Georgian Court UniversityHigher Education

2025-001 Special Tests and Provisions – Enrollment Reporting Federal Assistance Listing Number: 84.007, 84.033, 84.063, 84.268 and 84.379 Name of Program or Cluster: Student Financial Aid Cluster Agency: U.S. Department of Education Criteria: The University is required to update students’ statuses on the National Student Loans Data System (“NSLDS”) website if they graduate, withdraw or have an increase/decrease in attendance level during the year within 60 days of the date the University becomes aware of the change in enrollment status. Condition: The University did not submit an accurate status change notification or timely notification to the NSLDS website for six out of sixty students sampled from a total population of 606 who graduated, withdrew, or had an increase/decrease in attendance level during the year. Cause: Management oversight. Effect: Noncompliance with OMB federal grant compliance requirements. Questioned Costs: None. Repeat Finding: Yes. Recommendation: The University should properly follow its policies and procedures over enrollment reporting to ensure that all status changes are submitted to the NSLDS website accurately and within the required timeframe. Views of Responsible Officials: See corrective action plan attached.

2024-001 Special Tests and Provisions – Disbursements to or on Behalf of Students Federal Assistance Listing Number: 84.007, 84.033, 84.063, 84.268 and 84.379 Name of Program or Cluster: Student Financial Aid Cluster Agency: U.S. Department of Education Criteria: N. Special Tests and Provisions – Disbursements to or on Behalf of Students - Credit Balances – An institution is required to refund credit balances on student accounts within 14 days of the creation of the credit balance. If an institution attempts to refund the credit balance by check and the check is not cashed, the institution must return the funds to the Department of Education no later than 240 days after the date the school issued the check. Condition: The University did not refund credit balances to four out of sixty studentssampled from a total population of 1,495 within the required timeframe. Cause: Management oversight. Effect: Noncompliance with OMB federal grant compliance requirements. Questioned Costs: None. Repeat Finding: No. Recommendation: The University should develop a process to ensure all credit balances are refunded to student accounts within the required timeframe. Views of Responsible Officials: See corrective action plan attached.

2024-002 Special Tests and Provisions – Enrollment Reporting Federal Assistance Listing Number: 84.007, 84.033, 84.063, 84.268 and 84.379 Name of Program or Cluster: Student Financial Aid Cluster Agency: U.S. Department of Education Criteria: The University is required to update students’ statuses on the National Student Loans Data System (“NSLDS”) website if they graduate, withdraw or have an increase/decrease in attendance level during the year within 60 days of the date the University becomes aware of the change in enrollment status. Condition: The University did not submit an accurate status change notification or timely notification to the NSLDS website for thirty-three out of sixty students sampled from a total population of 682 who graduated, withdrew, or had an increase/decrease in attendance level during the year. Cause: Management oversight. Effect: Noncompliance with OMB federal grant compliance requirements. Questioned Costs: None. Repeat Finding: Yes. Recommendation: The University should properly follow its policies and procedures over enrollment reporting to ensure that all status changes are submitted to the NSLDS website accurately and within the required timeframe. Views of Responsible Officials: See corrective action plan attached.

Federal Program Information: Transition Program for Students with Intellectual Disabilities into Higher Education Grant (ALN: 84.407A). Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): The auditee must prepare a schedule of expenditures of Federal awards (“SEFA”) for the period covered by the auditee's financial statements which must include the total Federal awards expended as determined in accordance with § 200.502. At a minimum, the schedule must: (1) List individual Federal programs by Federal agency. For a cluster of programs, provide the cluster name, list individual Federal programs within the cluster of programs, and provide the applicable Federal agency name. For R&D, total Federal awards expended must be shown either by individual Federal award or by Federal agency and major subdivision within the Federal agency. (2) For Federal awards received as a subrecipient, the name of the pass-through entity and identifying number assigned by the pass-through entity must be included. (3) Provide total Federal awards expended for each individual Federal program and the Assistance Listings Number or other identifying number when the Assistance Listings information is not available. For a cluster of programs also provide the total for the cluster. (4) Include the total amount provided to subrecipients from each Federal program. (5) For loan or loan guarantee programs described in § 200.502(b), identify in the notes to the schedule the balances outstanding at the end of the audit period. This is in addition to including the total Federal awards expended for loan or loan guarantee programs in the schedule. (6) Include notes that describe that significant accounting policies used in preparing the schedule, and note whether or not the auditee elected to use the 10% de minimis cost rate as covered in § 200.414 (2 CFR section 200.510(b)). Condition: For certain Federal grant programs presented on the SEFA, the total amount provided to subrecipients during the year was not included. Cause: Administrative oversight with respect to SEFA preparation. Effect or Potential Effect: The University was not in compliance with SEFA presentation and disclosure requirements. Questioned Costs: None. Context: The University did not properly present and disclose approximately $162,000 of funds passed to subrecipients under the Transition Programs for Students with Intellectual Disabilities into Higher Education grant (ALN 84.407A) on the SEFA for the year ended June 30, 2023. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend the University enhance its policies and procedures to ensure that the SEFA has been prepared in accordance with the required guidelines and that it contains all minimum required elements that must be presented and disclosed, in accordance with federal regulations. Views of Responsible Officials and Planned Corrective Actions: The University Finance department has updated their policies and procedures to ensure that the SEFA is being prepared in accordance with required guidelines. We will work closely with our grants department to ensure all required elements are properly identified and disclosed.

Federal Program Information: Federal Direct Loan Program (ALN: 84.268) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): C. Cash Management - Institutions are permitted to draw down Title IV funds prior to disbursing funds to eligible students and parents. The institution’s request must not exceed the amount immediately needed to disburse funds to students or parents. A disbursement of funds occurs on the date an institution credits a student’s account or pays a student or parent directly with either student financial aid funds or institutional funds. The institution must make the disbursements as soon as administratively feasible, but no later than 3 business days following the receipt of funds. Any amounts not disbursed by the end of the third business day are considered to be excess cash and generally are required to be promptly returned to the U.S. Department of Education (the “ED”) (34 CFR section 668.166(a)(1)). Excess cash includes any funds received from the ED that are deposited or transferred to the institution’s Federal account as a result of an award adjustment, cancellation, or recovery. However, an excess cash balance is allowed and considered tolerable if that balance: (1) is less than one percent of its prior-year drawdowns; and (2) is eliminated within the next 7 calendar days (34 CFR sections 668.166(a) and (b)). Condition: An instance was identified during the year in which funds drawn were held in excess of the allowable time frame. Cause: Administrative oversight with respect to Cash Management compliance requirements. Effect or Potential Effect: The University was not in compliance with Cash Management compliance requirements. Questioned Costs: None. Context: During our testing, we identified 1 instance of cash held in excess of allowable time frames for the Federal Direct Loan Program, as noted below: Date of Excess Cash 6/13/23 Drawdown Amount $ 4,665 Days in Excess 25 Identification of Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend the University enhance its procedures over to ensure that excess cash is returned timely, in accordance with federal regulations. Views of Responsible Officials and Planned Corrective Actions: A turnover in personnel led to inconsistent refund processing for the Summer 2023 semester. There are multiple terms within the summer semester and the new personnel did not run refund files during the first term but ran them during the 2nd term. This is when the loan disbursement was realized and returned. Policies have been set in place outlining disbursement dates that coincide with refund processing dates.

Federal Program Information: Federal Supplemental Educational Opportunity Grants (ALN: 84.007), Federal Work-Study Program (ALN: 84.033), Federal Pell Grant Program (ALN: 84.063), Federal Direct Student Loans (ALN: 84.268) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): E. Eligibility – Calculation of Benefits – Awards must be coordinated among the various programs and with other federal and nonfederal aid (need and non-need based aid) to ensure that total aid is not awarded in excess of the student’s financial need or cost of attendance (“COA”) (34 CFR 668.42, FWS, and FSEOG, 34 CFR 673.5 and 673.6; Direct Loan, 34 CFR 685.301). For Title IV programs, the COA is generally the sum of the following: tuition and fees; an allowance for books, supplies, transportation, and miscellaneous personal expenses; an allowance for room and board; when applicable, allowances for costs for dependent care; costs associated with study abroad and cooperative education; costs related to disabilities; and fees charged for student loans. Condition: For certain students identified through our testing, the University did not properly calculate the student’s COA. Cause: Administrative oversight and lack of sufficient internal controls with respect to Title IV aid award eligibility. Effect or Potential Effect: The University is not in compliance with aid awarding criteria under the eligibility requirements. Failure to properly determine students’ COAs and calculate eligible award amounts could result in improper disbursements of Title IV funds. Questioned Costs: None. Context: For 16 of 25 students selected for testing, the University either did not properly calculate the student’s COA or was unable to support the components of the student’s COA that was used for awarding and disbursing Title IV aid. For all students noted with COA issues, we determined that there were no overawards of federal and nonfederal aid. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its policies, procedures and internal controls to ensure that Title IV aid is properly calculated, awarded and disbursed, consistent with federal regulations. Views of Responsible Officials and Planned Corrective Actions: For the 2023-2024 academic year Cost of Attendance Budgets were reviewed and tested to correct any miscalculations and omissions. Pell Budgets were updated to correctly differentiate program tuition and fees. Testing for 2024-2025 academic year has been updated and reviewed to accurately calculate Cost of Attendance Budgets. In some of the findings it was later found that due to changes made in the student’s record, the record should have run through the dynamic redetermination process to update the budget. The staff has been retrained in this process. The process for summer periods of enrollment has been reviewed and revised to flag students who initially applied and or registered for summer classes and subsequently did not register or dropped the classes during the add/drop period and the summer period of enrollment remained, thereby calculating a Cost of Attendance for summer.

Federal Program Information: Federal Pell Grant Program (ALN: 84.063) and Federal Direct Loan Program (ALN: 84.268) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): L. Reporting – Financial Reporting – Federal regulations require that the University submit origination and disbursement records for students to the Common Origination and Disbursement (“COD”) system. Items considered key in student origination records, if applicable, are: Social Security number, award amount, enrollment date, verification status code (when the applicate is selected for verification), transaction number, COA, and the “Academic Start Date” and “Academic End Date”. Condition: For certain students identified through our testing, errors were identified in key items reported to the COD in student origination records. Cause: Administrative oversight and lack of sufficient internal controls with respect to accurate reporting of federal award information. Effect or Potential Effect: The University was not in compliance with COD reporting requirements. Questioned Costs: None. Context: We noted the following exceptions: • For 18 of 25 students selected for testing, the student’s COA was inaccurately reported within the COD system. • For 2 of 25 students selected for testing, the enrollment date or “Academic Start Date” was inaccurately reported. • For 1 of 25 students selected for testing, the transaction number was inaccurately reported. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its policies, procedures, and internal controls to ensure origination records are accurately reported to the COD for Federal Direct Loan Program and Federal Pell Grant Program recipients, in accordance with federal regulations. Views of Responsible Officials and Planned Corrective Actions: Corrective action has been taken to ensure that when students have a spring start date in the prior academic year, the enrollment start date is updated to the correct enrollment start date. A cross check with a selection set has been added to capture any incorrect records and adjust accordingly.

Federal Program Information: Federal Supplemental Educational Opportunity Grants (ALN: 84.007) and Federal Work-Study Program (ALN: 84.033) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): L. Reporting – Special Reporting – The Fiscal Operations Report and Application to Participate (“FISAP”) is an electronic report submitted annual to receive funds for the campus-based programs. The institution uses the Fiscal Operations Report portion to report its expenditures in the previous award year and the Application to Participate portion to apply for the following year. Key line items containing critical information include: Part I, Identifying Information, Certification, and Warning; Part II, Application to Participate (selected sections); Part III, Fiscal Operations Report, Part IV, Fiscal Operations Report Federal Supplemental Educational Opportunity Grant (“FSEOG”) Program; Part V, Fiscal Operations Report Federal Work-Study (“FWS”) Program; and Part VI, Program Summary for Award Year. Condition: Through our testing, certain errors in key line items of the University’s FISAP were identified. Cause: Administrative oversight with respect to FISAP reporting. Effect or Potential Effect: The University is not in compliance with FISAP reporting requirements. Failure to report accurate records of expenditures for the previous award year could impact future availability of Title IV aid. Questioned Costs: None. Context: The University incorrectly reported certain required line items disclosing the uses of FWS funds during the year in Part V of the FISAP. Additionally, the total of less-than-full-time students was not properly reported in Part VI of the FISAP. Identification of Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend the University enhance its policies and procedures to ensure that key line items containing critical information are properly reported in the FISAP, in accordance with federal regulations. Views of Responsible Officials and Planned Corrective Actions: Corrections to the FISAP were made prior to the correction submission deadline date. A review in the Detail Reporting process in Powerfaids was conducted and determined that the process in Powerfaids initially reported that students who should have been included as full time were reverted to part time status if the last period of enrollment was less than fulltime. We have worked with Powerfaids to resolve this issue. Corrections were made to all Part V errors prior to the correction submission date. Payroll has been apprised that only ten percent of the JDL administrator salary can be attributed to and or drawn down from Federal Work Study funds.

Federal Program Information: Federal Supplemental Educational Opportunity Grants (ALN: 84.007), Federal Pell Grant Program (ALN: 84.063), Federal Direct Student Loans (ALN: 84.268) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions – Return of Title IV Funds: The amount of earned Title IV grant or loan assistance is calculated by determining the percentage of Title IV grant or loan assistance that has been earned by the student and applying that percentage to the total amount of Title IV grant or loan assistance that was or could have been disbursed to the student for the payment period or period of enrollment as of the student’s withdrawal date. A student earns 100 percent if his or her withdrawal date is after the completion of 60 percent of (1) the calendar days in the payment period or period of enrollment for a program measured in credit hours, or (2) the clock hours scheduled to be completed for the payment period or period of enrollment for a program measured in clock hours (34 CFR 668.22(e)(2)). Otherwise, the percentage earned by the student is equal to the percentage (60 percent or less) of the payment period or period of enrollment that was completed as of the student’s withdrawal date. The percentage of Title IV grant or loan assistance that has not been earned by the student is the complement of one of these calculations. Standard termbased institutions must always use the payment period as the basis for the determination. The unearned amount of Title IV assistance to be returned is calculated by subtracting the amount of Title IV assistance earned by the student from the amount of Title IV aid that was disbursed to the student as of the date of the institution’s determination that the student withdrew (34 CFR 668.22(e)). Condition: For certain students identified through our testing, the University did not properly calculate the amounts to be returned to the ED. Cause: Administrative oversight with respect to return of Title IV fund calculations. Effect or Potential Effect: The University is not in compliance with the return of Title IV funds requirements. Questioned Costs: None. Context: For 1 of 2 students selected for testing, the University did not properly calculate the amount of Title IV aid to be returned to the ED. The amount returned to the ED was greater than the amount owed based upon the student’s withdrawal date. Identification of Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend the University enhance its procedures over the return of Title IV fund calculations to ensure that returns of funds are calculated accurately, in accordance with federal regulations. Views of Responsible Officials and Planned Corrective Actions: The issue has been addressed and reviewed. Going forward the Director of Financial Aid will set up and review all periods of enrollment and dates in the return of funds calculation on COD prior to the start of the academic year.

Federal Program Information: Federal Pell Grant Program (ALN: 84.063), Federal Direct Student Loans (ALN: 84.268), Teacher Education Assistance for College and Higher Education Grants (ALN: 84.379) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Enrollment Reporting: The University is required to update students’ statuses on the National Student Loans Data System (“NSLDS”) website if they graduate, withdraw or have an increase/decrease in attendance level during the year within 60 days of the date the University becomes aware of the change in enrollment status. 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. Institutions are responsible for accurately reporting the significant data elements under the Campus-Level Record and Program-Level Record that ED considers high risk. Additionally, institutions are responsible for timely reporting, whether they report directly or via a third-party servicer. As with any school/servicer arrangement for the administration of the Title IV programs, if the school uses a third party to meet the NSLDS enrollment reporting requirements it is the school that must ensure that enrollment information is submitted timely, accurately, and completely. Per the Federal Student Aid Handbook, schools are required to certify enrollment for all students who are included on their roster file scheduled at least every two months, and within 15 days of the date that NSLDS sends a roster file to the school or its third-party servicer. Any errors identified and returned by NSLDS in an Error/Acknowledgement file should be corrected and resubmitted within 10 days. Condition: The University did not submit an accurate status change notification or timely notification to the NSLDS website for certain students who graduated, withdrew, or had an increase/decrease in attendance level during the year. Additionally, the University’s fiscal year SCHER1 report included multiple instances in which error records were not corrected within the required timeframe. Cause: Administrative oversight with respect to enrollment reporting compliance requirements. Effect or Potential Effect: The University is not in compliance with enrollment reporting compliance requirements. Failure to promptly report accurate and timely changes in enrollment status may adversely impact the repayment status for student loan borrowers. Questioned Costs: None. Context: We noted the following exceptions as a result of our procedures: • For 1 of 40 students sampled whose status changed during the year, the University failed to accurately report all significant data elements under the Campus- Level Record in a timely notification to the NSLDS website. • For 4 of 25 students sampled whose status changed during the year, the University failed to accurately report all significant data elements under the Program-Level Record in a timely notification to the NSLDS website. • For 5 of 6 Error Reports tested, error records identified in Error/Acknowledgment files were not corrected within the required timeframe. Identification of Repeat Finding: This is a repeat finding from prior year. This was reported as Finding 2022-003 in the prior year schedule of findings and questioned costs. Recommendation: We recommend that the University properly follow its policies and procedures over enrollment reporting to ensure that all status changes are submitted to the NSLDS website within the required timeframe and that error records are corrected and submitted timely, consistent with federal regulations. Views of Responsible Officials and Planned Corrective Actions: With regards to Error #2023-007, some of the findings were related to incorrect reporting of graduation status, graduation date, and program begin date. We identified that some dates had not been correctly entered. We are working with our student information system software consultants and National Student Clearinghouse personnel to ensure that all staff understand reporting requirements, and we have taken steps to correct errors before we submit reports. Another finding was that error records were not corrected within the required timeframe. There has been a change in staffing in the office since the time periods of the audit findings, so a different person is now correcting error records. That individual has been made aware of the audit findings and has committed to work with office personnel and National Student Clearinghouse on correcting reported errors promptly.

Federal Program information: Federal Supplemental Educational Opportunity Grants (ALN: 84.007), Federal Work-Study Program (ALN: 84.033), Federal Pell Grant Program (ALN: 84.063), Federal Direct Student Loans (ALN: 84.268), Teacher Education Assistance for College and Higher Education Grants (ALN: 84.379) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Test and Provisions ? Verification - An institution shall require an applicant selected for verification to submit acceptable documentation that will verify or update the following information used to determine the applicant's Expected Family Contribution (EFC): adjusted gross income, U.S. income tax paid, aggregate number of family members in the household, number of family members in the household who are enrolled in as at least half-time students in postsecondary educational institutions if that number is greater than one and untaxed income subject to U.S. income tax reporting requirements in the base year which is included on the tax return form, excluding information contained on schedules appended to such forms. Untaxed income and benefits include: Social Security benefits if the institution has reason to believe that those benefits were received and were not reported or were not correctly reported; child support if the institution has reason to believe child support was received; U.S. income tax deductions for a payment made to an individual retirement account or Keough account; interest on tax-free bond; foreign income excluded from U.S. income taxation if the institution has reason to believe that foreign income was received; and all other untaxed income subject to U.S. income tax reporting requirements in the base year included on the tax return form, excluding information contained on schedules appended to such forms. (34 CFR section 668.56). Condition: For certain students selected for verification, the information required to be verified did not match the underlying supporting documentation. Cause: Administrative oversight with respect to verification procedures. Effect or Potential Effect: Federal awards were not disbursed in accordance with federal regulations, and the University was not in compliance with verification compliance requirements. Questioned Costs: Below reporting threshold. Context: For 3 of 25 students selected for verification testing, the University did not perform appropriate verification procedures. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend the University enhance its policies and procedures to ensure that the appropriate verification procedures are performed for all students who are selected for verification unless excluded by the federal regulations.

Federal Program information: Federal Direct Student Loan Program (ALN: 84.268) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Test and Provisions ? Disbursements To or On Behalf of Students ? Loan Disbursement Notification - Federal regulations (34 CFR section 668.165 (a)(6)(i)) require that the institution 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 the 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. Institutions that implement an affirmative confirmation process (as described in 34 CFR section 668.165 (a)(6)(i)) must make this notification to the student or parent no earlier than 30 days before, and no later than 30 days after, crediting the student?s account at the institution with Direct Loan or TEACH Grants. The Federal Student Aid Handbook further clarifies that in general, there are two types of notifications a school must provide: (1) a general notification to parent Direct PLUS borrowers and all students receiving Federal Student Aid (?FSA?) funds, and (2) a notice when FSA loan funds or TEACH Grant funds are credited to a student?s account. Condition: Certain borrowers did not receive a loan disbursement notification or the University was unable to provide a copy of the loan disbursement notification sent to the student. Cause: Administrative oversight with respect to loan disbursement notifications. Effect or Potential Effect: Students were not properly notified of loan disbursements and/or their right to cancel/decline loan awards. Questioned Costs: None. Context: For 3 of 25 students selected for testing, the University was unable to provide documentation supporting appropriate loan disbursement notification. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend the University enhance its procedures over loan disbursement notifications to ensure that such notifications are sent to student and/or parent borrowers within the required timeframe.

Federal Program information: Federal Pell Grant Program (ALN: 84.063), Federal Direct Student Loans (ALN: 84.268), Teacher Education Assistance for College and Higher Education Grants (ALN: 84.379) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Enrollment Reporting: The University is required to update students? statuses on the National Student Loans Data System (NSLDS) website if they graduate, withdraw or have an increase/decrease in attendance level during the year within 60 days of the date the University becomes aware of the change in enrollment status. 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. Institutions are responsible for accurately reporting the significant data elements under the Campus-Level Record and Program-Level Record that ED considers high risk. Additionally, institutions are responsible for timely reporting, whether they report directly or via a third-party servicer. As with any school/servicer arrangement for the administration of the Title IV programs, if the school uses a third party to meet the NSLDS enrollment reporting requirements it is the school that must ensure that enrollment information is submitted timely, accurately, and completely. Condition: The University did not submit an accurate status change notification or timely notification to the NSLDS website for certain students who graduated, withdrew, or had an increase/decrease in attendance level during the year. Cause: Administrative oversight with respect to enrollment reporting requirements. Effect or Potential Effect: The University is not in compliance with enrollment reporting requirements. Failure to promptly report accurate and timely changes in enrollment status may adversely impact the repayment status for student loan borrowers. Questioned Costs: None. Context: We noted the following exceptions as a result of our procedures: ? For 3 of 40 students sampled whose status changed during the year, the University failed to accurately report all significant data elements under the Campus-Level Record in a timely notification to the NSLDS website. ? For 1 of 25 students sampled whose status changed during the year, the University failed to accurately report all significant data elements under the Program-Level Record in a timely notification to the NSLDS website. Identification as a Repeat Finding: This is a repeat finding from prior year. This was reported as Finding 2021-002 in the prior year schedule of findings and questioned costs. Recommendation: We recommend that the University properly follow its policies and procedures over enrollment reporting to ensure that all status changes are submitted to the NSLDS website within the required timeframe.

Federal Program information: Federal Supplemental Educational Opportunity Grants (ALN: 84.007), Federal Work-Study Program (ALN: 84.033), Federal Pell Grant Program (ALN: 84.063), Federal Direct Student Loans (ALN: 84.268), Teacher Education Assistance for College and Higher Education Grants (ALN: 84.379) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions ? Disbursements to or on Behalf of Students - Credit Balances - An institution is required to refund credit balances on student accounts within 14 days of the creation of the credit balance. If an institution attempts to refund the credit balance by check and the check is not cashed, the institution must return the funds to the Department of Education no later than 240 days after the date the school issued the check. Condition: The University did not refund credit balances to certain students within the required timeframe. Cause: Administrative oversight with respect to the disbursement of federal awards. Effect or Potential Effect: The University was not in compliance with the required federal guidelines over credit balances from student financial assistance. Questioned Costs: None. Context: For 3 of 40 Federal Student Aid credit balances selected for testing, the credit balance was not refunded to the student within the required 14-day timeframe. Identification as a Repeat Finding: This is a repeat finding from prior year. This was reported as Finding 2021-003 in the prior year schedule of findings and questioned costs. Recommendation: We recommend that the University enhance its policies and procedures by implementing a process to disburse credit balances created by federal awards within the required time frame.

Federal Program information: COVID-19 Education Stabilization Fund (ESF) ? Student Aid Portion (ALN: 84.425E) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): L. Reporting ? Special Reporting ? Quarterly Public Reporting ? The University is required to publicly post certain information for the Student Aid Portion award on the University?s website in a conspicuous location. Institutions must post certain key line items identified by the ED as critical information directly to their website each calendar quarter, and reports must be updated no later than 10 days after the end of each calendar quarter. Condition: Certain key line items were not correctly reported in the University?s quarterly reports. Cause: Administrative oversight with respect to quarterly public reporting requirements. Effect or Potential Effect: The University is not in compliance with reporting requirements. Questioned Costs: None. Context: For 2 of 2 quarters selected for testing, certain required key line items for the Student Aid Portion awards reported on the University?s website contained inaccurate information. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend the University enhance its policies and procedures over quarterly reporting to ensure that all required information is reported accurately, in accordance with federal regulations.

Federal Program Information: Federal Work-Study Program (CFDA #84.033) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): Cash Management - Institutions are permitted to draw down Title IV funds prior to disbursing funds to eligible students and parents. The institution?s request must not exceed the amount immediately needed to disburse funds to students or parents. A disbursement of funds occurs on the date an institution credits a student?s account or pays a student or parent directly with either student financial aid funds or institutional funds. The institution must make the disbursements as soon as administratively feasible, but no later than 3 business days following the receipt of funds. Any amounts not disbursed by the end of the third business day are considered to be excess cash and generally are required to be promptly returned to the U.S. Department of Education (the ?ED?) (34 CFR section 668.166(a)(1)). Excess cash includes any funds received from the ED that are deposited or transferred to the institution?s Federal account as a result of an award adjustment, cancellation, or recovery. However, an excess cash balance tolerance is allowed if that balance: (1) is less than one percent of its prior-year drawdowns; and (2) is eliminated within the next 7 calendar days (34 CFR sections 668.166(a) and (b)). Condition: An instance was identified where funds drawn were held in excess of the allowable time frame. Cause: Lack of administrative oversight with respect to Cash Management compliance requirements. Effect or Potential Effect: The University is not in compliance with Cash Management compliance requirements. Questioned Costs: None. Context: 1 instance of cash held in excess of the allowable time frame for the Federal Work-Study Program was identified during the fiscal year. Identification as a Repeat Finding: This is a repeat finding from prior year. This was reported as Finding 2020-001 in the prior year schedule of findings and questioned costs. Recommendation: We recommend the University enhance its procedures to ensure that excess cash is returned timely.

Federal Program Information: Student Financial Assistance Cluster (CFDA#: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Enrollment Reporting - According to the Federal Student Aid Handbook, schools are required to certify enrollment for all students who are included on their roster file scheduled at least every two months, and within 15 days of the date that National Students Loan Data System (NSLDS) sends a roster file to the school or its third-party servicer. Any errors identified and returned by NSLDS in an Error/Acknowledgement file should be corrected and resubmitted within 10 days. Condition: For certain students selected for testing who graduated during the year, the University did not submit an appropriate and/or timely status change notification to the NSLDS website. Additionally, certain error files received from NSLDS were not corrected and submitted timely. Cause: Insufficient administrative oversight with respect to Reporting compliance requirements. Effect or Potential Effect: The University is not in compliance with Reporting compliance requirements. Questioned Costs: None. Context: We noted the following exceptions as a result of our procedures: ? For 2 of the 40 students? campus-level records selected for testing, the University did not submit an appropriate status change notification. ? For multiple instances during the fiscal year, error records identified in Error/Acknowledgment files were not corrected within the required timeframe. Identification as a Repeat Finding: This is a repeat finding from prior year. This was reported as Finding 2020-003 in the prior year schedule of findings and questioned costs. Recommendation: We recommend that the University implement procedures to ensure that error records are corrected and submitted timely.

Federal Program Information: Student Financial Assistance Cluster (CFDA #: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions ? Disbursements to or on Behalf of Students - Credit Balances - An institution is required to refund credit balances on student accounts within 14 days of the creation of the credit balance. If an institution attempts to refund the credit balance by check and the check is not cashed, the institution must return the funds to the Department of Education no later than 240 days after the date the school issued the check. Condition: The University did not refund credit balances to certain students within the required timeframe Cause: Lack of administrative oversight with respect to the disbursement of federal awards. Effect or Potential Effect: The University was not in compliance with the required federal guidelines over credit balances from student financial assistance. Questioned Costs: None. Context: For 4 of 40 Federal Student Aid credit balances selected for testing, the credit balance was not refunded to the student within the required 14-day timeframe. Identification as a Repeat Finding: This is a repeat finding from prior year. This was reported as Finding 2020-005 in the prior year schedule of findings and questioned costs. Recommendation: We recommend that the University enhance its policies and procedures by implementing a process to disburse credit balances created by federal awards within the required time frame.

Federal Program Information: Federal Direct Student Loan Program (CFDA #84.268) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): Cash Management - Institutions are permitted to draw down Title IV funds prior to disbursing funds to eligible students and parents. The institution?s request must not exceed the amount immediately needed to disburse funds to students or parents. A disbursement of funds occurs on the date an institution credits a student?s account or pays a student or parent directly with either student financial aid funds or institutional funds. The institution must make the disbursements as soon as administratively feasible, but no later than 3 business days following the receipt of funds. Any amounts not disbursed by the end of the third business day are considered to be excess cash and generally are required to be promptly returned to the U.S. Department of Education (the ?ED?) (34 CFR section 668.166(a)(1)). Excess cash includes any funds received from the ED that are deposited or transferred to the institution?s Federal account as a result of an award adjustment, cancellation, or recovery. However, an excess cash balance tolerance is allowed if that balance: (1) is less than one percent of its prior-year drawdowns; and (2) is eliminated within the next 7 calendar days (34 CFR sections 668.166(a) and (b)). Condition: An instance was identified where funds drawn were held in excess of the allowable time frame. Cause: Lack of administrative oversight with respect to Cash Management compliance requirements. Effect or Potential Effect: The University is not in compliance with Cash Management compliance requirements. Questioned Costs: None. Context: 1 instance of cash held in excess of the allowable time frame for the Federal Direct Student Loan Program was identified during the fiscal year. Identification as a Repeat Finding: There was no similar finding identified during the prior year. Recommendation: We recommend the University enhance its procedures to ensure that excess cash is returned timely. Views of Responsible Officials and Planned Corrective Actions: This occurred during the tenure of previous management who have since left the University. Under the current staffing in the Student Accounts Office, good record-keeping is being exercised in conjunction with the Financial Aid Office. Since reconciling Direct Loans is being performed on a regular basis. It is unlikely this issue will re-occur.

Federal Program Information: Student Financial Assistance Cluster (CFDA#: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions ? Verification - An institution shall require an applicant selected for verification to submit acceptable documentation that will verify or update the following information used to determine the applicant's expected family contribution (?EFC?): adjusted gross income, U.S. income tax paid, aggregate number of family members in the household, number of family members in the household who are enrolled in as at least half-time students in postsecondary educational institutions if that number is greater than one and untaxed income subject to U.S. income tax reporting requirements in the base year which is included on the tax return form, excluding information contained on schedules appended to such forms. Untaxed income and benefits include: Social Security benefits if the institution has reason to believe that those benefits were received and were not reported or were not correctly reported; child support if the institution has reason to believe child support was received; U.S. income tax deductions for a payment made to an individual retirement account or Keough account; interest on tax-free bond; foreign income excluded from U.S. income taxation if the institution has reason to believe that foreign income was received; and all other untaxed income subject to U.S. income tax reporting requirements in the base year included on the tax return form, excluding information contained on schedules appended to such forms. (34 CFR section 668.56). Condition: For certain students selected for verification, the information required to be verified either did not match the underlying supporting documentation (including tax information recorded on the students? W-2) or the information could not be provided by the University. Cause: Insufficient administrative oversight in regards to verification procedures. Effect or Potential Effect: Federal awards were not disbursed in accordance with federal regulations and the University was not in compliance with verification compliance requirements. Questioned Costs: None. Context: For 3 of 25 students selected for verification testing, the University did not perform appropriate verification procedures. Identification as a Repeat Finding: No similar findings identified in the prior year. Recommendation: We recommend that the University follow their established policies and procedures to ensure that the appropriate verification procedures are performed for all students who are selected for verification unless excluded by the federal regulations. Views of Responsible Officials and Planned Corrective Actions: For the past several years the Financial Aid Office has been understaffed and has experienced turnover of seasoned financial aid counselors. Staffing of counselors has stabilized and the University has recently approved and hired an Assistant Director of Financial Aid who will add another layer of quality control within the department. The verification findings were reviewed and clarified with the counselors. All staff members will be required to attend NASFAA Verification training webinars, maintain copies of the handouts provided for reference and participate in periodic staff reviews of the required verification data elements.

Federal Program Information: Student Financial Assistance Cluster (CFDA#: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Enrollment Reporting - According to the Federal Student Aid Handbook, schools are required to certify enrollment for all students who are included on their roster file scheduled at least every two months, and within 15 days of the date that NSLDS sends a roster file to the school or its third-party servicer. Any errors identified and returned by NSLDS in an Error/Acknowledgement file should be corrected and resubmitted within 10 days. Condition: The University?s fiscal year SCHER1 report, included multiple instances in which error records were not corrected within the required timeframe. Cause: Insufficient administrative oversight with respect to Reporting compliance requirements. Effect or Potential Effect: The University is not in compliance with Reporting compliance requirements. Questioned Costs: None. Context: For multiple instances during the fiscal year, error records identified in Error/Acknowledgment files were not corrected within the required timeframe. Identification as a Repeat Finding: This is a repeat finding from prior year. This was reported as Finding 2019-001 in the prior year schedule of findings and questioned costs. Recommendation: We recommend that the University implement procedures to ensure that error records are corrected and submitted timely. Views of Responsible Officials and Planned Corrective Actions: The primary reason for the delay in correction of errors in enrollment reporting is due to a series of personnel turnover and student responsiveness to requests for information. As of August 2020, Georgian Court University appointed Kathleen Boody as the primary responsible party for enrollment reporting in her capacity as Associate Vice President for Retention after the departure of the third Registrar within 18 months. Two additional positions have been added to the office of the Registrar to share all responsibilities including a new Assistant Registrar. Kathleen Boody, the Assistant Registrar and several other registrar office staff have been participating in ongoing trainings & webinars for enrollment reporting through the National Student Clearing House. For compliance with the NSLDS, reporting errors must be resolved timely, preferably within 10 days. The additional staff and training will permit that attention to accurate resolution of enrollment reporting. With the virtual work and enrollment environment (COVID -19 required), it has been challenging to obtain validation of social security numbers, names and other required documents timely from students. Mechanisms of enrollment holds were used as well as multiple email and phone calls to the students to resolve the matter proved difficult. The university will establish beyond enrollment holds, other metrics for gathering required documentation from students, such as removal from class access to the learning management system or deactivating student ID card access.

Federal Program Information: Student Financial Assistance Cluster (CFDA#: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions ? Disbursements To or On Behalf of Students - Transfer Monitoring - If a student received financial aid while attending one or more other institutions schools are required to request financial aid history using the National Student Loans Data System (?NSLDS?) Student Transfer Monitoring Process. Under this process, a school informs NSLDS about its transfer students. NSLDS will ?monitor? those students on the school?s ?inform? list and ?alert? the school of any relevant financial aid history changes. A school must wait 7 days after it ?informs? NSLDS about a transfer student before disbursing Title IV aid to that student (34 CFR section 668.19). Condition: For certain students that transferred in to the University during the fiscal year, the University did not add the students to the NSLDS `alert? list and was unable to provide documentation supporting that the students? financial aid history was reviewed prior to disbursing Title IV aid. Additionally, the University was unable to provide an accurate detail of all students who transferred into the University during the year. Cause: Insufficient administrative oversight in regards to monitoring of transfer students. Effect or Potential Effect: The University is not in compliance with the required federal guidelines over transfer monitoring. Questioned Costs: None. Context: For 2 out of 6 students selected for testing, the University did not appropriately add the students to the NSLDS `alert? list and was unable to provide documentation supporting that the students? financial aid history was reviewed prior to disbursing Title IV aid. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls to follow it policies and procedures in place to ensure that all transfer students are appropriately tracked/monitored as required. Views of Responsible Officials and Planned Corrective Actions: The past several years the Financial Aid Office has been understaffed and has experienced turnover of seasoned financial aid counselors. Staffing of counselors has stabilized and the University has recently approved and hired an Assistant Director of Financial Aid who will add another layer of quality control within the department. The transfer monitoring process has been enhanced to ensure all students are reported to NSLDS for transfer monitoring. For the 2020-2021 mid-year Transfer Monitoring process the department began using the NSLDS Transfer Monitoring functionality in PowerFAIDS. Transfer students were coded in PowerFAIDS when they were packaged for financial aid. Reports were then generated through PowerFAIDS and sent to NSLDS. Alert reports and acknowledgment files were received from NSLDS and reviewed.

Federal Program Information: Student Financial Assistance Cluster (CFDA #: Various) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions ? Disbursements to or on Behalf of Students - Credit Balances - An institution is required to refund credit balances on student accounts within 14 days of the creation of the credit balance. If an institution attempts to refund the credit balance by check and the check is not cashed, the institution must return the funds to the Department of Education no later than 240 days after the date the school issued the check. Condition: The University did not refund credit balances to certain students within the required timeframe Cause: Lack of administrative oversight with respect to the disbursement of federal awards. Effect or Potential Effect: The University was not in compliance with the required federal guidelines over credit balances from student financial assistance. Questioned Costs: None. Context: For 2 of 25 students selected for testing, the credit balance created by the disbursement of Title IV awards was not refunded to the student within the required 14-day timeframe. Identification as a Repeat Finding: There was no similar finding identified during the prior year. Recommendation: We recommend that the University enhance its policies and procedures by implementing a process to disburse credit balances created by federal awards within the required time frame. Views of Responsible Officials and Planned Corrective Actions: Staff turnover has left incomplete records for these two transactions. For the other transactions that were tested, current staff has complete records and are knowledgeable of the regulations and are meeting them completely. Except for the turnover in staff, the policies in place will ensure timely refunds when a credit balance is created.

Federal Program Information: Higher Education Emergency Relief Fund (?HEERF?) Student Aid Portion (CFDA 84.425E) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): Activities Allowed and Unallowed: Students who are or could be eligible to participate in programs under Section 484 in Title IV of the Higher Education Act of 1965, as amended (?HEA?), may receive emergency financial aid grants. Condition: In the process of the University?s review of students receiving the HEERF Student Aid, the University identified certain students who received a HEERF grant who were ineligible. Cause: Insufficient administrative oversight in regards to the disbursement of emergency financial aid grants. Effect or Potential Effect: The University is not in compliance with requirements related to allowable activities. Questioned Costs: Below reporting threshold. Context: 3 of 282 students who received HEERF emergency financial aid grants were ineligible. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend the University undertake a review of all students who receive future HEERF grants to determine eligibility prior to distribution of funds. Views of Responsible Officials and Planned Corrective Actions: For the past several years the Financial Aid Office has been understaffed and has experienced turnover of seasoned financial aid counselors. Staffing of counselors has stabilized and the University has recently approved and hired an Assistant Director of Financial Aid who will add another layer of quality control within the department. HEERF funds distributed to ineligible students were reversed and returned for distribution in the 2020-2021 academic year. The institution replaced the funds disbursed to the students with institutional funds. Additional processes have been implemented to review enrollment and program verification prior to funds being disbursed.

The University receives the Enrollment Reporting roster file every month. Utilizing the National Student Clearinghouse (the Clearinghouse), it submits enrollment information to NSLDS each time a roster is received. Furthermore, the University supplements these submissions with their own direct submissions to NSLDS on a more frequent basis in order to ensure proper reporting of each student?s status. For a sample of forty students selected for testwork, twenty-seven selections who withdrew or graduated, the change in status was appropriately reported to NSLDS, but not within the required timeframe. The number of days ranged from 1 to 329 days late.