Audit 9418

Questioned Costs $ ‐0‐ Finding No. 2023‐001: Financial Aid Administration – Control Deficiency Federal Agency: U.S. Department of Education Assistance Listing Number and Title: 84.063P – Federal Pell Grant Program Condition During our audit, for 4 out of 12 students selected for testing, the institution failed to report the student’s enrollment status to the National Student Loan Data System (“NSLDS”). Criteria Title 34, Section 685.309 (b)(2) of the U.S. Code of Federal Regulations (“CFR”) states that unless it expects to submit its next updated enrollment report to the Secretary within the next 60 days, an institution must notify the Secretary within 30 days after the date the institution discovers that a loan under Title IV of the Act was made to, or on behalf of, a student who was enrolled on at least a half‐time basis, or failed to enroll on at least a half‐time basis for the period which the loan was intended. Cause The institution failed to report the student’s enrollment status accurately and within a timely manner due to miscommunication between the Financial Aid Office and the Office of the Registrar. Effect In accordance with 34 CFR 668.84, the Secretary of Education may levy fines and/or penalties on the institution or suspend future participation in federal student financial assistance programs for failure to comply with the requirements applicable to Title IV of the HEA. Context A sample of 12 exit counseling sessions conducted with borrowers were selected for audit from a population of 1,668 exit counseling sessions conducted with borrowers. Our test found 4 students’ enrollment status were not updated in the NSLDS in a timely manner. Our sample was a statistically valid sample. Repeat Finding This is not a repeat finding. Recommendation We recommend that the institution update the student enrollment status in the NSLDS in an accurate and timely manner. Views of Responsible Officials and Planned Corrective Actions The institution is working with the Office of the Registrar to implement the National Student Clearinghouse (“NSC”) reporting functionality in the student information system. The NSC reporting functionality is scheduled to be implemented for the spring 2024 enrollment reporting process.

Questioned Costs $ ‐0‐ Finding No. 2023‐002: Return of Title IV Funds – Control Deficiency Federal Agency: U.S. Department of Education Assistance Listing Number and Title: 84.063P – Federal Pell Grant Program 84.268 – Federal Direct Student Loans Condition During our audit, for 4 out of 15 students selected for testing, the institution failed to remit the institutional portion of unearned Title IV funds to the Title IV program within 45 days after the institution determined that the student withdrew. Criteria Title 34, Section 668.22(j)(1) of the CFR requires the institution to return the amount of Title IV funds for which it is responsible for as soon as possible but no later than 45 days after the date of the institution’s determination that the student withdrew. Cause Due to turnover in critical positions within the financial aid office and lack of personnel training, the institution was unable to accurately perform the return of Title IV funds calculations timely. Effect In accordance with 34 CFR 668.84, the Secretary of Education may levy fines and/or penalties on the institution or suspend future participation in federal student financial assistance programs for failure to comply with the requirements applicable to Title IV of the Higher Education Act (“HEA”). Context A sample of 15 students who withdrew from the institution and were disbursed a total of $99,809 in Title IV funds was selected for audit from a population of 277 students who withdrew and were disbursed a total of $704,249 in Title IV funds. Our test results found 4 students’ return of Title IV funds were not remitted timely. Our sample was a statistically valid sample. Repeat Finding This is not a repeat finding. Recommendation We recommend that the institution remit the institutional portion of unearned aid to the appropriate Title IV program within the required 45‐day time period in accordance with federal regulations. Views of Responsible Officials and Planned Corrective Actions The institution has adjusted its procedures to remit the institutional portion of unearned Title IV funds to the Title IV program within 30 days after the institution determined that the student withdrew.

Questioned Costs $ ‐0‐ Finding No. 2023‐003: Return of Title IV Funds – Control Deficiency Federal Agency: U.S. Department of Education Assistance Listing Number and Title: 84.063P – Federal Pell Grant Program Condition During our audit, we noted the following instances of noncompliance: • For 1 out of 15 students selected for testing, the institution failed to remit the institutional portion of unearned Title IV funds to the Title IV program within 45 days after the institution determined that the student withdrew. • For 1 out of 15 students selected for testing, the institution failed to determine the withdrawal date for students who unofficially withdrew from the institution within 30 days after the end of the period of enrollment. Criteria Title 34, Section 668.22(j)(1) of the CFR requires the institution to return the amount of Title IV funds for which it is responsible for as soon as possible but no later than 45 days after the date of the institution’s determination that the student withdrew. Title 34, Section 668.22(j)(2) of the CFR requires if an institution is not required to take attendance, the institution must determine the withdrawal date for a student who withdraws without providing notification to the institution no later than 30 days after the end of the earlier of 1) the payment period or period of enrollment, as applicable; 2) the academic year; or 3) the program. Cause Due to turnover in critical positions within the financial aid office and lack of personnel training, the institution was unable to accurately perform the return of Title IV funds calculations timely. Effect In accordance with 34 CFR 668.84, the Secretary of Education may levy fines and/or penalties on the institution or suspend future participation in federal student financial assistance programs for failure to comply with the requirements applicable to Title IV of the HEA. Context A sample of 15 students who withdrew from the institution and were disbursed a total of $61,111 in Title IV funds was selected for testing from a population of 84 students who withdrew and were disbursed a total of $211,730 in Title IV funds. Our test results found that 1 student’s institutional portion of unearned aid was remitted untimely and the institution failed to determine the withdrawal date in a timely manner. Our sample was a statistically valid sample. Repeat Finding This is a repeat of prior audit Finding No. 2022‐006. Recommendation We recommend that institution perform the following to ensure compliance with Federal regulations: • Remit the institutional portion of unearned aid to the appropriate Title IV program within the required 45‐day time period in accordance with federal regulations. • Determine the withdrawal date for students who withdrew without providing notification within 30 days after the end of the period of enrollment in accordance with federal regulations. Views of Responsible Officials and Planned Corrective Actions The institution has implemented procedures to assist with the timely determination of students’ withdrawal dates and has also hired a permanent staff member within the financial aid office to assist in the calculation of the institutional portion of unearned Title IV funds that are required to be remitted to the Title IV program.

Questioned Costs $ 25 Finding No. 2023‐004: Financial Aid Administration – Control Deficiency Federal Agency: U.S. Department of Education Assistance Listing Number and Title: 84.063P – Federal Pell Grant Program 84.268 – Federal Direct Student Loans Condition During our audit, we noted the following instances of noncompliance: Return of Title IV Funds  For 1 out of 15 students selected for testing, the institution failed to remit the appropriate amount of Title IV funds for this student, resulting in a total underpayment of $25 to the Title IV program. Direct Student Loans  For 1 out of 12 students selected for testing, the institution failed to provide exit counseling to the borrower within a timely matter. Criteria Return of Title IV Funds Title 34, Section 668.22(a)(1) through (a)(5) of the CFR requires the institution to determine the amount of Title IV aid earned by the student as of the student’s withdrawal date when a recipient of Title IV grant or loan assistance withdraws from an institution during a payment period or period of enrollment in which the recipient began attendance. Direct Student Loans Title 34, Section 685.304 of the CFR states that an institution must ensure that exit counseling is conducted with each Direct Subsidized Loan or Director Unsubsidized Loan borrower and graduate or professional student Direct PLUS Loan borrower shortly before the student borrower ceases at least half‐time study at the institution. If a borrower withdraws from the institution without the institution’s prior knowledge or fails to complete an exit counseling session as required, the institution must ensure that exit counseling is provided through either interactive electronic means or by mailing counseling materials to the borrower at the borrower’s last known address within 30 days after learning that the borrower has withdrawn from the institution or failed to complete exit counseling as required. Cause Return of Title IV Funds Due to turnover in critical positions within the financial aid office and lack of personnel training, the institution was unable to accurately perform the return of Title IV funds calculations timely. Direct Student Loans The institution was unable to perform exit counseling to the borrower in a timely manner due to the absence of staff which hindered the timely processing of the loan exit. Effect In accordance with 34 CFR 668.84, the Secretary of Education may levy fines and/or penalties on the institution or suspend future participation in federal student financial assistance programs for failure to comply with the requirements applicable to Title IV of the HEA. Context Return of Title IV Funds A sample of 15 students who withdrew from the institution and were disbursed a total of $51,634 in Title IV funds was selected for testing from a population of 206 students who withdrew and were disbursed a total of $494,396 in Title IV funds. Our test results found 1 student’s return of Title IV funds was incorrectly calculated, resulting in a total questioned cost of $25. Our sample was a statistically valid sample. Direct Student Loans A sample of 12 exit counseling sessions conducted with borrowers were selected for audit from a population of 44 exit counseling sessions conducted with borrowers. Our test found 1 exit counseling session conducted with a borrower was not performed timely. Our sample was a statistically valid sample. Repeat Finding This is a not a repeat finding. Recommendation We recommend that the institution perform the following to ensure compliance with Federal regulations: Return of Title IV Funds  Ensure that the correct information is used to prepare the return of Title IV calculation. Direct Student Loans  Provide exit counseling to borrowers timely.  Update student enrollment status in the NSLDS in an accurate manner. Views of Responsible Officials and Planned Corrective Actions Return of Title IV Funds The institution is currently in the process of hiring additional personnel to assist in the preparation of the return of Title IV calculation and developing procedures to assist in the completion of the return of Title IV calculation in a timely and accurate manner. Direct Student Loans The institution is currently in the process of hiring additional personnel to assist in the timely execution of exit counseling to borrowers.

Questioned Costs $ ‐0‐ Finding No. 2023‐005: Return of Title IV Funds – Control Deficiency Federal Agency: U.S. Department of Education Assistance Listing Number and Title: 84.063P – Federal Pell Grant Program Condition During our audit, for 1 out of 15 students selected for testing, the institution failed to remit the institutional portion of unearned Title IV Funds to the Title IV program within 45 days after the institution determined that the student withdrew. Criteria Title 34, Section 668.22(j)(1) of the CFR requires the institution to return the amount of Title IV funds for which it is responsible for as soon as possible but no later than 45 days after the date of the institution’s determination that the student withdrew. Cause Due to turnover in critical positions within the financial aid office and lack of personnel training, the institution was unable to accurately perform the return of Title IV funds calculations timely. Effect In accordance with 34 CFR 668.84, the Secretary of Education may levy fines and/or penalties on the institution or suspend future participation in federal student financial assistance programs for failure to comply with the requirements applicable to Title IV of the HEA. Context A sample of 15 students who withdrew from the institution and were disbursed a total of $52,812 in Title IV funds was selected for testing from a population of 156 students who withdrew and were disbursed a total of $352,877 in Title IV funds. Our test results found 1 student’s return of Title IV funds was not remitted timely. Our sample was a statistically valid sample. Repeat Finding This is a repeat of prior audit Finding No. 2022‐002. Recommendation We recommend that the institution remit the institutional portion of unearned aid to the appropriate Title IV program within the required 45‐day time period in accordance with federal regulations. Views of Responsible Officials and Planned Corrective Actions The institution is currently in the process of hiring additional personnel to assist in the timely execution of exit counseling to borrowers.

Questioned Costs $ ‐0‐ Finding No. 2023‐002: Return of Title IV Funds – Control Deficiency Federal Agency: U.S. Department of Education Assistance Listing Number and Title: 84.063P – Federal Pell Grant Program 84.268 – Federal Direct Student Loans Condition During our audit, for 4 out of 15 students selected for testing, the institution failed to remit the institutional portion of unearned Title IV funds to the Title IV program within 45 days after the institution determined that the student withdrew. Criteria Title 34, Section 668.22(j)(1) of the CFR requires the institution to return the amount of Title IV funds for which it is responsible for as soon as possible but no later than 45 days after the date of the institution’s determination that the student withdrew. Cause Due to turnover in critical positions within the financial aid office and lack of personnel training, the institution was unable to accurately perform the return of Title IV funds calculations timely. Effect In accordance with 34 CFR 668.84, the Secretary of Education may levy fines and/or penalties on the institution or suspend future participation in federal student financial assistance programs for failure to comply with the requirements applicable to Title IV of the Higher Education Act (“HEA”). Context A sample of 15 students who withdrew from the institution and were disbursed a total of $99,809 in Title IV funds was selected for audit from a population of 277 students who withdrew and were disbursed a total of $704,249 in Title IV funds. Our test results found 4 students’ return of Title IV funds were not remitted timely. Our sample was a statistically valid sample. Repeat Finding This is not a repeat finding. Recommendation We recommend that the institution remit the institutional portion of unearned aid to the appropriate Title IV program within the required 45‐day time period in accordance with federal regulations. Views of Responsible Officials and Planned Corrective Actions The institution has adjusted its procedures to remit the institutional portion of unearned Title IV funds to the Title IV program within 30 days after the institution determined that the student withdrew.

Questioned Costs $ 25 Finding No. 2023‐004: Financial Aid Administration – Control Deficiency Federal Agency: U.S. Department of Education Assistance Listing Number and Title: 84.063P – Federal Pell Grant Program 84.268 – Federal Direct Student Loans Condition During our audit, we noted the following instances of noncompliance: Return of Title IV Funds  For 1 out of 15 students selected for testing, the institution failed to remit the appropriate amount of Title IV funds for this student, resulting in a total underpayment of $25 to the Title IV program. Direct Student Loans  For 1 out of 12 students selected for testing, the institution failed to provide exit counseling to the borrower within a timely matter. Criteria Return of Title IV Funds Title 34, Section 668.22(a)(1) through (a)(5) of the CFR requires the institution to determine the amount of Title IV aid earned by the student as of the student’s withdrawal date when a recipient of Title IV grant or loan assistance withdraws from an institution during a payment period or period of enrollment in which the recipient began attendance. Direct Student Loans Title 34, Section 685.304 of the CFR states that an institution must ensure that exit counseling is conducted with each Direct Subsidized Loan or Director Unsubsidized Loan borrower and graduate or professional student Direct PLUS Loan borrower shortly before the student borrower ceases at least half‐time study at the institution. If a borrower withdraws from the institution without the institution’s prior knowledge or fails to complete an exit counseling session as required, the institution must ensure that exit counseling is provided through either interactive electronic means or by mailing counseling materials to the borrower at the borrower’s last known address within 30 days after learning that the borrower has withdrawn from the institution or failed to complete exit counseling as required. Cause Return of Title IV Funds Due to turnover in critical positions within the financial aid office and lack of personnel training, the institution was unable to accurately perform the return of Title IV funds calculations timely. Direct Student Loans The institution was unable to perform exit counseling to the borrower in a timely manner due to the absence of staff which hindered the timely processing of the loan exit. Effect In accordance with 34 CFR 668.84, the Secretary of Education may levy fines and/or penalties on the institution or suspend future participation in federal student financial assistance programs for failure to comply with the requirements applicable to Title IV of the HEA. Context Return of Title IV Funds A sample of 15 students who withdrew from the institution and were disbursed a total of $51,634 in Title IV funds was selected for testing from a population of 206 students who withdrew and were disbursed a total of $494,396 in Title IV funds. Our test results found 1 student’s return of Title IV funds was incorrectly calculated, resulting in a total questioned cost of $25. Our sample was a statistically valid sample. Direct Student Loans A sample of 12 exit counseling sessions conducted with borrowers were selected for audit from a population of 44 exit counseling sessions conducted with borrowers. Our test found 1 exit counseling session conducted with a borrower was not performed timely. Our sample was a statistically valid sample. Repeat Finding This is a not a repeat finding. Recommendation We recommend that the institution perform the following to ensure compliance with Federal regulations: Return of Title IV Funds  Ensure that the correct information is used to prepare the return of Title IV calculation. Direct Student Loans  Provide exit counseling to borrowers timely.  Update student enrollment status in the NSLDS in an accurate manner. Views of Responsible Officials and Planned Corrective Actions Return of Title IV Funds The institution is currently in the process of hiring additional personnel to assist in the preparation of the return of Title IV calculation and developing procedures to assist in the completion of the return of Title IV calculation in a timely and accurate manner. Direct Student Loans The institution is currently in the process of hiring additional personnel to assist in the timely execution of exit counseling to borrowers.

Questioned Costs $ ‐0‐ Finding No. 2023‐001: Financial Aid Administration – Control Deficiency Federal Agency: U.S. Department of Education Assistance Listing Number and Title: 84.063P – Federal Pell Grant Program Condition During our audit, for 4 out of 12 students selected for testing, the institution failed to report the student’s enrollment status to the National Student Loan Data System (“NSLDS”). Criteria Title 34, Section 685.309 (b)(2) of the U.S. Code of Federal Regulations (“CFR”) states that unless it expects to submit its next updated enrollment report to the Secretary within the next 60 days, an institution must notify the Secretary within 30 days after the date the institution discovers that a loan under Title IV of the Act was made to, or on behalf of, a student who was enrolled on at least a half‐time basis, or failed to enroll on at least a half‐time basis for the period which the loan was intended. Cause The institution failed to report the student’s enrollment status accurately and within a timely manner due to miscommunication between the Financial Aid Office and the Office of the Registrar. Effect In accordance with 34 CFR 668.84, the Secretary of Education may levy fines and/or penalties on the institution or suspend future participation in federal student financial assistance programs for failure to comply with the requirements applicable to Title IV of the HEA. Context A sample of 12 exit counseling sessions conducted with borrowers were selected for audit from a population of 1,668 exit counseling sessions conducted with borrowers. Our test found 4 students’ enrollment status were not updated in the NSLDS in a timely manner. Our sample was a statistically valid sample. Repeat Finding This is not a repeat finding. Recommendation We recommend that the institution update the student enrollment status in the NSLDS in an accurate and timely manner. Views of Responsible Officials and Planned Corrective Actions The institution is working with the Office of the Registrar to implement the National Student Clearinghouse (“NSC”) reporting functionality in the student information system. The NSC reporting functionality is scheduled to be implemented for the spring 2024 enrollment reporting process.

Questioned Costs $ ‐0‐ Finding No. 2023‐002: Return of Title IV Funds – Control Deficiency Federal Agency: U.S. Department of Education Assistance Listing Number and Title: 84.063P – Federal Pell Grant Program 84.268 – Federal Direct Student Loans Condition During our audit, for 4 out of 15 students selected for testing, the institution failed to remit the institutional portion of unearned Title IV funds to the Title IV program within 45 days after the institution determined that the student withdrew. Criteria Title 34, Section 668.22(j)(1) of the CFR requires the institution to return the amount of Title IV funds for which it is responsible for as soon as possible but no later than 45 days after the date of the institution’s determination that the student withdrew. Cause Due to turnover in critical positions within the financial aid office and lack of personnel training, the institution was unable to accurately perform the return of Title IV funds calculations timely. Effect In accordance with 34 CFR 668.84, the Secretary of Education may levy fines and/or penalties on the institution or suspend future participation in federal student financial assistance programs for failure to comply with the requirements applicable to Title IV of the Higher Education Act (“HEA”). Context A sample of 15 students who withdrew from the institution and were disbursed a total of $99,809 in Title IV funds was selected for audit from a population of 277 students who withdrew and were disbursed a total of $704,249 in Title IV funds. Our test results found 4 students’ return of Title IV funds were not remitted timely. Our sample was a statistically valid sample. Repeat Finding This is not a repeat finding. Recommendation We recommend that the institution remit the institutional portion of unearned aid to the appropriate Title IV program within the required 45‐day time period in accordance with federal regulations. Views of Responsible Officials and Planned Corrective Actions The institution has adjusted its procedures to remit the institutional portion of unearned Title IV funds to the Title IV program within 30 days after the institution determined that the student withdrew.

Questioned Costs $ ‐0‐ Finding No. 2023‐003: Return of Title IV Funds – Control Deficiency Federal Agency: U.S. Department of Education Assistance Listing Number and Title: 84.063P – Federal Pell Grant Program Condition During our audit, we noted the following instances of noncompliance: • For 1 out of 15 students selected for testing, the institution failed to remit the institutional portion of unearned Title IV funds to the Title IV program within 45 days after the institution determined that the student withdrew. • For 1 out of 15 students selected for testing, the institution failed to determine the withdrawal date for students who unofficially withdrew from the institution within 30 days after the end of the period of enrollment. Criteria Title 34, Section 668.22(j)(1) of the CFR requires the institution to return the amount of Title IV funds for which it is responsible for as soon as possible but no later than 45 days after the date of the institution’s determination that the student withdrew. Title 34, Section 668.22(j)(2) of the CFR requires if an institution is not required to take attendance, the institution must determine the withdrawal date for a student who withdraws without providing notification to the institution no later than 30 days after the end of the earlier of 1) the payment period or period of enrollment, as applicable; 2) the academic year; or 3) the program. Cause Due to turnover in critical positions within the financial aid office and lack of personnel training, the institution was unable to accurately perform the return of Title IV funds calculations timely. Effect In accordance with 34 CFR 668.84, the Secretary of Education may levy fines and/or penalties on the institution or suspend future participation in federal student financial assistance programs for failure to comply with the requirements applicable to Title IV of the HEA. Context A sample of 15 students who withdrew from the institution and were disbursed a total of $61,111 in Title IV funds was selected for testing from a population of 84 students who withdrew and were disbursed a total of $211,730 in Title IV funds. Our test results found that 1 student’s institutional portion of unearned aid was remitted untimely and the institution failed to determine the withdrawal date in a timely manner. Our sample was a statistically valid sample. Repeat Finding This is a repeat of prior audit Finding No. 2022‐006. Recommendation We recommend that institution perform the following to ensure compliance with Federal regulations: • Remit the institutional portion of unearned aid to the appropriate Title IV program within the required 45‐day time period in accordance with federal regulations. • Determine the withdrawal date for students who withdrew without providing notification within 30 days after the end of the period of enrollment in accordance with federal regulations. Views of Responsible Officials and Planned Corrective Actions The institution has implemented procedures to assist with the timely determination of students’ withdrawal dates and has also hired a permanent staff member within the financial aid office to assist in the calculation of the institutional portion of unearned Title IV funds that are required to be remitted to the Title IV program.

Questioned Costs $ 25 Finding No. 2023‐004: Financial Aid Administration – Control Deficiency Federal Agency: U.S. Department of Education Assistance Listing Number and Title: 84.063P – Federal Pell Grant Program 84.268 – Federal Direct Student Loans Condition During our audit, we noted the following instances of noncompliance: Return of Title IV Funds  For 1 out of 15 students selected for testing, the institution failed to remit the appropriate amount of Title IV funds for this student, resulting in a total underpayment of $25 to the Title IV program. Direct Student Loans  For 1 out of 12 students selected for testing, the institution failed to provide exit counseling to the borrower within a timely matter. Criteria Return of Title IV Funds Title 34, Section 668.22(a)(1) through (a)(5) of the CFR requires the institution to determine the amount of Title IV aid earned by the student as of the student’s withdrawal date when a recipient of Title IV grant or loan assistance withdraws from an institution during a payment period or period of enrollment in which the recipient began attendance. Direct Student Loans Title 34, Section 685.304 of the CFR states that an institution must ensure that exit counseling is conducted with each Direct Subsidized Loan or Director Unsubsidized Loan borrower and graduate or professional student Direct PLUS Loan borrower shortly before the student borrower ceases at least half‐time study at the institution. If a borrower withdraws from the institution without the institution’s prior knowledge or fails to complete an exit counseling session as required, the institution must ensure that exit counseling is provided through either interactive electronic means or by mailing counseling materials to the borrower at the borrower’s last known address within 30 days after learning that the borrower has withdrawn from the institution or failed to complete exit counseling as required. Cause Return of Title IV Funds Due to turnover in critical positions within the financial aid office and lack of personnel training, the institution was unable to accurately perform the return of Title IV funds calculations timely. Direct Student Loans The institution was unable to perform exit counseling to the borrower in a timely manner due to the absence of staff which hindered the timely processing of the loan exit. Effect In accordance with 34 CFR 668.84, the Secretary of Education may levy fines and/or penalties on the institution or suspend future participation in federal student financial assistance programs for failure to comply with the requirements applicable to Title IV of the HEA. Context Return of Title IV Funds A sample of 15 students who withdrew from the institution and were disbursed a total of $51,634 in Title IV funds was selected for testing from a population of 206 students who withdrew and were disbursed a total of $494,396 in Title IV funds. Our test results found 1 student’s return of Title IV funds was incorrectly calculated, resulting in a total questioned cost of $25. Our sample was a statistically valid sample. Direct Student Loans A sample of 12 exit counseling sessions conducted with borrowers were selected for audit from a population of 44 exit counseling sessions conducted with borrowers. Our test found 1 exit counseling session conducted with a borrower was not performed timely. Our sample was a statistically valid sample. Repeat Finding This is a not a repeat finding. Recommendation We recommend that the institution perform the following to ensure compliance with Federal regulations: Return of Title IV Funds  Ensure that the correct information is used to prepare the return of Title IV calculation. Direct Student Loans  Provide exit counseling to borrowers timely.  Update student enrollment status in the NSLDS in an accurate manner. Views of Responsible Officials and Planned Corrective Actions Return of Title IV Funds The institution is currently in the process of hiring additional personnel to assist in the preparation of the return of Title IV calculation and developing procedures to assist in the completion of the return of Title IV calculation in a timely and accurate manner. Direct Student Loans The institution is currently in the process of hiring additional personnel to assist in the timely execution of exit counseling to borrowers.

Questioned Costs $ ‐0‐ Finding No. 2023‐005: Return of Title IV Funds – Control Deficiency Federal Agency: U.S. Department of Education Assistance Listing Number and Title: 84.063P – Federal Pell Grant Program Condition During our audit, for 1 out of 15 students selected for testing, the institution failed to remit the institutional portion of unearned Title IV Funds to the Title IV program within 45 days after the institution determined that the student withdrew. Criteria Title 34, Section 668.22(j)(1) of the CFR requires the institution to return the amount of Title IV funds for which it is responsible for as soon as possible but no later than 45 days after the date of the institution’s determination that the student withdrew. Cause Due to turnover in critical positions within the financial aid office and lack of personnel training, the institution was unable to accurately perform the return of Title IV funds calculations timely. Effect In accordance with 34 CFR 668.84, the Secretary of Education may levy fines and/or penalties on the institution or suspend future participation in federal student financial assistance programs for failure to comply with the requirements applicable to Title IV of the HEA. Context A sample of 15 students who withdrew from the institution and were disbursed a total of $52,812 in Title IV funds was selected for testing from a population of 156 students who withdrew and were disbursed a total of $352,877 in Title IV funds. Our test results found 1 student’s return of Title IV funds was not remitted timely. Our sample was a statistically valid sample. Repeat Finding This is a repeat of prior audit Finding No. 2022‐002. Recommendation We recommend that the institution remit the institutional portion of unearned aid to the appropriate Title IV program within the required 45‐day time period in accordance with federal regulations. Views of Responsible Officials and Planned Corrective Actions The institution is currently in the process of hiring additional personnel to assist in the timely execution of exit counseling to borrowers.

Questioned Costs $ ‐0‐ Finding No. 2023‐002: Return of Title IV Funds – Control Deficiency Federal Agency: U.S. Department of Education Assistance Listing Number and Title: 84.063P – Federal Pell Grant Program 84.268 – Federal Direct Student Loans Condition During our audit, for 4 out of 15 students selected for testing, the institution failed to remit the institutional portion of unearned Title IV funds to the Title IV program within 45 days after the institution determined that the student withdrew. Criteria Title 34, Section 668.22(j)(1) of the CFR requires the institution to return the amount of Title IV funds for which it is responsible for as soon as possible but no later than 45 days after the date of the institution’s determination that the student withdrew. Cause Due to turnover in critical positions within the financial aid office and lack of personnel training, the institution was unable to accurately perform the return of Title IV funds calculations timely. Effect In accordance with 34 CFR 668.84, the Secretary of Education may levy fines and/or penalties on the institution or suspend future participation in federal student financial assistance programs for failure to comply with the requirements applicable to Title IV of the Higher Education Act (“HEA”). Context A sample of 15 students who withdrew from the institution and were disbursed a total of $99,809 in Title IV funds was selected for audit from a population of 277 students who withdrew and were disbursed a total of $704,249 in Title IV funds. Our test results found 4 students’ return of Title IV funds were not remitted timely. Our sample was a statistically valid sample. Repeat Finding This is not a repeat finding. Recommendation We recommend that the institution remit the institutional portion of unearned aid to the appropriate Title IV program within the required 45‐day time period in accordance with federal regulations. Views of Responsible Officials and Planned Corrective Actions The institution has adjusted its procedures to remit the institutional portion of unearned Title IV funds to the Title IV program within 30 days after the institution determined that the student withdrew.

Questioned Costs $ 25 Finding No. 2023‐004: Financial Aid Administration – Control Deficiency Federal Agency: U.S. Department of Education Assistance Listing Number and Title: 84.063P – Federal Pell Grant Program 84.268 – Federal Direct Student Loans Condition During our audit, we noted the following instances of noncompliance: Return of Title IV Funds  For 1 out of 15 students selected for testing, the institution failed to remit the appropriate amount of Title IV funds for this student, resulting in a total underpayment of $25 to the Title IV program. Direct Student Loans  For 1 out of 12 students selected for testing, the institution failed to provide exit counseling to the borrower within a timely matter. Criteria Return of Title IV Funds Title 34, Section 668.22(a)(1) through (a)(5) of the CFR requires the institution to determine the amount of Title IV aid earned by the student as of the student’s withdrawal date when a recipient of Title IV grant or loan assistance withdraws from an institution during a payment period or period of enrollment in which the recipient began attendance. Direct Student Loans Title 34, Section 685.304 of the CFR states that an institution must ensure that exit counseling is conducted with each Direct Subsidized Loan or Director Unsubsidized Loan borrower and graduate or professional student Direct PLUS Loan borrower shortly before the student borrower ceases at least half‐time study at the institution. If a borrower withdraws from the institution without the institution’s prior knowledge or fails to complete an exit counseling session as required, the institution must ensure that exit counseling is provided through either interactive electronic means or by mailing counseling materials to the borrower at the borrower’s last known address within 30 days after learning that the borrower has withdrawn from the institution or failed to complete exit counseling as required. Cause Return of Title IV Funds Due to turnover in critical positions within the financial aid office and lack of personnel training, the institution was unable to accurately perform the return of Title IV funds calculations timely. Direct Student Loans The institution was unable to perform exit counseling to the borrower in a timely manner due to the absence of staff which hindered the timely processing of the loan exit. Effect In accordance with 34 CFR 668.84, the Secretary of Education may levy fines and/or penalties on the institution or suspend future participation in federal student financial assistance programs for failure to comply with the requirements applicable to Title IV of the HEA. Context Return of Title IV Funds A sample of 15 students who withdrew from the institution and were disbursed a total of $51,634 in Title IV funds was selected for testing from a population of 206 students who withdrew and were disbursed a total of $494,396 in Title IV funds. Our test results found 1 student’s return of Title IV funds was incorrectly calculated, resulting in a total questioned cost of $25. Our sample was a statistically valid sample. Direct Student Loans A sample of 12 exit counseling sessions conducted with borrowers were selected for audit from a population of 44 exit counseling sessions conducted with borrowers. Our test found 1 exit counseling session conducted with a borrower was not performed timely. Our sample was a statistically valid sample. Repeat Finding This is a not a repeat finding. Recommendation We recommend that the institution perform the following to ensure compliance with Federal regulations: Return of Title IV Funds  Ensure that the correct information is used to prepare the return of Title IV calculation. Direct Student Loans  Provide exit counseling to borrowers timely.  Update student enrollment status in the NSLDS in an accurate manner. Views of Responsible Officials and Planned Corrective Actions Return of Title IV Funds The institution is currently in the process of hiring additional personnel to assist in the preparation of the return of Title IV calculation and developing procedures to assist in the completion of the return of Title IV calculation in a timely and accurate manner. Direct Student Loans The institution is currently in the process of hiring additional personnel to assist in the timely execution of exit counseling to borrowers.