Felician University

2025 – 001 – Enrollment 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 Federal Award Identification Number and Year: P063P241812; P063Q231812; P268K251812 – 2024 Award Period: July 01, 2024 – June 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 National Student Loan Data System (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). 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. In addition, regulations require that an institution make necessary corrections and return the records within 10 days for any roster files that don’t pass the NSLDS enrollment reporting edits. ED requires the University to report changes in enrollment status within 30 or 60 days that the University determined the changes occurred (34 CFR 682.610). Condition: Certain students’ enrollment information was not accurately or timely reported to the NSLDS. Questioned costs: None. Context: During our testing of enrollment information at both the program and campus-level detail, we noted the following: • 9 out of 60 students’ change in status were not reported timely to the NSLDS • 5 out of 60 students’ program begin dates were reported incorrectly to the NSLDS • 1 out of 60 students were reported to the NSLDS with an incorrect enrollment status per campus-level records • 1 out of 60 students were reported to the NSLDS with an incorrect effective date per campus-level records • 1 out of 60 students were reported to the NSLDS with an incorrect enrollment status per program-level records • 2 out of 60 students were reported to the NSLDS with an incorrect effective date per program-level records Cause: The University uses a third-party servicer to submit their enrollment reports to the NSLDS. The enrollment information that was sent to the third-party servicer did not have enrollment information that followed the NSLDS guidelines. Effect: Inaccurate reporting to the NSLDS can result in incorrect determination of when the students’ grace period should begin. Repeat finding: Yes, 2024-001. Recommendation: We recommend the University evaluate its procedures and review regulations set by the Department of Education around NSLDS to ensure the University understands the definitions for each enrollment information that gets reported. Views of responsible officials: There is no disagreement with the audit finding.

2025 – 002 – Title IV Credit Balance Refund Federal Agency: U.S. Department of Education Federal Program Name: Federal Supplemental Educational Opportunity Grants; Federal Work Study Program; Federal Pell Grant Program; Federal Direct Student Loans Assistance Listing Number: 84.007; 84.033; 84.063; 84.268 Federal Award Identification Number and Year: P007A232562; P007A242562, P063P231812, P063P241812, P268K241812, P268K251812, P033A222562, P033A232562, P033A242562 Award Period: July 01, 2024 – June 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 668.164(e) states, "Whenever an institution disburses title IV, HEA program funds by crediting a student's account and the total amount of all title IV, HEA program funds credited exceeds the amount of tuition and fees, room and board, and other authorized charges the institution assessed the student, the institution must pay the resulting credit balance directly to the student or parent as soon as possible but— (1) No later than 14 days after the balance occurred if the credit balance occurred after the first day of class of a payment period; or (2) No later than 14 days after the first day of class of a payment period if the credit balance occurred on or before the first day of class of that payment period. Condition: Student Title IV credit balances were not refunded within the required 14-day time frame. Questioned costs: None. Context: During our testing, 1 student out of a sample of 40 had a credit balance because of receiving Title IV aid that was not returned within the required 14-day timeframe. Cause: Process and controls in place for ensuring timely return of credit balances were not functioning properly. Effect: The University did not refund the student's Title IV credit balance within 14 days as required by Department of Education regulations. Repeat finding: No. Recommendation: We recommend the University evaluate its procedures and review policies in overseeing student credit balances to ensure any credit balances resulting from Title IV aid are returned within the required timeframe. 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: P063P231812; P063P241812 Award Period: July 01, 2024 - June 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 690.62 states the Pell grant for an academic year is based upon the payment and disbursement scheduled published by the Secretary for each award year. The payment schedules take into account the cost of attendance, the Student Aid Index (SAI) and the enrollment status of the student. Condition: A student was under-awarded Pell funds due to an award calculation error. Questioned costs: $458 Context: During our testing, 1 student out of a sample of 40 was under-awarded Pell due to a calculation error during initial award processing. Cause: The University calculated the student's Pell award incorrectly. 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 performed based on the accurate cost of attendance, SAI and enrollment status of the student. Views of responsible officials: There is no disagreement with the audit finding.

2025 – 004 – Procurement and Suspension & Debarment Federal Agency: U.S. Department of Education Federal Program Name: Minority Serving Institutions and Higher Education Institutional Aid – Fostering Inclusive Excellence for STEM Achievement Assistance Listing Number: 84.031C Federal Award Identification Number and Year: P031C210072 - 2024 Award Period: July 01, 2024 - June 30, 2025 Type of Finding: • Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or specific requirement: The Uniform Administrative Guidance, Cost Principals, and Requirements for Federal Awards (Uniform Guidance) became effective for grants or incremental funding made on or after December 26, 2014. Entities are now required to have written policies and procedures in place over certain compliance requirements. Compliance requirements that have been significantly affected due to the changes in Uniform Guidance include allowable costs, procurement, and subrecipient monitoring. Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. When a non-federal entity enters into a covered transaction with an entity at a lower tier, the non-federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. Condition: The University had not consistently performed requirements for procurement and suspension and debarment as outlined in the Uniform Grant Guidance. Questioned costs: None Context: During our testing, suspension and debarment procedures were not performed for 4 of 5 vendors tested. As a result of timing of when the University formalized their written procurement policy, there were no formal procurement procedures performed for 1 of 5 vendors tested. Cause: The University was not following a formalized procurement policy. Effect: Procurements are not being made and suspension and debarment of vendors is not being checked in accordance with the Uniform Guidance. Repeat finding: Yes, 2024-005. Recommendation: We recommend the University follow their policy for procurement and suspension & debarment to ensure they are aligned with Uniform Grant Guidance. 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 Federal Award Identification Number and Year: P063P241812; P063Q231812; P268K251812 – 2024 Award Period: July 01, 2023 – June 30, 2024 Type of Finding: • Material Weakness in Internal Control over Compliance, Material Noncompliance (Modified Opinion) 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 National Student Loan Data System (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). 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. In addition, regulations require that an institution make necessary corrections and return the records within 10 days for any roster files that don’t pass the NSLDS enrollment reporting edits. ED requires the University to report changes in enrollment status within 30 or 60 days that the University determined the changes occurred (34 CFR 682.610). Condition: Certain students’ enrollment information was not accurately or timely reported to the NSLDS. Questioned costs: None. Context: During our testing of enrollment information at both the program and campus-level detail, we noted the following: • 4 out of 60 students were never reported to the NSLDS • 20 out of 60 students’ change in status were not reported timely to the NSLDS • 3 out of 60 students’ enrollment status were not being certified at least every 60 days within the NSLDS • 12 out of 60 students’ program begin dates were reported incorrectly to the NSLDS • 2 out of 60 students were reported to the NSLDS with an incorrect enrollment status per campus-level records • 3 out of 60 students were reported to the NSLDS with an incorrect effective date per campus-level records • 3 out of 60 students were reported to the NSLDS with an incorrect enrollment status per program-level records • 5 out of 60 students were reported to the NSLDS with an incorrect effective date per program-level records Cause: The University uses a third-party servicer to submit their enrollment reports to the NSLDS. The enrollment information that was sent to the third-party servicer did not have enrollment information that followed the NSLDS guidelines. Effect: Inaccurate reporting to the NSLDS can result in incorrect determination of when the students’ grace period should begin. Repeat finding: Yes, 2023-003. Recommendation: We recommend the University evaluate its procedures and review regulations set by the Department of Education around NSLDS to ensure the University understands the definitions for each enrollment information that gets reported. 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 Federal Award Identification Number and Year: P063P241812; P063Q231812; P268K251812 - 2024 Award Period: July 01, 2023 – June 30, 2024 Type of Finding: • Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or specific requirement: The Department of Education requires institutions to report the disbursement dates and amounts to the Common Origination and Disbursement (COD) system within 15 days of disbursing Pell and Direct Loan funds to a student (34 CFR 690.83(b)(2) and 34 CFR 685.309). Condition: During our testing of 40 disbursements, we noted the following: • 4 disbursement dates were incorrectly reported to COD • 8 disbursements were not reported to COD in a timely manner Questioned costs: None. Context: During our testing, disbursements were not reported to COD within the required 15 days or had incorrect disbursement dates. Cause: The University had errors within their batch process reports used when reporting to COD. Effect: Interest accrues based on disbursement date reported to COD, thus interest calculation could be skewed due to the discrepancy in disbursement dates and amounts reported. Repeat finding: Yes, 2023-004. Recommendation: We recommend the University evaluate its procedures and policies around reporting to the COD to ensure that student information is reported accurately and timely. Views of responsible officials: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Education Federal Program Name: Federal Supplemental Educational Opportunity Grants; Federal Work Study Program; Federal Pell Grant Program; Federal Direct Student Loans Assistance Listing Number: 84.007; 84.033; 84.063; 84.268 Federal Award Identification Number and Year: P007A242562; P033A242562; P063P241812; P063Q231812; P268K251812 - 2024 Award Period: July 01, 2023 – June 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 668.164e states, “Whenever an institution disburses Title IV, HEA program funds by crediting a student’s account and the total of all title IV, HEA program funds credited exceeds the amount of tuition and fees, room and board, and other authorized charges the institution assessed the student, the institution must pay the resulting credit balance directly to the student or parent as soon as possible but – (1) No later than 14 days after the balance occurred if the credit balance occurred after the first day of class of a payment period; or (2) No mater than 14 days after the first day of class of a payment period if the credit balance occurred on or before the first day of class of that payment period. Condition: Student Title IV credit balances were not refunded within the required 14-day time frame. Questioned costs: None. Context: During our testing, 7 students out of a sample of 40 had a credit balance because of receiving Title IV aid that was not returned within the required 14-day timeframe. Cause: Process and controls in place for ensuring timely return of credit balances were not functioning properly. Effect: The University did not refund Title IV credit balances within 14 days as required by the Department of Education. Repeat finding: No. Recommendation: We recommend the University evaluate its procedures and review policies in overseeing student credit balances to ensure credit balances are returned within the required 14 day timeframe. Views of responsible officials: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Education Federal Program Name: Federal Supplemental Educational Opportunity Grants; Federal Work Study Program; Federal Pell Grant Program; Federal Direct Student Loans Assistance Listing Number: 84.007; 84.033; 84.063; 84.268 Federal Award Identification Number and Year: P007A242562; P033A242562; P063P241812; P063Q231812; P268K251812 - 2024 Award Period: July 01, 2023 - June 30, 2024 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)). The Code of Federal Regulations, 34 CFR 668.22 defines the last date of attendance for schools that are required to take attendance and those that are not required. Condition: During our testing, we observed that the University's process failed to properly account for scheduled breaks in the R2T4 calculations for two students. Additionally, an incorrect withdrawal date was used in one student's R2T4 calculation. Questioned costs: $3,370 Context: During our testing of 22 students, we identified two instances where the University's R2T4 calculations did not correctly factor in scheduled breaks. Additionally, one student's R2T4 calculation was performed using an incorrect withdrawal date. Cause: The University did not have a review process in place to ensure scheduled breaks were properly factored into the R2T4 calculations or that the correct withdrawal date was used. Effect: The University is not performing an accurate R2T4 calculation in accordance with Department of Education guidelines. Repeat finding: No. Recommendation: We recommend that the University review the R2T4 requirements and implement procedures to ensure that scheduled breaks and correct withdrawal dates are properly factored into the calculations. Views of responsible officials: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Education Federal Program Name: Minority Serving Institutions and Higher Education Institutional Aid – Fostering Inclusive Excellence for STEM Achievement Assistance Listing Number: 84.031C Federal Award Identification Number and Year: P031C210072 - 2024 Award Period: July 01, 2023 - June 30, 2024 Type of Finding: • Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or specific requirement: The Uniform Administrative Guidance, Cost Principals, and Requirements for Federal Awards (Uniform Guidance) became effective for grants or incremental funding made on or after December 26, 2014. Entities are now required to have written policies and procedures in place over certain compliance requirements. Compliance requirements that have been significantly affected due to the changes in Uniform Guidance include allowable costs, procurement, and subrecipient monitoring. Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. When a non-federal entity enters into a covered transaction with an entity at a lower tier, the non-federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. Condition: The University had not consistently performed requirements for procurement and suspension and debarment as outlined in the Uniform Guidance. Questioned costs: None. Context: The University had not implemented formal, written policies and procedures to align with the Uniform Guidance requirements for procurement and suspension and debarment. Cause: The University does not have a formal written policy and procedures to align with the Uniform Guidance requirements for procurement and suspension and debarment. Effect: Procurements are not being made, and suspension and debarment of vendors is not being checked in accordance with the Uniform Guidance. Repeat finding: Yes, 2023-001. Recommendation: We recommend the University document and implement policies and procedures that are aligned with Uniform Guidance for procurement and suspension and debarment to ensure the University is following requirements. Views of responsible officials: There is no disagreement with the audit finding.

Federal Agency: Department of Commerce Federal Program Name: Connecting Minority Communities Pilot Program Assistance Listing Number: 11.028 Federal Award Identification Number and Year: 3409C13052 - 2024 Award Period: July 01, 2023 - June 30, 2024 Type of Finding: • Material Weakness in Internal Control over Compliance, Other Matters Criteria or specific requirement: In accordance with 47 CFR 302.9, each grant recipient shall submit semi-annual and annual performance reports to National Telecommunications and Information Administration (NTIA), following the procedures of 2 CFR 200.329. Condition: During our review of the performance reports submitted for fiscal year 2024, we identified inaccuracies in the reported dollar amounts of expenditures for the period. The key line items affected were 3a, 5a, 5d, and 8a through 8k. Questioned costs: None. Context: During our testing of the 2 performance reports, it was noted that: • 1 of the performance reports reflected budgeted amounts instead of actual expenditures for the period submitted for lines 3a, 5a, and 5d • 1 of the performance reports reflected budgeted amounts instead of actual expenditures for the period submitted for lines 3a, 5a, and 5d and lines 8a through 8k reflected the incorrect period of the report Cause: The University had not implemented formal, written policies and procedures to align with the Uniform Guidance requirements for procurement and suspension and debarment. Effect: The University did not report accurate information on performance reports submitted during the year. Repeat finding: No. Recommendation: We recommend the University review its procedures around completing and reviewing performance reports. Views of responsible officials: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Education Federal Program Name: Education Stabilization Fund – Higher Education Emergency Relief Fund – Minority Serving Institutions and Higher Education Institutional Aid – Fostering Inclusive Excellence for STEM Achievement Assistance Listing Number: 84.425L, 84.031C Award Period: July 01, 2022 – June 30, 2023 Type of Finding:  Material Weakness in Internal Control over Compliance, Other Matters Criteria or specific requirement: The Uniform Administrative Guidance, Cost Principals, and Requirements for Federal Awards (Uniform Guidance) became effective for grants or incremental funding made on or after December 26, 2014. Entities are now required to have written policies and procedures in place over certain compliance requirements. Compliance requirements that have been significantly affected due to the changes in Uniform Guidance include allowable costs, procurement, and subrecipient monitoring. Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. When a non-federal entity enters into a covered transaction with an entity at a lower tier, the non-federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. Condition: The University had not consistently performed requirements for procurement and suspension and debarment as outlined in the Uniform Grant Guidance. Questioned costs: None. Context: The University had not implemented formal, written policies and procedures to align with the Uniform Grant Guidance requirements for procurement and suspension and debarment. Cause: The University does not have a formal written policy and procedures to align with the Uniform Grant Guidance requirements for procurement and suspension and debarment. Effect: Procurements are not being made and suspension and debarment of vendors is not being checked in accordance with the Uniform Guidance. Repeat finding: Yes, 2022-003 for 84.425L only. Recommendation: We recommend the University document and implement policies and procedures that are aligned with Uniform Grant Guidance for procurement and suspension and debarment to ensure the University is following requirements. Views of responsible officials: Management agrees with the finding.

Federal Agency: U.S. Department of Education Federal Program Name: Education Stabilization Fund – Higher Education Emergency Relief Fund – Student Portion, and Minority Serving Institutions Assistance Listing Number: 84.425E and 84.425L Award Period: July 01, 2022 – June 30, 2023 Type of Finding:  Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: An essential part of internal control is that procedures are properly segregated, and the results of their performance be adequately reviewed. This is normally accomplished by assigning duties to that 1) no one person handles a transaction from beginning to end, and 2) incompatible duties between functions are not handled by the same person. In addition, a review of these completed duties should be performed by an individual independent of those functions. Condition: While testing cash management and reporting, we noted there is not a process in place to review and approve drawdowns and reports being submitted for cash management and reporting. One individual performs the process of creating and submitting reports and reimbursement requests. Questioned costs: None. Context: While testing cash management and reporting, we noted there is not a process in place to review and approve drawdowns and reports being submitted for cash management and reporting. One individual performs the process of creating and submitting reports and reimbursement requests. Cause: The University does not have formal procedures in place for reviewing calculations for funds to be drawn and reports prior to submission. Effect: When separation of duties is inadequate, there is an increased risk that errors can occur and not be detected. Repeat finding: Yes, 2022-004. Recommendation: We recommend that the University review the current assignment of duties for individuals and incorporate review processes for individuals where appropriate. Views of responsible officials: Management agrees with the finding.

Federal Agency: U.S. Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Number: 84.063; 84.268 Award Period: July 01, 2022 – June 30, 2023 Type of Finding:  Material Weakness in Internal Control over Compliance, Material Noncompliance (Modified Opinion) 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). 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. In addition, regulations require that an institution make necessary corrections and return the records within 10 days for any roster files that don’t pass the NSLDS enrollment reporting edits. ED requires the University to report changes in enrollment status within 30 or 60 days that the University 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 of enrollment information at both the program and campus-level detail, we noted the following:  15 out of 40 students were reported to the NSLDS with an incorrect campus-level enrollment status  17 out of 40 students were reported to the NSLDS with an incorrect effective date per campus-level records  25 out of 40 student enrollment effective statuses were not reported to the NSLDS in a timely manner  1 out of 40 students’ published program lengths reported to the NSLDS was not correct  6 out of 40 students’ program begin dates were reported incorrectly to the NSLDS.  21 out of 40 students were reported with an incorrect effective date and effective status on the program-level detail in the NSLDS Cause: The University uses a third-party servicer to submit their enrollment reports to the NSLDS. The enrollment information that was sent to the third-party servicer did not have enrollment information that followed the NSLDS guidelines. The University was calculating student's anticipated time for program lengths on a student-by-student situation instead of using published or common lengths for students in the program. The University was also not reporting summer term status changes. Effect: Inaccurate reporting to the NSLDS can result in incorrect determination of when the students’ grace period should begin. Repeat finding: Yes, 2022-005. Recommendation: We recommend the University evaluate its procedures and review regulations set by the Department of Education around reporting requirements to the NSLDS to ensure the University is in compliance with enrollment reporting requirements. Views of responsible officials: Management agrees with the finding.

Federal Agency: U.S. Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Number: 84.063, 84.268 Award Period: July 01, 2022 - June 30, 2023 Type of Finding:  Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or specific requirement: The Department of Education requires institutions to report the disbursement dates and amounts to the Common Origination and Disbursement (COD) system within 15 days of disbursing Pell and Direct Loan funds to a student (34 CFR 690.83(b)(2) and 34 CFR 685.309). Condition: During our testing of 40 students, we noted the following:  6 disbursement dates were incorrectly reported to the COD  3 disbursement amounts were incorrectly reported to the COD  10 disbursements were not reported to the COD in a timely manner Questioned costs: None. Context: During our testing, disbursements were not reported to COD within the required 15 days or had incorrect dates or disbursement amounts. Cause: The University had errors within their batch process reports used when reporting to COD. Effect: Interest accrues based on disbursement date reported to COD, thus interest calculation could be skewed due to the discrepancy in disbursement dates and amounts reported. Repeat finding: No. Recommendation: We recommend the University evaluate its procedures and policies around reporting to the COD to ensure that student information is reported accurately and timely. Views of responsible officials: Management agrees with the finding.

Federal Agency: U.S. Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Number: 84.007, 84.033, 84.063, 84.268 Award Period: July 01, 2022 - June 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 668.164(l)(3) states that an institution that attempts to disburse funds by check and the check is not cashed, the institution must return the funds to the Secretary no later than 240 days after the date it issued that check. Condition: During our testing of Title IV checks, we noted refunds of Title IV financial aid outstanding more than 240 days. Questioned costs: $13,996. Context: During our testing, we noted 10 Title IV refund checks not returned to the Department of Education within 240 days. Cause: Due to turnover and lack of documented policies and procedures, management did not ensure Title IV refund checks were properly reviewed and returned within prescribed timeframes. Effect: The University is not in compliance with Department of Education requirements that all student refund checks that are outstanding for more than 240 days be returned to the Department of Education. Repeat finding: No. Recommendation: We recommend the University review its policies and procedures related to Title IV outstanding checks to ensure they are being returned to the Department of Education after 240 days. Views of responsible officials: Management agrees with the finding.

Federal Agency: U.S. Department of Education Federal Program Name: Education Stabilization Fund – Higher Education Emergency Relief Fund – Student Portion, and Minority Serving Institutions Assistance Listing Number: 84.425E and 84.425L Award Period: July 01, 2022 – June 30, 2023 Type of Finding:  Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or specific requirement: American Rescue Plan (ARP) created two new requirements that a portion of Higher Education Emergency Relief Fund (HEERF) III institutional funds must be used (a) to implement evidence-based practices to monitor and suppress coronavirus in accordance with public health guidelines; and (b) conduct direct outreach to financial aid applicants about the opportunity to receive a financial aid adjustment due to the recent unemployment of a family member or independent student, or other circumstances, described in section 479A of the Higher Education Act. Spending under these categories indicates whether an institution has spent funds under a required use of funds established under the ARP. Condition: During our testing, it was noted the University did not spend any funds on direct outreach to financial aid applicants, as outlined per the terms of the agreement. Questioned costs: None. Context: While testing reporting and earmarking requirements, we noted that there were no funds spent on direct outreach to financial aid applicants. Cause: The University was not aware of all the earmarking requirements. Effect: The University is not in compliance with all provisions of the grant agreement. Repeat finding: No. Recommendation: We recommend the University implement a process to ensure all grant agreements are reviewed and there is a clear understanding of any reporting and/or earmarking requirements to limit the risk of noncompliance. Views of responsible officials: Management agrees with the finding.

Federal Agency: U.S. Department of Education Federal Program Name: Higher Education Institutional Aid – Fostering Inclusive Excellence for STEM Achievement Assistance Listing Number: 84.031C Award Period: July 01, 2022 - June 30, 2023 Type of Finding:  Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or specific requirement: A cost is allocable to a particular Federal award or other cost objective if the goods or services involved are chargeable or assignable to that Federal award or cost objective in accordance with relative benefits received. This standard is met if the cost: (1) Is incurred specifically for the Federal award; (2) Benefits both the Federal award and other work of the non-Federal entity and can be distributed in proportions that may be approximated using reasonable methods; and (3) Is necessary to the overall operation of the non-Federal entity and is assignable in part to the Federal award in accordance with the principles in this subpart. (CFR 200.405) Condition: During testing of indirect costs, it was noted that the University did not properly calculate the allocation of indirect costs. Questioned costs: $15,710. Context: During our testing, it was noted that the University used the budgeted amount of indirect costs from the grant agreement instead of calculating the indirect costs based on actual direct costs incurred multiplied by the University’s negotiated indirect cost rate. It was also noted that the grant period for year 1 was October 1, 2021 through September 30, 2022 and that majority of indirect costs for that period were claimed in fiscal year 2023 instead of as the direct costs were incurred. Cause: By utilizing the budgeted amount instead of calculating the indirect costs for the period based off actual expenditures, $15,170 of indirect costs were claimed that should not have been. Effect: The University is not in compliance with allowable cost principles. Repeat finding: No. Recommendation: We recommend the University calculate the indirect costs when the direct cost is incurred instead of claiming the amount per the budget to ensure indirect costs are consistently calculated and allocated throughout the grant term. Views of responsible officials: Management agrees with the finding.

Federal Agency: U.S. Department of Education Federal Program Name: Education Stabilization Fund ? Higher Education Emergency Relief Fund ? Institutional Portion Assistance Listing Number: 84.425F Federal Award Identification Number and Year: P425F200150 - 2022 Award Period: July 01, 2021 - June 30, 2022 Type of Finding: ? Significant Deficiency in Internal Control over Compliance ? Other Matters Criteria or specific requirement: The Uniform Administrative Guidance, Cost Principals, and Requirements for Federal Awards (Uniform Guidance) became effective for grants or incremental funding made on or after December 26, 2014. Entities are now required to have written policies and procedures in place over certain compliance requirements. Compliance requirements that have been significantly affected due to the changes in Uniform Guidance include allowable costs, procurement, and subrecipient monitoring. Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. When a non-federal entity enters into a covered transaction with an entity at a lower tier, the non-federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. Condition: It was noted that the University has not implemented formal, written policies and procedures to align with the Uniform Grant Guidance requirements for procurement and suspension and debarment. Questioned costs: None. Context: It was noted that the University has not implemented formal, written policies and procedures to align with the Uniform Grant Guidance requirements for procurement and suspension and debarment. Cause: The University does not have a formal written policy and procedures to align with the Uniform Grant Guidance requirements for procurement and suspension and debarment which could cause the University to be in noncompliance with certain federal awards they receive. Effect: The University could potentially be in noncompliance with certain regulations. Repeat Finding: No. Recommendation: We recommend the University document and implement policies and procedures that are aligned with Uniform Grant Guidance for procurement and suspension and debarment to limit the risk for noncompliance. Views of responsible officials: See corrective action plan.

Federal Agency: U.S. Department of Education Federal Program Name: Education Stabilization Fund ? Higher Education Emergency Relief Fund ? Institutional Portion, Student Portion, and Minority Serving Institutions Assistance Listing Number: 84.425F, 84.425E, 84.425L Federal Award Identification Number and Year: Various Award Period: July 01, 2021 - June 30, 2022 Type of Finding: ? Significant Deficiency in Internal Control over Compliance ? Other Matters Criteria or specific requirement: An essential part of internal control is that procedures are properly segregated, and the results of their performance be adequately reviewed. This is normally accomplished by assigning duties to that 1) no one person handles a transaction from beginning to end, and 2) incompatible duties between functions are not handled by the same person. In addition, a review of these completed duties should be performed by an individual independent of those functions. Condition: While testing controls over cash management and reporting, we noted there is no process of review of the funds being drawn for cash management and the reports being submitted for reporting requirements. One individual performs the process of creating and submitting reports and reimbursement. Questioned costs: None. Context: While testing controls over cash management and reporting, we noted there is no formal process of review of the funds being drawn for cash management and the reports being submitted for reporting requirements. One individual performs the process of creating and submitting reports and reimbursement. It was noted a transposition error on the one Higher Education Emergency Relief Fund - Student Portion reporting which could have been caught and fixed if review processes were in place. Cause: The University does not have formal procedures in place for reviewing reports prior to submission. Effect: When separation of duties is inadequate, there is a resulting danger that intentional fraud or unintentional errors could occur and not be detected. Repeat Finding: No. Recommendation: We recommend that the University review the current assignment of duties for individuals and incorporate review processes for individuals where appropriate. Views of responsible officials: See corrective action plan.

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: Various Award Period: July 01, 2021 - June 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 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). 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. In addition, regulations require that an institution make necessary corrections and return the records within 10 days for any roster files that don?t pass the NSLDS enrollment reporting edits. ED requires the University to report changes in enrollment status within 30 or 60 days that the University 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: ? 1 student out of sample of 5 students tested was reported to NSLDS with the incorrect enrollment status on both the campus-level and program-level records in the NSLDS. ? 2 students out of sample of 5 students tested were not reported to the campus-level record in the NSLDS within a timely manner. Cause: The University uses a third-party servicer to submit their enrollment reports to the NSLDS. Occasionally, the third-party servicer incorrectly or not timely communicates information to the NSLDS, which results in discrepancies between the University?s system and the 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, 2021-001.

Item 2021-001 Enrollment Reporting Federal Direct Student Loans (CFDA # 84.268) Condition We noted 2 instances where the enrollment status of a participating student in an applicable Title IV program was not updated in a timely manner. Criteria According to the Federal Register (34 CFR 685.309 (b)), an institution is required to report a participating student?s enrollment status on the Enrollment Reporting roster file in a timely manner as prescribed by U.S. Department of Education regulations. Questioned Costs ? None Cause These findings appear to be due to administrative oversights. Effect The effect of these findings is noncompliance with U.S. Department of Education regulations. Context Of the 25 randomly selected sample of participating students, the enrollment status was not updated in a timely manner for 2 students. Identification as a repeat finding Repeat finding - No Recommendation We recommend that the College review and revise, if necessary, its current procedures to ensure that participating student?s enrollment status on the Enrollment Reporting roster file via the National Student Loan Data System is reported in a timely manner as prescribed by U.S. Department of Education regulations. Views of Responsible Officials and Planned Corrective Actions We concur with this finding and have addressed it in our Corrective Action Plan

Item 2019-001 Fiscal Operations Report and Application to Participate Student Financial Assistance Cluster ((CFDA # 84.007, 84.033, 84.063, 84.268) Criteria According to the Federal Register (34 CFR 675.19(b)(3) & 34 CFR 676.19 (b)(3)), an institution is required to ensure that reported Campus-Based program data on the eligible aid applicants enrolled at the institution during the award year who applied for student Federal financial assistance during the award year is accurately reported. Condition We noted 13 instances where a participating student was omitted from Part II, Section F of the Fiscal Operations Report and Application to Participate. Cause These findings appear to be due to a clerical oversight. The University inadvertently omitted participating 1st year students from Part II, Section F of the Fiscal Operations Report and Application to Participate. Effect The effect of these findings is noncompliance with U.S. Department of Education regulations. Questioned Costs ? None Context A total of 25 participating students were included in our randomly selected sample. We noted 13 participating 1st year students were omitted from Part II, Section F of the Fiscal Operations Report and Application to Participate. In total, 663 participating 1st year students were omitted from Part II, Section F of the Fiscal Operations Report and Applicable to Participate. Identification as a Repeat Finding ? No Recommendation We recommend the University review and revise, if necessary, its current procedures to ensure the Fiscal Operations Report and Application to Participate includes all required data to be in compliance with U.S. Department of Education regulations. Views of Responsible Officials and Planned Corrective Actions We concur with this finding and the University has reviewed and revised as necessary, its current procedures and internal controls over its Fiscal Operations Report and Application to Participate reporting procedures to ensure that all data reported is accurate and can be reconciled back to supporting documentation in the University?s records. The completed Fiscal Operations Report and Application to Participate will be reviewed by the Executive Director of Student Financial Services and reconciled with the personnel from the Department of Finance and Institutional Research prior to submission.

Federal Work-Study Program (CFDA # 84.033) Criteria According to the Federal Register (Section 668.166), Title IV, HEA funds drawn down by the institution in excess of its immediate needs must be returned within the allowable timeframe as codified in the Federal Register. Condition The University maintained excess cash in one of its accounts containing Title IV funds under the Federal Work-Study Program. Cause This finding appears to be due to an administrative oversight. Effect The effect of this finding is noncompliance with the U.S. Department of Education regulations. Questioned Costs - None Context Authorized 2018-19 Federal Work-Study Program funds of $189,305 were drawn down via EDCAPS G5 and deposited through May 24, 2019. The $743 excess of 2018-19 Federal Work-Study Program funds drawn down and deposited of $189,305 over 2018-19 Federal Work-Study Program expenditures of $188,562 was not returned until November 5, 2019. Identification as a Repeat Finding ? No Recommendation We recommend that the University review its cash draw down and monitoring procedures to ensure all draw downs in excess of immediate needs are returned within allowable timeframes and in compliance with U.S. Department of Education regulations. Views of Responsible Officials and Planned Corrective Actions We concur with this finding and the University has reviewed and revised as necessary, its current procedures and internal controls over its draw down of Federal Work-Study funds to ensure that funds drawn down by the institution in excess of immediate need are returned within the allowable timeframe per regulation. The Executive Director and/or Associate Director will reconcile with the personnel from the Department of Finance and University?s payroll coordinator draw down request based on the Federal Work-Study payroll.

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