Rider UniversityHigher Education

2025-002 – Awarding of Direct Loans Federal Agency: U.S. Department of Education Federal Program Name: Federal Direct Student Loans Assistance Listing Number: 84.268 Federal Award Identification Number and Year: P268K241818; P268K251818 - 2025 Award Period: 7/1/2024 – 6/30/2025 Type of Finding: Significant Deficiency in Internal Control Over Compliance, Other Matters Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 685.203 specifies the annual and aggregate loan limits the Institutions may not exceed for an academic year of study under the Direct Loan program and also requires loans to be prorated for a program of student that is less than a full academic year in length. Condition: Testing identified that 1 out of 40 students was awarded and disbursed Direct Loans in excess of the annual loan limit applicable to the student’s grade level and dependency status. Questioned costs: $5,000 Context: During our testing, one student was awarded and disbursed $12,500 in direct loans, when they were only eligible for $7,500 based on their grade-level and dependency status. Cause: The University did not resolve an ISIR code that identified a direct loan over-award and did not effectively ensure loan limits were properly applied. Effect: The student received Direct Loan funds in excess of their eligible amount, resulting in noncompliance with federal program requirements. Repeat finding: No. Recommendation: We recommend the University strengthen its review procedures over student award packages, including a review at the start of each academic year, to ensure Direct Loans are awarded in accordance with grade level and dependency status limits. We also recommend the University review all ISIR codes and resolve any that are necessary. Views of responsible officials: There is no disagreement with the audit finding.

2025-003 – Common Origination and Disbursement (COD) Reporting Federal Agency: U.S. Department of Education Federal Program Name: Federal Pell Grant Program Assistance Listing Number: 84.063 Federal Award Identification Number and Year: P063P231818; P063P241818 - 2025 Award Period: 7/1/2024 – 6/30/2025 Type of Finding: Significant Deficiency in Internal Control Over Compliance, Other Matters Criteria or specific requirement: Department of Education regulations require institutions to report Pell Grant and Direct Loan disbursement dates and amounts to the Common Origination and Disbursement (COD) system within 15 days of disbursement (34 CFR 690.83(b)(2) and 34 CFR 685.309). Condition: During our testing, we noted the University did not have adequate internal controls to ensure timely reporting to the COD. Questioned costs: None. Context: During our testing, we noted 6 out of 18 Pell disbursements were not reported within the 15 days required to the COD. Cause: The University’s procedures for timely reporting Pell Grant disbursements to COD were not functioning effectively. Effect: The University is not in compliance with COD reporting requirements. Repeat finding: No. Recommendation: We recommend the University review and enhance its policies and procedures related to COD reporting to ensure all disbursement information is reported accurately and within required timeframes. Views of responsible officials: There is no disagreement with the audit finding.

2025-004 – Title IV Credit Balances Federal Agency: U.S. Department of Education Federal Program Name: Federal Pell Grant Program, Federal Direct Student Loans, Federal Supplemental Education Opportunity Grants, Federal Work-Study Program Assistance Listing Number: 84.063, 84.268, 84.007, 84.033 Federal Award Identification Number and Year: P268K241818; P268K251818; P063P231818; P063P241818; P007A232600; PA007A242600; P033A242600 - 2025 Award Period: 7/1/2024 – 6/30/2025 Type of Finding: Significant Deficiency in Internal Control Over Compliance, Other Matters Criteria or specific requirement: The Department of Education requires the University to obtain written authorization to hold a Title IV credit balance to apply to future charges within the same academic year. Condition: Testing identified that for 1 out of 40 students, a Title IV credit balance was applied to a subsequent academic term without obtaining written authorization from the student. Questioned costs: None. Context: During our testing, it was noted that a student had a Title IV credit balance and balance was applied to a subsequent term without obtaining written authorization from the student. Cause: The University did not have policies or procedures in place to ensure written authorization for holding Title IV credit balances was obtained and retained. Effect: The University did not comply with Title IV requirements related to the handling of student credit balances. Repeat finding: No. Recommendation: We recommend the University implement policies and monitoring procedures to ensure Title IV credit balances are either refunded to students in a timely manner or supported by documented written authorization. Views of responsible officials: There is no disagreement with the audit finding.

2025-005 – Return of Title IV (R2T4) Calculations Federal Agency: U.S. Department of Education Federal Program Name: Federal Pell Grant Program, Federal Direct Student Loans, Federal Supplemental Education Opportunity Grants Assistance Listing Number: 84.063, 84.268, 84.007 Federal Award Identification Number and Year: P268K241818; P268K251818; P063P231818; P063P241818; P007A232600; PA007A242600 - 2025 Award Period: 7/1/2024 – 6/30/2025 Type of Finding: Significant Deficiency in Internal Control Over Compliance, Other Matters Criteria or specific requirement: Federal regulations require institutions to determine a student’s withdrawal date and calculate the percentage of the payment period completed to determine the amount of Title IV aid earned. Institutionally scheduled breaks of five or more consecutive days must be excluded from the calculation (34 CFR 668.22(f)(2)(i)). Regulations also define withdrawal dates for institutions that are required to take attendance and those that are not (34 CFR 668.22). Condition: Testing disclosed that in 1 out of 12 R2T4 calculations, an incorrect withdrawal date was used. Questioned costs: $51. Context: During our testing, we noted 1 instance where an incorrect withdrawal date was used in the calculation. Cause: Human error resulted in incorrect data being used. Effect: An incorrect amount of Title IV funds was returned to the Department of Education. Repeat finding: No. Recommendation: We recommend the University review and strengthen its policies and procedures for completing R2T4 calculations to ensure accurate inputs. Views of responsible officials: There is no disagreement with the audit finding.

2025-006 – National Student Loan Data System Federal Agency: U.S. Department of Education Federal Program Name: Federal Pell Grant Program, Federal Direct Student Loans Assistance Listing Number: 84.063, 84.268 Federal Award Identification Number and Year: P268K241818; P268K251818; P063P231818; P063P241818; P063Q221818, P063Q231818, P063Q241818 - 2025 Award Period: 7/1/2024 – 6/30/2025 Type of Finding: Significant Deficiency in Internal Control Over Compliance, Other Matters Criteria or specific requirement: Per U.S. Department of Education (ED) regulations, all schools participating (or approved to participate) in the Federal Student Aid programs must have an arrangement to report student enrollment data to the NSLDS through a roster file. The school is required to report enrollment status at both the school and program level. The school is required to report changes in the student’s enrollment status, the effective date of the status and an anticipated completion date. An academic program is defined as the combination of the school’s Office of Postsecondary Education Identification (OPEID) number and the program’s Classification of Instructional Program (CIP) code, credential level, and published program length. ED requires the University to report changes in enrollment status and indicate the date that the changes occurred (34 CFR 685.309). Condition: Certain students' enrollment information was not reported accurately to NSLDS or no information was reported at all. Questioned costs: None. Context: Testing of 40 students identified that enrollment information for certain students was not reported accurately or was not reported at all. Specifically: • One student’s program-level effective date did not agree between University records and NSLDS. • One student was never reported to NSLDS. Cause: The University’s procedures for identifying and reporting enrollment status changes to NSLDS were not functioning effectively. Effect: Inaccurate reporting to the NSLDS can impact when students enter repayment periods or affect their interest rates. Repeat finding: No. Recommendation: We recommend the University evaluate its policies and procedures around reporting student status changes to the NSLDS to ensure that all relevant information is being captured and reported in accordance with applicable regulations. Views of responsible officials: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Education Federal Program Name: Federal Pell Grant Program, Federal Supplemental Education Opportunity Grants Assistance Listing Number: 84.063, 84.007 Federal Award Identification Number and Year: P063P191818; P063P231818; P063P241818; P063Q221818; P063Q231818; P007A222600; P007A242600 - 2024 Award Period: 7/1/2023 – 6/30/2024 Type of Finding: Significant Deficiency in Internal Control Over Compliance, Other Matters Criteria or specific requirement: Per the Code of Federal Regulations, 34 CFR 673.5, students may not be awarded need based aid in excess of their calculated need. In addition, 34 CFR 685.203(j) states that in no case may a loan amount exceed the student’s estimated cost of attendance for the period of enrollment for which the loan is intended less the student’s estimated financial assistance for that period and in the case of Direct Subsidized Loans, the borrower’s expected family contribution for that period. Condition: One out of forty students tested was awarded need-based Title IV aid greater than their estimated financial need. Questioned costs: $1,400 Context: During our testing, we noted that one student was awarded and disbursed $3,595 in need-based Title IV aid when they only had calculated financial need of $2,195. Cause: The University did not adjust need-based Title IV aid once financial need was met. Effect: Student was awarded need-based aid in excess of calculated need. Repeat finding: No. Recommendation: We recommend the University implement policies to review all student award packages at the start of the academic year or time of revision to ensure no over awards exist. In addition, we recommend the University implement procedures for adjusting aid when an outside scholarship is received by the student. Views of responsible officials: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Education Federal Program Name: Federal Pell Grant Program Assistance Listing Number: 84.063 Federal Award Identification Number and Year: P063P191818; P063P231818; P063P241818; P063Q221818; P063Q231818 - 2024 Award Period: 7/1/2023 – 6/30/2024 Type of Finding: Significant Deficiency in Internal Control Over Compliance, Other Matters Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 690.62 states the Pell grant for an academic year is based upon the payment and disbursement schedules published by the Secretary for each award year. The payment schedules take into account the cost of attendance, the student’s Estimated Family Contribution (EFC) and the enrollment status of the student. Condition: One out of a sample of forty students was under-awarded Pell grant funds. Questioned costs: $501 Context: During our testing, it was noted one student was under-awarded Pell due to the University using the incorrect EFC in the calculation. Cause: The University calculated the student’s Pell award with an incorrect EFC. Effect: The student was under-awarded Pell funds. Repeat finding: No. Recommendation: We recommend that a review is implemented to ensure calculations of Pell awards are using the correct EFC. Views of responsible officials: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Education Federal Program Name: Federal Direct Student Loans Assistance Listing Number: 84.268 Federal Award Identification Number and Year: P268K231818; P268K241818; P268K251818 - 2024 Award Period: 7/1/2023 – 6/30/2024 Type of Finding: Significant Deficiency in Internal Control Over Compliance, Other Matters Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 685.203(a) outline the maximum subsidized loan amounts for students based on their dependency status, year of education, and other factors. Condition: One out of forty students tested was under-awarded Subsidized Direct loans. Questioned costs: $1,479 Context: During our testing, we noted on student’s Subsidized Direct loan awarded and disbursed was less than the maximum amount they were eligible to receive. Cause: The University did not re-evaluate the student's account for additional loan eligibility after an adjustment to other aid was made. Effect: The student did not receive the maximum amount of eligible aid. Repeat finding: No. Recommendation: We recommend the University evaluate its procedures around packaging and awarding students to ensure loan eligibility is reassessed prior to disbursement. Views of responsible officials: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Education Federal Program Name: Federal Pell Grant Program, Federal Direct Student Loans Assistance Listing Number: 84.063, 84.268 Award Period: 7/1/2022 – 6/30/2023 Type of Finding: Significant Deficiency in Internal Control Over Compliance, Other Matters Criteria or specific requirement: Per U.S. Department of Education (ED) regulations, all schools participating (or approved to participate) in the Federal Student Aid programs must have an arrangement to report student enrollment data to the NSLDS through a roster file. The school is required to report enrollment status at both the school and program level. The school is required to report changes in the student’s enrollment status, the effective date of the status and an anticipated completion date. An academic program is defined as the combination of your school’s Office of Postsecondary Education Identification (OPEID) number and the program’s Classification of Instructional Program (CIP) code, credential level, and published program length. The Department of Education requires the University to report changes in enrollment status and indicate the date that the changes occurred (34 CFR 685.309). Changes in enrollment status must be reported within 30 days. However, if a roster file is expected within 60 days, you may provide the date on that roster file. ED requires the institution to report changes in enrollment status within 30 or 60 days that the institution determined the changes occurred (34 CFR 682.610). Condition: Certain students’ enrollment information was not reported accurately or timely to the NSLDS. Questioned costs: None. Context: During our testing, we noted the following: • In our sample of 40 students tested, 1 student was not reported to the NSLDS. • In our sample of 40 students tested, 1 student was not reported timely within the 30 or 60 day timeframe. • In our sample of 40 students tested, 1 student did not have the correct enrollment effective date in the NSLDS at the program level. Cause: The University uses a third-party servicer to submit their enrollment reports to NSLDS. Occasionally, the third party incorrectly communicates information to NSLDS which results in discrepancies between the University’s system and NSLDS. The University has the ultimate responsibility to ensure that reporting is correct. Effect: Inaccurate reporting to the NSLDS can result in incorrect determination of when the students’ grace period should begin. Repeat finding: Yes, 2022-002. Recommendation: We recommend the University review procedures around sending correct information to the NSLDS. In addition, we recommend the University develop a process to help better oversee the submissions completed by the third-party servicer. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.

Federal Agency: U.S. Department of Education Federal Program Name: Federal Direct Student Loans Assistance Listing Number: 84.268 Award Period: 7/1/2022 – 6/30/2023 Type of Finding: Significant Deficiency in Internal Control Over Compliance, Other Matters Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 685.304 require entrance counseling be performed before disbursing loan funds to the student for Direct Subsidized Loan, Direct Unsubsidized Loan and Direct PLUS Loan to a graduate or professional student. The regulations also require exit counseling for all students who ceases at least half-time study at the school. The Code of Federal Regulations, 34 CFR 674.16 requires institution to provide certain repayment information to students before making its first Perkins Loan disbursement to a student. 34 CFR 674.42 also requires exit counseling for all students who ceases at least half-time study at the school. Condition: During our testing, it was noted that some individuals did not receive exit counseling after their departure from the University. Questioned costs: None. Context: During our testing, it was noted that 2 out of 40 students did not receive exit counseling within the required 30 days of a student ceasing attendance. Cause: The University notes that these students graduated from their undergrad program in May of 2022. They then enrolled in a masters program and received new direct loans – they completed and graduated from these programs in May of 2023. Exit counseling was not sent after the May 2023 completion due to them completing such exit counseling in May 2022. Effect: Students are not receiving the proper loan counseling which may contribute to a higher default rate. Repeat finding: No. Recommendation: CLA recommends the University review its policies and procedures around sending exit counseling information to students to ensure students are receiving proper counseling. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.

Federal Agency: U.S. Department of Education Federal Program Name: Federal Perkins Loan Program Assistance Listing Number: 84.038 Award Period: 7/1/2022 – 6/30/2023 Type of Finding: Significant Deficiency in Internal Control Over Compliance, Other Matters Criteria or specific requirement: Code of Federal Regulations Title 34, Subtitle B, Chapter VI, Part 674.19 requires that in administering its Federal Perkins Loan program, an institution shall establish and maintain an internal control system of checks and balances that ensures that no office can both authorize payments and disburse funds to students. When an institution uses a third-party servicer for its Perkins Loan program, the institution must perform due diligence to ensure that the third-party service is in compliance with the requirements for the functions the third-party servicer is performing for the institution. Such due diligence could include obtaining and reviewing the third-party servicer’s most recent Title IV compliance audit. Condition: The University utilizes a third party service for its Perkins Loan servicing. This is a very common practice for colleges and universities in order to provide the most efficient and effective means to not only collect loans but meet the federal regulations for servicing student Perkins Loans. In order to perform the due diligence required per the Code of Regulations, the institution utilizes the external compliance report performed for the third party servicer by other auditors. The third party servicer’s compliance audit report for the year ended June 30, 2023 was not issued as of the report date of the uniform guidance report. Therefore, the University was unable to perform due diligence on the third party provider’s internal control over the Perkin’s requirements. Questioned costs: None. Context: We noted that the University was not able to obtain the third party’s compliance report as of the date of the Uniform Guidance Report. Cause: The third party servicer, did not have their Title IV compliance audit report completed for the year ending June 30, 2023 so that the University can perform their required due diligence on the third party servicer. Effect: The University did not perform due diligence to ensure that the third-party service is in compliance with the requirements for the functions the third-party servicer is performing for the institution. Repeat finding: No. Recommendation: We recommend the University implement a procedure with the third party servicer to ensure that their report is completed timely so that the University can perform the necessary due diligence they need to perform. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.

Federal Perkins Loan Program Record Retention Federal Agency: U.S. Department of Education Federal Program Name: Federal Perkins Loan Program Assistance Listing Number: 84.038 Award Period: 7/1/2021 ? 6/30/2022 Type of Finding: Significant Deficiency in Internal Control Over Compliance, Other Matters Criteria or specific requirement: Per U.S. Department of Education (ED) regulations, an institution shall retain disbursement and electronic authentication and signature records for each loan made using a Master Promissory Note (MPN) for at least three years from the date the loan is cancelled, repaid, or otherwise satisfied. (34 CFR 674.19 (e)). Condition: Certain loan MPNs were not retained for the three-year retention period. Questioned costs: None. Context: During our testing, we noted 7 of 40 loans tested that the University did not have a MPN on file. Cause: The University does not have a review process in place to ensure the MPNs are kept for least three years from the date the loan is cancelled, repaid, or otherwise satisfied. Effect: The University does not have a proper internal control system for the Federal Perkins Loan Program. Repeat finding: Yes, 2021-001. Recommendation: We recommend that the University keep MPNs for loans for the three-year retention period. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.

National Student Loan Data System (NSLDS) Reporting Federal Agency: U.S. Department of Education Federal Program Name: Federal Pell Grant Program, Federal Direct Student Loans Assistance Listing Number: 84.063, 84.268 Award Period: 7/1/2021 ? 6/30/2022 Type of Finding: Significant Deficiency in Internal Control Over Compliance, Other Matters Criteria or specific requirement: Per U.S. Department of Education (ED) regulations, all schools participating (or approved to participate) in the Federal Student Aid programs must have an arrangement to report student enrollment data to the NSLDS through a roster file. The school is required to report enrollment status at both the school and program level. The school is required to report changes in the student?s enrollment status, the effective date of the status and an anticipated completion date. An academic program is defined as the combination of your school?s Office of Postsecondary Education Identification (OPEID) number and the program?s Classification of Instructional Program (CIP) code, credential level, and published program length. The Department of Education requires the University to report changes in enrollment status and indicate the date that the changes occurred (34 CFR 685.309). Changes in enrollment status must be reported within 30 days. However, if a roster file is expected within 60 days, you may provide the date on that roster file. ED requires the institution to report changes in enrollment status within 30 or 60 days that the institution determined the changes occurred (34 CFR 682.610). Condition: Certain students? enrollment information was not reported accurately or timely to the NSLDS. Questioned costs: None. Context: During our testing, we noted the following: ? In our sample of 40 students tested, 2 students were not reported to the NSLDS. ? In our sample of 40 students tested, 2 students were not reported timely within the 30 or 60 day timeframe. ? In our sample of 40 students tested, 2 students did not have the correct enrollment effective date in the NSLDS at the campus and program level. ? In our sample of 40 students tested, 2 students? program descriptions per the University?s records did not match the program description per the program level of the NSLDS. Cause: The University uses a third-party servicer to submit their enrollment reports to NSLDS. Occasionally, the third party incorrectly communicates information to NSLDS which results in discrepancies between the University?s system and NSLDS. The University has the ultimate responsibility to ensure that reporting is correct. Effect: Inaccurate reporting to the NSLDS can result in incorrect determination of when the students? grace period should begin. Repeat finding: Yes, 2021-002. Recommendation: We recommend the University review procedures around sending correct information to the NSLDS. In addition, we recommend the University develop a process to help better oversee the submissions completed by the third-party servicer. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.

Higher Education Emergency Relief Fund (HEERF) Student Aid Portion Reporting Federal Agency: U.S. Department of Education Federal Program Name: Higher Education Emergency Relief Fund ? Student Aid Portion Assistance Listing Number: 84.425E Award Period: 7/1/2021 ? 6/30/2022 Type of Finding: Significant Deficiency in Internal Control Over Compliance, Reporting Criteria or specific requirement: Section 18004(e) of the Coronavirus Aid, Relief, and Economic Security Act (CARES) directs institutions receiving funds under Section 18004 of CARES to submit (in a time and manner required by the U.S. Department of Education (ED)), a report describing the use of funds distributed from the Higher Education Emergency Relief Fund (HEERF). The ED published additional information that described the public reporting requirements for emergency financial aid grants to students which extended this requirement to funds received under the Coronavirus Response and Relief Supplemental Appropriations Act (CRRSAA) and American Rescue Plan (ARP). In addition to posting information within 10 days after the end of each calendar quarter, the following information must appear in a format and location that is easily accessible to the public: 1. An acknowledgement that the institution signed and returned to the Department the Certification and Agreement and the assurance that the institution has used the applicable amount of funds designated under the CARES, CRRSAA and/or ARP (the programs) programs to provide emergency financial aid grants to students. 2. The total amount of funds that the institution will receive or has received from the Department pursuant to the institution?s Certification and Agreement for Emergency Financial Aid Grants to Students under the programs. 3. The total amount of Emergency Financial Aid Grants distributed to students under the programs as of the date of submission (i.e., as of the initial report and every calendar quarter thereafter). 4. The estimated total number of students at the institution that are eligible to receive Emergency Financial Aid Grants to Students under the programs. 5. The total number of students who have received an Emergency Financial Aid Grant to students under the programs. 6. The method(s) used by the institution to determine which students receive Emergency Financial Aid Grants and how much they would receive under programs. 7. Any instructions, directions, or guidance provided by the institution to students concerning the Emergency Financial Aid Grants. Condition: During our testing of the quarterly public reports for the student aid portion, we noted the University did not post one student quarterly report to their website timely and did not include all required information within the reports. Questioned costs: None. Context: During our testing of the quarterly public reports for the student aid portion, we note: ? In our sample of 2 quarterly public reports tested, 1 report was not published to the University?s website within the required timeframe. ? In our sample of 2 quarterly public reports tested, both reports did not include item number 5 above. ? In our sample of 2 quarterly public reports tested, 1 report (quarter ending December 31, 2021) did not include all the data through the end of the quarter reporting period. Cause: The University did not have procedures in place to ensure reports were being posted to the website on a timely basis or that they included the required information. Effect: Quarterly report was not posted timely to the website and/or did not include the required information resulting in the University being out of compliance with ED reporting guidelines. Repeat finding: No. Recommendation: We recommend the University establish a system to review reports for accuracy as well as ensure timely posting in accordance with applicable reporting requirements. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.

Return of Title IV (R2T4) Calculations Scheduled Breaks Federal Agency: U.S. Department of Education Federal Program Name: Federal Pell Grant Program, Federal Direct Student Loans, Federal Work-Study Program, Federal Supplemental Educational Opportunity Grants Assistance Listing Number: 84.063, 84.268, 84.033, 84.007 Award Period: 7/1/2021 ? 6/30/2022 Type of Finding: Significant Deficiency in Internal Control Over Compliance, Other Matters Criteria or specific requirement: Once a student?s withdrawal date is determined, a school needs to calculate the percentage of the payment period of enrollment completed. Institutionally scheduled breaks of five or more consecutive days are excluded from the R2T4 calculation as periods of nonattendance and, therefore, do not affect the calculation of the amount of Federal Student Aid earned (34 CFR 668.22(f)(2)(i)). Condition: During our testing, it was noted that the University's process did not ensure scheduled breaks were properly factored in the R2T4 calculations for Spring 2022 term. Questioned costs: $733 known questioned costs. Context: During our tested of 27 students, we noted 1 student's R2T4 calculation where the University did not correctly factor in scheduled breaks to the R2T4 calculations for the Spring 2022 term. Cause: The University does not have a review process in place for the calculations to ensure scheduled breaks are properly factored into the R2T4 calculations. Effect: The University did not complete an accurate calculation as defined by Federal regulations. Repeat finding: No. Recommendation: We recommend the University review the R2T4 requirements and implement procedures to ensure scheduled breaks are properly factored into calculations. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.

Return of Title IV (R2T4) Order of Funds Returned Federal Agency: U.S. Department of Education Federal Program Name: Federal Pell Grant Program, Federal Direct Student Loans, Federal Work-Study Program, Federal Supplemental Educational Opportunity Grants Assistance Listing Number: 84.063, 84.268, 84.033, 84.007 Award Period: 7/1/2021 ? 6/30/2022 Type of Finding: Significant Deficiency in Internal Control Over Compliance, Other Matters Criteria or specific requirement: R2T4 funds must be distributed in the order prescribed below. The prescribed order must be followed regardless of the institution?s agreements with other state agencies or private agencies (34 CFR 668.22(i)). a. Unsubsidized Federal Direct Stafford Loans b. Subsidized Federal Direct Stafford Loans c. Federal Direct PLUS d. Federal Pell Grant e. Iraq and Afghanistan Service Grant f. Federal Supplemental Educational Opportunity Grants g. Teacher Education Assistance for College and Higher Education Grants Condition: During our testing, it was noted that the University's process did not ensure that funds that were calculated to return were returned to the Department of Education in the correct order. Questioned costs: None. Context: During our testing of 27 students, 1 student's calculated returned funds were not returned to the Department of Education in the proper order. Cause: The University does not have a review process in place to ensure that the calculated funds to return were returned to the Department of Education in the proper order. Effect: The University did not complete an accurate calculation as defined by Federal regulations. Repeat finding: No. Recommendation: We recommend the University implements procedures to ensure that Title IV funds that are to be returned are returned in the proper order. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.

2021-001 ? Federal Perkins Loan Program Record Retention Federal agency: U.S. Department of Education Federal program title: Student Financial Assistance Cluster CFDA number: 84.038 Award period: 7/1/20 ? 6/30/21 Type of finding: Significant Deficiency in Internal Control Over Compliance, Other Matters Criteria or specific requirement: Per U.S. Department of Education (ED) regulations, an institution shall retain disbursement and electronic authentication and signature records for each loan made using a Master Promissory Note (MPN) for at least three years from the date the loan is cancelled, repaid, or otherwise satisfied. (34 CFR 674.19 (e)). Condition: Certain loan MPNs were not retained for the three-year retention period. Questioned costs: None. Context: During our testing, we noted 16 of 40 loans tested that the University did not have a MPN on file. Cause: The University does not have a review process in place to ensure the MPNs are kept for least three years from the date the loan is cancelled, repaid, or otherwise satisfied. Effect: The University does not have a proper internal control system for the Federal Perkins Loan Program. Repeat finding: No. Recommendation: We recommend that the University keep MPNs for loans for the three-year retention period. Views of responsible officials: See attached corrective action plan.

2021-002 ? National Student Loan Data System (NSLDS) Reporting Federal agency: U.S. Department of Education Federal program title: Student Financial Assistance Cluster CFDA number: 84.063, 84.268 Award period: 7/1/20 ? 6/30/21 Type of finding: Significant Deficiency in Internal Control Over Compliance, Other Matters Criteria or specific requirement: Per U.S. Department of Education (ED) regulations, all schools participating (or approved to participate) in the Federal Student Aid programs must have an arrangement to report student enrollment data to the NSLDS through a roster file. The school is required to report enrollment status at both the school and program level. The school is required to report changes in the student?s enrollment status, the effective date of the status and an anticipated completion date. An academic program is defined as the combination of your school?s Office of Postsecondary Education Identification (OPEID) number and the program?s Classification of Instructional Program (CIP) code, credential level, and published program length. The Department of Education requires the University to report changes in enrollment status and indicate the date that the changes occurred (34 CFR 685.309). Changes in enrollment status must be reported within 30 days. However, if a roster file is expected within 60 days, you may provide the date on that roster file. ED requires the institution to report changes in enrollment status within 30 or 60 days that the institution determined the changes occurred (34 CFR 682.610). Condition: Certain students? enrollment information was not reported accurately or timely to the NSLDS. Questioned costs: None Context: During our testing, we noted the following: ? In our sample of 40 students tested, 1 student was not reported to the NSLDS. ? In our sample of 40 students tested, 5 students were not reported timely within the 30- or 60-day timeframe. ? In our sample of 40 students tested, 2 students did not have the correct enrollment effective date in the NSLDS at the program level. Cause: The University uses a third-party servicer to submit their enrollment reports to NSLDS. Occasionally, the third party incorrectly communicates information to NSLDS which results in discrepancies between the University?s system and NSLDS. The University has the ultimate responsibility to ensure that reporting is correct. Effect: Inaccurate reporting to the NSLDS can result in incorrect determination of when the students? grace period should begin. Repeat finding: Yes, 2020-004. Recommendation: We recommend the University review procedures around sending correct information to the NSLDS. In addition, we recommend the University develop a process to help better oversee the submissions completed by the third-party servicer. Views of responsible officials: See attached corrective action plan.

2021-003 ? Higher Education Emergency Relief Fund (HEERF) Reporting Federal agency: U.S. Department of Education Federal program title: Higher Education Emergency Relief Fund ? Institutional Portion CFDA number: 84.425F ? Institutional Portion Award period: 7/1/20 ? 6/30/21 Type of finding: Significant Deficiency in Internal Control Over Compliance, Reporting Criteria or specific requirement: Section 18004(e) of the Coronavirus Aid, Relief, and Economic Security Act (CARES) directs institutions receiving funds under Section 18004 of CARES to submit (in a time and manner required by the U.S. Department of Education (ED)), a report describing the use of funds distributed from the Higher Education Emergency Relief Fund. The ED published additional information that described the public reporting requirements which extended this requirement to funds received under the Coronavirus Response and Relief Supplemental Appropriations Act (CRRSAA) and American Rescue Plan (ARP). Institutions must complete the following reporting requirements in accordance with ED guidance: ? Quarterly public reporting for the institutional portion requires a separate form to be posted covering aggregate amounts of funds spent under CARES, CRRSAA, and ARP each quarterly reporting period due no later than 10 days after the end of each calendar quarter. Condition: During our testing of the quarterly public reports for the institutional portion, we noted the University did not post the reports to the Institution?s website within the required 10-day timeframe. Questioned costs: None. Context: During our testing of the quarterly public reports for the institutional aid portion, we selected two quarterly reports, noting one was not posted within the required timeframe to the University?s website. Cause: The University did not have procedures in place to ensure reports were being posted to the website on a timely basis. Effect: Quarterly report was not posted timely to the website, resulting in the University being out of compliance with ED reporting guidelines. Repeat finding: No. Recommendation: We recommend the University establish a system to review reports as well as ensure timely posting in accordance with applicable reporting requirements. Views of responsible officials: See attached corrective action plan.

2020-001 ? Return of Title IV Funds ? Scheduled Breaks Federal agency: U.S. Department of Education Federal program title: Student Financial Assistance Cluster CFDA number: 84.007, 84.033, 84.038, 84.063, 84.268 Award period: 7/1/19 ? 6/30/20 Type of finding: Significant Deficiency in Internal Control Over Compliance, Other Matters Criteria or specific requirement: When a recipient of Title IV grant for loan assistance withdraws from an institution during a payment period or period of enrollment in which the recipient began attendance, the institution must determine the amount of Title IV grant or loan assistance that the student earned as of the student?s withdrawal date. 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 (34 CFR 668.22(a)(1) and 668.22(f)(2)(i). Condition: During our testing, it was noted the University did not include the correct number of days in the R2T4 calculation. As a result, the University returned more Title IV funds than was required. Questioned costs: $3,422 Context: During our testing, we noted the University did not correctly factor in scheduled breaks to the return calculations for the Fall and Spring terms. 4 out of a sample of 14 students? refunds were calculated using the incorrect number of days which resulted in the University returning more Title IV funds than was required. The remaining 10 students had completed more than 60% of the term. Therefore, the scheduled breaks did not impact these calculations. The sample was not and is not intended to be statistically valid. Cause: The University does not have a review process in place to ensure scheduled breaks are properly factored into the calculations. Effect: The University did not complete an accurate calculation as defined by Federal regulations and returned more funds than necessary. Repeat finding: No. Recommendation: We recommend that the University review the refund requirements and implement procedures to ensure that refund calculations are using the correct amount of term days and are accurately completed. Views of responsible officials: See attached corrective action plan.

2020-002 ? Return of Title IV Funds ? Post Withdrawal Disbursements Federal agency: U.S. Department of Education Federal program title: Student Financial Assistance Cluster CFDA number: 84.007, 84.033, 84.063, 84.268 Award period: 7/1/19 ? 6/30/20 Type of finding: Significant Deficiency in Internal Control Over Compliance, Other Matters Criteria or specific requirement: When a recipient of Title IV grant or loan assistance withdraws from an institution during a payment period or period of enrollment in which the recipient began attendance, the institution must determine the amount of Title IV aid earned by the student as of the student?s withdrawal date. If the total amount of Title IV assistance earned by the student is less than the amount that was disbursed to the student or on his or her behalf as of the date of the institution?s determination that the student withdrew, the difference must be returned to the Title IV programs and no additional disbursements may be made to the student for the payment period or period of enrollment. If the amount the student earned is greater than the amount disbursed, the difference between the amounts must be treated as a post withdrawal disbursement (34 CFR sections 668.22(a)(1) through (a)(5)). Condition: During our testing of return of Title IV calculations, we noted the University did not utilize the correct input for a Pell award. As a result, the University returned more Title IV funds than was required rather than making a post withdrawal disbursement to the eligible student. Questioned costs: $2,921. Context: During our testing, we noted 1 instance out of a sample of 14 students that was not disbursed their Pell award amount before withdrawing from the University. However, the University included a Pell disbursement in the student?s calculation, which resulted in the University returning more Tile IV funds than was required. Had this disbursement been properly excluded from the calculation, the student would have been eligible for a post withdrawal disbursement of $189. The sample was not and is not intended to be statistically valid. Cause: Improper inclusion of Pell aid in the return calculation that was not disbursed to the student. Effect: The University was not required to return a portion of Title IV funds and the student should have received a post withdrawal disbursement. Repeat finding: No. Recommendation: We recommend the University review the policies and procedures around the calculation of return of Title IV funding to ensure the correct amounts are utilized in calculations and reflect actual amounts disbursed and awarded. Views of responsible officials: See attached corrective action plan.

2020-003 ? Direct Loan Disbursement Notifications Federal agency: U.S. Department of Education Federal program title: Student Financial Assistance Cluster CFDA number: 84.268 Award period: 7/1/19 ? 6/30/20 Type of finding: Significant Deficiency in Internal Control Over Compliance, Other Matters Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 668.165(a) requires notification be sent to students when Direct Loan funds are being credited to a student?s account. The school must also notify the borrower in writing (paper or electronically) of the anticipated date and amount of the disbursement, a student?s or parent?s right to cancel all or a portion of a loan or loan disbursement and have the loan proceeds returned to the Department; and procedures and deadlines by which the student or parent must notify the school that he or she wishes to cancel the loan or a loan disbursement. Condition: During the testing of eligibility, it was noted that the University did not notify the student or parent of the Direct Loan disbursements being credited to the student's account. Questioned costs: None. Context: During our testing, we noted 37 out of a sample of 40 students that the University did not notify the student and/or parent of the disbursement being credited to the student's account. The sample was not and is not intended to be statistically valid. Cause: Management did not verify the notifications were sent. Effect: A student may not have been aware of when their federal aid was disbursed and therefore may not know their rights to be able to return loan funds. The University is not in compliance with Department of Education requirements. Repeat finding: No. Recommendation: We recommend the University review and strengthen its procedures for notifying students of their Direct Loan disbursements within the required time frame and that documentation of the notification is maintained. Views of responsible officials: See attached corrective action plan.

2020-004 ? National Student Loan Data System (NSLDS) Reporting Federal agency: U.S. Department of Education Federal program title: Student Financial Assistance Cluster CFDA number: 84.007, 84.033, 84.038, 84.063, 84.268 Award period: 7/1/19 ? 6/30/20 Type of finding: Significant Deficiency in Internal Control Over Compliance, Other Matters Criteria or specific requirement: Per U.S. Department of Education (ED) regulations, all schools participating (or approved to participate) in the Federal Student Aid programs must have an arrangement to report student enrollment data to NSLDS through a roster file. The school is required to report enrollment status at both the school and program level. The school is required to report changes in the student?s enrollment status, the effective date of the status and an anticipated completion date. An academic program is defined as the combination of your school?s Office of Postsecondary Education Identification (OPEID) number and the program?s Classification of Instructional Program (CIP) code, credential level, and published program length. The Department of Education requires the University to report changes in enrollment status and indicate the date that the changes occurred (34 CFR 685.309). Changes in enrollment status must be reported within 30 days. However, if a roster file is expected within 60 days, you may provide the date on that roster file. ED requires the institution to report changes in enrollment status within 30 or 60 days that the institution determined the changes occurred (34 CFR 682.610). Condition: Certain students? enrollment information was not reported accurately to the NSLDS. In one instance, a student's enrollment effective date was not reported timely due to oversight. Questioned costs: None Context: During our testing, we noted the following: ? In our sample of 40 students tested, 2 students were reported with the incorrect enrollment status to NSLDS. ? In our sample of 40 students tested, 2 students were reported with the incorrect effective date at the campus level. ? In our sample of 40 students tested, 3 students were not reported timely within the 30 or 60 day timeframe. ? In our sample of 40 students tested, 1 student was not reported to NSLDS every 60 days throughout the semester. ? In our sample of 40 students tested, 1 student did not have the correct program begin date in NSLDS at the program level. The sample was not and is not intended to be statistically valid. Cause: The student?s effective date was not properly updated within NSLDS by the registrar department. Additionally, the University uses a third-party servicer to submit their enrollment reports to NSLDS. Occasionally, the third party incorrectly communicates information to NSLDS which results in discrepancies between the University?s system and NSLDS. The University has the ultimate responsibility to ensure that reporting is correct. Effect: Incorrect reporting to NSLDS can result in students entering repayment periods or affect their interest rates. Repeat finding: No. Recommendation: We recommend the University review procedures around sending correct information to NSLDS. In addition, we recommend the University develop a process to help better oversee the submissions completed by the third-party servicer. Views of responsible officials: See attached corrective action plan.

2020-005 ? Third-Party Servicer ? Perkins Loans Federal agency: U.S. Department of Education Federal program title: Student Financial Assistance Cluster CFDA number: 84.038 Award period: 7/1/19 ? 6/30/20 Type of finding: Significant Deficiency in Internal Control Over Compliance, Other Matters Criteria or specific requirement: A servicer shall send a first overdue notice within 15 days after the due date of the payment if the servicer has not received a payment, a request for deferment or a request for postponement or for cancellation. Further, a servicer shall send a second overdue notice within 30 days after the first overdue notice is sent and a final demand letter within 15 days after the second overdue notice. This letter must inform the borrower that unless the institution receives a payment or a request for deferment, postponement, or cancellation within 30 days of the date of the letter, it will refer the account for collection or litigation, and will report the default to a credit bureau (34 CFR 674.43). Condition: The University utilizes University Accounting Service, LLC (UAS) for its third-party Perkins Loan servicing. This is a very common practice for colleges and universities in order to provide the most efficient and effective means to not only collect loans but meet the federal regulations for servicing student Perkins loans. In auditing the compliance features for the loan servicing, we utilize the external compliance report performed by UAS by other auditors. We noted within the UAS compliance audit report for the year ended June 30, 2020, there was a finding for not contacting the student within the required timeframes. The audit did not specify the students that were not contacted within the required guidelines and UAS is one of the largest third-party servicers for federal student loans. Therefore, we do not know if there were any University students that were impacted by the noncompliance noted at UAS. Questioned costs: None. Context: We noted the University?s third-party servicer, UAS, failed to comply with notifying students of their grace period as required. 2 students were sent past due notices late and 1 student was not sent the proper past due notice. Cause: UAS, the third-party servicer, did not have controls in place to ensure they complied with Department of Education Rules and Regulations in regard to timely engagement with students with federal loans. Given the University relies on UAS to meet their compliance responsibilities and there was not testing completed specifically for the University to determine if the noncompliance is specific to them, this is a finding for the University. Effect: UAS is not in compliance with all statutory or regulatory provisions as it pertains to the notification of students regarding their past due balances. Any finding UAS receives that is not mitigated with additional testing (with results of no errors specific to the college or university), that finding becomes a finding of the institutions they service. Repeat finding: No. Recommendation: We recommend that the University implement a thorough review process of all third-party servicer contracts to make sure they comply with all Department of Education Rules and Regulations. Views of responsible officials: See attached corrective action plan.

2020-006 ? Completion and Submission of Annual Single Audit Federal agency: U.S. Department of Education Federal program title: Student Financial Assistance Cluster CFDA number: 84.007, 84.033, 84.038, 84.063, 84.268 Award period: 7/1/19 ? 6/30/20 Type of finding: Significant Deficiency in Internal Control Over Compliance, Other Matters Criteria or specific requirement: Pursuant to Uniform Guidance section 200.512(a), the University is required to undergo and complete a Single Audit and file the Single Audit and related Data Collection Form within nine months of its calendar year-end. In March 2020, the due date was extended an additional six months as a result of coronavirus (COVID-19). Questioned costs: None. Context: The University?s Single Audit and reporting package was delayed for the year ended June 30, 2019 beyond the extended due date of September 30, 2020. Cause: The University?s 2019 audit was delayed beyond the extended filing deadline as a result of filing issues when submitting the Data Collection Form in combination with a change in audit firms. Effect: The University is not in compliance with the Single Audit reporting requirements. Repeat finding: No. Recommendation: We recommend that the University evaluate its procedures and policies around reporting their federal expenditure activity to ensure that their submission of the Single Audit is reported accurately and timely. Views of responsible officials: See attached corrective action plan.

Criteria All schools receiving Pell grants submit Pell payment data to the U.S. Department of Education through the Common Origination and Disbursement (COD) system. In accordance with Federal Register Volume 82, Number 122, institutions must report student data within 15 calendar days after the school makes a payment; or become aware of the need to make an adjustment to previously reported student payment data or expected student payment data. Condition We selected a sample of fifty students who received Pell grants during the school year. For twelve of fifty students, we tested Pell disbursements for the year (typically fall and spring), and while we noted that the data was accurately reported to the COD for these students, the reporting occurred more than 15 calendar days after the University disbursed the aid. This was due to an unscheduled employee leave of absence. Cause The University did not have proper procedures in place to ensure submission of Pell disbursements were reported through the COD within the required timeframe when employees are on unscheduled leave of absence. Effect Certain Pell payment data was not submitted through the COD within the required timeframe. Questioned Costs There are no questioned costs. Whether the Sample was Statically Valid The sample was not intended to be, and was not, a statistically valid sample. Identification of Whether this is a Repeat Finding This is not a repeat finding. Recommendation We recommend that the University enhance its current procedures to ensure that Pell payment data is submitted within 15 days through the COD, including a plan for when employees are on an unscheduled leave of absence. View of Responsible Officials The finding noted above was due to the absence of the staff member responsible for oversight of this requirement. We have since cross trained staff in the department to ensure that there are multiple staff members who aware of the deadlines and have the training and ability to reconcile Pell within the required time frame. The Director of Financial has worked directly with the assistant directors that oversee Pell reconciliation and ensured that we have redundancy in the case of unexpected absences in the future.

Criteria In accordance with Gramm-Leach-Bliley Act (GLBA) the University is required to: ? designate an individual to coordinate the information security program; ? perform a risk assessment to address three required areas in accordance with 16 C.F.R. 314.4(b), including (1) employee training and management; (2) information systems, including network and software design as well as information processing, storage, transmission and disposal; and (3) detecting, preventing and responding to attacks, intrusions or other systems failures. ? document a safeguard for each risk identified. Condition The University has documented cyber security risks as part of its Enterprise Risk Management process. However that risk assessment did not specifically address each required element in accordance with 16 CFR 314.4(b), and accordingly failed to document a safeguard for each risk identified in accordance with the GLBA compliance requirements. Cause The University?s control to verify the specificity of the GLBA provisions regarding the risk assessment and safeguards in place for each risk identified is not operating effectively. Effect The University is not in compliance with GLBA provisions for documentation of its risk assessment and safeguards in place for each risk identified. Questioned Costs There are no questioned costs. Whether the Sample was Statically Valid This test was not performed on a sample base. This sample was not intended to be, and was not, a statistically valid sample. Identification of Whether this is a Repeat Finding This is not a repeat finding. Recommendation We recommend the University enhance its current cyber risk assessment to address each of the required elements under 16 CFR 314.4(b) and document a safeguard for each risk identified. View of Responsible Officials This non-compliance was largely due to turnover in IT leadership during the period July 1, 2018 to June 30, 2019. To address this, a comprehensive security audit using The Center for Internet Security (CIS) Controls (https:www.cisecurity.org/controls/) has already and independently been initiated. This includes a documented risk assessment as well as a corresponding safeguard and response structure for each risk identified. The initial risk assessment and response structure will be completed by April 13, 2020.