MASSACHUSETTS COLLEGE OF ART & DESIGNHigher Education

Criteria According to 34 CFR 685.304(b): Counseling Borrowers - Exit Counseling (1) A school must ensure that exit counseling is conducted with each Direct Subsidized Loan or Direct Unsubsidized Loan borrower and graduate or professional student Direct PLUS Loan borrower shortly before the student borrower ceases at least half-time study at the school. (2) The exit counseling must be in person, by audiovisual presentation, or by interactive electronic means. In each case, the school must ensure that an individual with expertise in the title IV programs is reasonably available shortly after the counseling to answer the student borrower's questions. As an alternative, in the case of a student borrower enrolled in a correspondence program or a studyabroad program approved for credit at the home institution, the student borrower may be provided with written counseling materials within 30 days after the student borrower completes the program. (3) If a student borrower withdraws from school without the school's prior knowledge or fails to complete the exit counseling as required, exit counseling must, within 30 days after the school learns that the student borrower has withdrawn from school or failed to complete the exit counseling as required, be provided either through interactive electronic means, by mailing written counseling materials to the student borrower at the student borrower's last known address, or by sending written counseling materials to an email address provided by the student borrower that is not an email address associated with the school sending the counseling materials. Condition The Federal Government requires that when the student ceases at least half-time study, withdraws from all classes or graduates, the college must provide exit counseling to students within 30 days. During our testing, we noted 6 students, out of a sample of 40, did not have evidence that exit counseling was performed. Cause The College did not have adequate controls in place to ensure that exit counseling was conducted with Direct Loans borrowers following changes in enrollment which require administration of exit counseling for Direct Loans. Effect The College did not meet federal requirements and students did not complete exit counseling following graduation, cease of enrollment. Questioned Costs Not applicable. Perspective Our sample was not, and was not intended to be, statistically valid. Of the 40 students selected for testing, 6 students, or 15% of our sample, had students that graduated or disenrolled and did not complete exit counseling. Identification as a Repeat Finding, if applicable See finding 2024-001 included in the summary schedule of prior year findings. Recommendation The College should strengthen their procedures to ensure exit counseling is completed for a student when student ceases enrollment at least half-time, withdraws, or graduates from the College. View of Responsible Officials The College agrees with the finding.

Criteria According to 2024-2025 Federal Student Aid Handbook, Volume 4, Chapter 2, Reporting Disbursements Within 15 Days Schools must submit Direct Loan, Pell, and TEACH Grant disbursement records to the COD System no later than 15 days after making the disbursement or becoming aware of the need to adjust a previously reported disbursement. See Federal Register Volume 88, Number 120, June 23, 2023. The Department considers that Title IV funds are disbursed on the date that schools (a) credit those funds in their general ledger or any subledger to a student’s account or (b) pay those funds to a student or parent directly. Title IV aid is disbursed even if schools use their own funds in advance of receiving program funds from the Department. Failure to submit disbursement records within the required time frame may result in a rejection of all or part of the reported disbursement, an audit or program review finding, or possible fines or other penalties. Condition Federal regulations require the College to report to the Federal Government’s Common Origination and Disbursement System (“COD”) Federal Direct Loan disbursements made to students within 15 days of the funds being disbursed to the student. During our testing, we noted 32 students, out of a sample of 40, were not reported within the required timeframe by 12-19 days. Cause The College maintains established policies and procedures to ensure that disbursement records are reported to the Department of Education through the COD system within the required fifteen-calendar-day timeframe. In this instance, however, staffing transitions within the financial aid department resulted in a delay of two to three weeks in submitting the records. Effect The College did not report Direct Loan disbursements to COD within the required time frame. Questioned Costs Not applicable. Perspective Our sample was not, and was not intended to be, statistically valid. Of the 40 students selected for testing, 32 students, or 80% of our sample, were not reported to COD within the required timeframe. Identification as a Repeat Finding, if applicable Not applicable. Recommendation We recommend that management provide adequate cross-training for staff processing Direct Loan disbursements to ensure all Direct Loans are reported within the required timeframe. View of Responsible Officials The College agrees with the finding.

Criteria According to 2 CFR Part 200, Appendix XI Compliance Supplement updated May 2024: Under the Pell Grant and loan programs, institutions must complete and return within 15 days the Enrollment Reporting roster file placed in their Student Aid Internet Gateway mailboxes sent by ED or accessed on the Enrollment Maintenance Page via the National Student Loan Data System (“NSLDS”). The institution determines how often it receives the Enrollment Reporting roster file with the default set at a minimum of every 60 days. Once received, the institution must update for changes in student status, report the date the enrollment status was effective, enter the new anticipated completion date, and submit the changes electronically through the batch method or the NSLDS website. Institutions are responsible for timely reporting, whether they report directly or via a third-party servicer. Condition The Federal Government requires the College to report student enrollment changes to the National Student Loan Data System (“NSLDS”) within 60 days. During our testing, 30 out of 40 students were reported late to the NSLDS by 82-259 days. Cause The College did not have appropriate review to ensure that enrollment-status changes were reported to NSLDS in a timely manner. Staffing transitions within the Registrar’s Office during the spring semester contributed to the delay in reporting. Effect The College did not report the student’s correct status within the required timeframe, which may affect the students’ loan grace periods. Questioned Costs Not applicable Perspective Our sample was not, and was not intended to be, statistically valid. Of the 40 students selected for testing, 30 students, or 75% of our sample was not reported within the required timeframe. Identification as a Repeat Finding, if applicable Not applicable. Recommendation We recommend that management enhance cross-training among employees involved in the NSLDS reporting process to support consistency and continuity in meeting federal reporting requirements. View of Responsible Officials The College agrees with the finding.

Criteria According to 34 CFR 668.164(l): (1) Notwithstanding any State law (such as a law that allows funds to escheat to the State), an institution must return to the Secretary any Title IV, Higher Education Act (“HEA”) program funds, except Federal Work Study (“FWS”) program funds, that it attempts to disburse directly to a student or parent that are not received by the student or parent. For FWS program funds, the institution is required to return only the Federal portion of the payroll disbursement. (2) If an EFT to a student's or parent's financial account is rejected, or a check to a student or parent is returned, the institution may make additional attempts to disburse the funds, provided that those attempts are made not later than 45 days after the EFT was rejected or the check returned. In cases where the institution does not make another attempt, the funds must be returned to the Secretary before the end of this 45-day period. (3) If a check sent to a student or parent is not returned to the institution but is not cashed, the institution must return the funds to the Secretary no later than 240 days after the date it issued the check. Condition Federal regulations require an institution to return unclaimed Title IV funds issued by check or EFT within 240 days. During our testing, we noted 1 student, out of a sample of 7, that had an unclaimed fund exceeding the federal day limit by 78 days. Cause The College did not have appropriate internal controls in place to monitor the outstanding check aging to ensure that the 240-day timeframe was not exceeded. Effect The College did not return Title IV unclaimed funds to the Department of Education within the required 240-day time frame. Questioned Costs $132 pertained specifically to federal-sourced funds. Perspective Our sample was not, and was not intended to be, statistically valid. Of the 7 students selected for testing, 1 student, or 14% of our sample had an unclaimed fund exceeding the federal day limit. Identification as a Repeat Finding, if applicable Not applicable. Recommendation We recommend that the College consider reviewing and, if necessary, refining its policies and procedures related to unclaimed funds, including the identification of aged balances and the process for cancelling checks and returning funds to the Department of Education. View of Responsible Officials The College agrees with the finding.

Criteria According to 34 CFR 668.22(j)(1): Timeframe for the return of title IV funds. An institution must return the amount of title IV funds for which it is responsible under paragraph (g) of this section as soon as possible but no later than 45 days after the date of the institution's determination that the student withdrew as defined in paragraph (l)(3) of this section. According to 34 CFR 668.173(b): Timely return of Title IV, HEA program funds. In accordance with procedures established by the Secretary or Federal Family Education Loan (“FFEL”) program lender, an institution returns unearned Title IV, HEA program funds timely if – (1) The institution deposits or transfers the funds into the bank account it maintains under 34 CFR Sections 668.163 no later than 45 days after the date it determines the student withdrew; (2) The institution initiates an electronic funds transfer no later than 45 days after the date it determines that the student withdrew; (3) The institution initiates an electronic transaction no later than 45 days after the date it determines that the student withdrew, that informs a FFEL lender to adjust the borrower’s loan account for the amount returned; or (4) The institution issues a check no later than 45 days after the date it determines that the student withdrew. An institution does not satisfy this requirement if – (i) The institution’s records show that the check was issued more than 45 days after the date the institution determined the student withdrew; or (ii) The date on the cancelled check shows that the bank used by the Secretary or FFEL Program lender endorsed that check more than 60 days after the date the institution determined that the student withdrew. Condition Federal regulations state that any unearned Title IV grant or loan assistance received by a student must be refunded to the Title IV programs upon a student’s withdrawal from the institution. The College has 45 days from the date it determined the student withdrew to return any unearned portions of Title IV funds. During our testing, we noted 1 student, out of a sample of 5, had unearned Title IV aid that was not returned to the Federal Government, within 45 days of the determined withdrawal date, by 266 days. Cause The College did not consistently follow the procedures in place to monitor student withdrawals related to Title IV funds that must be returned to the Department of Education within 45 days. Effect The College did not return unearned Title IV funds within the required 45-day time frame. Questioned Costs Not applicable Perspective Our sample was not, and was not intended to be, statistically valid. Of the 5 students selected for testing, 1 student, or 20% of our sample, had unearned Title IV funds that were not returned to the Department of Education within the 45-day required timeframe. Identification as a Repeat Finding, if applicable Not applicable. Recommendation We recommend that the College consider refining its process for completing and reviewing Return of Title IV calculations to help ensure funds are returned to the Department of Education within the required timeframe. View of Responsible Officials The College agrees with the finding.

Criteria According to 34 CFR 685.304: Counseling Borrowers – Exit Counseling – (1) A school must ensure that exit counseling is conducted with each Direct Subsidized Loan or Direct Unsubsidized Loan borrower and graduate or professional student Direct PLUS Loan borrower shortly before the student borrower ceases at least half-time study at the school. (2) The exit counseling must be in person, by audiovisual presentation, or by interactive electronic means. In each case, the school must ensure that an individual with expertise in the title IV programs is reasonably available shortly after the counseling to answer the student borrower's questions. As an alternative, in the case of a student borrower enrolled in a correspondence program or a study-abroad program approved for credit at the home institution, the student borrower may be provided with written counseling materials within 30 days after the student borrower completes the program. (3) If a student borrower withdraws from school without the school's prior knowledge or fails to complete the exit counseling as required, exit counseling must, within 30 days after the school learns that the student borrower has withdrawn from school or failed to complete the exit counseling as required, be provided either through interactive electronic means, by mailing written counseling materials to the student borrower at the student borrower's last known address, or by sending written counseling materials to an email address provided by the student borrower that is not an email address associated with the school sending the counseling materials. (4) The exit counseling must – (i) Inform the student borrower of the average anticipated monthly repayment amount based on the student borrower's indebtedness or on the average indebtedness of student borrowers who have obtained Direct Subsidized Loans and Direct Unsubsidized Loans, student borrowers who have obtained only Direct PLUS Loans, or student borrowers who have obtained Direct Subsidized, Direct Unsubsidized, and Direct PLUS Loans, depending on the types of loans the student borrower has obtained, for attendance at the same school or in the same program of study at the same school;   (ii) Review for the student borrower available repayment plan options including the standard repayment, extended repayment, graduated repayment, income-contingent repayment, and income-based repayment plans, including a description of the different features of each plan and sample information showing the average anticipated monthly payments, and the difference in interest paid and total payments under each plan; (iii) Explain to the borrower the options to prepay each loan, to pay each loan on a shorter schedule, and to change repayment plans; (iv) Provide Information on the effects of loan consolidation including, at a minimum – (A) The effects of consolidation on total interest to be paid, fees to be paid, and length of repayment; (B) The effects of consolidation on a borrower's underlying loan benefits, including grace periods, loan forgiveness, cancellation, and deferment opportunities; (C) The options of the borrower to prepay the loan and to change repayment plans; and (D) That borrower benefit programs may vary among different lenders; (v) Include debt-management strategies that are designed to facilitate repayment; (vi) Explain to the student borrower how to contact the party servicing the student borrower's Direct Loans; (vii) Meet the requirements described in paragraphs (a)(6)(i), (a)(6)(ii), and (a)(6)(iv) of this section; (viii) Meet the requirements described in paragraphs (a)(6)(i), (a)(6)(ii), and (a)(6)(iv) of this section; (ix) Provide – (A) The effects of consolidation on total interest to be paid, fees to be paid, and length of repayment; (B) A copy, either in print or by electronic means, of the information the Secretary makes available pursuant to section 485(d) of the HEA; (x) Review for the student borrower information on the availability of the Department's Student Loan Ombudsman's office; (xi) Inform the student borrower of the availability of title IV loan information in the National Student Loan Data System (NSLDS) and how NSLDS can be used to obtain title IV loan status information; (xii) A general description of the types of tax benefits that may be available to borrowers; and (xiii) Require the student borrower to provide current information concerning name, address, social security number, references, and driver's license number and State of issuance, as well as the student borrower's expected permanent address, the address of the student borrower's next of kin, and the name and address of the student borrower's expected employer (if known). (5) The school must ensure that the information required in paragraph (b)(4)(xiii) of this section is provided to the Secretary within 60 days after the student borrower provides the information. (6) If exit counseling is conducted through interactive electronic means, a school must take reasonable steps to ensure that each student borrower receives the counseling materials, and participates in and completes the exit counseling. (7) The school must maintain documentation substantiating the school's compliance with this section for each student borrower. (8) (i) For students who have received loans under both the FFEL Program and the Direct Loan Program for attendance at a school, the school's compliance with the exit counseling requirements in paragraph (b) of this section satisfies the exit counseling requirements in 34 CFR 682.604(a) if the school ensures that the exit counseling also provides the borrower with the information described in 34 CFR 682.604(a)(2)(i) and (ii). (ii) A student's completion of electronic interactive exit counseling offered by the Secretary satisfies the requirements of paragraph (b) of this section and, for students who have also received FFEL Program loans for attendance at the school, 34 CFR 682.604(a). Condition Federal regulations state that a school must ensure that exit counseling is conducted with each Direct Subsidized Loan or Direct Unsubsidized Loan borrower and graduate or professional student Direct PLUS Loan borrower shortly before the student borrower ceases at least half-time study at the school. Cause The College did not complete and document exit counseling for one student that graduated and one student that disenrolled due to human error. Effect The College did not conduct exit counseling for two students who graduated/disenrolled. Questioned Costs Not applicable. Perspective Our sample was not, and was not intended to be, statistically valid. Of the 40 students selected for testing, two students, or 5% of our sample, had students that graduated or disenrolled and did not complete exit counseling.   Identification as a Repeat Finding, if applicable Not applicable. Recommendation The College should strengthen their controls surrounding the review of students that graduated or disenrolled and received Direct Subsidized or Direct Unsubsidized Loans. View of Responsible Officials The College agrees with the finding.

Criteria According to 34 CFR 685.304: Counseling Borrowers – Exit Counseling – (1) A school must ensure that exit counseling is conducted with each Direct Subsidized Loan or Direct Unsubsidized Loan borrower and graduate or professional student Direct PLUS Loan borrower shortly before the student borrower ceases at least half-time study at the school. (2) The exit counseling must be in person, by audiovisual presentation, or by interactive electronic means. In each case, the school must ensure that an individual with expertise in the title IV programs is reasonably available shortly after the counseling to answer the student borrower's questions. As an alternative, in the case of a student borrower enrolled in a correspondence program or a study-abroad program approved for credit at the home institution, the student borrower may be provided with written counseling materials within 30 days after the student borrower completes the program. (3) If a student borrower withdraws from school without the school's prior knowledge or fails to complete the exit counseling as required, exit counseling must, within 30 days after the school learns that the student borrower has withdrawn from school or failed to complete the exit counseling as required, be provided either through interactive electronic means, by mailing written counseling materials to the student borrower at the student borrower's last known address, or by sending written counseling materials to an email address provided by the student borrower that is not an email address associated with the school sending the counseling materials. (4) The exit counseling must – (i) Inform the student borrower of the average anticipated monthly repayment amount based on the student borrower's indebtedness or on the average indebtedness of student borrowers who have obtained Direct Subsidized Loans and Direct Unsubsidized Loans, student borrowers who have obtained only Direct PLUS Loans, or student borrowers who have obtained Direct Subsidized, Direct Unsubsidized, and Direct PLUS Loans, depending on the types of loans the student borrower has obtained, for attendance at the same school or in the same program of study at the same school;   (ii) Review for the student borrower available repayment plan options including the standard repayment, extended repayment, graduated repayment, income-contingent repayment, and income-based repayment plans, including a description of the different features of each plan and sample information showing the average anticipated monthly payments, and the difference in interest paid and total payments under each plan; (iii) Explain to the borrower the options to prepay each loan, to pay each loan on a shorter schedule, and to change repayment plans; (iv) Provide Information on the effects of loan consolidation including, at a minimum – (A) The effects of consolidation on total interest to be paid, fees to be paid, and length of repayment; (B) The effects of consolidation on a borrower's underlying loan benefits, including grace periods, loan forgiveness, cancellation, and deferment opportunities; (C) The options of the borrower to prepay the loan and to change repayment plans; and (D) That borrower benefit programs may vary among different lenders; (v) Include debt-management strategies that are designed to facilitate repayment; (vi) Explain to the student borrower how to contact the party servicing the student borrower's Direct Loans; (vii) Meet the requirements described in paragraphs (a)(6)(i), (a)(6)(ii), and (a)(6)(iv) of this section; (viii) Meet the requirements described in paragraphs (a)(6)(i), (a)(6)(ii), and (a)(6)(iv) of this section; (ix) Provide – (A) The effects of consolidation on total interest to be paid, fees to be paid, and length of repayment; (B) A copy, either in print or by electronic means, of the information the Secretary makes available pursuant to section 485(d) of the HEA; (x) Review for the student borrower information on the availability of the Department's Student Loan Ombudsman's office; (xi) Inform the student borrower of the availability of title IV loan information in the National Student Loan Data System (NSLDS) and how NSLDS can be used to obtain title IV loan status information; (xii) A general description of the types of tax benefits that may be available to borrowers; and (xiii) Require the student borrower to provide current information concerning name, address, social security number, references, and driver's license number and State of issuance, as well as the student borrower's expected permanent address, the address of the student borrower's next of kin, and the name and address of the student borrower's expected employer (if known). (5) The school must ensure that the information required in paragraph (b)(4)(xiii) of this section is provided to the Secretary within 60 days after the student borrower provides the information. (6) If exit counseling is conducted through interactive electronic means, a school must take reasonable steps to ensure that each student borrower receives the counseling materials, and participates in and completes the exit counseling. (7) The school must maintain documentation substantiating the school's compliance with this section for each student borrower. (8) (i) For students who have received loans under both the FFEL Program and the Direct Loan Program for attendance at a school, the school's compliance with the exit counseling requirements in paragraph (b) of this section satisfies the exit counseling requirements in 34 CFR 682.604(a) if the school ensures that the exit counseling also provides the borrower with the information described in 34 CFR 682.604(a)(2)(i) and (ii). (ii) A student's completion of electronic interactive exit counseling offered by the Secretary satisfies the requirements of paragraph (b) of this section and, for students who have also received FFEL Program loans for attendance at the school, 34 CFR 682.604(a). Condition Federal regulations state that a school must ensure that exit counseling is conducted with each Direct Subsidized Loan or Direct Unsubsidized Loan borrower and graduate or professional student Direct PLUS Loan borrower shortly before the student borrower ceases at least half-time study at the school. Cause The College did not complete and document exit counseling for one student that graduated and one student that disenrolled due to human error. Effect The College did not conduct exit counseling for two students who graduated/disenrolled. Questioned Costs Not applicable. Perspective Our sample was not, and was not intended to be, statistically valid. Of the 40 students selected for testing, two students, or 5% of our sample, had students that graduated or disenrolled and did not complete exit counseling.   Identification as a Repeat Finding, if applicable Not applicable. Recommendation The College should strengthen their controls surrounding the review of students that graduated or disenrolled and received Direct Subsidized or Direct Unsubsidized Loans. View of Responsible Officials The College agrees with the finding.

Criteria According to 34 CFR 685.304: Counseling Borrowers – Exit Counseling – (1) A school must ensure that exit counseling is conducted with each Direct Subsidized Loan or Direct Unsubsidized Loan borrower and graduate or professional student Direct PLUS Loan borrower shortly before the student borrower ceases at least half-time study at the school. (2) The exit counseling must be in person, by audiovisual presentation, or by interactive electronic means. In each case, the school must ensure that an individual with expertise in the title IV programs is reasonably available shortly after the counseling to answer the student borrower's questions. As an alternative, in the case of a student borrower enrolled in a correspondence program or a study-abroad program approved for credit at the home institution, the student borrower may be provided with written counseling materials within 30 days after the student borrower completes the program. (3) If a student borrower withdraws from school without the school's prior knowledge or fails to complete the exit counseling as required, exit counseling must, within 30 days after the school learns that the student borrower has withdrawn from school or failed to complete the exit counseling as required, be provided either through interactive electronic means, by mailing written counseling materials to the student borrower at the student borrower's last known address, or by sending written counseling materials to an email address provided by the student borrower that is not an email address associated with the school sending the counseling materials. (4) The exit counseling must – (i) Inform the student borrower of the average anticipated monthly repayment amount based on the student borrower's indebtedness or on the average indebtedness of student borrowers who have obtained Direct Subsidized Loans and Direct Unsubsidized Loans, student borrowers who have obtained only Direct PLUS Loans, or student borrowers who have obtained Direct Subsidized, Direct Unsubsidized, and Direct PLUS Loans, depending on the types of loans the student borrower has obtained, for attendance at the same school or in the same program of study at the same school;   (ii) Review for the student borrower available repayment plan options including the standard repayment, extended repayment, graduated repayment, income-contingent repayment, and income-based repayment plans, including a description of the different features of each plan and sample information showing the average anticipated monthly payments, and the difference in interest paid and total payments under each plan; (iii) Explain to the borrower the options to prepay each loan, to pay each loan on a shorter schedule, and to change repayment plans; (iv) Provide Information on the effects of loan consolidation including, at a minimum – (A) The effects of consolidation on total interest to be paid, fees to be paid, and length of repayment; (B) The effects of consolidation on a borrower's underlying loan benefits, including grace periods, loan forgiveness, cancellation, and deferment opportunities; (C) The options of the borrower to prepay the loan and to change repayment plans; and (D) That borrower benefit programs may vary among different lenders; (v) Include debt-management strategies that are designed to facilitate repayment; (vi) Explain to the student borrower how to contact the party servicing the student borrower's Direct Loans; (vii) Meet the requirements described in paragraphs (a)(6)(i), (a)(6)(ii), and (a)(6)(iv) of this section; (viii) Meet the requirements described in paragraphs (a)(6)(i), (a)(6)(ii), and (a)(6)(iv) of this section; (ix) Provide – (A) The effects of consolidation on total interest to be paid, fees to be paid, and length of repayment; (B) A copy, either in print or by electronic means, of the information the Secretary makes available pursuant to section 485(d) of the HEA; (x) Review for the student borrower information on the availability of the Department's Student Loan Ombudsman's office; (xi) Inform the student borrower of the availability of title IV loan information in the National Student Loan Data System (NSLDS) and how NSLDS can be used to obtain title IV loan status information; (xii) A general description of the types of tax benefits that may be available to borrowers; and (xiii) Require the student borrower to provide current information concerning name, address, social security number, references, and driver's license number and State of issuance, as well as the student borrower's expected permanent address, the address of the student borrower's next of kin, and the name and address of the student borrower's expected employer (if known). (5) The school must ensure that the information required in paragraph (b)(4)(xiii) of this section is provided to the Secretary within 60 days after the student borrower provides the information. (6) If exit counseling is conducted through interactive electronic means, a school must take reasonable steps to ensure that each student borrower receives the counseling materials, and participates in and completes the exit counseling. (7) The school must maintain documentation substantiating the school's compliance with this section for each student borrower. (8) (i) For students who have received loans under both the FFEL Program and the Direct Loan Program for attendance at a school, the school's compliance with the exit counseling requirements in paragraph (b) of this section satisfies the exit counseling requirements in 34 CFR 682.604(a) if the school ensures that the exit counseling also provides the borrower with the information described in 34 CFR 682.604(a)(2)(i) and (ii). (ii) A student's completion of electronic interactive exit counseling offered by the Secretary satisfies the requirements of paragraph (b) of this section and, for students who have also received FFEL Program loans for attendance at the school, 34 CFR 682.604(a). Condition Federal regulations state that a school must ensure that exit counseling is conducted with each Direct Subsidized Loan or Direct Unsubsidized Loan borrower and graduate or professional student Direct PLUS Loan borrower shortly before the student borrower ceases at least half-time study at the school. Cause The College did not complete and document exit counseling for one student that graduated and one student that disenrolled due to human error. Effect The College did not conduct exit counseling for two students who graduated/disenrolled. Questioned Costs Not applicable. Perspective Our sample was not, and was not intended to be, statistically valid. Of the 40 students selected for testing, two students, or 5% of our sample, had students that graduated or disenrolled and did not complete exit counseling.   Identification as a Repeat Finding, if applicable Not applicable. Recommendation The College should strengthen their controls surrounding the review of students that graduated or disenrolled and received Direct Subsidized or Direct Unsubsidized Loans. View of Responsible Officials The College agrees with the finding.

Criteria According to 34 CFR 685.304: Counseling Borrowers – Exit Counseling – (1) A school must ensure that exit counseling is conducted with each Direct Subsidized Loan or Direct Unsubsidized Loan borrower and graduate or professional student Direct PLUS Loan borrower shortly before the student borrower ceases at least half-time study at the school. (2) The exit counseling must be in person, by audiovisual presentation, or by interactive electronic means. In each case, the school must ensure that an individual with expertise in the title IV programs is reasonably available shortly after the counseling to answer the student borrower's questions. As an alternative, in the case of a student borrower enrolled in a correspondence program or a study-abroad program approved for credit at the home institution, the student borrower may be provided with written counseling materials within 30 days after the student borrower completes the program. (3) If a student borrower withdraws from school without the school's prior knowledge or fails to complete the exit counseling as required, exit counseling must, within 30 days after the school learns that the student borrower has withdrawn from school or failed to complete the exit counseling as required, be provided either through interactive electronic means, by mailing written counseling materials to the student borrower at the student borrower's last known address, or by sending written counseling materials to an email address provided by the student borrower that is not an email address associated with the school sending the counseling materials. (4) The exit counseling must – (i) Inform the student borrower of the average anticipated monthly repayment amount based on the student borrower's indebtedness or on the average indebtedness of student borrowers who have obtained Direct Subsidized Loans and Direct Unsubsidized Loans, student borrowers who have obtained only Direct PLUS Loans, or student borrowers who have obtained Direct Subsidized, Direct Unsubsidized, and Direct PLUS Loans, depending on the types of loans the student borrower has obtained, for attendance at the same school or in the same program of study at the same school;   (ii) Review for the student borrower available repayment plan options including the standard repayment, extended repayment, graduated repayment, income-contingent repayment, and income-based repayment plans, including a description of the different features of each plan and sample information showing the average anticipated monthly payments, and the difference in interest paid and total payments under each plan; (iii) Explain to the borrower the options to prepay each loan, to pay each loan on a shorter schedule, and to change repayment plans; (iv) Provide Information on the effects of loan consolidation including, at a minimum – (A) The effects of consolidation on total interest to be paid, fees to be paid, and length of repayment; (B) The effects of consolidation on a borrower's underlying loan benefits, including grace periods, loan forgiveness, cancellation, and deferment opportunities; (C) The options of the borrower to prepay the loan and to change repayment plans; and (D) That borrower benefit programs may vary among different lenders; (v) Include debt-management strategies that are designed to facilitate repayment; (vi) Explain to the student borrower how to contact the party servicing the student borrower's Direct Loans; (vii) Meet the requirements described in paragraphs (a)(6)(i), (a)(6)(ii), and (a)(6)(iv) of this section; (viii) Meet the requirements described in paragraphs (a)(6)(i), (a)(6)(ii), and (a)(6)(iv) of this section; (ix) Provide – (A) The effects of consolidation on total interest to be paid, fees to be paid, and length of repayment; (B) A copy, either in print or by electronic means, of the information the Secretary makes available pursuant to section 485(d) of the HEA; (x) Review for the student borrower information on the availability of the Department's Student Loan Ombudsman's office; (xi) Inform the student borrower of the availability of title IV loan information in the National Student Loan Data System (NSLDS) and how NSLDS can be used to obtain title IV loan status information; (xii) A general description of the types of tax benefits that may be available to borrowers; and (xiii) Require the student borrower to provide current information concerning name, address, social security number, references, and driver's license number and State of issuance, as well as the student borrower's expected permanent address, the address of the student borrower's next of kin, and the name and address of the student borrower's expected employer (if known). (5) The school must ensure that the information required in paragraph (b)(4)(xiii) of this section is provided to the Secretary within 60 days after the student borrower provides the information. (6) If exit counseling is conducted through interactive electronic means, a school must take reasonable steps to ensure that each student borrower receives the counseling materials, and participates in and completes the exit counseling. (7) The school must maintain documentation substantiating the school's compliance with this section for each student borrower. (8) (i) For students who have received loans under both the FFEL Program and the Direct Loan Program for attendance at a school, the school's compliance with the exit counseling requirements in paragraph (b) of this section satisfies the exit counseling requirements in 34 CFR 682.604(a) if the school ensures that the exit counseling also provides the borrower with the information described in 34 CFR 682.604(a)(2)(i) and (ii). (ii) A student's completion of electronic interactive exit counseling offered by the Secretary satisfies the requirements of paragraph (b) of this section and, for students who have also received FFEL Program loans for attendance at the school, 34 CFR 682.604(a). Condition Federal regulations state that a school must ensure that exit counseling is conducted with each Direct Subsidized Loan or Direct Unsubsidized Loan borrower and graduate or professional student Direct PLUS Loan borrower shortly before the student borrower ceases at least half-time study at the school. Cause The College did not complete and document exit counseling for one student that graduated and one student that disenrolled due to human error. Effect The College did not conduct exit counseling for two students who graduated/disenrolled. Questioned Costs Not applicable. Perspective Our sample was not, and was not intended to be, statistically valid. Of the 40 students selected for testing, two students, or 5% of our sample, had students that graduated or disenrolled and did not complete exit counseling.   Identification as a Repeat Finding, if applicable Not applicable. Recommendation The College should strengthen their controls surrounding the review of students that graduated or disenrolled and received Direct Subsidized or Direct Unsubsidized Loans. View of Responsible Officials The College agrees with the finding.

Criteria According to 34 CFR 668.22(j)(1): Timeframe for the Return of Title IV funds. An institution must return the amount of Title IV funds for which it is responsible under paragraph (g) of this section as soon as possible but no later than 45 days after the date of the institution's determination that the student withdrew as defined in paragraph (l)(3) of this section. According to 34 CFR 668.173(b): Timely Return of Title IV, HEA program funds. In accordance with procedures established by the Secretary or Federal Family Education Loan (“FFEL”) program lender, an institution returns unearned Title IV, HEA program funds timely if – (1) The institution deposits or transfers the funds into the bank account it maintains under 34 CFR Sections 668.163 no later than 45 days after the date it determines the student withdrew; (2) The institution initiates an electronic funds transfer no later than 45 days after the date it determines that the student withdrew; (3) The institution initiates an electronic transaction no later than 45 days after the date it determines that the student withdrew, that informs a FFEL lender to adjust the borrower’s loan account for the amount returned; or (4) The institution issues a check no later than 45 days after the date it determines that the student withdrew. An institution does not satisfy this requirement if – (i) The institution’s records show that the check was issued more than 45 days after the date the institution determined the student withdrew; or (ii) The date on the cancelled check shows that the bank used by the Secretary or FFEL Program lender endorsed that check more than 60 days after the date the institution determined that the student withdrew. Condition Federal regulations state that any unearned Title IV grant or loan assistance received by a student must be refunded to the Title IV programs upon a student’s withdrawal from the institution. The College has 45 days from the date they determined the student withdrew to return any unearned portions of Title IV funds. During our testing, we noted 1 student, out of a sample of 5, had unearned Title IV aid that was not returned to the Federal Government, within 45 days of the determined withdrawal date, by 250 days.   Cause The College did not consistently follow the procedures in place to monitor student withdrawals related to Title IV funds that must be returned to the Department of Education within 45 days due to human error. Effect The College did not return unearned Title IV funds within the required 45-day time frame. Questioned Costs Not applicable. Perspective Our sample was not, and was not intended to be, statistically valid. Of the 5 students selected for testing, 1 student, or 20% of our sample, had unearned Title IV funds that were not returned to the Department of Education within the 45-day required time frame. Identification as a Repeat Finding, if applicable Not applicable. Recommendation The College should strengthen their controls surrounding the review Return of Title IV calculations in a timely manner to ensure that all funds are returned to the Department of Education within the required time frame. View of Responsible Officials The College agrees with the finding.

Section III ? Federal Award Findings and Questioned Costs: Finding number: 2021-001 Federal agency: U.S. Department of Education Programs: Federal Direct Student Loans Assistance Listing #: 84.268 Award year: 2021 Criteria According to 34 CFR 690.83(b) (1) An institution shall report to the Secretary any change for which a student qualifies including any related Payment Data changes by submitting to the Secretary the student?s Payment Data that discloses the basis and result of the change in award for each student. The institution shall submit the student?s Payment Data reporting any to the Secretary by the reporting deadlines published by the Secretary in the Federal Register. (2) An institution shall submit, in accordance with the deadline dates established by the Secretary, through publication in the Federal Register, other reports and information the Secretary requires and shall comply with the procedures the Secretary finds necessary to ensure that the reports are correct. According to the Federal Register (Volume 83, Number 233): An institution must submit Pell Grant, Iraq and Afghanistan Service Grant, Direct Loan, and TEACH Grant disbursement records to COD, no later than 15 days after making the disbursement or becoming aware of the need to adjust a previously reported disbursement. In accordance with 34 CFR 668.164(a), title IV, Higher Education Act (?HEA?) program funds are disbursed on the date that the institution: (a) Credits those funds to a student?s account in the institution?s general ledger or any subledger of the general ledger; or (b) pays those funds to a student directly. Title IV, HEA program funds are disbursed even if an institution uses its own funds in advance of receiving program funds from the Department. Condition Federal regulations require the College to report Federal Direct Loan disbursements made to students to the Federal Government?s Common Origination and Disbursement System (?COD?) within 15 days of the funds being disbursed to the student. During our testing, we noted 1 student, out of a sample of 40, was not reported within the required timeframe by 81 days. Cause The College has policies and procedures in place to report the disbursement records to the Department of Education through the COD system within the required fifteen calendar days, however, in this case the procedures were not completed properly. Effect The College did not report Direct Student Loan disbursements to COD within the required time frame. Questioned Costs Not applicable Perspective Our sample was not, and was not intended to be, statistically valid. Of the 40 students selected for testing, 1 student, or 2.5% of our sample, was determined to be reported late to the COD by 81 days. Recommendation We recommend that management of the College review, and if necessary, update the policies and procedures to ensure all Direct Student Loan funds are reported within the required timeframe. View of Responsible Officials The College agrees with the finding.

Finding number: 2020-001 Federal agency: U.S. Department of Education Programs: Federal Pell Grants CFDA #: 84.063 Award year: 2020 Criteria According to 34 CFR 690.83(b) (1) An institution shall report to the Secretary any change for which a student qualifies including any related Payment Data changes by submitting to the Secretary the student?s Payment Data that discloses the basis and result of the change in award for each student. The institution shall submit the student?s Payment Data reporting any to the Secretary by the reporting deadlines published by the Secretary in the Federal Register. (2) An institution shall submit, in accordance with the deadline dates established by the Secretary, through publication in the Federal Register, other reports and information the Secretary requires and shall comply with the procedures the Secretary finds necessary to ensure that the reports are correct. According to the Federal Register (Volume 83, Number 233): An institution must submit Pell Grant, Iraq and Afghanistan Service Grant, Direct Loan, and TEACH Grant disbursement records to COD, no later than 15 days after making the disbursement or becoming aware of the need to adjust a previously reported disbursement. In accordance with 34 CFR 668.164(a), title IV, Higher Education Act (?HEA?) program funds are disbursed on the date that the institution: (a) Credits those funds to a student?s account in the institution?s general ledger or any subledger of the general ledger; or (b) pays those funds to a student directly. Title IV, HEA program funds are disbursed even if an institution uses its own funds in advance of receiving program funds from the Department. Condition Federal regulations require the College to report to the Federal Government?s Common Origination and Disbursement System (?COD?) Federal Pell Grant disbursements made to students within 15 days of the funds being disbursed to the student. During our testing, we noted 1 student, out of a sample of 40, was not reported within the required timeframe by 42 days. Cause The College has policies and procedures in place to report the disbursement records to the Department of Education through the COD system within the required fifteen calendar days, however, in this case the procedures were not completed properly. Effect The College did not report Pell Grant disbursements to COD within the required time frame. Questioned Costs Not applicable Perspective Our sample was not, and was not intended to be, statistically valid. Of the 40 students selected for testing, 1 student, or 2.5% of our sample, was determined to be reported late to the COD by 42 days. Recommendation We recommend that management of the College review, and if necessary, update the policies and procedures to ensure all Pell Grant funds are reported within the required timeframe. View of Responsible Officials The College agrees with the finding.

Finding number: 2020-002 Federal agency: U.S. Department of Education Programs: Student Financial Assistance Cluster CFDA #: 84.063 Award year: 2020 Criteria According to 34 CFR 668.22(j)(1): Timeframe for the return of title IV funds. An institution must return the amount of title IV funds for which it is responsible under paragraph (g) of this section as soon as possible but no later than 45 days after the date of the institution's determination that the student withdrew as defined in paragraph (l)(3) of this section. According to 34 CFR 668.173(b): Timely return of Title IV, HEA program funds. In accordance with procedures established by the Secretary or Federal Family Education Loan (?FFEL?) program lender, an institution returns unearned Title IV, HEA program funds timely if ? (1) The institution deposits or transfers the funds into the bank account it maintains under 34 CFR Sections 668.163 no later than 45 days after the date it determines the student withdrew; (2) The institution initiates an electronic funds transfer no later than 45 days after the date it determines that the student withdrew; (3) The institution initiates an electronic transaction no later than 45 days after the date it determines that the student withdrew, that informs a FFEL lender to adjust the borrower?s loan account for the amount returned; or (4) The institution issues a check no later than 45 days after the date it determines that the student withdrew. An institution does not satisfy this requirement if ? (i) The institution?s records show that the check was issued more than 45 days after the date the institution determined the student withdrew; or (ii) The date on the cancelled check shows that the bank used by the Secretary or FFEL Program lender endorsed that check more than 60 days after the date the institution determined that the student withdrew. Condition Federal regulations state that any unearned Title IV grant or loan assistance received by a student must be refunded to the Title IV programs upon a student?s withdrawal from the institution. The College has 45 days from the date they determined the student withdrew to return any unearned portions of Title IV funds. During our testing, we noted 1 student, out of a sample of 5, had unearned Title IV aid that was not returned to the Federal Government, within 45 days of the determined withdrawal date, by 3 days. Cause The College did not consistently follow the procedures in place to monitor student withdrawals related to Title IV funds that must be returned to the Department of Education within 45 days due to management oversight. Effect The College did not return unearned Title IV funds within the required 45-day time frame. Questioned Costs Not applicable Perspective Our sample was not, and was not intended to be, statistically valid. Of the 5 students selected for testing, 1 student, or 20% of our sample, had unearned Title IV funds that were not returned to the Department of Education within the 45-day required time frame. Recommendation The College should strengthen their controls surrounding the review Return of Title IV calculations in a timely manner to ensure that all funds are returned to the Department of Education within the required time frame. View of Responsible Officials The College agrees with the finding.

Finding number: 2020-003 Federal agency: U.S. Department of Education Programs: Higher Education Emergency Relief Fund - Student Aid Portion CFDA #: 84.425E Award year: 2020 Criteria Section 18004(a)(1) of the Coronavirus Aid, Relief, and Economic Security Act required that institutions submit an Annual Report to the Department of Education that details the institution's annual expenditures accurately and that the expenditures reconcile with institution's underlying records. Condition During our testing, we noted that the Annual Report submitted by the College was not accurate and did not reconcile with the College's underlying records. The College included the student aid amount award through December 31, 2020 in the institutional aid section of the report therefore overstating the amount of institutional aid expended. Effect The College's annual report submitted to the Department of Education was not accurate. Identification as a Repeat Finding, if applicable Not applicable Recommendation The College should create procedures to ensure College is in compliance with the program's reporting requirements. View of Responsible Officials The College included the student aid amount award through December 31, 2020 in the institutional aid section of the report therefore overstating the amount of institutional aid expended.

GSA_MIGRATION

GSA_MIGRATION

GSA_MIGRATION

GSA_MIGRATION

GSA_MIGRATION

GSA_MIGRATION

GSA_MIGRATION