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Finding 2025-001 - Special Tests and Provisions - Exit Counseling - Significant Deficiency Name of Federal Agency: U.S. Department of Education Federal Program Name: Federal Direct Student Loans Assistance Listing Number: 84.268 Federal Award Identification Number and Year: P268K263382 2025 Name of Pass-through Entity: N/A Criteria According to the Federal Register (34 CFR 685.304 (b) (1)), for students who withdrew, graduated, or had a leave of absence an institution must ensure exit counseling is conducted with each Federal Direct Loans Program borrower and the institution must maintain in the student borrower's file documents substantiating compliance with these requirements (34 CFR 685.304 (b)(7)). Condition We noted 3 instances where the Institute failed to document exit counseling which should have been conducted with a participating student during the award year. Cause There was an administrative oversight that caused the above mentioned condition. Effect or Potential Effect The Institute was not in compliance with federal regulations regarding special tests and provisions for the year ended September 30, 2025. Questioned Costs None Context A total of 10 students who were credited with Federal Direct Loan Program proceeds that either withdrew, graduate, or had a leave of absence during the year were included in the haphazardly selected sample of 40 participating students. Our testing noted that 3 of the students with Federal Direct Loan Program proceeds credited to their account that either withdrew, graduated, or had a leave of absence did not have the required exit counseling documented. Identification as a repeat finding This finding is a repeat finding (see prior year finding number: 2024-001). Recommendation We recommend the Institute continue its efforts to ensure all required exit counseling procedures are conducted and documented in compliance with U.S. Department of Education regulations. Views of Responsible Officials As reported in the Institutes fiscal 2024 Corrective Action Plan, in May 2025, the Institute revised its current procedures to include having an employee independent from the exit conference process review that any student not enrolled in a new semester or that is enrolled at less than half time status has received proper exit conferencing and that exit conferencing has been properly documented. Two of the findings in the current fiscal 2025 occurred prior to the May revision by the Institute of its procedures. The third finding occurred during a period that the independent party performing the review function was on leave due to a death in the family. The Institute recognizes the importance of ensuring that exit conferences are performed timely and properly documented. Management has met with its staff involved in this process to emphasize its importance. Additionally, an additional staff member has been assigned to perform the review procedures if the staff member responsible is not available to timely perform the procedures.