Findings Citing § 200.303

2024-003 Drawdowns Segregation of Duties Compliance Requirement Cash management Finding Type Significant Deficiency in Internal Controls Federal Agency US Department of Education ALN 84.031 Federal Program Higher Education Institutional Aid ALN 84.042A Federal Program TRIO Cluster Program ALN 84.425F and 84.425L Federal Program COVID-19 - Education Stabilization Fund Criteria 2 CFR § 200.303, Internal Controls The recipient and subrecipient must: (a) Establish, document, and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control-Integrated Framework” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition The individual reviewing and approving the reimbursements to be requested to the Federal awarding agency is the same person performing the request and drawdown. Cause Lack of segregation of duties between the responsibilities for reviewing and approving reimbursements and those performing the request and drawdown. Effect The University has not implemented internal controls to ensure Federal awards are managed in compliance with Federal statutes, regulations, and the terms and conditions of the awards. This noncompliance can lead to financial penalties, resulting in disallowed costs that are not reimbursed by federal funds. Additionally, federal awards could be suspended or terminated, impacting the University's ability to fund its programs and operations. Increased scrutiny in future audits may lead to greater administrative burdens and oversight. In severe cases, the University may face suspension or debarment from receiving future federal funding. Recommendations We recommend that the University ensures compliance with federal statutes, regulations, and the terms and conditions of the awards by assigning another employee within the Administration of Federal & State Funds to handle the drawdown process. The Director should review and approve this process. Additionally, it is important to document the procedures for reimbursement requests and approvals, clearly specifying the roles and responsibilities of each individual involved. Views of responsible official Refer to Corrective Action Plan (Unaudited)

2024-003 Drawdowns Segregation of Duties Compliance Requirement Cash management Finding Type Significant Deficiency in Internal Controls Federal Agency US Department of Education ALN 84.031 Federal Program Higher Education Institutional Aid ALN 84.042A Federal Program TRIO Cluster Program ALN 84.425F and 84.425L Federal Program COVID-19 - Education Stabilization Fund Criteria 2 CFR § 200.303, Internal Controls The recipient and subrecipient must: (a) Establish, document, and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control-Integrated Framework” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition The individual reviewing and approving the reimbursements to be requested to the Federal awarding agency is the same person performing the request and drawdown. Cause Lack of segregation of duties between the responsibilities for reviewing and approving reimbursements and those performing the request and drawdown. Effect The University has not implemented internal controls to ensure Federal awards are managed in compliance with Federal statutes, regulations, and the terms and conditions of the awards. This noncompliance can lead to financial penalties, resulting in disallowed costs that are not reimbursed by federal funds. Additionally, federal awards could be suspended or terminated, impacting the University's ability to fund its programs and operations. Increased scrutiny in future audits may lead to greater administrative burdens and oversight. In severe cases, the University may face suspension or debarment from receiving future federal funding. Recommendations We recommend that the University ensures compliance with federal statutes, regulations, and the terms and conditions of the awards by assigning another employee within the Administration of Federal & State Funds to handle the drawdown process. The Director should review and approve this process. Additionally, it is important to document the procedures for reimbursement requests and approvals, clearly specifying the roles and responsibilities of each individual involved. Views of responsible official Refer to Corrective Action Plan (Unaudited)

2024-003 Drawdowns Segregation of Duties Compliance Requirement Cash management Finding Type Significant Deficiency in Internal Controls Federal Agency US Department of Education ALN 84.031 Federal Program Higher Education Institutional Aid ALN 84.042A Federal Program TRIO Cluster Program ALN 84.425F and 84.425L Federal Program COVID-19 - Education Stabilization Fund Criteria 2 CFR § 200.303, Internal Controls The recipient and subrecipient must: (a) Establish, document, and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control-Integrated Framework” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition The individual reviewing and approving the reimbursements to be requested to the Federal awarding agency is the same person performing the request and drawdown. Cause Lack of segregation of duties between the responsibilities for reviewing and approving reimbursements and those performing the request and drawdown. Effect The University has not implemented internal controls to ensure Federal awards are managed in compliance with Federal statutes, regulations, and the terms and conditions of the awards. This noncompliance can lead to financial penalties, resulting in disallowed costs that are not reimbursed by federal funds. Additionally, federal awards could be suspended or terminated, impacting the University's ability to fund its programs and operations. Increased scrutiny in future audits may lead to greater administrative burdens and oversight. In severe cases, the University may face suspension or debarment from receiving future federal funding. Recommendations We recommend that the University ensures compliance with federal statutes, regulations, and the terms and conditions of the awards by assigning another employee within the Administration of Federal & State Funds to handle the drawdown process. The Director should review and approve this process. Additionally, it is important to document the procedures for reimbursement requests and approvals, clearly specifying the roles and responsibilities of each individual involved. Views of responsible official Refer to Corrective Action Plan (Unaudited)

2024-003 Drawdowns Segregation of Duties Compliance Requirement Cash management Finding Type Significant Deficiency in Internal Controls Federal Agency US Department of Education ALN 84.031 Federal Program Higher Education Institutional Aid ALN 84.042A Federal Program TRIO Cluster Program ALN 84.425F and 84.425L Federal Program COVID-19 - Education Stabilization Fund Criteria 2 CFR § 200.303, Internal Controls The recipient and subrecipient must: (a) Establish, document, and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control-Integrated Framework” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition The individual reviewing and approving the reimbursements to be requested to the Federal awarding agency is the same person performing the request and drawdown. Cause Lack of segregation of duties between the responsibilities for reviewing and approving reimbursements and those performing the request and drawdown. Effect The University has not implemented internal controls to ensure Federal awards are managed in compliance with Federal statutes, regulations, and the terms and conditions of the awards. This noncompliance can lead to financial penalties, resulting in disallowed costs that are not reimbursed by federal funds. Additionally, federal awards could be suspended or terminated, impacting the University's ability to fund its programs and operations. Increased scrutiny in future audits may lead to greater administrative burdens and oversight. In severe cases, the University may face suspension or debarment from receiving future federal funding. Recommendations We recommend that the University ensures compliance with federal statutes, regulations, and the terms and conditions of the awards by assigning another employee within the Administration of Federal & State Funds to handle the drawdown process. The Director should review and approve this process. Additionally, it is important to document the procedures for reimbursement requests and approvals, clearly specifying the roles and responsibilities of each individual involved. Views of responsible official Refer to Corrective Action Plan (Unaudited)

2024-004 Segregation of Duties Compliance Requirement Level of Effort Finding Type Significant Deficiency in Internal Controls Federal Agency US Department of Education ALN 84.031 Federal Program Higher Education Institutional Aid Criteria 2 CFR § 200.303, Internal controls. The recipient and subrecipient must: (a) Establish, document, and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control-Integrated Framework” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition In one instance, we identified a level of effort report without the proper approval. Cause Recent transition of personnel into a new leadership role contributing to the oversight. Effect Time being charged to the wrong project or funding source, and/or charging time not actually worked or unrelated to the award’s purpose. Additionally, this type of circumstance could result in management override of controls. Questioned Costs None. Recommendation We recommend the University to implement a comprehensive training sessions for employees transitioning into new roles. These sessions should emphasize the importance of completing all pending approvals prior to their transfer. Views of Responsible Officials Refer to Corrective Action Plan (Unaudited)

2024-004 Segregation of Duties Compliance Requirement Level of Effort Finding Type Significant Deficiency in Internal Controls Federal Agency US Department of Education ALN 84.031 Federal Program Higher Education Institutional Aid Criteria 2 CFR § 200.303, Internal controls. The recipient and subrecipient must: (a) Establish, document, and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control-Integrated Framework” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition In one instance, we identified a level of effort report without the proper approval. Cause Recent transition of personnel into a new leadership role contributing to the oversight. Effect Time being charged to the wrong project or funding source, and/or charging time not actually worked or unrelated to the award’s purpose. Additionally, this type of circumstance could result in management override of controls. Questioned Costs None. Recommendation We recommend the University to implement a comprehensive training sessions for employees transitioning into new roles. These sessions should emphasize the importance of completing all pending approvals prior to their transfer. Views of Responsible Officials Refer to Corrective Action Plan (Unaudited)

2024-004 Segregation of Duties Compliance Requirement Level of Effort Finding Type Significant Deficiency in Internal Controls Federal Agency US Department of Education ALN 84.031 Federal Program Higher Education Institutional Aid Criteria 2 CFR § 200.303, Internal controls. The recipient and subrecipient must: (a) Establish, document, and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control-Integrated Framework” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition In one instance, we identified a level of effort report without the proper approval. Cause Recent transition of personnel into a new leadership role contributing to the oversight. Effect Time being charged to the wrong project or funding source, and/or charging time not actually worked or unrelated to the award’s purpose. Additionally, this type of circumstance could result in management override of controls. Questioned Costs None. Recommendation We recommend the University to implement a comprehensive training sessions for employees transitioning into new roles. These sessions should emphasize the importance of completing all pending approvals prior to their transfer. Views of Responsible Officials Refer to Corrective Action Plan (Unaudited)

2024-004 Segregation of Duties Compliance Requirement Level of Effort Finding Type Significant Deficiency in Internal Controls Federal Agency US Department of Education ALN 84.031 Federal Program Higher Education Institutional Aid Criteria 2 CFR § 200.303, Internal controls. The recipient and subrecipient must: (a) Establish, document, and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control-Integrated Framework” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition In one instance, we identified a level of effort report without the proper approval. Cause Recent transition of personnel into a new leadership role contributing to the oversight. Effect Time being charged to the wrong project or funding source, and/or charging time not actually worked or unrelated to the award’s purpose. Additionally, this type of circumstance could result in management override of controls. Questioned Costs None. Recommendation We recommend the University to implement a comprehensive training sessions for employees transitioning into new roles. These sessions should emphasize the importance of completing all pending approvals prior to their transfer. Views of Responsible Officials Refer to Corrective Action Plan (Unaudited)

Criteria: Under 2 CFR §200.302(b), §200.303, and §200.305, non-federal entities must establish internal controls over federal awards to ensure proper financial management, allowability of costs, timely and accurate reporting, and proper cash management. Additionally, under GAAP (ASC 958-605), grant revenue should be recognized when allowable costs have been incurred. Documentation and supervisory review are necessary to support revenue recognition and ensure expenditures and drawdowns are accurately reported. Condition: The Organization did not document a monthly reconciliation review process to confirm that federal revenues recorded in the general ledger and federal grant drawdowns were supported by allowable costs incurred. Additionally, there was no evidence of review or reconciliation of annual SF-425 Federal Financial Reports to verify that cumulative drawdowns reconciled to allowable costs and recorded revenue. Cause: The Organization lacked a formal internal control process requiring review and sign-off of the reconciliation of grant expenditures, grant revenue, drawdowns, and SF-425 federal financial reporting. Effect: Inadequate internal controls over allowable costs, cash management, and federal financial reporting increased the risk of improper grant revenue recognition recorded, expenditures not being accurately reported, and unallowable costs being claimed, which could lead to misstatements in the financial statements, Schedule of Expenditures of Federal Awards (SEFA), and required federal reports, and result in noncompliance with Uniform Guidance and GAAP. Questioned Cost: None Recommendation: Implement a documented monthly reconciliation process to verify that federal revenues recorded and drawn down are supported by allowable costs incurred in accordance with grant terms. Include supervisory review of SF-425 reports and supporting schedules to confirm alignment with recorded expenditures and revenues. Reconciliations should be reviewed and signed by the CFO and retained in grant records to ensure compliance with Uniform Guidance and GAAP.

U.S. Department of Housing and Urban Development #14.251 Economic Development Initiative, Community Project Funding, and Miscellaneous Grants 2024-004 Lack of Documented Approval (Significant Deficiency) Criteria: Per 2 CFR §200.303, the entity must establish and maintain effective internal controls over federal awards that provide reasonable assurance that the entity is managing the award in compliance with federal statutes, regulations, and the terms and conditions of the award. Adequate documentation of approvals is a fundamental internal control to ensure expenditures are necessary, allowable, and properly authorized. Condition: During our testing of expenditures charged to the Community Project Funding funded by the US Department of Housing and Urban Development, we noted that the Organization did not maintain documented evidence of management approval prior to incurring or paying costs. The transactions reviewed lacked documented authorizations, supervisor sign-offs, or other documentation showing formal approval. Cause: The lack of documented approval appears to be due to inconsistent application of internal controls and the absence of a standardized process for documenting expenditure authorization for federal programs. Effect: Without documented approval, there is an increased risk that unallowable or unauthorized expenditures could be charged to the federal award. It also weakens the audit trail and compliance with Uniform Guidance requirements. Questioned Costs: None noted. Recommendation: We recommend the Organization implement and enforce a formal process requiring documented pre-approval of all expenditures charged to federal programs. This may include standardized approval forms or electronic workflows that clearly demonstrate appropriate review and authorization prior to payment. Views of Responsible Officials and Planned Corrective Actions: Management agrees documentation must demonstrate proper approval. Corrective Action: Utilize standard purchase authorization and maintain approval documentation with supporting invoices/receipts.

Finding No. 2024-003 – Documentation of Internal Controls over Compliance Material Weakness Federal Program – Student Financial Aid Cluster – Federal Direct Student Loans (ALN 84.268), U.S. Department of Education Criteria – Auditee requirements contained in Title 2 U.S. Code of Federal Regulations (2 CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, Subpart D – Post Federal Award Requirements, Section 200.303 – Internal Controls, requires the auditee to establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with a framework such as the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (“COSO”). Condition – We noted that controls identified by management over material compliance requirements lacked sufficient documentation to conclude application of controls is in place. Cause – The cause is due to ineffective internal control procedures with no physical indication of review or an audit trail that indicates that the identified control took place. Effect – Ineffective internal control procedures resulted in compliance findings. See Finding No. 2024-002. Reportable Questioned Costs: None Context – Internal controls in place over material compliance requirements identified by management had no documentation in place to demonstrate application of controls. Repeat Finding – This is a repeat finding of 2023-003. Recommendation – We recommend the Institute ensures all internal control procedures in place include documentation that demonstrates application of controls. Views of Responsible Officials – Management agrees with the finding. See Corrective Action Plan.

2024-003 United States Department Agriculture Federal Financial Assistance Listing #10.766 Community Facilities Loans and Grant Special Tests and Provisions Significant Deficiency in Internal Control Over Compliance Criteria – 2 CFR 200.303(a) establishes that the auditee must establish and maintain effective internal control over the federal award that provides assurance that the entity is managing the federal award in compliance with federal statutes, regulations, and conditions of the federal award. Condition – During our testing, there was no formal review separate from the preparer over the reserve fund reconciliation for the federal program and there was no formal review of the balance in comparison to the required minimum reserve balance. Cause – The Health Center did not have an adequate internal control policy in place to ensure review and approval over the amount of the reserve fund. Effect – The lack of adequate policies governing review increases the risk that employees participating in the federal award administration may not be able to detect and correct noncompliance in a timely manner. Questioned Costs – None reported. Context – Sampling was not used. The Health Center has one reserve account, which includes the debt service and emergency and replacement reserve, that was tested. Repeat Finding from Prior Years – Yes, Finding 2023-004 Recommendation – We recommend that the Health Center enhance internal control policies to ensure that a formal review over the reserve fund reconciliation and a formal review of the balance in comparison to the required minimum reserve balance be completed by staff separate from the preparer. Views of Responsible Officials – Management agrees with the finding.

Program - AL 21.027 - COVID-19 – Coronavirus State and Local Fiscal Recovery Funds – Suspension & Debarment Grant Number & Year - SLFRP1468; March 3, 2021, through December 31, 2024 Federal Grantor Agency - U.S. Department of the Treasury Criteria - Title 2 of the U.S. Code of Federal Regulations (CFR) § 200.303 (January 1, 2024) states the following, in relevant part: The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). The U.S. Department of the Treasury adopted the Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards in 2 CFR § 1000.10 (January 1, 2024), which states the following: Except for the deviations set forth elsewhere in this Part, the Department of the Treasury adopts the Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, set forth at 2 CFR part 200. 2 CFR § 200.214 (January 1, 2024) states the following: Non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. The regulations in 2 CFR part 180 restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. 2 CFR § 180.300 (January 1, 2024) requires non-Federal entities to verify that an entity is not excluded or disqualified prior to entering into a covered transaction by: “(a) Checking SAM Exclusions; or (b) Collecting a certification from that . . . [entity]; or (c) Adding a clause or condition to the covered transaction with that . . . [entity].” A good internal control plan requires the County to have proper procedures in place to verify that vendors paid with Federal funds are not suspended, debarred, or otherwise excluded from or ineligible for participation in Federal programs or activities. Condition - The County could not provide documentation to support that the County implementedeffective internal controls to ensure that suspension and debarment requirements were followed and adequately documented. We noted the County used Coronavirus State and Local Fiscal Recovery Funds to pay two vendors over $25,000, totaling $548,036 during the fiscal year ended June 30, 2024. The County failed to ensure that these vendors were not excluded or disqualified prior to entering into these covered transactions. We reviewed sam.gov and noted that none of these vendors were suspended, debarred, or otherwise excluded from participation in Federal programs or activities as of the date testing was performed. Repeat Finding - No Questioned Costs - None Statistical Sample - No Context - The following table provides details of the covered transactions noted: Cause - Lack of procedures and knowledge regarding suspension and debarment requirements. Effect - Without adequate procedures to ensure vendors are not suspended, debarred, or otherwise excluded from or ineligible for participation in Federal programs or activities, there is an increased risk for the misuse of Federal funds and noncompliance with Federal regulations, leading to possible Federal sanctions. Recommendation - We recommend the County implement procedures to ensure, prior to entering into acovered transaction, that a vendor is not suspended, debarred, or otherwise excluded fromor ineligible for participation in Federal programs or activities, and those procedures areadequately documented. View of Officials - The County will implement procedures to ensure when a contractor is paid with federal funds, sam.gov will be utilized to verify the entity has not been suspended or debarred and such procedure will be adequately documented.

Finding 2024-001: Untimely and Inaccurate Enrollment Reporting Compliance Requirement: Special Tests & Provisions: Enrollment Reporting Type: Material Weakness in Internal Control over Compliance; Material Noncompliance Federal Awarding Agency: U.S. Department of Education AL Numbers and Titles: 84.063 and 84.268 – Student Financial Aid Cluster Grant Award Period: July 1, 2023 through June 30, 2024 Questioned Costs: None Repeat Finding: No Criteria: Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Additionally, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless of if they receive aid from the institution or not. Changes to said status are required to be reported within 30 days of becoming aware of the status change, or with the next scheduled transmission of statuses if the scheduled transmission is within 60 days. Condition: During our testing of 12 students, we identified 9 students for which the student's enrollment status was not reported timely to the National Student Loan Data System (NSLDS) and 8 students whose graduation status was not accurately reported to the NSLDS. Cause: During the year, the University submitted its listing of individuals who graduated to Clearinghouse to upload to NSLDS. However, the University did not review the listing of exceptions from Clearinghouse related to the students whose status changes were not uploaded to NSLDS, which caused the enrollment changes for students who graduated to not be reported in accordance with federal requirements. This caused students to not be reported to NSLDS until the audit.Effect: The University was not in compliance with the requirements to properly report student enrollment data correctly. Incorrect dates submitted to NSLDS may be used to determine the grace period for the repayment and interest of outstanding Title IV student loans. Recommendation: We recommend the University review current processes for reporting to NSLDS and implement procedures to ensure submissions are reported timely and accurately. Views of Responsible Officials Corrective Actions: The University agrees with this finding. Please refer to the Corrective Action Plan.

Finding 2024-001: Untimely and Inaccurate Enrollment Reporting Compliance Requirement: Special Tests & Provisions: Enrollment Reporting Type: Material Weakness in Internal Control over Compliance; Material Noncompliance Federal Awarding Agency: U.S. Department of Education AL Numbers and Titles: 84.063 and 84.268 – Student Financial Aid Cluster Grant Award Period: July 1, 2023 through June 30, 2024 Questioned Costs: None Repeat Finding: No Criteria: Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Additionally, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless of if they receive aid from the institution or not. Changes to said status are required to be reported within 30 days of becoming aware of the status change, or with the next scheduled transmission of statuses if the scheduled transmission is within 60 days. Condition: During our testing of 12 students, we identified 9 students for which the student's enrollment status was not reported timely to the National Student Loan Data System (NSLDS) and 8 students whose graduation status was not accurately reported to the NSLDS. Cause: During the year, the University submitted its listing of individuals who graduated to Clearinghouse to upload to NSLDS. However, the University did not review the listing of exceptions from Clearinghouse related to the students whose status changes were not uploaded to NSLDS, which caused the enrollment changes for students who graduated to not be reported in accordance with federal requirements. This caused students to not be reported to NSLDS until the audit.Effect: The University was not in compliance with the requirements to properly report student enrollment data correctly. Incorrect dates submitted to NSLDS may be used to determine the grace period for the repayment and interest of outstanding Title IV student loans. Recommendation: We recommend the University review current processes for reporting to NSLDS and implement procedures to ensure submissions are reported timely and accurately. Views of Responsible Officials Corrective Actions: The University agrees with this finding. Please refer to the Corrective Action Plan.

2024-003 Department of Agriculture Federal Assistance Listing #10.766 Community Facilities Loans and Grants Cluster Special Tests and Provisions Significant Deficiency in Internal Control over Compliance Criteria - 2 CFR 200.303(a) establishes that the auditee must establish and maintain effective internal control over federal award that provides assurance that the entity is managing the federal award in compliance with federal statutes, regulations, and conditions of the federal awards. Condition - During our testing, there was no formal review separate from the preparer over the reserve fund reconciliations for the federal program. Cause - The Home did not have an adequate internal control policy in place to ensure review and approval over the reserve fund reconciliations. Effect - The lack of adequate policies governing review increases the risk that employees participating in the federal award administration may not be able to detect and correct noncompliance in a timely manner. Questioned Costs - None reported. Context/Sampling - Sampling was not used. The Home has two required reserve fund requirements that were tested. Repeat Finding from Prior Years - Yes - 2023-004 Recommendation - We recommend that the Home enhance internal control policies to ensure that formal documentation of reviews is present. Views of Responsible Officials - Management agrees with the finding.

Finding # 2024-002 Program: AL 21.027 – COVID-19 – Coronavirus State and Local Fiscal Recovery Funds – Suspension & Debarment Grant Number & Year: SLFRP0847, March 3, 2021, through December 31, 2024 Federal Grantor Agency: U.S. Department of the Treasury Criteria: Title 2 of the U.S. Code of Federal Regulations (CFR) § 200.303 (January 1, 2024) states the following, in relevant part: The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). 2 CFR § 200.214 (January 1, 2024) states the following: Non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. The regulations in 2 CFR part 180 restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. The U.S. Department of the Treasury adopted the Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards in 2 CFR § 1000.10 (January 1, 2024), which states the following: Except for the deviations set forth elsewhere in this Part, the Department of the Treasury adopts the Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, set forth at 2 CFR part 200. 2 CFR § 180.300 (January 1, 2024) requires non-Federal entities to verify that an entity is not excluded or disqualified prior to entering into a covered transaction by “(a) Checking SAM Exclusions; or (b) Collecting a certification from that . . . [entity]; or (c) Adding a clause or condition to the covered transaction with that . . . [entity].” A good internal control plan requires the County to have proper procedures in place to verify that contractors paid with Federal funds are not suspended, debarred, or otherwise excluded from or ineligible for participation in Federal programs or activities, and those procedures are adequately documented. Condition: Dawson County could not provide documentation to support that the County implemented effective internal controls to ensure that suspension and debarment requirements were followed and adequately documented. We noted the County used Coronavirus State and Local Fiscal Recovery Funds to pay 12 vendors over $25,000 each, totaling $2,875,367, during the fiscal year ended June 30, 2024. The County was unable to support that a review was performed to ensure that these vendors were not excluded or disqualified prior to entering into these covered transactions. We reviewed SAM.gov, and noted that none of these vendors were suspended, debarred, or otherwise excluded from participation in Federal programs or activities as of the date testing was performed. Repeat Finding: 2023-002 Questioned Costs: None Statistical Sample: No Context: The following table provides details of the covered transactions noted: Cause: Lack of procedures and knowledge regarding suspension and debarment requirements; long-time County Clerk retired during the fiscal year. Effect: Without adequate procedures to ensure contractors are not suspended, debarred, or otherwise excluded from or ineligible for participation in Federal programs or activities, there is an increased risk for the misuse of Federal funds and noncompliance with Federal regulations, leading to possible Federal sanctions. Recommendation: We recommend the County implement procedures to ensure, prior to entering into a covered transaction, that a contractor is not suspended, debarred, or otherwise excluded from or ineligible for participation in Federal programs or activities, and those procedures are adequately documented. View of Officials: The County has procedures in place; when a contractor is hired, sam.gov will be utilized to verify the entity has not been suspended or debarred.

Condition: During our testing we noted that for 2 out of 3 vendors selected for procurement testing there was no documentation to demonstrate that procurement was conducted in full and open competition according to 2CFR section 200.319 or any documentation of the rationale to limit competition in those cases where competition was limited and ascertain if the limitation was justified per 2CFR sections 200.319 and 200.320(f) and 48 CFR section 52.244-5. Criteria: 2 CFR 200.303 requires non-federal entities to, among other things, establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Effective internal controls should include procedures to ensure procurement files are complete and adequately document decisions made to sole source procurements of goods and services in accordance with the Institute’s procurement policies. Cause: Hubbs-SeaWorld Research Institute’s procurement policy was not in alignment with the procurement compliance requirements stated in 2 CFR 200.303. Effect: Hubbs-SeaWorld Research Institute did not document and maintain records for the procurement of goods and services resulting in noncompliance with the procurement compliance requirements stated in 2 CFR 200.303 during the year ending June 30, 2024. Recommendation: Hubbs-SeaWorld Research Institute should improve its policies and procedures regarding the procurement process and maintain documentation. Management Response: The management staff of Hubbs-SeaWorld Research Institute take very seriously the federal compliance related to the procurement of goods and services. Hubbs-SeaWorld Research Institute acknowledges the finding and has subsequently updated their procurement policy and procedures to be in compliance with 2 CFR 200.303. Management has adopted a plan of action to prevent future instances of non-compliance.

Condition: During our testing we noted that for 2 out of 3 vendors selected for procurement testing there was no documentation to demonstrate that procurement was conducted in full and open competition according to 2CFR section 200.319 or any documentation of the rationale to limit competition in those cases where competition was limited and ascertain if the limitation was justified per 2CFR sections 200.319 and 200.320(f) and 48 CFR section 52.244-5. Criteria: 2 CFR 200.303 requires non-federal entities to, among other things, establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Effective internal controls should include procedures to ensure procurement files are complete and adequately document decisions made to sole source procurements of goods and services in accordance with the Institute’s procurement policies. Cause: Hubbs-SeaWorld Research Institute’s procurement policy was not in alignment with the procurement compliance requirements stated in 2 CFR 200.303. Effect: Hubbs-SeaWorld Research Institute did not document and maintain records for the procurement of goods and services resulting in noncompliance with the procurement compliance requirements stated in 2 CFR 200.303 during the year ending June 30, 2024. Recommendation: Hubbs-SeaWorld Research Institute should improve its policies and procedures regarding the procurement process and maintain documentation. Management Response: The management staff of Hubbs-SeaWorld Research Institute take very seriously the federal compliance related to the procurement of goods and services. Hubbs-SeaWorld Research Institute acknowledges the finding and has subsequently updated their procurement policy and procedures to be in compliance with 2 CFR 200.303. Management has adopted a plan of action to prevent future instances of non-compliance.

Condition: During our testing we noted that for 2 out of 3 vendors selected for procurement testing there was no documentation to demonstrate that procurement was conducted in full and open competition according to 2CFR section 200.319 or any documentation of the rationale to limit competition in those cases where competition was limited and ascertain if the limitation was justified per 2CFR sections 200.319 and 200.320(f) and 48 CFR section 52.244-5. Criteria: 2 CFR 200.303 requires non-federal entities to, among other things, establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Effective internal controls should include procedures to ensure procurement files are complete and adequately document decisions made to sole source procurements of goods and services in accordance with the Institute’s procurement policies. Cause: Hubbs-SeaWorld Research Institute’s procurement policy was not in alignment with the procurement compliance requirements stated in 2 CFR 200.303. Effect: Hubbs-SeaWorld Research Institute did not document and maintain records for the procurement of goods and services resulting in noncompliance with the procurement compliance requirements stated in 2 CFR 200.303 during the year ending June 30, 2024. Recommendation: Hubbs-SeaWorld Research Institute should improve its policies and procedures regarding the procurement process and maintain documentation. Management Response: The management staff of Hubbs-SeaWorld Research Institute take very seriously the federal compliance related to the procurement of goods and services. Hubbs-SeaWorld Research Institute acknowledges the finding and has subsequently updated their procurement policy and procedures to be in compliance with 2 CFR 200.303. Management has adopted a plan of action to prevent future instances of non-compliance.

Condition: During our testing we noted that for 2 out of 3 vendors selected for procurement testing there was no documentation to demonstrate that procurement was conducted in full and open competition according to 2CFR section 200.319 or any documentation of the rationale to limit competition in those cases where competition was limited and ascertain if the limitation was justified per 2CFR sections 200.319 and 200.320(f) and 48 CFR section 52.244-5. Criteria: 2 CFR 200.303 requires non-federal entities to, among other things, establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Effective internal controls should include procedures to ensure procurement files are complete and adequately document decisions made to sole source procurements of goods and services in accordance with the Institute’s procurement policies. Cause: Hubbs-SeaWorld Research Institute’s procurement policy was not in alignment with the procurement compliance requirements stated in 2 CFR 200.303. Effect: Hubbs-SeaWorld Research Institute did not document and maintain records for the procurement of goods and services resulting in noncompliance with the procurement compliance requirements stated in 2 CFR 200.303 during the year ending June 30, 2024. Recommendation: Hubbs-SeaWorld Research Institute should improve its policies and procedures regarding the procurement process and maintain documentation. Management Response: The management staff of Hubbs-SeaWorld Research Institute take very seriously the federal compliance related to the procurement of goods and services. Hubbs-SeaWorld Research Institute acknowledges the finding and has subsequently updated their procurement policy and procedures to be in compliance with 2 CFR 200.303. Management has adopted a plan of action to prevent future instances of non-compliance.

Condition: During our testing we noted that for 2 out of 3 vendors selected for procurement testing there was no documentation to demonstrate that procurement was conducted in full and open competition according to 2CFR section 200.319 or any documentation of the rationale to limit competition in those cases where competition was limited and ascertain if the limitation was justified per 2CFR sections 200.319 and 200.320(f) and 48 CFR section 52.244-5. Criteria: 2 CFR 200.303 requires non-federal entities to, among other things, establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Effective internal controls should include procedures to ensure procurement files are complete and adequately document decisions made to sole source procurements of goods and services in accordance with the Institute’s procurement policies. Cause: Hubbs-SeaWorld Research Institute’s procurement policy was not in alignment with the procurement compliance requirements stated in 2 CFR 200.303. Effect: Hubbs-SeaWorld Research Institute did not document and maintain records for the procurement of goods and services resulting in noncompliance with the procurement compliance requirements stated in 2 CFR 200.303 during the year ending June 30, 2024. Recommendation: Hubbs-SeaWorld Research Institute should improve its policies and procedures regarding the procurement process and maintain documentation. Management Response: The management staff of Hubbs-SeaWorld Research Institute take very seriously the federal compliance related to the procurement of goods and services. Hubbs-SeaWorld Research Institute acknowledges the finding and has subsequently updated their procurement policy and procedures to be in compliance with 2 CFR 200.303. Management has adopted a plan of action to prevent future instances of non-compliance.

Condition: During our testing we noted that for 2 out of 3 vendors selected for procurement testing there was no documentation to demonstrate that procurement was conducted in full and open competition according to 2CFR section 200.319 or any documentation of the rationale to limit competition in those cases where competition was limited and ascertain if the limitation was justified per 2CFR sections 200.319 and 200.320(f) and 48 CFR section 52.244-5. Criteria: 2 CFR 200.303 requires non-federal entities to, among other things, establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Effective internal controls should include procedures to ensure procurement files are complete and adequately document decisions made to sole source procurements of goods and services in accordance with the Institute’s procurement policies. Cause: Hubbs-SeaWorld Research Institute’s procurement policy was not in alignment with the procurement compliance requirements stated in 2 CFR 200.303. Effect: Hubbs-SeaWorld Research Institute did not document and maintain records for the procurement of goods and services resulting in noncompliance with the procurement compliance requirements stated in 2 CFR 200.303 during the year ending June 30, 2024. Recommendation: Hubbs-SeaWorld Research Institute should improve its policies and procedures regarding the procurement process and maintain documentation. Management Response: The management staff of Hubbs-SeaWorld Research Institute take very seriously the federal compliance related to the procurement of goods and services. Hubbs-SeaWorld Research Institute acknowledges the finding and has subsequently updated their procurement policy and procedures to be in compliance with 2 CFR 200.303. Management has adopted a plan of action to prevent future instances of non-compliance.

Condition: During our testing we noted that for 2 out of 3 vendors selected for procurement testing there was no documentation to demonstrate that procurement was conducted in full and open competition according to 2CFR section 200.319 or any documentation of the rationale to limit competition in those cases where competition was limited and ascertain if the limitation was justified per 2CFR sections 200.319 and 200.320(f) and 48 CFR section 52.244-5. Criteria: 2 CFR 200.303 requires non-federal entities to, among other things, establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Effective internal controls should include procedures to ensure procurement files are complete and adequately document decisions made to sole source procurements of goods and services in accordance with the Institute’s procurement policies. Cause: Hubbs-SeaWorld Research Institute’s procurement policy was not in alignment with the procurement compliance requirements stated in 2 CFR 200.303. Effect: Hubbs-SeaWorld Research Institute did not document and maintain records for the procurement of goods and services resulting in noncompliance with the procurement compliance requirements stated in 2 CFR 200.303 during the year ending June 30, 2024. Recommendation: Hubbs-SeaWorld Research Institute should improve its policies and procedures regarding the procurement process and maintain documentation. Management Response: The management staff of Hubbs-SeaWorld Research Institute take very seriously the federal compliance related to the procurement of goods and services. Hubbs-SeaWorld Research Institute acknowledges the finding and has subsequently updated their procurement policy and procedures to be in compliance with 2 CFR 200.303. Management has adopted a plan of action to prevent future instances of non-compliance.

Condition: During our testing we noted that for 2 out of 3 vendors selected for procurement testing there was no documentation to demonstrate that procurement was conducted in full and open competition according to 2CFR section 200.319 or any documentation of the rationale to limit competition in those cases where competition was limited and ascertain if the limitation was justified per 2CFR sections 200.319 and 200.320(f) and 48 CFR section 52.244-5. Criteria: 2 CFR 200.303 requires non-federal entities to, among other things, establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Effective internal controls should include procedures to ensure procurement files are complete and adequately document decisions made to sole source procurements of goods and services in accordance with the Institute’s procurement policies. Cause: Hubbs-SeaWorld Research Institute’s procurement policy was not in alignment with the procurement compliance requirements stated in 2 CFR 200.303. Effect: Hubbs-SeaWorld Research Institute did not document and maintain records for the procurement of goods and services resulting in noncompliance with the procurement compliance requirements stated in 2 CFR 200.303 during the year ending June 30, 2024. Recommendation: Hubbs-SeaWorld Research Institute should improve its policies and procedures regarding the procurement process and maintain documentation. Management Response: The management staff of Hubbs-SeaWorld Research Institute take very seriously the federal compliance related to the procurement of goods and services. Hubbs-SeaWorld Research Institute acknowledges the finding and has subsequently updated their procurement policy and procedures to be in compliance with 2 CFR 200.303. Management has adopted a plan of action to prevent future instances of non-compliance.

Condition: During our testing we noted that for 2 out of 3 vendors selected for procurement testing there was no documentation to demonstrate that procurement was conducted in full and open competition according to 2CFR section 200.319 or any documentation of the rationale to limit competition in those cases where competition was limited and ascertain if the limitation was justified per 2CFR sections 200.319 and 200.320(f) and 48 CFR section 52.244-5. Criteria: 2 CFR 200.303 requires non-federal entities to, among other things, establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Effective internal controls should include procedures to ensure procurement files are complete and adequately document decisions made to sole source procurements of goods and services in accordance with the Institute’s procurement policies. Cause: Hubbs-SeaWorld Research Institute’s procurement policy was not in alignment with the procurement compliance requirements stated in 2 CFR 200.303. Effect: Hubbs-SeaWorld Research Institute did not document and maintain records for the procurement of goods and services resulting in noncompliance with the procurement compliance requirements stated in 2 CFR 200.303 during the year ending June 30, 2024. Recommendation: Hubbs-SeaWorld Research Institute should improve its policies and procedures regarding the procurement process and maintain documentation. Management Response: The management staff of Hubbs-SeaWorld Research Institute take very seriously the federal compliance related to the procurement of goods and services. Hubbs-SeaWorld Research Institute acknowledges the finding and has subsequently updated their procurement policy and procedures to be in compliance with 2 CFR 200.303. Management has adopted a plan of action to prevent future instances of non-compliance.

Condition: During our testing we noted that for 2 out of 3 vendors selected for procurement testing there was no documentation to demonstrate that procurement was conducted in full and open competition according to 2CFR section 200.319 or any documentation of the rationale to limit competition in those cases where competition was limited and ascertain if the limitation was justified per 2CFR sections 200.319 and 200.320(f) and 48 CFR section 52.244-5. Criteria: 2 CFR 200.303 requires non-federal entities to, among other things, establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Effective internal controls should include procedures to ensure procurement files are complete and adequately document decisions made to sole source procurements of goods and services in accordance with the Institute’s procurement policies. Cause: Hubbs-SeaWorld Research Institute’s procurement policy was not in alignment with the procurement compliance requirements stated in 2 CFR 200.303. Effect: Hubbs-SeaWorld Research Institute did not document and maintain records for the procurement of goods and services resulting in noncompliance with the procurement compliance requirements stated in 2 CFR 200.303 during the year ending June 30, 2024. Recommendation: Hubbs-SeaWorld Research Institute should improve its policies and procedures regarding the procurement process and maintain documentation. Management Response: The management staff of Hubbs-SeaWorld Research Institute take very seriously the federal compliance related to the procurement of goods and services. Hubbs-SeaWorld Research Institute acknowledges the finding and has subsequently updated their procurement policy and procedures to be in compliance with 2 CFR 200.303. Management has adopted a plan of action to prevent future instances of non-compliance.

Condition: During our testing we noted that for 2 out of 3 vendors selected for procurement testing there was no documentation to demonstrate that procurement was conducted in full and open competition according to 2CFR section 200.319 or any documentation of the rationale to limit competition in those cases where competition was limited and ascertain if the limitation was justified per 2CFR sections 200.319 and 200.320(f) and 48 CFR section 52.244-5. Criteria: 2 CFR 200.303 requires non-federal entities to, among other things, establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Effective internal controls should include procedures to ensure procurement files are complete and adequately document decisions made to sole source procurements of goods and services in accordance with the Institute’s procurement policies. Cause: Hubbs-SeaWorld Research Institute’s procurement policy was not in alignment with the procurement compliance requirements stated in 2 CFR 200.303. Effect: Hubbs-SeaWorld Research Institute did not document and maintain records for the procurement of goods and services resulting in noncompliance with the procurement compliance requirements stated in 2 CFR 200.303 during the year ending June 30, 2024. Recommendation: Hubbs-SeaWorld Research Institute should improve its policies and procedures regarding the procurement process and maintain documentation. Management Response: The management staff of Hubbs-SeaWorld Research Institute take very seriously the federal compliance related to the procurement of goods and services. Hubbs-SeaWorld Research Institute acknowledges the finding and has subsequently updated their procurement policy and procedures to be in compliance with 2 CFR 200.303. Management has adopted a plan of action to prevent future instances of non-compliance.

2024 – 001: Improper Payroll Calculation Federal Agency: U.S. Department of Energy Federal Program Name: Research & Development Cluster Assistance Listing Number: 81.049 Federal Award Identification Number: DE-SC0023385 Award Period: July 1, 2023 – June 30, 2024 Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or specific requirement: Internal Control – Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Compliance – Per 2 CFR § 200.403, except where otherwise authorized by statute, costs must meet the following general criteria to be allowable under Federal awards: (a) Be necessary and reasonable for the performance of the Federal award to be allocable thereto under these principles. (b) Conform to any limitations or exclusions set forth in these principles or in the Federal award regarding types or amount of cost items. (c) Be consistent with policies and procedures that apply uniformly to both federally‐financed and other activities of the non‐Federal entity. (d) Be accorded consistent treatment. A cost may not be assigned to a Federal award as a direct cost if any other cost incurred for the same purpose in like circumstances has been allocated to the Federal award as an indirect cost. (e) Be determined in accordance with generally accepted accounting principles (GAAP), except for state and local governments and Indian tribes only, as otherwise provided for in this part. (f) Not be included as a cost or used to meet cost sharing or matching requirements of any other federally‐financed program in either the current or a prior period. (g) Be adequately documented. Condition: The University incorrectly calculated payroll costs charged to the grant after an employee was double paid for the same work hours. Questioned costs: $400. Context: This condition occurred for 1 out of 40 payroll costs selected for testing resulting in $400 being incorrectly charged to the program. Cause: An employee failed to accurately enter time worked into the university timekeeping system for the pay period 5/1/24 – 5/15/24. The employee reported the hours to their department contact on 5/29/24, which was after the pay period had closed and paychecks had already been processed. The department liaison contacted Kronos Support to have the hours added to the timecard retroactively. Kronos Support received confirmation from the employee that the missed hours could be added to the paycheck for 6/14/24.   During payroll processing for 6/14/24, Kronos Support added the missed hours to the employee’s payline on 6/5/24. The department liaison also submitted a CU Special Pay for the same missed hours on 6/5/24. Due to the timing of each separate transaction, Kronos Support did not have visibility into the duplication of the hours. The department failed to identify the duplication during its review of payroll reports. Effect: Expenditures may be incorrectly charged to the program. Repeat Finding: No Recommendation: We recommend that the institution strengthen its internal controls to ensure that expenditures are reviewed and adjusted for, if necessary, in a timely manner. Views of responsible officials: Management acknowledges the finding.

2024 – 002: Subrecipient Monitoring Federal Agency: U.S. Department of Health and Human Services Federal Program Name: Public Health Emergency Response: Cooperative Agreement for Emergency Response: Public Health Crisis response Assistance Listing Number: 93.354 Federal Award Identification Number: NU90TP922168, NU90TP921992 Pass-Through Agency: South Carolina Department of Health and Environmental Control Pass-Through Numbers: PH-2-533, CY-19-018 Award Period: July 1, 2023 – June 30, 2024 Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or specific requirement: Internal Control – Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Compliance - Per 2 CFR section 200.332(a), the subaward is to clearly identify to the subrecipient required information, including identification of whether the award is R&D. Condition: The University incorrectly documented the subaward as a Research and Development grant to the subrecipient. Questioned costs: None Context: This condition occurred for 5 out of 5 subawards selected for testing. Cause: Attachment 2 of the Federal Awards Terms and Conditions template of the FDP Cost Reimbursement Subaward includes a field that is pre-selected and defaults to the R&D selection, requiring the field to be unchecked for the subawards that are not classified as R&D. Effect: The subrecipient may not be aware of certain award information in order to comply with federal statutes, regulations, and the terms and conditions of the award and properly classify its schedule of expenditures of federal awards. Repeat Finding: No Recommendation: We recommend the University strengthen its internal controls to ensure that subawards report the correct information. Views of responsible officials: Management acknowledges the finding.

2024 – 002: Subrecipient Monitoring Federal Agency: U.S. Department of Health and Human Services Federal Program Name: Public Health Emergency Response: Cooperative Agreement for Emergency Response: Public Health Crisis response Assistance Listing Number: 93.354 Federal Award Identification Number: NU90TP922168, NU90TP921992 Pass-Through Agency: South Carolina Department of Health and Environmental Control Pass-Through Numbers: PH-2-533, CY-19-018 Award Period: July 1, 2023 – June 30, 2024 Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or specific requirement: Internal Control – Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Compliance - Per 2 CFR section 200.332(a), the subaward is to clearly identify to the subrecipient required information, including identification of whether the award is R&D. Condition: The University incorrectly documented the subaward as a Research and Development grant to the subrecipient. Questioned costs: None Context: This condition occurred for 5 out of 5 subawards selected for testing. Cause: Attachment 2 of the Federal Awards Terms and Conditions template of the FDP Cost Reimbursement Subaward includes a field that is pre-selected and defaults to the R&D selection, requiring the field to be unchecked for the subawards that are not classified as R&D. Effect: The subrecipient may not be aware of certain award information in order to comply with federal statutes, regulations, and the terms and conditions of the award and properly classify its schedule of expenditures of federal awards. Repeat Finding: No Recommendation: We recommend the University strengthen its internal controls to ensure that subawards report the correct information. Views of responsible officials: Management acknowledges the finding.

Criteria or Specific Requirement: The amount of a student's Pell Grant for an academic year is based upon the payment and disbursement schedules published by the Secretary for each award year (34 CFR 690.62) The Code of Federal Regulations (34 CFR 690.80(b)(1)) states if the student’s enrollment status changes from one academic term to another within the same award year, the institution shall recalculate the Federal Pell Grant award for the new payment period taking into account any changes in the cost of attendance. Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Effective internal controls should include procedures to ensure students are awarded and disbursed the proper federal fund amounts. Condition: The College under-awarded funds for the Pell Grant. Questioned Costs: None. Context: During our testing we noted one of forty students, from a statistically valid sample, were disbursed awarded and disbursed less Pell funds than should have been awarded based on the 23-24 Pell payment schedule. The Pell payment schedule considers the cost of attendance, the student's Expected Family Contribution and the enrollment status of the student. Cause: The College did not award the correct amount of the Pell grant due to the lack of a manual adjustment that was needed for this instance. Effect: Failure to properly determine and disburse Title IV funds based on eligibility for each type of aid in accordance with federal regulations may result in students receiving incorrect funds. Repeat Finding: No. Recommendation: We recommend the College review its current procedures for awarding Title IV funds and implement any changes necessary to ensure federal funds are awarded and disbursed in accordance with federal regulations. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding and has developed a plan to correct it.

Federal Agency: U.S. Department of Education; Federal Program Name: Student Financial Assistance Cluster; Assistance Listing Number: 84.268 – Federal Direct Loans; 84.063 – Federal Pell Grant Program; 84.007 – Federal Supplemental Educational Opportunity Grants; Federal Award Identification Number and Year: 2023-2024 – P268K240101, P063P230101, P007A231093; Award Period: July 1, 2023 to June 30, 2024. Type of finding: Significant Deficiency in Internal Control Over Compliance and Other Matters. Criteria or specific requirement: 2 CFR part 200 section 200.303 requires that non-Federal entities receiving federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the federal award. The Code of federal Regulations, 34 CFR 688.164, requires any Title IV federal funds disbursed to a student or parent that are not received or negotiated must be returned to the appropriated federal financial aid program no later than 240 days after the check or electronic fund transfer (EFT) was issued. If a check or an EFT is returned, the University may make additional attempts to deliver the funds, provided that those attempts are made no later than 45 days after the funds were returned or rejected. In case where the University does not make another attempt, the funds must be returned before the end of the initial 45-day period. The University must cease all attempts to disburse the funds and return them no later than 240 days after the date it issued the first check. Under no circumstances may unclaimed Title IV FSA funds escheat to the state, or revert to the University, or any other third party. Condition: The University does not have a control or process in place that would specifically monitor outstanding checks to students for Title IV federal funded checks so that the University would be able to timely return the money prior to 240 days after issuance of the check. Questioned costs: Unknown. Context: During our testing, it was noted the University did not have a control in place to identify the outstanding Title IV federal funded checks that were old and needed to be returned to the U.S. Department of Education prior to 240 days after issuance. In the current year testing of outstanding checks, we did not note any exceptions. However, we did note that checks over the 240 days from the prior year were returned at various times during the year with all checks being cleared by year end. Cause: The University did not have a process in place to specifically monitor the federal checks throughout the year. For some of the prior year checks returned late during the year, the University had to wait until the prior award years were re-opened in order to return them. Effect: The University is not in compliance with Department of Education requirements. Repeat finding: Yes, 2023-001. Recommendation: CliftonLarsonAllen LLP (CLA) recommends the University review the requirement and implement an internal process and control to specifically monitor the outstanding Title IV funded checks throughout the year. Views of responsible officials: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Education; Federal Program Name: Student Financial Assistance Cluster; Assistance Listing Number: 84.268 – Federal Direct Loans, 84.063 – Federal Pell Grant Program, 84.007 – Federal Supplemental Educational Opportunity Grants, 84.033 – Federal Work Study Program; Federal Award Identification Number and Year: 2023-2024 – P268K240101, P063P230101, P007A231093, P033A231093; Award Period: July 1, 2023 to June 30, 2024. Type of finding: Significant Deficiency in Internal Control Over Compliance and Other Matters. Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless of if they receive aid from the institution or not. This includes the enrollment effective date and related enrollment status, which must be reported for both the Campus-Level and the Program-Level, as well as the program begin date. Changes to said status are required to be reported within 30 days of becoming aware of the status change, or with the next scheduled transmission of statuses if the scheduled transmission is within 60 days. In addition, Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving federal awards establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Condition: There were instances in which the University did not report the correct status and effective dates, and status changes were not always reported timely. Questioned costs: None. Context: In our statistically valid sample of sixty students selected for National Student Loan Data System (NSLDS) enrollment reporting testing, we identified one student whose change in enrollment status was not properly updated and the enrollment effective date was not reported correctly or timely. We identified one student in which the program enrollment effective date did not match the University’s records. We noted one student whose program enrollment status was not uploaded to reflect the University’s records. Cause: University of Idaho did not have proper procedures in place to verify students’ status in NSLDS matched the institutions records in a timely manner. Effect: Failure to properly report enrollment status changes on NSLDS could affect the timing of the grace period for repayment of Title IV loans. Additionally, the University was not in compliance with the requirements to properly report student enrollment data correctly or timely to NSLDS. Repeat finding: Yes, 2023-002. Recommendation: We recommend the University work with their third-party servicer and implement procedures to ensure that enrollment data, changes in status and effective dates within NSLDS are reported timely and accurately. Views of responsible officials: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Education; Federal Program Name: Student Financial Assistance Cluster; Assistance Listing Number: 84.007 – Federal Supplemental Educational Opportunity Grants; Federal Award Identification Number and Year: 2023-2024 – P007A231093; Award Period: July 1, 2023 to June 30, 2024. Type of Finding: Significant Deficiency in Internal Control Over Compliance and Other matters. Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 676.10(a)(1) and (2) states “In selecting among eligible students for FSEOG awards in each award year, an institution shall select those students with the lowest expected family contributions who will also receive Federal Pell Grants in that year. If the institution has FSEOG funds remaining after giving FSEOG awards to all the Federal Pell Grant recipients at the institution, the institution shall award the remaining FSEOG funds to those eligible students with the lowest expected family contributions who will not receive Federal Pell Grants.” In addition, Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving federal awards establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Condition: The University awarded FSEOG to students with EFC’s higher than zero (the lowest expected family contribution) when there were students with the zero EFCs who did not receive FSEOG and were eligible to receive FSEOG. Questioned costs: $800. Context: In our sample of 13 FSEOG recipients two were identified that had an EFC higher than zero. Both were within the University's policy to award eligible students with EFCs in the 0-3500 range who meet the priority deadline. In our eligibility sample of 40, we identified 2 Pell recipients with a zero EFC and remaining need that were not awarded FSEOG funds. Cause: The University's policy is to award FSEOG to PELL recipients who have met the FAFSA priority deadline and have an EFC below 3,500. The University policy for awarding FSEOG funds was not capturing all students who had the lowest EFC and remaining need. Effect: The University is not in compliance with the FSEOG awarding guidelines. Repeat finding: Yes, 2023-004. Recommendation: We recommend that the University review their FSEOG awarding policy and procedures to ensure FSEOG is awarded to students with the lowest expected family contributions. Views of responsible officials: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Education; Federal Program Name: Student Financial Assistance Cluster; Assistance Listing Number: 84.268 – Federal Direct Loans, 84.063 – Federal Pell Grant Program, 84.007 – Federal Supplemental Educational Opportunity Grants, 84.033 – Federal Work Study Program; Federal Award Identification Number and Year: 2023-2024 – P268K240101, P063P230101, P007A231093, P033A231093; Award Period: July 1, 2023 to June 30, 2024. Type of finding: Significant Deficiency in Internal Control Over Compliance and Other Matters. Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless of if they receive aid from the institution or not. This includes the enrollment effective date and related enrollment status, which must be reported for both the Campus-Level and the Program-Level, as well as the program begin date. Changes to said status are required to be reported within 30 days of becoming aware of the status change, or with the next scheduled transmission of statuses if the scheduled transmission is within 60 days. In addition, Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving federal awards establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Condition: There were instances in which the University did not report the correct status and effective dates, and status changes were not always reported timely. Questioned costs: None. Context: In our statistically valid sample of sixty students selected for National Student Loan Data System (NSLDS) enrollment reporting testing, we identified one student whose change in enrollment status was not properly updated and the enrollment effective date was not reported correctly or timely. We identified one student in which the program enrollment effective date did not match the University’s records. We noted one student whose program enrollment status was not uploaded to reflect the University’s records. Cause: University of Idaho did not have proper procedures in place to verify students’ status in NSLDS matched the institutions records in a timely manner. Effect: Failure to properly report enrollment status changes on NSLDS could affect the timing of the grace period for repayment of Title IV loans. Additionally, the University was not in compliance with the requirements to properly report student enrollment data correctly or timely to NSLDS. Repeat finding: Yes, 2023-002. Recommendation: We recommend the University work with their third-party servicer and implement procedures to ensure that enrollment data, changes in status and effective dates within NSLDS are reported timely and accurately. Views of responsible officials: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Education; Federal Program Name: Student Financial Assistance Cluster; Assistance Listing Number: 84.268 – Federal Direct Loans; 84.063 – Federal Pell Grant Program; 84.007 – Federal Supplemental Educational Opportunity Grants; Federal Award Identification Number and Year: 2023-2024 – P268K240101, P063P230101, P007A231093; Award Period: July 1, 2023 to June 30, 2024. Type of finding: Significant Deficiency in Internal Control Over Compliance and Other Matters. Criteria or specific requirement: 2 CFR part 200 section 200.303 requires that non-Federal entities receiving federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the federal award. The Code of federal Regulations, 34 CFR 688.164, requires any Title IV federal funds disbursed to a student or parent that are not received or negotiated must be returned to the appropriated federal financial aid program no later than 240 days after the check or electronic fund transfer (EFT) was issued. If a check or an EFT is returned, the University may make additional attempts to deliver the funds, provided that those attempts are made no later than 45 days after the funds were returned or rejected. In case where the University does not make another attempt, the funds must be returned before the end of the initial 45-day period. The University must cease all attempts to disburse the funds and return them no later than 240 days after the date it issued the first check. Under no circumstances may unclaimed Title IV FSA funds escheat to the state, or revert to the University, or any other third party. Condition: The University does not have a control or process in place that would specifically monitor outstanding checks to students for Title IV federal funded checks so that the University would be able to timely return the money prior to 240 days after issuance of the check. Questioned costs: Unknown. Context: During our testing, it was noted the University did not have a control in place to identify the outstanding Title IV federal funded checks that were old and needed to be returned to the U.S. Department of Education prior to 240 days after issuance. In the current year testing of outstanding checks, we did not note any exceptions. However, we did note that checks over the 240 days from the prior year were returned at various times during the year with all checks being cleared by year end. Cause: The University did not have a process in place to specifically monitor the federal checks throughout the year. For some of the prior year checks returned late during the year, the University had to wait until the prior award years were re-opened in order to return them. Effect: The University is not in compliance with Department of Education requirements. Repeat finding: Yes, 2023-001. Recommendation: CliftonLarsonAllen LLP (CLA) recommends the University review the requirement and implement an internal process and control to specifically monitor the outstanding Title IV funded checks throughout the year. Views of responsible officials: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Education; Federal Program Name: Student Financial Assistance Cluster; Assistance Listing Number: 84.268 – Federal Direct Loans, 84.063 – Federal Pell Grant Program, 84.007 – Federal Supplemental Educational Opportunity Grants, 84.033 – Federal Work Study Program; Federal Award Identification Number and Year: 2023-2024 – P268K240101, P063P230101, P007A231093, P033A231093; Award Period: July 1, 2023 to June 30, 2024. Type of finding: Significant Deficiency in Internal Control Over Compliance and Other Matters. Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless of if they receive aid from the institution or not. This includes the enrollment effective date and related enrollment status, which must be reported for both the Campus-Level and the Program-Level, as well as the program begin date. Changes to said status are required to be reported within 30 days of becoming aware of the status change, or with the next scheduled transmission of statuses if the scheduled transmission is within 60 days. In addition, Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving federal awards establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Condition: There were instances in which the University did not report the correct status and effective dates, and status changes were not always reported timely. Questioned costs: None. Context: In our statistically valid sample of sixty students selected for National Student Loan Data System (NSLDS) enrollment reporting testing, we identified one student whose change in enrollment status was not properly updated and the enrollment effective date was not reported correctly or timely. We identified one student in which the program enrollment effective date did not match the University’s records. We noted one student whose program enrollment status was not uploaded to reflect the University’s records. Cause: University of Idaho did not have proper procedures in place to verify students’ status in NSLDS matched the institutions records in a timely manner. Effect: Failure to properly report enrollment status changes on NSLDS could affect the timing of the grace period for repayment of Title IV loans. Additionally, the University was not in compliance with the requirements to properly report student enrollment data correctly or timely to NSLDS. Repeat finding: Yes, 2023-002. Recommendation: We recommend the University work with their third-party servicer and implement procedures to ensure that enrollment data, changes in status and effective dates within NSLDS are reported timely and accurately. Views of responsible officials: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Education; Federal Program Name: Student Financial Assistance Cluster; Assistance Listing Number: 84.268 – Federal Direct Loans 84.063 – Federal Pell Grant Program; Federal Award Identification Number and Year: 2023-2024 -- P268K240101, P063P230101; Award Period: July 1, 2023 to June 30, 2024. Type of Finding: Significant Deficiency in Internal Control Over Compliance and Other Matters. Criteria or specific requirement: The Department of Education requires the College to report the disbursement dates and amounts to the Common Origination and Disbursement (COD) system within 15 days of disbursing Pell (34 CFR 690.83(b)(2) and Direct Loan (34 CFR 685.309) funds to a student. In addition, per the Uniform Guidance 2 CRF 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonable ensure compliance with federal laws, regulations, and program compliance requirements. Condition: The University did not report COD disbursements within the required 15 days reporting requirement. Questioned costs: None. Context: During our testing of COD reporting, we identified two of 40 disbursements were not reported to COD within 15 days of the disbursement date. Cause: The University did not have proper procedures in place to identify COD reporting errors and fix them within a timely manner. Effect: A lack of timely reporting may prevent the University and other schools from having the most accurate student information which may lead to over awards. Repeat finding: No. Recommendation: We recommend that the University evaluate and enhance its procedures and policies around reporting disbursements to COD to ensure that student information is reported accurately and timely. Views of responsible officials: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Education; Federal Program Name: Student Financial Assistance Cluster; Assistance Listing Number: 84.268 – Federal Direct Loans; 84.063 – Federal Pell Grant Program; 84.007 – Federal Supplemental Educational Opportunity Grants; Federal Award Identification Number and Year: 2023-2024 – P268K240101, P063P230101, P007A231093; Award Period: July 1, 2023 to June 30, 2024. Type of finding: Significant Deficiency in Internal Control Over Compliance and Other Matters. Criteria or specific requirement: 2 CFR part 200 section 200.303 requires that non-Federal entities receiving federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the federal award. The Code of federal Regulations, 34 CFR 688.164, requires any Title IV federal funds disbursed to a student or parent that are not received or negotiated must be returned to the appropriated federal financial aid program no later than 240 days after the check or electronic fund transfer (EFT) was issued. If a check or an EFT is returned, the University may make additional attempts to deliver the funds, provided that those attempts are made no later than 45 days after the funds were returned or rejected. In case where the University does not make another attempt, the funds must be returned before the end of the initial 45-day period. The University must cease all attempts to disburse the funds and return them no later than 240 days after the date it issued the first check. Under no circumstances may unclaimed Title IV FSA funds escheat to the state, or revert to the University, or any other third party. Condition: The University does not have a control or process in place that would specifically monitor outstanding checks to students for Title IV federal funded checks so that the University would be able to timely return the money prior to 240 days after issuance of the check. Questioned costs: Unknown. Context: During our testing, it was noted the University did not have a control in place to identify the outstanding Title IV federal funded checks that were old and needed to be returned to the U.S. Department of Education prior to 240 days after issuance. In the current year testing of outstanding checks, we did not note any exceptions. However, we did note that checks over the 240 days from the prior year were returned at various times during the year with all checks being cleared by year end. Cause: The University did not have a process in place to specifically monitor the federal checks throughout the year. For some of the prior year checks returned late during the year, the University had to wait until the prior award years were re-opened in order to return them. Effect: The University is not in compliance with Department of Education requirements. Repeat finding: Yes, 2023-001. Recommendation: CliftonLarsonAllen LLP (CLA) recommends the University review the requirement and implement an internal process and control to specifically monitor the outstanding Title IV funded checks throughout the year. Views of responsible officials: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Education; Federal Program Name: Student Financial Assistance Cluster; Assistance Listing Number: 84.268 – Federal Direct Loans, 84.063 – Federal Pell Grant Program, 84.007 – Federal Supplemental Educational Opportunity Grants, 84.033 – Federal Work Study Program; Federal Award Identification Number and Year: 2023-2024 – P268K240101, P063P230101, P007A231093, P033A231093; Award Period: July 1, 2023 to June 30, 2024. Type of finding: Significant Deficiency in Internal Control Over Compliance and Other Matters. Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless of if they receive aid from the institution or not. This includes the enrollment effective date and related enrollment status, which must be reported for both the Campus-Level and the Program-Level, as well as the program begin date. Changes to said status are required to be reported within 30 days of becoming aware of the status change, or with the next scheduled transmission of statuses if the scheduled transmission is within 60 days. In addition, Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving federal awards establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Condition: There were instances in which the University did not report the correct status and effective dates, and status changes were not always reported timely. Questioned costs: None. Context: In our statistically valid sample of sixty students selected for National Student Loan Data System (NSLDS) enrollment reporting testing, we identified one student whose change in enrollment status was not properly updated and the enrollment effective date was not reported correctly or timely. We identified one student in which the program enrollment effective date did not match the University’s records. We noted one student whose program enrollment status was not uploaded to reflect the University’s records. Cause: University of Idaho did not have proper procedures in place to verify students’ status in NSLDS matched the institutions records in a timely manner. Effect: Failure to properly report enrollment status changes on NSLDS could affect the timing of the grace period for repayment of Title IV loans. Additionally, the University was not in compliance with the requirements to properly report student enrollment data correctly or timely to NSLDS. Repeat finding: Yes, 2023-002. Recommendation: We recommend the University work with their third-party servicer and implement procedures to ensure that enrollment data, changes in status and effective dates within NSLDS are reported timely and accurately. Views of responsible officials: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Education; Federal Program Name: Student Financial Assistance Cluster; Assistance Listing Number: 84.268 – Federal Direct Loans 84.063 – Federal Pell Grant Program; Federal Award Identification Number and Year: 2023-2024 -- P268K240101, P063P230101; Award Period: July 1, 2023 to June 30, 2024. Type of Finding: Significant Deficiency in Internal Control Over Compliance and Other Matters. Criteria or specific requirement: The Department of Education requires the College to report the disbursement dates and amounts to the Common Origination and Disbursement (COD) system within 15 days of disbursing Pell (34 CFR 690.83(b)(2) and Direct Loan (34 CFR 685.309) funds to a student. In addition, per the Uniform Guidance 2 CRF 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonable ensure compliance with federal laws, regulations, and program compliance requirements. Condition: The University did not report COD disbursements within the required 15 days reporting requirement. Questioned costs: None. Context: During our testing of COD reporting, we identified two of 40 disbursements were not reported to COD within 15 days of the disbursement date. Cause: The University did not have proper procedures in place to identify COD reporting errors and fix them within a timely manner. Effect: A lack of timely reporting may prevent the University and other schools from having the most accurate student information which may lead to over awards. Repeat finding: No. Recommendation: We recommend that the University evaluate and enhance its procedures and policies around reporting disbursements to COD to ensure that student information is reported accurately and timely. Views of responsible officials: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Education; Federal Program Name: Student Financial Assistance Cluster; Assistance Listing Number: 84.268 – Federal Direct Loans; Federal Award Identification Number and Year: P268K240101 – 2024; Award Period: July 1, 2023 to June 30, 2024. Type of Finding: Significant Deficiency in Internal Control Over Compliance and Other Matters. Criteria or specific requirement: The institution must notify the student, or parent, in writing of (1) the date and amount of the disbursement; (2) the student’s right, or parent’s right, to cancel all or a portion of that loan or loan disbursement and have the loan proceeds returned to the holder of that loan or the TEACH Grant payments returned to ED; and (3) the procedure and time by which the student or parent must notify the institution that he or she wishes to cancel the loan, TEACH Grant, or TEACH Grant disbursement. The notification requirement for loan funds applies only if the funds are disbursed by EFT payment or master check (34 CFR 668.165). In addition, per the Uniform Guidance 2 CRF 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonable ensure compliance with federal laws, regulations, and program compliance requirements. Condition: During our testing of loan disbursements, we identified instances in which students did not receive notification of their loan disbursement. Questioned costs: None. Context: In our testing of loan disbursements, we identified 23 out of 40 students tested did not receive notification of their loan disbursement. Students were only notified if there was a change to their loan award and were not notified of loan disbursements. Cause: The University did not have proper procedures in place to ensure all students were notified of their loan disbursements. Effect: The University was not in compliance with the requirement to provide notification to a student when their loan disbursement is made. Repeat finding: No. Recommendation: We recommend the University evaluate the procedures around disbursements of loans and ensure that notifications of disbursements are sent and contain all the required elements outlined in the FSA Handbook. Views of responsible officials: There is no disagreement with the audit finding.

Federal agency: U.S. Department of Agriculture; Federal Program Name: Partnerships for Climate-Smart Commodities; Assistance Listing Number: 10.937; Federal Award Identification Number and Year: 2023-2024 – NR233A750004G038; Award Period: July 1, 2023 to June 30, 2024. Type of Finding: Significant Deficiency in Internal Control Over Compliance. Criteria or specific requirement: Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving federal awards establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Condition: The University did not have observable controls to test over the Federal Funding. Accountability and Transparency Act (FFATA) reporting process. Questioned costs: None. Context: During our testing of the 3 FFATA reports submitted by the University during the year ended June 30, 2024, we noted there was no documentation of the University’s review process of the FFATA reports. Cause: The procedures the University had over the review of the FFATA reports did not include documentation of the control over reporting. Effect: It is possible that errors could occur and not be caught in a timely manner. Repeat finding: No. Recommendation: We recommend the University revise their procedures to include documentation of the review over FFATA reporting. The documentation should include the date of the review and the individual(s) performing the review. Views of responsible officials and planned corrective action: Management agrees they were not able to provide evidence of the review of the FFATA report.

2024 – 001: Special Tests and Provisions – NSLDS Enrollment Reporting Federal Agency: U.S. Department of Education Federal Program Name: Student Financial Aid Cluster Assistance Listing Number: 84.063, 84.268 Federal Award Identification Number: P063P231544, P268K241544 Award Period: July 1, 2023 – June 30, 2024 Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or specific requirement: Internal Control – Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Compliance – The Code of Federal Regulations, 34 CFR 685.309(b), states that: Institutions must have some arrangement to report student enrollment data to NSLDS through an enrollment roster file. The institution is required to report changes in the enrollment status, the effective date of the status, and an anticipated completion date. Also, the Code of Federal Regulations, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless if they receive aid from the institution or not. Condition: During testing of the enrollment status reporting, we noted that the incorrect enrollment status and effective date was reported in NSLDS. Questioned costs: None Context: The enrollment data was incorrectly reported for 1 out of 60 students. Cause: The student’s enrollment status update was delayed due to the sequence of file submissions by the college. Although the college transmitted accurate information with each Spring 2024 enrollment file, the initial sequencing of the Fall 2023 graduation file led to a delay in updating the student’s enrollment status and effective date in NSLDS until Fall 2024. Effect: Student enrollment status was not reported accurately in NSLDS. Repeat Finding: No Recommendation: The institution should evaluate their procedures and policies related to reporting status changes and effective dates to NSLDS and enhance as deemed necessary to ensure that accurate information is reported to NSLDS. Views of responsible officials: There is no disagreement with the audit finding.

2024 – 001: Special Tests and Provisions – NSLDS Enrollment Reporting Federal Agency: U.S. Department of Education Federal Program Name: Student Financial Aid Cluster Assistance Listing Number: 84.063, 84.268 Federal Award Identification Number: P063P231544, P268K241544 Award Period: July 1, 2023 – June 30, 2024 Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or specific requirement: Internal Control – Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Compliance – The Code of Federal Regulations, 34 CFR 685.309(b), states that: Institutions must have some arrangement to report student enrollment data to NSLDS through an enrollment roster file. The institution is required to report changes in the enrollment status, the effective date of the status, and an anticipated completion date. Also, the Code of Federal Regulations, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless if they receive aid from the institution or not. Condition: During testing of the enrollment status reporting, we noted that the incorrect enrollment status and effective date was reported in NSLDS. Questioned costs: None Context: The enrollment data was incorrectly reported for 1 out of 60 students. Cause: The student’s enrollment status update was delayed due to the sequence of file submissions by the college. Although the college transmitted accurate information with each Spring 2024 enrollment file, the initial sequencing of the Fall 2023 graduation file led to a delay in updating the student’s enrollment status and effective date in NSLDS until Fall 2024. Effect: Student enrollment status was not reported accurately in NSLDS. Repeat Finding: No Recommendation: The institution should evaluate their procedures and policies related to reporting status changes and effective dates to NSLDS and enhance as deemed necessary to ensure that accurate information is reported to NSLDS. Views of responsible officials: There is no disagreement with the audit finding.

Type of Finding – Significant Deficiency in Internal Control Over Compliance. Condition/Context – Internal control procedures over eligible disbursements did not ensure compliance with federal awards. An employee reimbursement was billed twice, and employee bonuses, which are not allowable costs, were included within the reimbursement request. Criteria – In accordance with the Compliance Supplement Part 6 - Internal Control, 2 CFR section 200.303 requires that nonfederal entities receiving federal awards establish and maintain internal control over the federal awards that provides reasonable assurance that the nonfederal entity is managing the federal awards in compliance with federal statutes, regulations, and the terms and conditions of the federal awards. Cause – Clerical oversight. Effect – Noncompliance with the Compliance Supplement and Uniform Guidance. Repeat Finding – No Questioned Costs - $12,177 Recommendation – We would recommend management to review and to ensure that expenditures being requested for reimbursement are for allowable costs. View of Responsible Officials – There is no disagreement with the audit findings.

Department of Health and Human Services Federal Financial Assistance Listing #93.332 Cooperative Agreement to Support Navigators in Federally-facilitated Exchanges Reporting Significant Deficiency in Internal Control over Compliance Criteria - 2 CFR 200.303(a) establishes that the auditee must establish and maintain effective internal control over the federal award that provides assurance that the entity is managing the federal award in compliance with federal statutes, regulations, and conditions of the federal award. Condition – There was no evidence retained that the Medical Center’s compliance and financial reports submitted to the Department of Health and Human Services were reviewed and approved prior to submission. Cause - The Medical Center did have an internal control policy in place to ensure documented review and approval of the compliance and financial reports was documented; however, this was not followed consistently throughout the year. Effect - The lack of adequate policies governing review and approval increases the risk that employees participating in the federal awards administration may not be able to detect and correct noncompliance in a timely manner. Questioned Costs - None Reported. Context/Sampling - A nonstatistical sample of 10 out of 69 reports were selected for detail testing and 5 did not include evidence of a review by someone other than the preparer. Repeat Finding from Prior Year(s) – Yes, 2022-002 Recommendation - We recommend the Medical Center follow its internal control policies to ensure that formal documentation of review and approval is obtained and retained. Views of Responsible Officials – Management agrees with the finding.

Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Assistance Cluster Assistance Listing Number: 84.063 & 84.268 Federal Award Identification Number and Year: P063P230097 & P268K240097 Award Period: July 1, 2023 to June 30, 2024 Type of Finding: 􀁸 Other Matters 􀁸 Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: Institutions are required to report enrollment information under the Pell grant and the Direct Loan programs via the National Student Loan Data System (NSLDS) (OMB No. 1845-0035) (Pell, 34 CFR 690.83(b)(2); Direct Loan, 34 CFR 685.309.) The administration of the Title IV programs depends heavily on the accuracy and timeliness of the enrollment information reported by institutions. Institutions must review, update, and certify student enrollment statuses, program information, and effective dates that appear on the Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS Professional Access (NSLDSFAP) website which the financial aid administrator can access for the auditor. The data on the institution’s Enrollment Reporting Roster, or Enrollment Maintenance page, is what NSLDS has as the most recently certified enrollment. There are two categories of enrollment information, “Campus Level” and “Program Level,” both of which need to be reported accurately and have separate record types. The NSLDS Enrollment Reporting Guide provides the requirements and guidance for reporting enrollment details using the NSLDS Enrollment Reporting Process. Per 2 CFR 200.303, entities must establish and maintain internal controls which provide reasonable assurance that federal award expenditures are in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition: During testing of the accuracy of NSLDS reporting, we identified eight out of forty samples where the program effective date per institutional records did not match the program effective date reported in NSLDS. Context: Out of 40 students tested, we identified eight students in which the program effective date per institutional records did not match the program effective date reported in NSLDS. Questioned costs: None.Effect: The University was out of compliance as it relates to ensuring the program effective date reported in NSLDS matches institutional records. Cause: The program effective dates per institutional records not matching program effective date per NSLDS program enrollment was due to either and old admissions software or the Online Major Change (OMC) tool. Repeat finding: No. Recommendation: We recommend the University review its current procedures for NSLDS reporting and implement additional procedures to ensure program effective dates in NSLDS match institutional records. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.

Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Assistance Cluster Assistance Listing Number: 84.063 & 84.268 Federal Award Identification Number and Year: P063P230097 & P268K240097 Award Period: July 1, 2023 to June 30, 2024 Type of Finding: 􀁸 Other Matters 􀁸 Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: Institutions are required to report enrollment information under the Pell grant and the Direct Loan programs via the National Student Loan Data System (NSLDS) (OMB No. 1845-0035) (Pell, 34 CFR 690.83(b)(2); Direct Loan, 34 CFR 685.309.) The administration of the Title IV programs depends heavily on the accuracy and timeliness of the enrollment information reported by institutions. Institutions must review, update, and certify student enrollment statuses, program information, and effective dates that appear on the Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS Professional Access (NSLDSFAP) website which the financial aid administrator can access for the auditor. The data on the institution’s Enrollment Reporting Roster, or Enrollment Maintenance page, is what NSLDS has as the most recently certified enrollment. There are two categories of enrollment information, “Campus Level” and “Program Level,” both of which need to be reported accurately and have separate record types. The NSLDS Enrollment Reporting Guide provides the requirements and guidance for reporting enrollment details using the NSLDS Enrollment Reporting Process. Per 2 CFR 200.303, entities must establish and maintain internal controls which provide reasonable assurance that federal award expenditures are in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition: During testing of the accuracy of NSLDS reporting, we identified eight out of forty samples where the program effective date per institutional records did not match the program effective date reported in NSLDS. Context: Out of 40 students tested, we identified eight students in which the program effective date per institutional records did not match the program effective date reported in NSLDS. Questioned costs: None.Effect: The University was out of compliance as it relates to ensuring the program effective date reported in NSLDS matches institutional records. Cause: The program effective dates per institutional records not matching program effective date per NSLDS program enrollment was due to either and old admissions software or the Online Major Change (OMC) tool. Repeat finding: No. Recommendation: We recommend the University review its current procedures for NSLDS reporting and implement additional procedures to ensure program effective dates in NSLDS match institutional records. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.