunity Grant, Federal Work-Study, Federal Pell Grant, Federal Direct Student Loan, Primary Care Loan, Loan for Disadvantaged Students, Health Professions Student Loans, Nursing Student Loan Award Year: FY2023 CFDA Number: 84.007, 84.033, 84.063, 84.268, 93.342, 93.342, 93.342, 93.364 Criteria The University has a centralized office of student financial assistance, as well as individual offices at various schools within the University. Through testing of various compliance requirements, PwC noted improvements are needed to the documentation and execution of certain student financial aid requirements throughout the University. Specific criteria related to areas that need improvement are as follows: • An institution is required to establish written policies and procedures that incorporate the provisions of 34 CFR 668.51 through 668.61 for verifying applicant information for those applicants selected for verification by the Department of Education (ED). The institution shall require each applicant whose application is selected by ED to verify the information required for the Verification Tracking Group to which the applicant is assigned. • The Electronic Signatures in Global and National Commerce Act (“E-Sign Act”) states that a school must obtain a student’s voluntary consent to participate in electronic transactions. • University policy is to maintain a formal Title IV calculation form when a student withdraws or takes a leave of absence from the University. • An institution must communicate Campus-Level and Program-Level enrollment data when there is a student status change (34 CFR 674.19). • 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 (CFR 668.34). Condition As part of PwC’s testing over the student financial assistance cluster, they noted the following: • PwC selected 25 students who were selected by the Department of Education for verification. For six out of the 25 students selected, the University was required to obtain a statement of identity. The University could not provide documentation that evidenced a statement of identity was obtained. In examining 25 student records, the University did not receive a student's consent to participate in electronic transactions for one of the selections. After further investigation by the University, it was determined there were a total of 361 students that did not sign the voluntary consent, inclusive of the one PwC selected. • PwC selected 16 students that required a Return of Title IV calculation. For two of the selected students, the University did not formally document the refund calculation performed. For one student, a return of Title IV funds was not needed and for the other student, the required return of Title IV funds was appropriately made within the required timeframe. • PwC selected 25 students that had a student status change. For two of the selections, the University enrollment change was communicated to the NSLDS accurately and timely, however the program level data was not communicated as required by the regulations. • PwC reviewed the University’s policies over satisfactory academic progress. There were four schools within the University that did not document procedures for disbursements to students on financial aid warning status or financial aid probation status. Additionally, there was one school that did not document policies stating that students who (1) have not achieved the required GPA, (2) are not successfully completing their program of study at the required pace (if required), or (3) have not completed the program within the maximum time frame will no longer be eligible for Title IV aid. Questioned Costs None noted. Cause The University does not have consistent policies and procedures in place that require the appropriate documentation to be maintained to support compliance with the regulatory requirements. Effect Failure to maintain, distribute and enforce uniform policies and procedures across the University may result in appropriate documentation not being maintained for compliance purposes. Recommendation PwC recommends the University establish consistent policies and procedures for all compliance areas and hold trainings to ensure that student financial aid staff are aware of the required policies. Management’s Views and Corrective Action Plan Management's views and corrective action plan is included in Section V.

Award Information Cluster: Student Financial Assistance Grantor: Department of Education Award Name: Federal Supplemental Educational Opportunity Grant, Federal Work-Study, Federal Pell Grant, Federal Direct Student Loan, Primary Care Loan, Loan for Disadvantaged Students, Health Professions Student Loans, Nursing Student Loan Award Year: FY2023 CFDA Number: 84.007, 84.033, 84.063, 84.268, 93.342, 93.342, 93.342, 93.364 Criteria The University has a centralized office of student financial assistance, as well as individual offices at various schools within the University. Through testing of various compliance requirements, PwC noted improvements are needed to the documentation and execution of certain student financial aid requirements throughout the University. Specific criteria related to areas that need improvement are as follows: • An institution is required to establish written policies and procedures that incorporate the provisions of 34 CFR 668.51 through 668.61 for verifying applicant information for those applicants selected for verification by the Department of Education (ED). The institution shall require each applicant whose application is selected by ED to verify the information required for the Verification Tracking Group to which the applicant is assigned. • The Electronic Signatures in Global and National Commerce Act (“E-Sign Act”) states that a school must obtain a student’s voluntary consent to participate in electronic transactions. • University policy is to maintain a formal Title IV calculation form when a student withdraws or takes a leave of absence from the University. • An institution must communicate Campus-Level and Program-Level enrollment data when there is a student status change (34 CFR 674.19). • 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 (CFR 668.34). Condition As part of PwC’s testing over the student financial assistance cluster, they noted the following: • PwC selected 25 students who were selected by the Department of Education for verification. For six out of the 25 students selected, the University was required to obtain a statement of identity. The University could not provide documentation that evidenced a statement of identity was obtained. In examining 25 student records, the University did not receive a student's consent to participate in electronic transactions for one of the selections. After further investigation by the University, it was determined there were a total of 361 students that did not sign the voluntary consent, inclusive of the one PwC selected. • PwC selected 16 students that required a Return of Title IV calculation. For two of the selected students, the University did not formally document the refund calculation performed. For one student, a return of Title IV funds was not needed and for the other student, the required return of Title IV funds was appropriately made within the required timeframe. • PwC selected 25 students that had a student status change. For two of the selections, the University enrollment change was communicated to the NSLDS accurately and timely, however the program level data was not communicated as required by the regulations. • PwC reviewed the University’s policies over satisfactory academic progress. There were four schools within the University that did not document procedures for disbursements to students on financial aid warning status or financial aid probation status. Additionally, there was one school that did not document policies stating that students who (1) have not achieved the required GPA, (2) are not successfully completing their program of study at the required pace (if required), or (3) have not completed the program within the maximum time frame will no longer be eligible for Title IV aid. Questioned Costs None noted. Cause The University does not have consistent policies and procedures in place that require the appropriate documentation to be maintained to support compliance with the regulatory requirements. Effect Failure to maintain, distribute and enforce uniform policies and procedures across the University may result in appropriate documentation not being maintained for compliance purposes. Recommendation PwC recommends the University establish consistent policies and procedures for all compliance areas and hold trainings to ensure that student financial aid staff are aware of the required policies. Management’s Views and Corrective Action Plan Management's views and corrective action plan is included in Section V.

Award Information Cluster: Student Financial Assistance Grantor: Department of Education Award Name: Federal Supplemental Educational Opportunity Grant, Federal Work-Study, Federal Pell Grant, Federal Direct Student Loan, Primary Care Loan, Loan for Disadvantaged Students, Health Professions Student Loans, Nursing Student Loan Award Year: FY2023 CFDA Number: 84.007, 84.033, 84.063, 84.268, 93.342, 93.342, 93.342, 93.364 Criteria The University has a centralized office of student financial assistance, as well as individual offices at various schools within the University. Through testing of various compliance requirements, PwC noted improvements are needed to the documentation and execution of certain student financial aid requirements throughout the University. Specific criteria related to areas that need improvement are as follows: • An institution is required to establish written policies and procedures that incorporate the provisions of 34 CFR 668.51 through 668.61 for verifying applicant information for those applicants selected for verification by the Department of Education (ED). The institution shall require each applicant whose application is selected by ED to verify the information required for the Verification Tracking Group to which the applicant is assigned. • The Electronic Signatures in Global and National Commerce Act (“E-Sign Act”) states that a school must obtain a student’s voluntary consent to participate in electronic transactions. • University policy is to maintain a formal Title IV calculation form when a student withdraws or takes a leave of absence from the University. • An institution must communicate Campus-Level and Program-Level enrollment data when there is a student status change (34 CFR 674.19). • 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 (CFR 668.34). Condition As part of PwC’s testing over the student financial assistance cluster, they noted the following: • PwC selected 25 students who were selected by the Department of Education for verification. For six out of the 25 students selected, the University was required to obtain a statement of identity. The University could not provide documentation that evidenced a statement of identity was obtained. In examining 25 student records, the University did not receive a student's consent to participate in electronic transactions for one of the selections. After further investigation by the University, it was determined there were a total of 361 students that did not sign the voluntary consent, inclusive of the one PwC selected. • PwC selected 16 students that required a Return of Title IV calculation. For two of the selected students, the University did not formally document the refund calculation performed. For one student, a return of Title IV funds was not needed and for the other student, the required return of Title IV funds was appropriately made within the required timeframe. • PwC selected 25 students that had a student status change. For two of the selections, the University enrollment change was communicated to the NSLDS accurately and timely, however the program level data was not communicated as required by the regulations. • PwC reviewed the University’s policies over satisfactory academic progress. There were four schools within the University that did not document procedures for disbursements to students on financial aid warning status or financial aid probation status. Additionally, there was one school that did not document policies stating that students who (1) have not achieved the required GPA, (2) are not successfully completing their program of study at the required pace (if required), or (3) have not completed the program within the maximum time frame will no longer be eligible for Title IV aid. Questioned Costs None noted. Cause The University does not have consistent policies and procedures in place that require the appropriate documentation to be maintained to support compliance with the regulatory requirements. Effect Failure to maintain, distribute and enforce uniform policies and procedures across the University may result in appropriate documentation not being maintained for compliance purposes. Recommendation PwC recommends the University establish consistent policies and procedures for all compliance areas and hold trainings to ensure that student financial aid staff are aware of the required policies. Management’s Views and Corrective Action Plan Management's views and corrective action plan is included in Section V.

Award Information Cluster: Student Financial Assistance Grantor: Department of Education Award Name: Federal Supplemental Educational Opportunity Grant, Federal Work-Study, Federal Pell Grant, Federal Direct Student Loan, Primary Care Loan, Loan for Disadvantaged Students, Health Professions Student Loans, Nursing Student Loan Award Year: FY2023 CFDA Number: 84.007, 84.033, 84.063, 84.268, 93.342, 93.342, 93.342, 93.364 Criteria The University has a centralized office of student financial assistance, as well as individual offices at various schools within the University. Through testing of various compliance requirements, PwC noted improvements are needed to the documentation and execution of certain student financial aid requirements throughout the University. Specific criteria related to areas that need improvement are as follows: • An institution is required to establish written policies and procedures that incorporate the provisions of 34 CFR 668.51 through 668.61 for verifying applicant information for those applicants selected for verification by the Department of Education (ED). The institution shall require each applicant whose application is selected by ED to verify the information required for the Verification Tracking Group to which the applicant is assigned. • The Electronic Signatures in Global and National Commerce Act (“E-Sign Act”) states that a school must obtain a student’s voluntary consent to participate in electronic transactions. • University policy is to maintain a formal Title IV calculation form when a student withdraws or takes a leave of absence from the University. • An institution must communicate Campus-Level and Program-Level enrollment data when there is a student status change (34 CFR 674.19). • 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 (CFR 668.34). Condition As part of PwC’s testing over the student financial assistance cluster, they noted the following: • PwC selected 25 students who were selected by the Department of Education for verification. For six out of the 25 students selected, the University was required to obtain a statement of identity. The University could not provide documentation that evidenced a statement of identity was obtained. In examining 25 student records, the University did not receive a student's consent to participate in electronic transactions for one of the selections. After further investigation by the University, it was determined there were a total of 361 students that did not sign the voluntary consent, inclusive of the one PwC selected. • PwC selected 16 students that required a Return of Title IV calculation. For two of the selected students, the University did not formally document the refund calculation performed. For one student, a return of Title IV funds was not needed and for the other student, the required return of Title IV funds was appropriately made within the required timeframe. • PwC selected 25 students that had a student status change. For two of the selections, the University enrollment change was communicated to the NSLDS accurately and timely, however the program level data was not communicated as required by the regulations. • PwC reviewed the University’s policies over satisfactory academic progress. There were four schools within the University that did not document procedures for disbursements to students on financial aid warning status or financial aid probation status. Additionally, there was one school that did not document policies stating that students who (1) have not achieved the required GPA, (2) are not successfully completing their program of study at the required pace (if required), or (3) have not completed the program within the maximum time frame will no longer be eligible for Title IV aid. Questioned Costs None noted. Cause The University does not have consistent policies and procedures in place that require the appropriate documentation to be maintained to support compliance with the regulatory requirements. Effect Failure to maintain, distribute and enforce uniform policies and procedures across the University may result in appropriate documentation not being maintained for compliance purposes. Recommendation PwC recommends the University establish consistent policies and procedures for all compliance areas and hold trainings to ensure that student financial aid staff are aware of the required policies. Management’s Views and Corrective Action Plan Management's views and corrective action plan is included in Section V.

Award Information Cluster: Student Financial Assistance Grantor: Department of Education Award Name: Federal Supplemental Educational Opportunity Grant, Federal Work-Study, Federal Pell Grant, Federal Direct Student Loan, Primary Care Loan, Loan for Disadvantaged Students, Health Professions Student Loans, Nursing Student Loan Award Year: FY2023 CFDA Number: 84.007, 84.033, 84.063, 84.268, 93.342, 93.342, 93.342, 93.364 Criteria The University has a centralized office of student financial assistance, as well as individual offices at various schools within the University. Through testing of various compliance requirements, PwC noted improvements are needed to the documentation and execution of certain student financial aid requirements throughout the University. Specific criteria related to areas that need improvement are as follows: • An institution is required to establish written policies and procedures that incorporate the provisions of 34 CFR 668.51 through 668.61 for verifying applicant information for those applicants selected for verification by the Department of Education (ED). The institution shall require each applicant whose application is selected by ED to verify the information required for the Verification Tracking Group to which the applicant is assigned. • The Electronic Signatures in Global and National Commerce Act (“E-Sign Act”) states that a school must obtain a student’s voluntary consent to participate in electronic transactions. • University policy is to maintain a formal Title IV calculation form when a student withdraws or takes a leave of absence from the University. • An institution must communicate Campus-Level and Program-Level enrollment data when there is a student status change (34 CFR 674.19). • 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 (CFR 668.34). Condition As part of PwC’s testing over the student financial assistance cluster, they noted the following: • PwC selected 25 students who were selected by the Department of Education for verification. For six out of the 25 students selected, the University was required to obtain a statement of identity. The University could not provide documentation that evidenced a statement of identity was obtained. In examining 25 student records, the University did not receive a student's consent to participate in electronic transactions for one of the selections. After further investigation by the University, it was determined there were a total of 361 students that did not sign the voluntary consent, inclusive of the one PwC selected. • PwC selected 16 students that required a Return of Title IV calculation. For two of the selected students, the University did not formally document the refund calculation performed. For one student, a return of Title IV funds was not needed and for the other student, the required return of Title IV funds was appropriately made within the required timeframe. • PwC selected 25 students that had a student status change. For two of the selections, the University enrollment change was communicated to the NSLDS accurately and timely, however the program level data was not communicated as required by the regulations. • PwC reviewed the University’s policies over satisfactory academic progress. There were four schools within the University that did not document procedures for disbursements to students on financial aid warning status or financial aid probation status. Additionally, there was one school that did not document policies stating that students who (1) have not achieved the required GPA, (2) are not successfully completing their program of study at the required pace (if required), or (3) have not completed the program within the maximum time frame will no longer be eligible for Title IV aid. Questioned Costs None noted. Cause The University does not have consistent policies and procedures in place that require the appropriate documentation to be maintained to support compliance with the regulatory requirements. Effect Failure to maintain, distribute and enforce uniform policies and procedures across the University may result in appropriate documentation not being maintained for compliance purposes. Recommendation PwC recommends the University establish consistent policies and procedures for all compliance areas and hold trainings to ensure that student financial aid staff are aware of the required policies. Management’s Views and Corrective Action Plan Management's views and corrective action plan is included in Section V.

Award Information Cluster: Student Financial Assistance Grantor: Department of Education Award Name: Federal Supplemental Educational Opportunity Grant, Federal Work-Study, Federal Pell Grant, Federal Direct Student Loan, Primary Care Loan, Loan for Disadvantaged Students, Health Professions Student Loans, Nursing Student Loan Award Year: FY2023 CFDA Number: 84.007, 84.033, 84.063, 84.268, 93.342, 93.342, 93.342, 93.364 Criteria The University has a centralized office of student financial assistance, as well as individual offices at various schools within the University. Through testing of various compliance requirements, PwC noted improvements are needed to the documentation and execution of certain student financial aid requirements throughout the University. Specific criteria related to areas that need improvement are as follows: • An institution is required to establish written policies and procedures that incorporate the provisions of 34 CFR 668.51 through 668.61 for verifying applicant information for those applicants selected for verification by the Department of Education (ED). The institution shall require each applicant whose application is selected by ED to verify the information required for the Verification Tracking Group to which the applicant is assigned. • The Electronic Signatures in Global and National Commerce Act (“E-Sign Act”) states that a school must obtain a student’s voluntary consent to participate in electronic transactions. • University policy is to maintain a formal Title IV calculation form when a student withdraws or takes a leave of absence from the University. • An institution must communicate Campus-Level and Program-Level enrollment data when there is a student status change (34 CFR 674.19). • 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 (CFR 668.34). Condition As part of PwC’s testing over the student financial assistance cluster, they noted the following: • PwC selected 25 students who were selected by the Department of Education for verification. For six out of the 25 students selected, the University was required to obtain a statement of identity. The University could not provide documentation that evidenced a statement of identity was obtained. In examining 25 student records, the University did not receive a student's consent to participate in electronic transactions for one of the selections. After further investigation by the University, it was determined there were a total of 361 students that did not sign the voluntary consent, inclusive of the one PwC selected. • PwC selected 16 students that required a Return of Title IV calculation. For two of the selected students, the University did not formally document the refund calculation performed. For one student, a return of Title IV funds was not needed and for the other student, the required return of Title IV funds was appropriately made within the required timeframe. • PwC selected 25 students that had a student status change. For two of the selections, the University enrollment change was communicated to the NSLDS accurately and timely, however the program level data was not communicated as required by the regulations. • PwC reviewed the University’s policies over satisfactory academic progress. There were four schools within the University that did not document procedures for disbursements to students on financial aid warning status or financial aid probation status. Additionally, there was one school that did not document policies stating that students who (1) have not achieved the required GPA, (2) are not successfully completing their program of study at the required pace (if required), or (3) have not completed the program within the maximum time frame will no longer be eligible for Title IV aid. Questioned Costs None noted. Cause The University does not have consistent policies and procedures in place that require the appropriate documentation to be maintained to support compliance with the regulatory requirements. Effect Failure to maintain, distribute and enforce uniform policies and procedures across the University may result in appropriate documentation not being maintained for compliance purposes. Recommendation PwC recommends the University establish consistent policies and procedures for all compliance areas and hold trainings to ensure that student financial aid staff are aware of the required policies. Management’s Views and Corrective Action Plan Management's views and corrective action plan is included in Section V.

Award Information Cluster: Student Financial Assistance Grantor: Department of Education Award Name: Federal Supplemental Educational Opportunity Grant, Federal Work-Study, Federal Pell Grant, Federal Direct Student Loan, Primary Care Loan, Loan for Disadvantaged Students, Health Professions Student Loans, Nursing Student Loan Award Year: FY2023 CFDA Number: 84.007, 84.033, 84.063, 84.268, 93.342, 93.342, 93.342, 93.364 Criteria The University has a centralized office of student financial assistance, as well as individual offices at various schools within the University. Through testing of various compliance requirements, PwC noted improvements are needed to the documentation and execution of certain student financial aid requirements throughout the University. Specific criteria related to areas that need improvement are as follows: • An institution is required to establish written policies and procedures that incorporate the provisions of 34 CFR 668.51 through 668.61 for verifying applicant information for those applicants selected for verification by the Department of Education (ED). The institution shall require each applicant whose application is selected by ED to verify the information required for the Verification Tracking Group to which the applicant is assigned. • The Electronic Signatures in Global and National Commerce Act (“E-Sign Act”) states that a school must obtain a student’s voluntary consent to participate in electronic transactions. • University policy is to maintain a formal Title IV calculation form when a student withdraws or takes a leave of absence from the University. • An institution must communicate Campus-Level and Program-Level enrollment data when there is a student status change (34 CFR 674.19). • 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 (CFR 668.34). Condition As part of PwC’s testing over the student financial assistance cluster, they noted the following: • PwC selected 25 students who were selected by the Department of Education for verification. For six out of the 25 students selected, the University was required to obtain a statement of identity. The University could not provide documentation that evidenced a statement of identity was obtained. In examining 25 student records, the University did not receive a student's consent to participate in electronic transactions for one of the selections. After further investigation by the University, it was determined there were a total of 361 students that did not sign the voluntary consent, inclusive of the one PwC selected. • PwC selected 16 students that required a Return of Title IV calculation. For two of the selected students, the University did not formally document the refund calculation performed. For one student, a return of Title IV funds was not needed and for the other student, the required return of Title IV funds was appropriately made within the required timeframe. • PwC selected 25 students that had a student status change. For two of the selections, the University enrollment change was communicated to the NSLDS accurately and timely, however the program level data was not communicated as required by the regulations. • PwC reviewed the University’s policies over satisfactory academic progress. There were four schools within the University that did not document procedures for disbursements to students on financial aid warning status or financial aid probation status. Additionally, there was one school that did not document policies stating that students who (1) have not achieved the required GPA, (2) are not successfully completing their program of study at the required pace (if required), or (3) have not completed the program within the maximum time frame will no longer be eligible for Title IV aid. Questioned Costs None noted. Cause The University does not have consistent policies and procedures in place that require the appropriate documentation to be maintained to support compliance with the regulatory requirements. Effect Failure to maintain, distribute and enforce uniform policies and procedures across the University may result in appropriate documentation not being maintained for compliance purposes. Recommendation PwC recommends the University establish consistent policies and procedures for all compliance areas and hold trainings to ensure that student financial aid staff are aware of the required policies. Management’s Views and Corrective Action Plan Management's views and corrective action plan is included in Section V.

Award Information Cluster: Student Financial Assistance Grantor: Department of Education Award Name: Federal Supplemental Educational Opportunity Grant, Federal Work-Study, Federal Pell Grant, Federal Direct Student Loan, Primary Care Loan, Loan for Disadvantaged Students, Health Professions Student Loans, Nursing Student Loan Award Year: FY2023 CFDA Number: 84.007, 84.033, 84.063, 84.268, 93.342, 93.342, 93.342, 93.364 Criteria The University has a centralized office of student financial assistance, as well as individual offices at various schools within the University. Through testing of various compliance requirements, PwC noted improvements are needed to the documentation and execution of certain student financial aid requirements throughout the University. Specific criteria related to areas that need improvement are as follows: • An institution is required to establish written policies and procedures that incorporate the provisions of 34 CFR 668.51 through 668.61 for verifying applicant information for those applicants selected for verification by the Department of Education (ED). The institution shall require each applicant whose application is selected by ED to verify the information required for the Verification Tracking Group to which the applicant is assigned. • The Electronic Signatures in Global and National Commerce Act (“E-Sign Act”) states that a school must obtain a student’s voluntary consent to participate in electronic transactions. • University policy is to maintain a formal Title IV calculation form when a student withdraws or takes a leave of absence from the University. • An institution must communicate Campus-Level and Program-Level enrollment data when there is a student status change (34 CFR 674.19). • 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 (CFR 668.34). Condition As part of PwC’s testing over the student financial assistance cluster, they noted the following: • PwC selected 25 students who were selected by the Department of Education for verification. For six out of the 25 students selected, the University was required to obtain a statement of identity. The University could not provide documentation that evidenced a statement of identity was obtained. In examining 25 student records, the University did not receive a student's consent to participate in electronic transactions for one of the selections. After further investigation by the University, it was determined there were a total of 361 students that did not sign the voluntary consent, inclusive of the one PwC selected. • PwC selected 16 students that required a Return of Title IV calculation. For two of the selected students, the University did not formally document the refund calculation performed. For one student, a return of Title IV funds was not needed and for the other student, the required return of Title IV funds was appropriately made within the required timeframe. • PwC selected 25 students that had a student status change. For two of the selections, the University enrollment change was communicated to the NSLDS accurately and timely, however the program level data was not communicated as required by the regulations. • PwC reviewed the University’s policies over satisfactory academic progress. There were four schools within the University that did not document procedures for disbursements to students on financial aid warning status or financial aid probation status. Additionally, there was one school that did not document policies stating that students who (1) have not achieved the required GPA, (2) are not successfully completing their program of study at the required pace (if required), or (3) have not completed the program within the maximum time frame will no longer be eligible for Title IV aid. Questioned Costs None noted. Cause The University does not have consistent policies and procedures in place that require the appropriate documentation to be maintained to support compliance with the regulatory requirements. Effect Failure to maintain, distribute and enforce uniform policies and procedures across the University may result in appropriate documentation not being maintained for compliance purposes. Recommendation PwC recommends the University establish consistent policies and procedures for all compliance areas and hold trainings to ensure that student financial aid staff are aware of the required policies. Management’s Views and Corrective Action Plan Management's views and corrective action plan is included in Section V.

Award Information Cluster: Student Financial Assistance Grantor: Department of Education Award Name: Federal Supplemental Educational Opportunity Grant, Federal Work-Study, Federal Pell Grant, Federal Direct Student Loan, Primary Care Loan, Loan for Disadvantaged Students, Health Professions Student Loans, Nursing Student Loan Award Year: FY2023 CFDA Number: 84.007, 84.033, 84.063, 84.268, 93.342, 93.342, 93.342, 93.364 Criteria The University has a centralized office of student financial assistance, as well as individual offices at various schools within the University. Through testing of various compliance requirements, PwC noted improvements are needed to the documentation and execution of certain student financial aid requirements throughout the University. Specific criteria related to areas that need improvement are as follows: • An institution is required to establish written policies and procedures that incorporate the provisions of 34 CFR 668.51 through 668.61 for verifying applicant information for those applicants selected for verification by the Department of Education (ED). The institution shall require each applicant whose application is selected by ED to verify the information required for the Verification Tracking Group to which the applicant is assigned. • The Electronic Signatures in Global and National Commerce Act (“E-Sign Act”) states that a school must obtain a student’s voluntary consent to participate in electronic transactions. • University policy is to maintain a formal Title IV calculation form when a student withdraws or takes a leave of absence from the University. • An institution must communicate Campus-Level and Program-Level enrollment data when there is a student status change (34 CFR 674.19). • 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 (CFR 668.34). Condition As part of PwC’s testing over the student financial assistance cluster, they noted the following: • PwC selected 25 students who were selected by the Department of Education for verification. For six out of the 25 students selected, the University was required to obtain a statement of identity. The University could not provide documentation that evidenced a statement of identity was obtained. In examining 25 student records, the University did not receive a student's consent to participate in electronic transactions for one of the selections. After further investigation by the University, it was determined there were a total of 361 students that did not sign the voluntary consent, inclusive of the one PwC selected. • PwC selected 16 students that required a Return of Title IV calculation. For two of the selected students, the University did not formally document the refund calculation performed. For one student, a return of Title IV funds was not needed and for the other student, the required return of Title IV funds was appropriately made within the required timeframe. • PwC selected 25 students that had a student status change. For two of the selections, the University enrollment change was communicated to the NSLDS accurately and timely, however the program level data was not communicated as required by the regulations. • PwC reviewed the University’s policies over satisfactory academic progress. There were four schools within the University that did not document procedures for disbursements to students on financial aid warning status or financial aid probation status. Additionally, there was one school that did not document policies stating that students who (1) have not achieved the required GPA, (2) are not successfully completing their program of study at the required pace (if required), or (3) have not completed the program within the maximum time frame will no longer be eligible for Title IV aid. Questioned Costs None noted. Cause The University does not have consistent policies and procedures in place that require the appropriate documentation to be maintained to support compliance with the regulatory requirements. Effect Failure to maintain, distribute and enforce uniform policies and procedures across the University may result in appropriate documentation not being maintained for compliance purposes. Recommendation PwC recommends the University establish consistent policies and procedures for all compliance areas and hold trainings to ensure that student financial aid staff are aware of the required policies. Management’s Views and Corrective Action Plan Management's views and corrective action plan is included in Section V.

Award Information Cluster: Student Financial Assistance Grantor: Department of Education Award Name: Federal Supplemental Educational Opportunity Grant, Federal Work-Study, Federal Pell Grant, Federal Direct Student Loan, Primary Care Loan, Loan for Disadvantaged Students, Health Professions Student Loans, Nursing Student Loan Award Year: FY2023 CFDA Number: 84.007, 84.033, 84.063, 84.268, 93.342, 93.342, 93.342, 93.364 Criteria The University has a centralized office of student financial assistance, as well as individual offices at various schools within the University. Through testing of various compliance requirements, PwC noted improvements are needed to the documentation and execution of certain student financial aid requirements throughout the University. Specific criteria related to areas that need improvement are as follows: • An institution is required to establish written policies and procedures that incorporate the provisions of 34 CFR 668.51 through 668.61 for verifying applicant information for those applicants selected for verification by the Department of Education (ED). The institution shall require each applicant whose application is selected by ED to verify the information required for the Verification Tracking Group to which the applicant is assigned. • The Electronic Signatures in Global and National Commerce Act (“E-Sign Act”) states that a school must obtain a student’s voluntary consent to participate in electronic transactions. • University policy is to maintain a formal Title IV calculation form when a student withdraws or takes a leave of absence from the University. • An institution must communicate Campus-Level and Program-Level enrollment data when there is a student status change (34 CFR 674.19). • 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 (CFR 668.34). Condition As part of PwC’s testing over the student financial assistance cluster, they noted the following: • PwC selected 25 students who were selected by the Department of Education for verification. For six out of the 25 students selected, the University was required to obtain a statement of identity. The University could not provide documentation that evidenced a statement of identity was obtained. In examining 25 student records, the University did not receive a student's consent to participate in electronic transactions for one of the selections. After further investigation by the University, it was determined there were a total of 361 students that did not sign the voluntary consent, inclusive of the one PwC selected. • PwC selected 16 students that required a Return of Title IV calculation. For two of the selected students, the University did not formally document the refund calculation performed. For one student, a return of Title IV funds was not needed and for the other student, the required return of Title IV funds was appropriately made within the required timeframe. • PwC selected 25 students that had a student status change. For two of the selections, the University enrollment change was communicated to the NSLDS accurately and timely, however the program level data was not communicated as required by the regulations. • PwC reviewed the University’s policies over satisfactory academic progress. There were four schools within the University that did not document procedures for disbursements to students on financial aid warning status or financial aid probation status. Additionally, there was one school that did not document policies stating that students who (1) have not achieved the required GPA, (2) are not successfully completing their program of study at the required pace (if required), or (3) have not completed the program within the maximum time frame will no longer be eligible for Title IV aid. Questioned Costs None noted. Cause The University does not have consistent policies and procedures in place that require the appropriate documentation to be maintained to support compliance with the regulatory requirements. Effect Failure to maintain, distribute and enforce uniform policies and procedures across the University may result in appropriate documentation not being maintained for compliance purposes. Recommendation PwC recommends the University establish consistent policies and procedures for all compliance areas and hold trainings to ensure that student financial aid staff are aware of the required policies. Management’s Views and Corrective Action Plan Management's views and corrective action plan is included in Section V.

Award Information Cluster: Student Financial Assistance Grantor: Department of Education Award Name: Federal Supplemental Educational Opportunity Grant, Federal Work-Study, Federal Pell Grant, Federal Direct Student Loan, Primary Care Loan, Loan for Disadvantaged Students, Health Professions Student Loans, Nursing Student Loan Award Year: FY2023 CFDA Number: 84.007, 84.033, 84.063, 84.268, 93.342, 93.342, 93.342, 93.364 Criteria The University has a centralized office of student financial assistance, as well as individual offices at various schools within the University. Through testing of various compliance requirements, PwC noted improvements are needed to the documentation and execution of certain student financial aid requirements throughout the University. Specific criteria related to areas that need improvement are as follows: • An institution is required to establish written policies and procedures that incorporate the provisions of 34 CFR 668.51 through 668.61 for verifying applicant information for those applicants selected for verification by the Department of Education (ED). The institution shall require each applicant whose application is selected by ED to verify the information required for the Verification Tracking Group to which the applicant is assigned. • The Electronic Signatures in Global and National Commerce Act (“E-Sign Act”) states that a school must obtain a student’s voluntary consent to participate in electronic transactions. • University policy is to maintain a formal Title IV calculation form when a student withdraws or takes a leave of absence from the University. • An institution must communicate Campus-Level and Program-Level enrollment data when there is a student status change (34 CFR 674.19). • 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 (CFR 668.34). Condition As part of PwC’s testing over the student financial assistance cluster, they noted the following: • PwC selected 25 students who were selected by the Department of Education for verification. For six out of the 25 students selected, the University was required to obtain a statement of identity. The University could not provide documentation that evidenced a statement of identity was obtained. In examining 25 student records, the University did not receive a student's consent to participate in electronic transactions for one of the selections. After further investigation by the University, it was determined there were a total of 361 students that did not sign the voluntary consent, inclusive of the one PwC selected. • PwC selected 16 students that required a Return of Title IV calculation. For two of the selected students, the University did not formally document the refund calculation performed. For one student, a return of Title IV funds was not needed and for the other student, the required return of Title IV funds was appropriately made within the required timeframe. • PwC selected 25 students that had a student status change. For two of the selections, the University enrollment change was communicated to the NSLDS accurately and timely, however the program level data was not communicated as required by the regulations. • PwC reviewed the University’s policies over satisfactory academic progress. There were four schools within the University that did not document procedures for disbursements to students on financial aid warning status or financial aid probation status. Additionally, there was one school that did not document policies stating that students who (1) have not achieved the required GPA, (2) are not successfully completing their program of study at the required pace (if required), or (3) have not completed the program within the maximum time frame will no longer be eligible for Title IV aid. Questioned Costs None noted. Cause The University does not have consistent policies and procedures in place that require the appropriate documentation to be maintained to support compliance with the regulatory requirements. Effect Failure to maintain, distribute and enforce uniform policies and procedures across the University may result in appropriate documentation not being maintained for compliance purposes. Recommendation PwC recommends the University establish consistent policies and procedures for all compliance areas and hold trainings to ensure that student financial aid staff are aware of the required policies. Management’s Views and Corrective Action Plan Management's views and corrective action plan is included in Section V.

Award Information Cluster: Student Financial Assistance Grantor: Department of Education Award Name: Federal Supplemental Educational Opportunity Grant, Federal Work-Study, Federal Pell Grant, Federal Direct Student Loan, Primary Care Loan, Loan for Disadvantaged Students, Health Professions Student Loans, Nursing Student Loan Award Year: FY2023 CFDA Number: 84.007, 84.033, 84.063, 84.268, 93.342, 93.342, 93.342, 93.364 Criteria The University has a centralized office of student financial assistance, as well as individual offices at various schools within the University. Through testing of various compliance requirements, PwC noted improvements are needed to the documentation and execution of certain student financial aid requirements throughout the University. Specific criteria related to areas that need improvement are as follows: • An institution is required to establish written policies and procedures that incorporate the provisions of 34 CFR 668.51 through 668.61 for verifying applicant information for those applicants selected for verification by the Department of Education (ED). The institution shall require each applicant whose application is selected by ED to verify the information required for the Verification Tracking Group to which the applicant is assigned. • The Electronic Signatures in Global and National Commerce Act (“E-Sign Act”) states that a school must obtain a student’s voluntary consent to participate in electronic transactions. • University policy is to maintain a formal Title IV calculation form when a student withdraws or takes a leave of absence from the University. • An institution must communicate Campus-Level and Program-Level enrollment data when there is a student status change (34 CFR 674.19). • 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 (CFR 668.34). Condition As part of PwC’s testing over the student financial assistance cluster, they noted the following: • PwC selected 25 students who were selected by the Department of Education for verification. For six out of the 25 students selected, the University was required to obtain a statement of identity. The University could not provide documentation that evidenced a statement of identity was obtained. In examining 25 student records, the University did not receive a student's consent to participate in electronic transactions for one of the selections. After further investigation by the University, it was determined there were a total of 361 students that did not sign the voluntary consent, inclusive of the one PwC selected. • PwC selected 16 students that required a Return of Title IV calculation. For two of the selected students, the University did not formally document the refund calculation performed. For one student, a return of Title IV funds was not needed and for the other student, the required return of Title IV funds was appropriately made within the required timeframe. • PwC selected 25 students that had a student status change. For two of the selections, the University enrollment change was communicated to the NSLDS accurately and timely, however the program level data was not communicated as required by the regulations. • PwC reviewed the University’s policies over satisfactory academic progress. There were four schools within the University that did not document procedures for disbursements to students on financial aid warning status or financial aid probation status. Additionally, there was one school that did not document policies stating that students who (1) have not achieved the required GPA, (2) are not successfully completing their program of study at the required pace (if required), or (3) have not completed the program within the maximum time frame will no longer be eligible for Title IV aid. Questioned Costs None noted. Cause The University does not have consistent policies and procedures in place that require the appropriate documentation to be maintained to support compliance with the regulatory requirements. Effect Failure to maintain, distribute and enforce uniform policies and procedures across the University may result in appropriate documentation not being maintained for compliance purposes. Recommendation PwC recommends the University establish consistent policies and procedures for all compliance areas and hold trainings to ensure that student financial aid staff are aware of the required policies. Management’s Views and Corrective Action Plan Management's views and corrective action plan is included in Section V.

Award Information Cluster: Student Financial Assistance Grantor: Department of Education Award Name: Federal Supplemental Educational Opportunity Grant, Federal Work-Study, Federal Pell Grant, Federal Direct Student Loan, Primary Care Loan, Loan for Disadvantaged Students, Health Professions Student Loans, Nursing Student Loan Award Year: FY2023 CFDA Number: 84.007, 84.033, 84.063, 84.268, 93.342, 93.342, 93.342, 93.364 Criteria The University has a centralized office of student financial assistance, as well as individual offices at various schools within the University. Through testing of various compliance requirements, PwC noted improvements are needed to the documentation and execution of certain student financial aid requirements throughout the University. Specific criteria related to areas that need improvement are as follows: • An institution is required to establish written policies and procedures that incorporate the provisions of 34 CFR 668.51 through 668.61 for verifying applicant information for those applicants selected for verification by the Department of Education (ED). The institution shall require each applicant whose application is selected by ED to verify the information required for the Verification Tracking Group to which the applicant is assigned. • The Electronic Signatures in Global and National Commerce Act (“E-Sign Act”) states that a school must obtain a student’s voluntary consent to participate in electronic transactions. • University policy is to maintain a formal Title IV calculation form when a student withdraws or takes a leave of absence from the University. • An institution must communicate Campus-Level and Program-Level enrollment data when there is a student status change (34 CFR 674.19). • 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 (CFR 668.34). Condition As part of PwC’s testing over the student financial assistance cluster, they noted the following: • PwC selected 25 students who were selected by the Department of Education for verification. For six out of the 25 students selected, the University was required to obtain a statement of identity. The University could not provide documentation that evidenced a statement of identity was obtained. In examining 25 student records, the University did not receive a student's consent to participate in electronic transactions for one of the selections. After further investigation by the University, it was determined there were a total of 361 students that did not sign the voluntary consent, inclusive of the one PwC selected. • PwC selected 16 students that required a Return of Title IV calculation. For two of the selected students, the University did not formally document the refund calculation performed. For one student, a return of Title IV funds was not needed and for the other student, the required return of Title IV funds was appropriately made within the required timeframe. • PwC selected 25 students that had a student status change. For two of the selections, the University enrollment change was communicated to the NSLDS accurately and timely, however the program level data was not communicated as required by the regulations. • PwC reviewed the University’s policies over satisfactory academic progress. There were four schools within the University that did not document procedures for disbursements to students on financial aid warning status or financial aid probation status. Additionally, there was one school that did not document policies stating that students who (1) have not achieved the required GPA, (2) are not successfully completing their program of study at the required pace (if required), or (3) have not completed the program within the maximum time frame will no longer be eligible for Title IV aid. Questioned Costs None noted. Cause The University does not have consistent policies and procedures in place that require the appropriate documentation to be maintained to support compliance with the regulatory requirements. Effect Failure to maintain, distribute and enforce uniform policies and procedures across the University may result in appropriate documentation not being maintained for compliance purposes. Recommendation PwC recommends the University establish consistent policies and procedures for all compliance areas and hold trainings to ensure that student financial aid staff are aware of the required policies. Management’s Views and Corrective Action Plan Management's views and corrective action plan is included in Section V.

Award Information Cluster: Student Financial Assistance Grantor: Department of Education Award Name: Federal Supplemental Educational Opportunity Grant, Federal Work-Study, Federal Pell Grant, Federal Direct Student Loan, Primary Care Loan, Loan for Disadvantaged Students, Health Professions Student Loans, Nursing Student Loan Award Year: FY2023 CFDA Number: 84.007, 84.033, 84.063, 84.268, 93.342, 93.342, 93.342, 93.364 Criteria The University has a centralized office of student financial assistance, as well as individual offices at various schools within the University. Through testing of various compliance requirements, PwC noted improvements are needed to the documentation and execution of certain student financial aid requirements throughout the University. Specific criteria related to areas that need improvement are as follows: • An institution is required to establish written policies and procedures that incorporate the provisions of 34 CFR 668.51 through 668.61 for verifying applicant information for those applicants selected for verification by the Department of Education (ED). The institution shall require each applicant whose application is selected by ED to verify the information required for the Verification Tracking Group to which the applicant is assigned. • The Electronic Signatures in Global and National Commerce Act (“E-Sign Act”) states that a school must obtain a student’s voluntary consent to participate in electronic transactions. • University policy is to maintain a formal Title IV calculation form when a student withdraws or takes a leave of absence from the University. • An institution must communicate Campus-Level and Program-Level enrollment data when there is a student status change (34 CFR 674.19). • 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 (CFR 668.34). Condition As part of PwC’s testing over the student financial assistance cluster, they noted the following: • PwC selected 25 students who were selected by the Department of Education for verification. For six out of the 25 students selected, the University was required to obtain a statement of identity. The University could not provide documentation that evidenced a statement of identity was obtained. In examining 25 student records, the University did not receive a student's consent to participate in electronic transactions for one of the selections. After further investigation by the University, it was determined there were a total of 361 students that did not sign the voluntary consent, inclusive of the one PwC selected. • PwC selected 16 students that required a Return of Title IV calculation. For two of the selected students, the University did not formally document the refund calculation performed. For one student, a return of Title IV funds was not needed and for the other student, the required return of Title IV funds was appropriately made within the required timeframe. • PwC selected 25 students that had a student status change. For two of the selections, the University enrollment change was communicated to the NSLDS accurately and timely, however the program level data was not communicated as required by the regulations. • PwC reviewed the University’s policies over satisfactory academic progress. There were four schools within the University that did not document procedures for disbursements to students on financial aid warning status or financial aid probation status. Additionally, there was one school that did not document policies stating that students who (1) have not achieved the required GPA, (2) are not successfully completing their program of study at the required pace (if required), or (3) have not completed the program within the maximum time frame will no longer be eligible for Title IV aid. Questioned Costs None noted. Cause The University does not have consistent policies and procedures in place that require the appropriate documentation to be maintained to support compliance with the regulatory requirements. Effect Failure to maintain, distribute and enforce uniform policies and procedures across the University may result in appropriate documentation not being maintained for compliance purposes. Recommendation PwC recommends the University establish consistent policies and procedures for all compliance areas and hold trainings to ensure that student financial aid staff are aware of the required policies. Management’s Views and Corrective Action Plan Management's views and corrective action plan is included in Section V.

Award Information Cluster: Student Financial Assistance Grantor: Department of Education Award Name: Federal Supplemental Educational Opportunity Grant, Federal Work-Study, Federal Pell Grant, Federal Direct Student Loan, Primary Care Loan, Loan for Disadvantaged Students, Health Professions Student Loans, Nursing Student Loan Award Year: FY2023 CFDA Number: 84.007, 84.033, 84.063, 84.268, 93.342, 93.342, 93.342, 93.364 Criteria The University has a centralized office of student financial assistance, as well as individual offices at various schools within the University. Through testing of various compliance requirements, PwC noted improvements are needed to the documentation and execution of certain student financial aid requirements throughout the University. Specific criteria related to areas that need improvement are as follows: • An institution is required to establish written policies and procedures that incorporate the provisions of 34 CFR 668.51 through 668.61 for verifying applicant information for those applicants selected for verification by the Department of Education (ED). The institution shall require each applicant whose application is selected by ED to verify the information required for the Verification Tracking Group to which the applicant is assigned. • The Electronic Signatures in Global and National Commerce Act (“E-Sign Act”) states that a school must obtain a student’s voluntary consent to participate in electronic transactions. • University policy is to maintain a formal Title IV calculation form when a student withdraws or takes a leave of absence from the University. • An institution must communicate Campus-Level and Program-Level enrollment data when there is a student status change (34 CFR 674.19). • 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 (CFR 668.34). Condition As part of PwC’s testing over the student financial assistance cluster, they noted the following: • PwC selected 25 students who were selected by the Department of Education for verification. For six out of the 25 students selected, the University was required to obtain a statement of identity. The University could not provide documentation that evidenced a statement of identity was obtained. In examining 25 student records, the University did not receive a student's consent to participate in electronic transactions for one of the selections. After further investigation by the University, it was determined there were a total of 361 students that did not sign the voluntary consent, inclusive of the one PwC selected. • PwC selected 16 students that required a Return of Title IV calculation. For two of the selected students, the University did not formally document the refund calculation performed. For one student, a return of Title IV funds was not needed and for the other student, the required return of Title IV funds was appropriately made within the required timeframe. • PwC selected 25 students that had a student status change. For two of the selections, the University enrollment change was communicated to the NSLDS accurately and timely, however the program level data was not communicated as required by the regulations. • PwC reviewed the University’s policies over satisfactory academic progress. There were four schools within the University that did not document procedures for disbursements to students on financial aid warning status or financial aid probation status. Additionally, there was one school that did not document policies stating that students who (1) have not achieved the required GPA, (2) are not successfully completing their program of study at the required pace (if required), or (3) have not completed the program within the maximum time frame will no longer be eligible for Title IV aid. Questioned Costs None noted. Cause The University does not have consistent policies and procedures in place that require the appropriate documentation to be maintained to support compliance with the regulatory requirements. Effect Failure to maintain, distribute and enforce uniform policies and procedures across the University may result in appropriate documentation not being maintained for compliance purposes. Recommendation PwC recommends the University establish consistent policies and procedures for all compliance areas and hold trainings to ensure that student financial aid staff are aware of the required policies. Management’s Views and Corrective Action Plan Management's views and corrective action plan is included in Section V.

Award Information Cluster: Student Financial Assistance Grantor: Department of Education Award Name: Federal Supplemental Educational Opportunity Grant, Federal Work-Study, Federal Pell Grant, Federal Direct Student Loan, Primary Care Loan, Loan for Disadvantaged Students, Health Professions Student Loans, Nursing Student Loan Award Year: FY2023 CFDA Number: 84.007, 84.033, 84.063, 84.268, 93.342, 93.342, 93.342, 93.364 Criteria The University has a centralized office of student financial assistance, as well as individual offices at various schools within the University. Through testing of various compliance requirements, PwC noted improvements are needed to the documentation and execution of certain student financial aid requirements throughout the University. Specific criteria related to areas that need improvement are as follows: • An institution is required to establish written policies and procedures that incorporate the provisions of 34 CFR 668.51 through 668.61 for verifying applicant information for those applicants selected for verification by the Department of Education (ED). The institution shall require each applicant whose application is selected by ED to verify the information required for the Verification Tracking Group to which the applicant is assigned. • The Electronic Signatures in Global and National Commerce Act (“E-Sign Act”) states that a school must obtain a student’s voluntary consent to participate in electronic transactions. • University policy is to maintain a formal Title IV calculation form when a student withdraws or takes a leave of absence from the University. • An institution must communicate Campus-Level and Program-Level enrollment data when there is a student status change (34 CFR 674.19). • 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 (CFR 668.34). Condition As part of PwC’s testing over the student financial assistance cluster, they noted the following: • PwC selected 25 students who were selected by the Department of Education for verification. For six out of the 25 students selected, the University was required to obtain a statement of identity. The University could not provide documentation that evidenced a statement of identity was obtained. In examining 25 student records, the University did not receive a student's consent to participate in electronic transactions for one of the selections. After further investigation by the University, it was determined there were a total of 361 students that did not sign the voluntary consent, inclusive of the one PwC selected. • PwC selected 16 students that required a Return of Title IV calculation. For two of the selected students, the University did not formally document the refund calculation performed. For one student, a return of Title IV funds was not needed and for the other student, the required return of Title IV funds was appropriately made within the required timeframe. • PwC selected 25 students that had a student status change. For two of the selections, the University enrollment change was communicated to the NSLDS accurately and timely, however the program level data was not communicated as required by the regulations. • PwC reviewed the University’s policies over satisfactory academic progress. There were four schools within the University that did not document procedures for disbursements to students on financial aid warning status or financial aid probation status. Additionally, there was one school that did not document policies stating that students who (1) have not achieved the required GPA, (2) are not successfully completing their program of study at the required pace (if required), or (3) have not completed the program within the maximum time frame will no longer be eligible for Title IV aid. Questioned Costs None noted. Cause The University does not have consistent policies and procedures in place that require the appropriate documentation to be maintained to support compliance with the regulatory requirements. Effect Failure to maintain, distribute and enforce uniform policies and procedures across the University may result in appropriate documentation not being maintained for compliance purposes. Recommendation PwC recommends the University establish consistent policies and procedures for all compliance areas and hold trainings to ensure that student financial aid staff are aware of the required policies. Management’s Views and Corrective Action Plan Management's views and corrective action plan is included in Section V.

Award Information Cluster: Student Financial Assistance Grantor: Department of Education Award Name: Federal Supplemental Educational Opportunity Grant, Federal Work-Study, Federal Pell Grant, Federal Direct Student Loan, Primary Care Loan, Loan for Disadvantaged Students, Health Professions Student Loans, Nursing Student Loan Award Year: FY2023 CFDA Number: 84.007, 84.033, 84.063, 84.268, 93.342, 93.342, 93.342, 93.364 Criteria The University has a centralized office of student financial assistance, as well as individual offices at various schools within the University. Through testing of various compliance requirements, PwC noted improvements are needed to the documentation and execution of certain student financial aid requirements throughout the University. Specific criteria related to areas that need improvement are as follows: • An institution is required to establish written policies and procedures that incorporate the provisions of 34 CFR 668.51 through 668.61 for verifying applicant information for those applicants selected for verification by the Department of Education (ED). The institution shall require each applicant whose application is selected by ED to verify the information required for the Verification Tracking Group to which the applicant is assigned. • The Electronic Signatures in Global and National Commerce Act (“E-Sign Act”) states that a school must obtain a student’s voluntary consent to participate in electronic transactions. • University policy is to maintain a formal Title IV calculation form when a student withdraws or takes a leave of absence from the University. • An institution must communicate Campus-Level and Program-Level enrollment data when there is a student status change (34 CFR 674.19). • 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 (CFR 668.34). Condition As part of PwC’s testing over the student financial assistance cluster, they noted the following: • PwC selected 25 students who were selected by the Department of Education for verification. For six out of the 25 students selected, the University was required to obtain a statement of identity. The University could not provide documentation that evidenced a statement of identity was obtained. In examining 25 student records, the University did not receive a student's consent to participate in electronic transactions for one of the selections. After further investigation by the University, it was determined there were a total of 361 students that did not sign the voluntary consent, inclusive of the one PwC selected. • PwC selected 16 students that required a Return of Title IV calculation. For two of the selected students, the University did not formally document the refund calculation performed. For one student, a return of Title IV funds was not needed and for the other student, the required return of Title IV funds was appropriately made within the required timeframe. • PwC selected 25 students that had a student status change. For two of the selections, the University enrollment change was communicated to the NSLDS accurately and timely, however the program level data was not communicated as required by the regulations. • PwC reviewed the University’s policies over satisfactory academic progress. There were four schools within the University that did not document procedures for disbursements to students on financial aid warning status or financial aid probation status. Additionally, there was one school that did not document policies stating that students who (1) have not achieved the required GPA, (2) are not successfully completing their program of study at the required pace (if required), or (3) have not completed the program within the maximum time frame will no longer be eligible for Title IV aid. Questioned Costs None noted. Cause The University does not have consistent policies and procedures in place that require the appropriate documentation to be maintained to support compliance with the regulatory requirements. Effect Failure to maintain, distribute and enforce uniform policies and procedures across the University may result in appropriate documentation not being maintained for compliance purposes. Recommendation PwC recommends the University establish consistent policies and procedures for all compliance areas and hold trainings to ensure that student financial aid staff are aware of the required policies. Management’s Views and Corrective Action Plan Management's views and corrective action plan is included in Section V.

Award Information Cluster: Student Financial Assistance Grantor: Department of Education Award Name: Federal Supplemental Educational Opportunity Grant, Federal Work-Study, Federal Pell Grant, Federal Direct Student Loan, Primary Care Loan, Loan for Disadvantaged Students, Health Professions Student Loans, Nursing Student Loan Award Year: FY2023 CFDA Number: 84.007, 84.033, 84.063, 84.268, 93.342, 93.342, 93.342, 93.364 Criteria The University has a centralized office of student financial assistance, as well as individual offices at various schools within the University. Through testing of various compliance requirements, PwC noted improvements are needed to the documentation and execution of certain student financial aid requirements throughout the University. Specific criteria related to areas that need improvement are as follows: • An institution is required to establish written policies and procedures that incorporate the provisions of 34 CFR 668.51 through 668.61 for verifying applicant information for those applicants selected for verification by the Department of Education (ED). The institution shall require each applicant whose application is selected by ED to verify the information required for the Verification Tracking Group to which the applicant is assigned. • The Electronic Signatures in Global and National Commerce Act (“E-Sign Act”) states that a school must obtain a student’s voluntary consent to participate in electronic transactions. • University policy is to maintain a formal Title IV calculation form when a student withdraws or takes a leave of absence from the University. • An institution must communicate Campus-Level and Program-Level enrollment data when there is a student status change (34 CFR 674.19). • 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 (CFR 668.34). Condition As part of PwC’s testing over the student financial assistance cluster, they noted the following: • PwC selected 25 students who were selected by the Department of Education for verification. For six out of the 25 students selected, the University was required to obtain a statement of identity. The University could not provide documentation that evidenced a statement of identity was obtained. In examining 25 student records, the University did not receive a student's consent to participate in electronic transactions for one of the selections. After further investigation by the University, it was determined there were a total of 361 students that did not sign the voluntary consent, inclusive of the one PwC selected. • PwC selected 16 students that required a Return of Title IV calculation. For two of the selected students, the University did not formally document the refund calculation performed. For one student, a return of Title IV funds was not needed and for the other student, the required return of Title IV funds was appropriately made within the required timeframe. • PwC selected 25 students that had a student status change. For two of the selections, the University enrollment change was communicated to the NSLDS accurately and timely, however the program level data was not communicated as required by the regulations. • PwC reviewed the University’s policies over satisfactory academic progress. There were four schools within the University that did not document procedures for disbursements to students on financial aid warning status or financial aid probation status. Additionally, there was one school that did not document policies stating that students who (1) have not achieved the required GPA, (2) are not successfully completing their program of study at the required pace (if required), or (3) have not completed the program within the maximum time frame will no longer be eligible for Title IV aid. Questioned Costs None noted. Cause The University does not have consistent policies and procedures in place that require the appropriate documentation to be maintained to support compliance with the regulatory requirements. Effect Failure to maintain, distribute and enforce uniform policies and procedures across the University may result in appropriate documentation not being maintained for compliance purposes. Recommendation PwC recommends the University establish consistent policies and procedures for all compliance areas and hold trainings to ensure that student financial aid staff are aware of the required policies. Management’s Views and Corrective Action Plan Management's views and corrective action plan is included in Section V.

Award Information Cluster: Student Financial Assistance Grantor: Department of Education Award Name: Federal Supplemental Educational Opportunity Grant, Federal Work-Study, Federal Pell Grant, Federal Direct Student Loan, Primary Care Loan, Loan for Disadvantaged Students, Health Professions Student Loans, Nursing Student Loan Award Year: FY2023 CFDA Number: 84.007, 84.033, 84.063, 84.268, 93.342, 93.342, 93.342, 93.364 Criteria The University has a centralized office of student financial assistance, as well as individual offices at various schools within the University. Through testing of various compliance requirements, PwC noted improvements are needed to the documentation and execution of certain student financial aid requirements throughout the University. Specific criteria related to areas that need improvement are as follows: • An institution is required to establish written policies and procedures that incorporate the provisions of 34 CFR 668.51 through 668.61 for verifying applicant information for those applicants selected for verification by the Department of Education (ED). The institution shall require each applicant whose application is selected by ED to verify the information required for the Verification Tracking Group to which the applicant is assigned. • The Electronic Signatures in Global and National Commerce Act (“E-Sign Act”) states that a school must obtain a student’s voluntary consent to participate in electronic transactions. • University policy is to maintain a formal Title IV calculation form when a student withdraws or takes a leave of absence from the University. • An institution must communicate Campus-Level and Program-Level enrollment data when there is a student status change (34 CFR 674.19). • 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 (CFR 668.34). Condition As part of PwC’s testing over the student financial assistance cluster, they noted the following: • PwC selected 25 students who were selected by the Department of Education for verification. For six out of the 25 students selected, the University was required to obtain a statement of identity. The University could not provide documentation that evidenced a statement of identity was obtained. In examining 25 student records, the University did not receive a student's consent to participate in electronic transactions for one of the selections. After further investigation by the University, it was determined there were a total of 361 students that did not sign the voluntary consent, inclusive of the one PwC selected. • PwC selected 16 students that required a Return of Title IV calculation. For two of the selected students, the University did not formally document the refund calculation performed. For one student, a return of Title IV funds was not needed and for the other student, the required return of Title IV funds was appropriately made within the required timeframe. • PwC selected 25 students that had a student status change. For two of the selections, the University enrollment change was communicated to the NSLDS accurately and timely, however the program level data was not communicated as required by the regulations. • PwC reviewed the University’s policies over satisfactory academic progress. There were four schools within the University that did not document procedures for disbursements to students on financial aid warning status or financial aid probation status. Additionally, there was one school that did not document policies stating that students who (1) have not achieved the required GPA, (2) are not successfully completing their program of study at the required pace (if required), or (3) have not completed the program within the maximum time frame will no longer be eligible for Title IV aid. Questioned Costs None noted. Cause The University does not have consistent policies and procedures in place that require the appropriate documentation to be maintained to support compliance with the regulatory requirements. Effect Failure to maintain, distribute and enforce uniform policies and procedures across the University may result in appropriate documentation not being maintained for compliance purposes. Recommendation PwC recommends the University establish consistent policies and procedures for all compliance areas and hold trainings to ensure that student financial aid staff are aware of the required policies. Management’s Views and Corrective Action Plan Management's views and corrective action plan is included in Section V.

Award Information Cluster: Student Financial Assistance Grantor: Department of Education Award Name: Federal Supplemental Educational Opportunity Grant, Federal Work-Study, Federal Pell Grant, Federal Direct Student Loan, Primary Care Loan, Loan for Disadvantaged Students, Health Professions Student Loans, Nursing Student Loan Award Year: FY2023 CFDA Number: 84.007, 84.033, 84.063, 84.268, 93.342, 93.342, 93.342, 93.364 Criteria The University has a centralized office of student financial assistance, as well as individual offices at various schools within the University. Through testing of various compliance requirements, PwC noted improvements are needed to the documentation and execution of certain student financial aid requirements throughout the University. Specific criteria related to areas that need improvement are as follows: • An institution is required to establish written policies and procedures that incorporate the provisions of 34 CFR 668.51 through 668.61 for verifying applicant information for those applicants selected for verification by the Department of Education (ED). The institution shall require each applicant whose application is selected by ED to verify the information required for the Verification Tracking Group to which the applicant is assigned. • The Electronic Signatures in Global and National Commerce Act (“E-Sign Act”) states that a school must obtain a student’s voluntary consent to participate in electronic transactions. • University policy is to maintain a formal Title IV calculation form when a student withdraws or takes a leave of absence from the University. • An institution must communicate Campus-Level and Program-Level enrollment data when there is a student status change (34 CFR 674.19). • 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 (CFR 668.34). Condition As part of PwC’s testing over the student financial assistance cluster, they noted the following: • PwC selected 25 students who were selected by the Department of Education for verification. For six out of the 25 students selected, the University was required to obtain a statement of identity. The University could not provide documentation that evidenced a statement of identity was obtained. In examining 25 student records, the University did not receive a student's consent to participate in electronic transactions for one of the selections. After further investigation by the University, it was determined there were a total of 361 students that did not sign the voluntary consent, inclusive of the one PwC selected. • PwC selected 16 students that required a Return of Title IV calculation. For two of the selected students, the University did not formally document the refund calculation performed. For one student, a return of Title IV funds was not needed and for the other student, the required return of Title IV funds was appropriately made within the required timeframe. • PwC selected 25 students that had a student status change. For two of the selections, the University enrollment change was communicated to the NSLDS accurately and timely, however the program level data was not communicated as required by the regulations. • PwC reviewed the University’s policies over satisfactory academic progress. There were four schools within the University that did not document procedures for disbursements to students on financial aid warning status or financial aid probation status. Additionally, there was one school that did not document policies stating that students who (1) have not achieved the required GPA, (2) are not successfully completing their program of study at the required pace (if required), or (3) have not completed the program within the maximum time frame will no longer be eligible for Title IV aid. Questioned Costs None noted. Cause The University does not have consistent policies and procedures in place that require the appropriate documentation to be maintained to support compliance with the regulatory requirements. Effect Failure to maintain, distribute and enforce uniform policies and procedures across the University may result in appropriate documentation not being maintained for compliance purposes. Recommendation PwC recommends the University establish consistent policies and procedures for all compliance areas and hold trainings to ensure that student financial aid staff are aware of the required policies. Management’s Views and Corrective Action Plan Management's views and corrective action plan is included in Section V.

Award Information Cluster: Student Financial Assistance Grantor: Department of Education Award Name: Federal Supplemental Educational Opportunity Grant, Federal Work-Study, Federal Pell Grant, Federal Direct Student Loan, Primary Care Loan, Loan for Disadvantaged Students, Health Professions Student Loans, Nursing Student Loan Award Year: FY2023 CFDA Number: 84.007, 84.033, 84.063, 84.268, 93.342, 93.342, 93.342, 93.364 Criteria The University has a centralized office of student financial assistance, as well as individual offices at various schools within the University. Through testing of various compliance requirements, PwC noted improvements are needed to the documentation and execution of certain student financial aid requirements throughout the University. Specific criteria related to areas that need improvement are as follows: • An institution is required to establish written policies and procedures that incorporate the provisions of 34 CFR 668.51 through 668.61 for verifying applicant information for those applicants selected for verification by the Department of Education (ED). The institution shall require each applicant whose application is selected by ED to verify the information required for the Verification Tracking Group to which the applicant is assigned. • The Electronic Signatures in Global and National Commerce Act (“E-Sign Act”) states that a school must obtain a student’s voluntary consent to participate in electronic transactions. • University policy is to maintain a formal Title IV calculation form when a student withdraws or takes a leave of absence from the University. • An institution must communicate Campus-Level and Program-Level enrollment data when there is a student status change (34 CFR 674.19). • 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 (CFR 668.34). Condition As part of PwC’s testing over the student financial assistance cluster, they noted the following: • PwC selected 25 students who were selected by the Department of Education for verification. For six out of the 25 students selected, the University was required to obtain a statement of identity. The University could not provide documentation that evidenced a statement of identity was obtained. In examining 25 student records, the University did not receive a student's consent to participate in electronic transactions for one of the selections. After further investigation by the University, it was determined there were a total of 361 students that did not sign the voluntary consent, inclusive of the one PwC selected. • PwC selected 16 students that required a Return of Title IV calculation. For two of the selected students, the University did not formally document the refund calculation performed. For one student, a return of Title IV funds was not needed and for the other student, the required return of Title IV funds was appropriately made within the required timeframe. • PwC selected 25 students that had a student status change. For two of the selections, the University enrollment change was communicated to the NSLDS accurately and timely, however the program level data was not communicated as required by the regulations. • PwC reviewed the University’s policies over satisfactory academic progress. There were four schools within the University that did not document procedures for disbursements to students on financial aid warning status or financial aid probation status. Additionally, there was one school that did not document policies stating that students who (1) have not achieved the required GPA, (2) are not successfully completing their program of study at the required pace (if required), or (3) have not completed the program within the maximum time frame will no longer be eligible for Title IV aid. Questioned Costs None noted. Cause The University does not have consistent policies and procedures in place that require the appropriate documentation to be maintained to support compliance with the regulatory requirements. Effect Failure to maintain, distribute and enforce uniform policies and procedures across the University may result in appropriate documentation not being maintained for compliance purposes. Recommendation PwC recommends the University establish consistent policies and procedures for all compliance areas and hold trainings to ensure that student financial aid staff are aware of the required policies. Management’s Views and Corrective Action Plan Management's views and corrective action plan is included in Section V.

Award Information Cluster: Student Financial Assistance Grantor: Department of Education Award Name: Federal Supplemental Educational Opportunity Grant, Federal Work-Study, Federal Pell Grant, Federal Direct Student Loan, Primary Care Loan, Loan for Disadvantaged Students, Health Professions Student Loans, Nursing Student Loan Award Year: FY2023 CFDA Number: 84.007, 84.033, 84.063, 84.268, 93.342, 93.342, 93.342, 93.364 Criteria The University has a centralized office of student financial assistance, as well as individual offices at various schools within the University. Through testing of various compliance requirements, PwC noted improvements are needed to the documentation and execution of certain student financial aid requirements throughout the University. Specific criteria related to areas that need improvement are as follows: • An institution is required to establish written policies and procedures that incorporate the provisions of 34 CFR 668.51 through 668.61 for verifying applicant information for those applicants selected for verification by the Department of Education (ED). The institution shall require each applicant whose application is selected by ED to verify the information required for the Verification Tracking Group to which the applicant is assigned. • The Electronic Signatures in Global and National Commerce Act (“E-Sign Act”) states that a school must obtain a student’s voluntary consent to participate in electronic transactions. • University policy is to maintain a formal Title IV calculation form when a student withdraws or takes a leave of absence from the University. • An institution must communicate Campus-Level and Program-Level enrollment data when there is a student status change (34 CFR 674.19). • 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 (CFR 668.34). Condition As part of PwC’s testing over the student financial assistance cluster, they noted the following: • PwC selected 25 students who were selected by the Department of Education for verification. For six out of the 25 students selected, the University was required to obtain a statement of identity. The University could not provide documentation that evidenced a statement of identity was obtained. In examining 25 student records, the University did not receive a student's consent to participate in electronic transactions for one of the selections. After further investigation by the University, it was determined there were a total of 361 students that did not sign the voluntary consent, inclusive of the one PwC selected. • PwC selected 16 students that required a Return of Title IV calculation. For two of the selected students, the University did not formally document the refund calculation performed. For one student, a return of Title IV funds was not needed and for the other student, the required return of Title IV funds was appropriately made within the required timeframe. • PwC selected 25 students that had a student status change. For two of the selections, the University enrollment change was communicated to the NSLDS accurately and timely, however the program level data was not communicated as required by the regulations. • PwC reviewed the University’s policies over satisfactory academic progress. There were four schools within the University that did not document procedures for disbursements to students on financial aid warning status or financial aid probation status. Additionally, there was one school that did not document policies stating that students who (1) have not achieved the required GPA, (2) are not successfully completing their program of study at the required pace (if required), or (3) have not completed the program within the maximum time frame will no longer be eligible for Title IV aid. Questioned Costs None noted. Cause The University does not have consistent policies and procedures in place that require the appropriate documentation to be maintained to support compliance with the regulatory requirements. Effect Failure to maintain, distribute and enforce uniform policies and procedures across the University may result in appropriate documentation not being maintained for compliance purposes. Recommendation PwC recommends the University establish consistent policies and procedures for all compliance areas and hold trainings to ensure that student financial aid staff are aware of the required policies. Management’s Views and Corrective Action Plan Management's views and corrective action plan is included in Section V.

Award Information Cluster: Student Financial Assistance Grantor: Department of Education Award Name: Federal Supplemental Educational Opportunity Grant, Federal Work-Study, Federal Pell Grant, Federal Direct Student Loan, Primary Care Loan, Loan for Disadvantaged Students, Health Professions Student Loans, Nursing Student Loan Award Year: FY2023 CFDA Number: 84.007, 84.033, 84.063, 84.268, 93.342, 93.342, 93.342, 93.364 Criteria The University has a centralized office of student financial assistance, as well as individual offices at various schools within the University. Through testing of various compliance requirements, PwC noted improvements are needed to the documentation and execution of certain student financial aid requirements throughout the University. Specific criteria related to areas that need improvement are as follows: • An institution is required to establish written policies and procedures that incorporate the provisions of 34 CFR 668.51 through 668.61 for verifying applicant information for those applicants selected for verification by the Department of Education (ED). The institution shall require each applicant whose application is selected by ED to verify the information required for the Verification Tracking Group to which the applicant is assigned. • The Electronic Signatures in Global and National Commerce Act (“E-Sign Act”) states that a school must obtain a student’s voluntary consent to participate in electronic transactions. • University policy is to maintain a formal Title IV calculation form when a student withdraws or takes a leave of absence from the University. • An institution must communicate Campus-Level and Program-Level enrollment data when there is a student status change (34 CFR 674.19). • 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 (CFR 668.34). Condition As part of PwC’s testing over the student financial assistance cluster, they noted the following: • PwC selected 25 students who were selected by the Department of Education for verification. For six out of the 25 students selected, the University was required to obtain a statement of identity. The University could not provide documentation that evidenced a statement of identity was obtained. In examining 25 student records, the University did not receive a student's consent to participate in electronic transactions for one of the selections. After further investigation by the University, it was determined there were a total of 361 students that did not sign the voluntary consent, inclusive of the one PwC selected. • PwC selected 16 students that required a Return of Title IV calculation. For two of the selected students, the University did not formally document the refund calculation performed. For one student, a return of Title IV funds was not needed and for the other student, the required return of Title IV funds was appropriately made within the required timeframe. • PwC selected 25 students that had a student status change. For two of the selections, the University enrollment change was communicated to the NSLDS accurately and timely, however the program level data was not communicated as required by the regulations. • PwC reviewed the University’s policies over satisfactory academic progress. There were four schools within the University that did not document procedures for disbursements to students on financial aid warning status or financial aid probation status. Additionally, there was one school that did not document policies stating that students who (1) have not achieved the required GPA, (2) are not successfully completing their program of study at the required pace (if required), or (3) have not completed the program within the maximum time frame will no longer be eligible for Title IV aid. Questioned Costs None noted. Cause The University does not have consistent policies and procedures in place that require the appropriate documentation to be maintained to support compliance with the regulatory requirements. Effect Failure to maintain, distribute and enforce uniform policies and procedures across the University may result in appropriate documentation not being maintained for compliance purposes. Recommendation PwC recommends the University establish consistent policies and procedures for all compliance areas and hold trainings to ensure that student financial aid staff are aware of the required policies. Management’s Views and Corrective Action Plan Management's views and corrective action plan is included in Section V.

Award Information Cluster: Student Financial Assistance Grantor: Department of Education Award Name: Federal Supplemental Educational Opportunity Grant, Federal Work-Study, Federal Pell Grant, Federal Direct Student Loan, Primary Care Loan, Loan for Disadvantaged Students, Health Professions Student Loans, Nursing Student Loan Award Year: FY2023 CFDA Number: 84.007, 84.033, 84.063, 84.268, 93.342, 93.342, 93.342, 93.364 Criteria The University has a centralized office of student financial assistance, as well as individual offices at various schools within the University. Through testing of various compliance requirements, PwC noted improvements are needed to the documentation and execution of certain student financial aid requirements throughout the University. Specific criteria related to areas that need improvement are as follows: • An institution is required to establish written policies and procedures that incorporate the provisions of 34 CFR 668.51 through 668.61 for verifying applicant information for those applicants selected for verification by the Department of Education (ED). The institution shall require each applicant whose application is selected by ED to verify the information required for the Verification Tracking Group to which the applicant is assigned. • The Electronic Signatures in Global and National Commerce Act (“E-Sign Act”) states that a school must obtain a student’s voluntary consent to participate in electronic transactions. • University policy is to maintain a formal Title IV calculation form when a student withdraws or takes a leave of absence from the University. • An institution must communicate Campus-Level and Program-Level enrollment data when there is a student status change (34 CFR 674.19). • 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 (CFR 668.34). Condition As part of PwC’s testing over the student financial assistance cluster, they noted the following: • PwC selected 25 students who were selected by the Department of Education for verification. For six out of the 25 students selected, the University was required to obtain a statement of identity. The University could not provide documentation that evidenced a statement of identity was obtained. In examining 25 student records, the University did not receive a student's consent to participate in electronic transactions for one of the selections. After further investigation by the University, it was determined there were a total of 361 students that did not sign the voluntary consent, inclusive of the one PwC selected. • PwC selected 16 students that required a Return of Title IV calculation. For two of the selected students, the University did not formally document the refund calculation performed. For one student, a return of Title IV funds was not needed and for the other student, the required return of Title IV funds was appropriately made within the required timeframe. • PwC selected 25 students that had a student status change. For two of the selections, the University enrollment change was communicated to the NSLDS accurately and timely, however the program level data was not communicated as required by the regulations. • PwC reviewed the University’s policies over satisfactory academic progress. There were four schools within the University that did not document procedures for disbursements to students on financial aid warning status or financial aid probation status. Additionally, there was one school that did not document policies stating that students who (1) have not achieved the required GPA, (2) are not successfully completing their program of study at the required pace (if required), or (3) have not completed the program within the maximum time frame will no longer be eligible for Title IV aid. Questioned Costs None noted. Cause The University does not have consistent policies and procedures in place that require the appropriate documentation to be maintained to support compliance with the regulatory requirements. Effect Failure to maintain, distribute and enforce uniform policies and procedures across the University may result in appropriate documentation not being maintained for compliance purposes. Recommendation PwC recommends the University establish consistent policies and procedures for all compliance areas and hold trainings to ensure that student financial aid staff are aware of the required policies. Management’s Views and Corrective Action Plan Management's views and corrective action plan is included in Section V.