Hilbert CollegeHigher Education

2025–001 National Student Loan Database System (NSLDS) Enrollment Reporting Federal Agency: U.S. Department of Education Federal Program Name: Student Financial Aid Cluster Assistance Listing Number: 84.063, 84.268, 84.007, 84.038, 84.033 Federal Award Identification Number and Year: P268K251853, P063P241853; 2025 Award Period: June 1, 2024 – May 31, 2025 Type of Finding:  Significant Deficiency in Internal Control over Compliance  Other Matters Criteria or specific requirement: In accordance with 34 CFR 685.309(b) and the National Student Loan Data System (NSLDS) Enrollment Reporting Guide published by the Department of Education, schools must review, update, and verify 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. In addition, schools must report enrollment status changes within 30 days of becoming aware of the status change or in its next scheduled enrollment submission if the scheduled submission is within 60 days. Condition/Context: During our testing of enrollment status submissions, the following was noted:  4 students out of a sample of 23 students tested were reported with incorrect enrollment status effective dates at the campus level.  2 students out of a sample of 23 students tested were reported outside the 30- or 60-day window.  2 students out of a sample of 23 students tested were reported with incorrect enrollment effective dates at both the campus and program levels.  1 student out of a sample of 23 students tested were reported with incorrect enrollment effective date at the program level.  2 students out of a sample of 23 students tested were reported as a withdrawal status at both the campus and programs levels but was graduated per Institution’s record, and student status was never subsequently updated. Questioned costs: None. Cause: The College's internal controls did not identify the errors for compliance with the criteria mentioned above. Effect: Inaccurate information is reflected in the NSLDS database. A student’s enrollment data protects the rights of borrowers by ensuring that loan interest subsidies are based on accurate enrollment data, ensures loan repayment dates are accurately based on the last data of attendance, allows in-school deferments to be automatically granted using NSLDS enrollment data, and provides vast amounts of critical data about the effectiveness of Title IV aid programs, including completion data. Repeat Finding: No. Recommendation: The College should review its policies and procedures on reporting enrollment status changes to NSLDS to ensure that all status changes are being reported timely and accurately to be in compliance with regulations. Views of responsible officials: Please refer to the attached corrective action plan.

2025–002 Return of Title IV Funds Federal Agency: U.S. Department of Education Federal Program Name: Student Financial Aid Cluster Assistance Listing Number: 84.063, 84.268, 84.007, 84.038, 84.033 Federal Award Identification Number and Year: P268K251853, P063P241853; 2025 Award Period: June 1, 2024 – May 31, 2025 Type of Finding:  Significant Deficiency in Internal Control over Compliance  Other Matters Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 668.22(f)(2), states that: 1) The total number of calendar days in a payment period or period of enrollment includes all days within the period that the student was scheduled to complete, except that scheduled breaks of at least five consecutive days are excluded from the total number of calendar days in a payment period or period of enrollment and the number of calendar days completed in that period. 2) Per the Return of Title IV Funds Worksheet, when calculating percentages, Institutions should round to three decimal places in order to properly calculate the refund. Condition/Context: During our testing of return of Title IV funds, the following was noted:  1 student out of a sample of 8 students tested had the incorrect number of scheduled breaks used in the calculation of percentage of the payment period which resulted in the College over returning funds of $38.  2 students out of a sample of 8 students tested had the incorrect percentage earned used in the R2T4 worksheet, as the College did not round to three decimal places. This resulted in the College under returning funds of $33. Questioned costs: $5 Cause: The College's internal controls did not identify the errors for compliance with the criteria mentioned above. Effect: The College did not comply with accurately calculating the return of Title IV funds for these students. Repeat Finding: No. Recommendation: The College should review its policies and procedures on determining student's withdrawals, specifically the proper calculation elements and proper rounding where necessary to ensure timely and accurate return of Title IV funds. Views of responsible officials: Please refer to the attached corrective action plan.

2025–003 Verification Federal Agency: U.S. Department of Education Federal Program Name: Student Financial Aid Cluster Assistance Listing Number: 84.063, 84.268, 84.007, 84.038, 84.033 Federal Award Identification Number and Year: P268K251853; 2025 Award Period: June 1, 2024 – May 31, 2025 Type of Finding:  Significant Deficiency in Internal Control over Compliance  Other Matters Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 668.51 through 668.61 states that the institution shall require applicants to verify any information used to calculate an applicant’s student aid index (SAI) that the institution has reason to believe is inaccurate and provide an accurate code for the individual’s verification status in the Common Origination and Disbursement (COD) system. Condition/Context: Student's verification status was not correctly coded in COD. Questioned costs: No. Cause: The College’s internal controls did not identify the errors for compliance with the criteria mentioned above. Effect: Inaccurate information reported to COD regarding student's verification status. Repeat Finding: No. Recommendation: The College should review its policies and procedures on reporting student's verification statuses to COD timely and accurately to be in compliance with regulations. Views of responsible officials: Please refer to the attached corrective action plan.

2025–004 FISAP Reporting Federal Agency: U.S. Department of Education Federal Program Name: Student Financial Aid Cluster Assistance Listing Number: 84.063, 84.268, 84.007, 84.038, 84.033 Federal Award Identification Number and Year: P268K251853, P063P241853, P007A242813, P033A24813; 2025 Award Period: June 1, 2024 – May 31, 2025 Type of Finding:  Significant Deficiency in Internal Control over Compliance  Other Matters Criteria or specific requirement: Per U.S. Department of Education guidelines for the Fiscal Operations Report and Application to Participate (FISAP), institutions must accurately report tuition and fees in Part II, Section E, Line 22 based on official institutional records and applicable accounting standards. Condition/Context: During our testing of the FISAP submission, we noted that Part II (Application), Section E, Line 22: Total Tuition and Fees did not contain correct information. Questioned costs: No. Cause: The College's internal controls did not identify the errors for compliance with the criteria mentioned above. Effect: Inaccurate information of institutional financial data is reported to the Department of Education, which may affect federal funding calculations and trigger additional compliance reviews. Repeat Finding: No. Recommendation: We recommend the College review its reporting procedures to ensure that key line Items within the FISAP are reviewed and accurately reported to the Department of Education as required by regulations. Views of responsible officials: Please refer to the attached corrective action plan.

2025–005 Common Origination and Disbursement (COD) Reporting Federal Agency: U.S. Department of Education Federal Program Name: Student Financial Aid Cluster Assistance Listing Number: 84.063, 84.268, 84.007, 84.038, 84.033 Federal Award Identification Number and Year: P268K251853, P063P241853, P007A242813, P033A24813; 2025 Award Period: June 1, 2024 – May 31, 2025 Type of Finding:  Significant Deficiency in Internal Control over Compliance  Other Matters Criteria or specific requirement: Per U.S. Department of Education guidelines for COD reporting, institutions submit Direct Loan, Pell Grant, TEACH Grant, and IASG origination records and disbursement records to the COD system. The disbursement record reports the actual disbursement date and the amount of the disbursement. ED processes origination and/or disbursement records and returns acknowledgments to the institution. The acknowledgments identify the processing status of each record: Rejected, Accepted with Corrections, or Accepted. In testing the origination and disbursement data, the auditor should be most concerned with the data ED has categorized as accepted or accepted with corrections. Institutions must report student disbursement data within 15 calendar days after the institution makes a disbursement or becomes aware of the need to make an adjustment to previously reported student disbursement data or expected student disbursement data. Institutions may do this by reporting once every 15 calendar days, bi-weekly or weekly, or may set up their own system to ensure that changes are reported in a timely manner. Condition/Context: During our testing of COD reporting, the following was noted:  10 disbursements out of a sample of 40 disbursements tested were not applied within 15 days to COD.  3 disbursements out of a sample of 40 disbursements tested, the disbursement date in COD did not match the actual date of disbursement on the student’s ledger card. Questioned costs: No. Cause: During our testing, it was noted that the College did not have the proper procedures and review in place to ensure that disbursements are reported accurately and timely to COD. Effect: Inaccurate dates and late reporting to COD regarding student disbursements. Repeat Finding: No. Recommendation: We recommend that the College review its reporting procedures to COD to ensure disbursements are reported timely and accurately to be in compliance with regulations. Views of responsible officials: Please refer to the attached corrective action plan.

2025–006 Title IV Credit Balances Federal Agency: U.S. Department of Education Federal Program Name: Student Financial Aid Cluster Assistance Listing Number: 84.063, 84.268, 84.007, 84.038, 84.033 Federal Award Identification Number and Year: P268K251853, P063P241853, P007A242813, P033A24813; 2025 Award Period: June 1, 2024 – May 31, 2025 Type of Finding:  Significant Deficiency in Internal Control over Compliance  Other Matters Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 668.164(e) states, that whenever an institution disburses Title IV funds by crediting a student’s account and the total amount of all Title IV funds credited exceeds the amount of tuition and fees, room and board, and other authorized charges the institution assessed the student, the institution must pay the resulting credit balance directly to the student or parent as soon as possible but – 1) No later than 14 days after the balance occurred if the credit balance occurred after the first day of class of a payment period; or 2) No later than 14 days after the first day of class of a payment period if the credit balance occurred on or before the first day of class of that payment period Condition/Context: During our testing, 3 students out of a sample of 40 had a credit balance as a result of receiving Title IV aid that was not returned to the student or parent borrower within the required 14-days from the date the credit balance was derived. Questioned costs: No. Cause: The College’s internal controls for ensuring timely return of credit balances did not function properly. Effect: The College did not refund a student within 14 days for a credit balance that arose from federal funds as required by the Department of Education regulations. Repeat Finding: No. Recommendation: We recommend the College evaluate its procedures and review policies in overseeing student credit balances to ensure that any credit balances as a result of Title IV aid are returned within the required timeframe. Views of responsible officials: Please refer to the attached corrective action plan.

2025–007 Pell Award Federal Agency: U.S. Department of Education Federal Program Name: Student Financial Aid Cluster Assistance Listing Number: 84.063 Federal Award Identification Number and Year: P268K251853; 2025 Award Period: June 1, 2024 – May 31, 2025 Type of Finding:  Significant Deficiency in Internal Control over Compliance  Other Matters Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 690.61 states that: § 690.61 Submission process and deadline for a Student Aid Report or Institutional Student Information Record. (a) Submission process. (1) Except as provided in paragraph (a)(2) of this section, an institution must disburse a Federal Pell Grant to an eligible student who is otherwise qualified to receive that disbursement and electronically transmit Federal Pell Grant disbursement data to the Secretary for that student if— (i) The student submits a valid SAR to the institution; or (ii) The institution obtains a valid ISIR for the student. (2) In determining a student's eligibility to receive his or her Federal Pell Grant, an institution is entitled to assume that SAR information or ISIR information is accurate and complete except under the conditions set forth in 34 CFR 668.16(f) and 668.60. (b) Valid Student Aid Report or Valid Institutional Student Information Record deadline. Except as provided in the verification provisions of § 668.60 and the late disbursement provisions of § 668.164(g) of this chapter, for a student to receive a Federal Pell Grant for an award year, the student must submit the relevant parts of the valid SAR to his or her institution or the institution must obtain a valid ISIR by the earlier of— (1) The last date that the student is still enrolled and eligible for payment at that institution; or (2) By the deadline date established by the Secretary through publication of a notice in the Federal Register. § 690.62 Calculation of a Federal Pell Grant. (a) 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. (b) (1) (i) For a confined or incarcerated individual enrolled in an eligible prison education program, no Federal Pell Grant may exceed the cost of attendance (as defined in section 472 of the HEA) at the institution that student attends. (ii) If an institution determines that the amount of a Federal Pell Grant for that student exceeds the cost of attendance for that year, the amount of the Federal Pell Grant must be reduced until the Federal Pell Grant does not exceed the cost of attendance at such institution and does not result in a title IV credit balance under 34 CFR 668.164(h). Condition/Context: During our testing, it was noted that the student's student aid index (SAI) recorded in the College's system did not match the student's SAI per their ISIR. Since the College did not use the ISIR SAI to determine the student's Pell award for the 2024-2025 academic year, the College ultimately over-awarded the student $360 in Pell. Questioned costs: $360 Cause: During our testing, it was noted a student was over-awarded Pell due to the College using the incorrect SAI for the student. Effect: Inaccurate Pell amount awarded to student which could lead to compliance issues with regulations. Repeat Finding: No. Recommendation: We recommend that the College review its procedures to ensure their internal system pulls the correct SAI amounts directly from the student's ISIR when calculating a student’s Pell award. Views of responsible officials: Please refer to the attached corrective action plan.

Finding 2024-001: Assistance Listing #84.063 Federal Pell Grant Program. Criteria: The College is required to calculate the Federal Pell Grant award for a payment period by dividing the award amount by two semesters or three trimesters (34 CFR § 690.63 (b)). Condition: 4 students in our sample of 40 students were eligible for the annual Pell award, initially established to be paid over 3 trimesters based on expected enrollment. The students only attended the first 2 of the 3 trimesters and the award was not recalculated across the adjusted payment period. Cause: Due to the nature of the program enrolled, the students were expected to be on a trimester payment period. If the student did not complete the full trimester, the Pell Grant award was not recalculated to disburse the total eligible award amount. Effect: The College’s process to calculate a Pell Grant award was automated within the system and was not functioning properly for students enrolled in trimesters. The amount the College did not disburse to eligible students totaled $7,319. Questioned Costs: None Auditors’ Recommendation: The College should review its procedures for calculating the Pell Grant award to ensure compliance with requirements. Views of Responsible Officials: The College, upon identification of this issue, recalculated the Pell Grant awards and disbursed the eligible amounts to the 4 students. The College also conducted an internal review of students whose payment period was 3 trimesters based on expected enrollment and identified two additional students who only attended the first 2 of the three trimesters; the College recalculated and disbursed the eligible amounts to these two students. Additionally, the College immediately reviewed its procedures and made necessary changes.