THE BOARD OF DIRECTORS OF WITTENBERG COLLEGEHigher Education

Federal Program: Student Financial Assistance Cluster Federal Assistance Listing Number: 84.063 and 84.268 Federal Agency: Department of Education Federal Award Numbers: P063P242023, P268K252023; Award Year: 2025 Criteria: Per 34 CFR §668.164(a) and related Department of Education guidance, institutions are required to submit accurate disbursement records for Federal student aid programs to the Common Origination and Disbursement (COD) system within 15 calendar days of the disbursement date or becoming aware of the need to adjust a disbursement. Additionally, per 34 CFR §668.16(b) and 34 CFR §673.3, institutions are required to establish and maintain administrative and fiscal procedures to ensure proper and accurate reporting of Title IV program activity, including the accurate preparation and submission of the Fiscal Operations Report and Application to Participate (FISAP). Condition: During our testing of reporting compliance, we identified the following: 1. COD Reporting: For 2 of 37 Federal Direct Loan awards tested, the student's aid year and/or cost of attendance was incorrectly reported to COD. 17 of 17 Pell Grant fall disbursements tested were not reported to COD within the required 15-day period. 2 of 37 Federal Direct Loan disbursements tested were not reported within the required timeframe. The sample was not intended to be, and was not, a statistically valid sample. 2. FISAP Reporting: The FISAP was not initially prepared and submitted accurately, resulting in the need for subsequent correction. In addition, management was unable to provide supporting documentation for various information that was reported in the FISAP. Cause: Turnover within the financial aid department during the period resulted in a lack of continuity in established reporting processes. Effect: Failure to report disbursement data timely to COD and to accurately prepare and submit the FISAP may result in noncompliance with federal requirements and may affect the reliability of information reported to the U.S. Department of Education. Questioned Costs: None reported Context: The exceptions identified above represent deviations from federal reporting requirements across both real-time (COD) and periodic (FISAP) reporting processes within the Student Financial Assistance Cluster. Repeat Finding: Yes Recommendations: The University should evaluate its processes and controls to ensure reporting is completed accurately and timely. Views of Responsible Officials: Management agrees with the finding. See management's corrective action plan.

Federal Program: Student Financial Assistance Cluster Federal Assistance Listing Number: 84.063, 84.033, 84.038, 84.007, 84.268, 84.379 Federal Agency: Department of Education (DOE) Federal Award Numbers: P063P242023, P033A243392, Unknown, P007A243392, P268K252023, P379T0972023; Award Year: 2025 Criteria: Under the GLBA Safeguards Rule, entities serving in the capacity of financial institutions must develop, implement, and maintain a comprehensive information security program that includes administrative, technical, and physical safeguards. Condition: The institution has not fully implemented or documented controls as required by the GLBA. Specifically, based on testing we noted that: • Customer data is not encrypted • Periodic inventories of data were not performed for the period 7/1/2024-3/1/2025 • While an annual risk assessment was performed, which included required elements, many of those elements were not found to be satisfactorily implemented for all or part of the year. Cause: The institution did not have adequate internal controls or monitoring procedures in place to ensure compliance with the GLBA Act. Effect: Failure to implement and enforce access controls increases the risk of unauthorized access to sensitive customer data, potentially leading to data breaches, regulatory penalties, and reputational harm. Questioned Costs: None reported Context: Controls did not operate properly for the University to comply with requirements of the GLBA Act. Repeat Finding: Yes Recommendations: We recommend that the University evaluate its processes and controls to ensure all requirements of GLBA are monitored and addressed. Views of Responsible Officials: Management agrees with the finding. See management's corrective action plan.

Federal Program: Student Financial Assistance Cluster Federal Assistance Listing Number: 84.063, 84.033, 84.038, 84.007, 84.268, 84.379 Federal Agency: Department of Education (DOE) Federal Award Numbers: P063P242023, P033A243392, Unknown, P007A243392, P268K252023, P379T0972023; Award Year: 2025 Criteria: Federal regulations require institutions to pay Title IV credit balance refunds to students or parents as soon as possible, but no later than 14 days after the credit balance occurs. In addition, institutions must establish and maintain on a current basis, financial records that reflect each Title IV program transaction; and general ledger control accounts and related subsidiary accounts that identify each Title IV program transaction and separate those transactions from all other institutional financial activity in accordance with 34 C.F.R, 668.24(b)(2). Condition: During our review, we identified 5 of 40 student credit balance refunds that were processed outside of the required 14-day timeframe. Controls for proper review and approval of these refunds were not in place during the entire year under audit. In addition, the University was unable to produce a report to specifically identify which credit balances were attributable to federal financial assistance, as opposed to institutional, state, or other non-federal sources. The sample was not intended to be, and was not, a statistically valid sample. Cause: The institution did not have adequate internal controls or monitoring procedures in place to ensure compliance with credit balance requirements Effect: The University did not fully comply with federal Title IV requirements. Failure to timely process credit balance refunds and to properly identify federal aid credit balances increases the risk of noncompliance, potential regulatory findings, and possible enforcement actions by the U.S. Department of Education. Questioned Costs: None reported Context: Controls did not operate properly for the University to comply with requirements for disbursements to and on behalf of students. Repeat Finding: Yes Recommendations: We recommend that the University implement proper processes and controls to ensure all credit balances resulting from federal aid are properly identified and returned timely. Views of Responsible Officials: Management agrees with the finding. See management's corrective action plan.

Federal Program: Student Financial Assistance Cluster Federal Assistance Listing Number: 84.007, 84.063, 84.268 Federal Agency: Department of Education (DOE) Federal Award Numbers: P007A243392, P063P242023, P268K252023; Award Year: 2025 Criteria: Federal regulations require institutions to minimize the time between the drawdown of federal funds and their disbursement to students, and to ensure that drawdowns do not exceed immediate cash needs. Institutions must maintain adequate internal controls to ensure federal funds are not drawn in excess of amounts needed for disbursement. Condition: During testing, it was noted that the University drew down Student Financial Assistance funds in excess of immediate disbursement needs at various points throughout the year. Specifically: • Pell Grant funds of up to $35,531 at different points of the year were drawn but not disbursed within the required timeframe. Funds totaling $4,224 remained overdrawn as of June 30, 2025. • SEOG funds of up to $120,508 at different points of the year were drawn but not disbursed within the required timeframe. Funds totaling $120,508 remained overdrawn as of June 30, 2025. • Federal Direct Loans of up to $351,211 at different points of the year were drawn but not disbursed within the required timeframe. Funds totaling $73,597 remained overdrawn as of June 30, 2025. Cause: The University did not have adequate monitoring controls in place to ensure that drawdowns were limited to immediate cash needs and that fund balances were reconciled timely and accurately across programs. Testing indicated reconciliations were not routinely performed between the University's systems and federal systems, resulting in these errors. Effect: The University was not in compliance with federal cash management requirements, as federal funds were drawn in excess of allowable amounts. This increases the risk of improper cash management and potential noncompliance with Department of Education regulations. Questioned Costs: None reported Context: Testing identified multiple instances of overdrawn fund positions across the SEOG, Federal Direct Loan, and Pell programs throughout the fiscal year, occurring at various points in time and in varying amounts. Overdrawn conditions were not isolated to a single period or program but were observed intermittently across all three programs. At fiscal year-end, two of the three programs tested (SEOG and Federal Direct Loan) remained in an overdrawn position, while the Pell program was resolved prior to year-end. Repeat Finding: Yes Recommendations: We recommend that the University evaluate its processes and controls to ensure cash draws are completed for appropriate amounts. Views of Responsible Officials: Management agrees with the finding. See management's corrective action plan.

Federal Program: Student Financial Assistance Cluster Federal Assistance Listing Number: 84.063, 84.268 Federal Agency: Department of Education (DOE) Federal Award Numbers: P063P242023, P268K252023; Award Year: 2025 Criteria: Per 34 CFR §668.22, institutions are required to perform Return of Title IV (R2T4) calculations when a student withdraws and must return any unearned Title IV funds within 45 days of the date the institution determines the student withdrew. Institutions are also required to accurately calculate the amount of aid earned by the student and the amount required to be returned. Condition: The institution did not consistently perform R2T4 calculations during the year. As a result: 1. 3 of the 4 students tested had R2T4 calculations that were performed late, resulting in $14,074 of returned funds outside the required timeframe. 2. Of the R2T4 calculations tested, 4 of 4 students had R2T4 calculations that were performed incorrectly, resulting in $691 of net over returned Title IV aid. The sample was not intended to be, and was not, a statistically valid sample. Cause: Turnover within the financial aid department during the period resulted in a lack of continuity in processes related to identifying withdrawn students and completing R2T4 calculations. Effect: Failure to perform timely and accurate R2T4 calculations resulted in noncompliance with federal regulations. Late returns may subject the institution to increased scrutiny, potential liabilities, and interest assessments. Inaccurate calculations result in improper return amounts, impacting both the U.S. Department of Education and affected students. Questioned Costs: $691 related to inaccurate calculations (over/under-returned aid). Context: The University did not have proper controls in place to complete R2T4 calculations timely or accurately. Repeat Finding: Yes Recommendations: We recommend that the University evaluate its processes and controls to ensure R2T4 calculations are completed accurately and timely. Views of Responsible Officials: Management agrees with the finding. See management's corrective action plan.

Federal Program: Student Financial Assistance Cluster Federal Assistance Listing Number: 84.038 Federal Agency: Department of Education (DOE) Federal Award Numbers: Unknown; Award Year: 2025 Criteria: Per 34 CFR §674.19(e), institutions participating in the Federal Perkins Loan Program are required to maintain loan documentation, including properly executed promissory notes and repayment records, for each loan. Such records must be retained until the loan is satisfied, assigned to the U.S. Department of Education, or otherwise resolved, with certain repayment documentation retained for a minimum period following loan resolution. Condition: During prior year testing of Perkins loan documentation, the following exceptions were identified from a sample of 25 loans: 1. 3 of 25 loans did not have a signed promissory note on file. 2. 24 of 25 loans did not have adequate repayment documentation maintained. Due to the nature of the requirement and the extended document retention period, the conditions noted above continue to represent noncompliance with federal requirements. Cause: Turnover within the financial aid and related administrative departments resulted in a lack of continuity in maintaining Perkins loan documentation. Effect: The absence of promissory notes and repayment documentation increases the risk that the institution cannot support loan balances, enforce repayment in the event of default, or demonstrate compliance with federal program requirements. This may result in potential liability, including required assignment of loans to the U.S. Department of Education. Questioned Costs: None reported Context: The prior year exceptions reflect deficiencies in maintaining required Perkins loan documentation across a significant portion of the population tested. Due to the long-term retention requirements associated with Perkins loans, these deficiencies remain relevant in the current year. Repeat Finding: Yes Recommendations: We recommend that the University evaluate its processes and controls to ensure Perkins loan documentation is maintained according to requirements. Views of Responsible Officials: Management agrees with the finding. See management's corrective action plan.

Federal Program: Student Financial Assistance Cluster Federal Assistance Listing Number: 84.063, 84.033, 84.038, 84.007, 84.268, 84.379 Federal Agency: Department of Education (DOE) Federal Award Numbers: P063P242023, P033A243392, Unknown, P007A243392, P268K252023, P379T0972023; Award Year: 2025 Criteria: Under 2 CFR §200.512 (Uniform Guidance), auditees must submit the reporting package and Data Collection Form (DCF) to the Federal Audit Clearinghouse within 30 calendar days after receipt of the auditor’s report, but no later than nine months after the end of the audit period. Condition: The University submitted the DCF after the required deadline: DCF due date: 3/31/2026 No documented extension or waiver was obtained. Status of DCF and audit was questioned by funding source. Cause: The institution did not have adequate internal controls or monitoring procedures in place to timely submit the DCF. Effect: Increased risk of federal oversight or sanctions for repeated late filings. Questioned Costs: None reported Context: Controls did not operate properly for the University to timely submit the DCF. Repeat Finding: Yes Recommendations: We recommend that the University evaluate its processes and controls to ensure DCF filings are completed timely. Views of Responsible Officials: Management agrees with the finding. See management's corrective action plan.

Federal Program: Student Financial Assistance Cluster Federal Assistance Listing Number: 84.007 Federal Agency: Department of Education (DOE) Federal Award Numbers: P007A243392; Award Year: 2025 Criteria: Pursuant to 34 CFR 668.164 and 34 CFR 668.165, institutions must disburse Title IV funds by crediting the funds to the student’s account for allowable charges within the applicable payment period. Condition: During testing, it was noted that the Institution applied $85,880 of SEOG funding related to the 2024–2025 award year to student accounts during fiscal year 2026. These funds were not awarded or disbursed during the applicable award year due to the Institution not initially allocating the full amount of available SEOG funding to eligible students. Cause: Turnover within the financial aid department during the period resulted in a lack of continuity in processes related to timely awarding of aid Effect: As a result, SEOG funds were disbursed outside of the applicable award year, resulting in noncompliance with federal program requirements related to the timing of disbursements. Questioned Costs: Questioned costs of $85,880 are associated with this finding, as the allowability of these late disbursements is not in accordance with program requirements. Context: Controls did not operate properly for the University to timely and accurately apply federal aid. Repeat Finding: No Recommendations: We recommend that the University evaluate its processes and controls to ensure federal aid disbursement are completed timely. Views of Responsible Officials: Management agrees with the finding. See management's corrective action plan.

Federal Program: Student Financial Assistance Cluster Federal Assistance Listing Number: 84.063, 84.033, 84.038, 84.007, 84.268, 84.379 Federal Agency: Department of Education (DOE) Federal Award Numbers: P063P242023, P033A243392, Unknown, P007A243392, P268K252023, P379T0972023; Award Year: 2025 Criteria: Institutions are required to perform verification procedures for students selected for verification by the U.S. Department of Education (ED), including obtaining required documentation, comparing the information to the student’s FAFSA data, making necessary corrections, and updating verification status, in accordance with 34 CFR 668.51–668.60 and the OMB Compliance Supplement. Condition: During testing of students selected for verification, we noted that 2 of 3 students tested did not have evidence that required verification procedures were performed. Specifically, the institution did not obtain or document supporting verification information or complete required comparison and correction procedures for this student. Additionally, controls to track verification processes were being completed timely and accurately were not operating during the academic year. The sample was not intended to be, and was not, a statistically valid sample. Cause: The condition is attributable to turnover within the Student Financial Assistance office during the year, which resulted in gaps in personnel responsible for performing and monitoring verification procedures. As a result, the institution did not maintain effective oversight or continuity in its verification processes to ensure that all students selected for verification had required procedures completed and documented. Effect: Failure to perform required verification procedures may result in the disbursement of Title IV funds based on inaccurate or unverified student information, increasing the risk of improper payments and noncompliance with federal requirements. Questioned Costs: None reported Context: Failure to perform verification procedures for students selected by the U.S. Department of Education represents noncompliance within the “Special Tests and Provisions—Verification” compliance requirement and increases the risk that aid may be awarded based on incomplete or inaccurate information. Repeat Finding: No Recommendations: We recommend that the University evaluate its processes and controls to ensure verifications are properly performed and documented. Views of Responsible Officials: Management agrees with the finding. See management's corrective action plan.

Federal Program: Student Financial Assistance Cluster Federal Assistance Listing Number: 84.063, 84.033, 84.038, 84.007, 84.268, 84.379 Federal Agency: Department of Education (DOE) Federal Award Numbers: P063P242023, P033A243392, Unknown, P007A243392, P268K252023, P379T0972023; Award Year: 2025 Criteria: Institutions participating in the Title IV programs are required to report enrollment status changes, including student withdrawals, to the National Student Loan Data System (NSLDS) accurately and within the required reporting timeframe. Enrollment information must reflect the student's actual effective date of withdrawal and be reported no later than 60 days from the date the institution becomes aware of the status change. Condition: Of the forty student records tested for NSLDS withdrawal reporting, we identified the following: • One student where the effective date of withdrawal was reported as the end of the semester rather than the student's actual withdrawal date. • Six students where the effective date of withdrawal was reported as the date the student was notified rather than the actual effective withdrawal date. • One student where the student's withdrawal was not reported timely and was not included on the first enrollment roster following the withdrawal. As a result, eight student records contained inaccurate or untimely withdrawal reporting information submitted to NSLDS. The sample was not intended to be, and was not, a statistically valid sample. Cause: The institution's procedures and controls for determining and reporting withdrawal dates to NSLDS were not operating effectively to ensure that the actual effective date of withdrawal was reported accurately and that enrollment status changes were reported timely. Effect: Inaccurate or delayed reporting to NSLDS may result in incorrect enrollment information being maintained in federal systems, which could affect loan servicing activities, deferment eligibility, and the Department of Education's monitoring of student enrollment status. Questioned Costs: None reported Context: Controls did not operate properly for the University to timely and accurately report withdrawal information to NSLDS. Repeat Finding: No Recommendation: We recommend that the University evaluate its processes and controls to ensure withdrawal reporting information submitted to NSLDS is accurate and timely. Views of Responsible Officials: Management agrees with the finding. See management's corrective action plan.

Federal Program: TRIO Cluster Federal Assistance Listing Number: 84.047 Federal Agency: Department of Education Award Year: 2024 Criteria: According to the Uniform Guidance (2 CFR Part 200) and TRIO program regulations, the University is required to maintain internal controls to ensure federal funds are spent on allowable, allocable, and reasonable expenses that directly support the objectives of the program. Any expenditure that does not meet these criteria may be subject to disallowance or repayment. Condition: During testing of expenditures related to the TRIO program, it was observed that documentation supporting approvals of expenditures and indirect costs was not consistently maintained or approved in accordance with the University ’s internal policy and internal controls. Specifically, invoices and indirect cost calculations were not supported by specific/approved requests and calculations and certain invoices were not formally approved. Cause: The lack of approval and formal calculations appear to stem from inadequate oversight of expense approvals or inconsistent documentation practices. In some cases, personnel responsible for financial management may not have received sufficient training or turnover resulted in a lack of documentation retention noting formal approval. Effect: The University did not have proper internal controls to ensure costs were properly approved in accordance with Uniform Guidance. Questioned Costs: None Repeat Finding: No Recommendations: The University should modify its internal controls to ensure proper approval of federal funds. Implement and document an overall quality assurance process including adequate controls to prevent overall noncompliance. Management's Response: Management agrees with the finding. See corrective action plan.

Federal Program: TRIO Cluster Federal Assistance Listing Number: 84.047 Federal Agency: Department of Education Award Year: 2024 Criteria: According to the Uniform Guidance (2 CFR Part 200) and TRIO program regulations, the University is required to maintain internal controls to ensure the University minimizes the time between the drawdown of federal funds and their disbursement for federal program purposes. The University is required to maintain internal controls to ensure this objective is met and supported. Condition: The University did not maintain proper internal controls over the drawdown of federal funds. Specifically, it was observed that documentation supporting the drawdowns and approval of the drawdowns themselves were not maintained. Management was subsequently able to provide support for the drawdown. Cause: The lack of documentation of support and approval for federal drawdowns appears to stem from inadequate oversight of the federal drawdown process. In some cases, personnel responsible for financial management may not have received sufficient training or turnover resulted in a lack of documentation retention noting formal approval. Context: In our testing, 2 of 2 drawdowns the University initiated did not include support of or evidence supporting the approval of the amounts requested. Management was able to subsequently provide support for the drawdown by providing evidence from the general ledger that supported the amounts requested. Effect: The University did not have proper internal controls to ensure federal drawdowns were supported and approved prior to requesting funds. Questioned Costs: None Repeat Finding: No Recommendations: The University should modify its internal controls to ensure proper support and approval of federal fund drawdowns. Management's Response: Management agrees with the finding. See corrective action plan.

Federal Program: Student Financial Assistance Cluster Federal Assistance Listing Number: 84.063, 84.033, 84.038, 84.007, 84.268, and 84.379 Federal Agency: Department of Education Award Year: 2024 Criteria: The University must establish procedures to ensure credit balances arising from the application of federal aid are refunded in accordance with regulations, within 14 days. Condition: In our testing, we found that eight students out of a sample of 25 did not receive their credit balance refunds within the required timeframe, and one student received only a partial refund on time. Cause: The University lacked sufficient internal controls or monitoring procedures to ensure credit balance refunds were processed in a timely manner. Context: Controls were not in place for the University to refund credit balances within the required timeframe. Effect: The University did not meet specific requirements outlined in the FSA Handbook and Federal Code of Regulations regarding the refunds of credit balances to students. Questioned Costs: None Repeat Finding: No Recommendations: It is advised that the University establish and record a comprehensive quality assurance process with appropriate controls to reduce the risk of noncompliance. Management's Response: Management agrees with the finding. See corrective action plan.

Federal Program: Student Financial Assistance Cluster Federal Assistance Listing Number: 84.063 and 84.268 Federal Agency: Department of Education Award Year: 2024 Criteria: Under 34 CFR 668.162, institutions must limit Title IV drawdowns to the amount needed to meet immediate disbursement needs. Funds drawn in excess of actual disbursements must be returned to the U.S. Department of Education (DOE) within three business days. Additionally, institutions must reconcile drawn funds with actual disbursements reported in the Common Origination and Disbursement (COD) system. Condition: During the course of our cash management testing, we identified the University drew down Title IV funds in excess of the amounts awarded and disbursed to students. Specifically: • Pell Grant funds totaling $64,976 and $59,913 at different points in the year were drawn but not disbursed within the required timeframe. $13,626 of this remained overdrawn as of June 30, 2024. • Direct Loan funds totaling $296,282 and $121,250 at different points in the year were drawn in anticipation of disbursements that did not occur due to student ineligibility or withdrawal. All funds had been properly distributed as of June 30, 2024. Cause: The University lacked sufficient internal controls and monitoring procedures to ensure that federal funding draws did not exceed the awarded amounts. Context: Controls did not operate properly for the University to disburse funding drawn within the required timeframe. Effect: The University has not complied with certain requirements of FSA Handbook and Federal Code of Regulations to ensure federal funds drawn did not exceed awarded amounts. Questioned Costs: $13,626 Repeat Finding: No Recommendations: The University should implement and document an overall quality assurance process including adequate controls to prevent overall noncompliance. Management's Response: Management agrees with the finding. See corrective action plan.

Federal Program: Student Financial Assistance Cluster Federal Assistance Listing Number: 84.063 and 84.268 Federal Agency: Various Award Year: 2024 Criteria: According to 34 CFR 685.301(a)(8), institutions must certify that the information provided to the Secretary is accurate and supported by institutional records. Additionally, 34 CFR 685.309(b) requires institutions to report to the Secretary accurate and complete information necessary for the administration of the Direct Loan Program, including student eligibility, loan amounts, and disbursement data. Condition: During the review of Direct Loan records, it was noted that 4 out of 36 students tested had discrepancies between the underlying support for Cost of Attendance (COA) and/or grade level and the information reported in the Common Origination and Disbursement (COD) system. Cause: The University did not have adequate internal controls or monitoring procedures in place to accurately report student data. Context: Controls did operate properly for the University to properly report student data to COD. Effect: The University has not complied with certain requirements of FSA Handbook and Federal Code of Regulations to properly report student data. Questioned Costs: None Repeat Finding: No Recommendations: The University should implement and document an overall quality assurance process including adequate controls to prevent overall noncompliance. Management's Response: Management agrees with the finding. See corrective action plan.

Federal Program: Student Financial Assistance Cluster Federal Assistance Listing Number: 84.063 Federal Agency: Department of Education Award Year: 2024 Criteria: Under 34 CFR 690.63, institutions must calculate a student's Pell Grant award based on enrollment status and cost of attendance. Condition: During the course of our testing, we identified one student from a sample of 40 who had a Pell grant calculated incorrectly, which resulted in an under-award of $250. The University was not able to specifically identify why it was calculated incorrectly. Cause: The University has not complied with certain requirements of FSA Handbook and Federal Code of Regulations to calculate Pell Awards. Context: Controls did operate properly for the University to disburse Pell funding according to federal schedules. Effect: The University has not complied with certain requirements of FSA Handbook and Federal Code of Regulations to calculate Pell Awards. Questioned Costs: None Repeat Finding: No Recommendations: The University should implement and document an overall quality assurance process including adequate controls to prevent overall noncompliance. Management's Response: Management agrees with the finding. See corrective action plan.

Federal Program: Student Financial Assistance Cluster Federal Assistance Listing Number: 84.063, 84.033, 84.038, 84.007, 84.268, and 84.379 Federal Agency: Department of Education Award Year: 2024 Criteria: Under the Gramm Leach Bliley Act (GLBA) Safeguards Rule, the University must develop, implement, and maintain a comprehensive information security program that includes administrative, technical, and physical safeguards. Condition: The University has not fully implemented or documented controls as required by the Gramm Leach Bliley Act. Specifically, the audit team observed that: • Customer data is not encrypted • Periodic inventories of data are not performed • While an annual risk assessment was performed, which included required elements, many of those elements were not found to be satisfactorily implemented. Cause: The University did not have adequate internal controls or monitoring procedures in place to ensure compliance with the GLBA Act. Context: Controls did operate properly for the University to comply with requirements of the GLBA Act Effect: Failure to implement and enforce access controls increases the risk of unauthorized access to sensitive customer data, potentially leading to data breaches, regulatory penalties, and reputational harm. Questioned Costs: None Repeat Finding: No Recommendations: The University should implement and document an overall quality assurance process including adequate controls to prevent overall noncompliance. Management's Response: Management agrees with the finding. See corrective action plan.

Federal Program: Student Financial Assistance Cluster Federal Assistance Listing Number: 84.063 (Pell) and 84.268 (Direct Loans) Federal Agency: Department of Education Award Year: 2024 Criteria: In our initial testing of the completeness of the withdraw population, we identified missing students. As a result, management performed further completeness procedures and identified 11 instances of missing R2T4 calculations. In total, the University calculated $31,830 of Direct Loans and $3,499 of Pell Grant funding as amounts to be returned. Management corrected these; however, they were returned outside the required 45 day timeframe.  Condition: In testing the completeness of the withdraw population, we identified 11 instances of missing R2T4 calculations, resulting in late R2T4 returns. In total, the University calculated $31,830 of Direct Loans and $3,499 of Pell Grant funding as amounts to be returned; however, these amounts were not returned within the required 45 day timeframe.  Additionally, in a sample of 5 R2T4 recalculations, 3 used incorrect semester dates and/or aid amounts, resulting in: • One student over-returning $75 of loans; • One student under-returning $75 of loans; and • One student with no net impact because the student attended the majority of the semester (the misdated inputs did not change the proration outcome). Cause: The University did not have adequate internal controls or monitoring procedures in place to ensure proper calculations and timely returns for R2T4 funds. Context: Controls did not operate properly for the University to properly calculate R2T4 returns and return aid timely. Effect: Noncompliance with the R2T4 timing requirement increases the risk of ED findings, potential liabilities, and interest assessments for late returns. Additionally, inaccurate R2T4 calculations lead to improper amounts returned on behalf of students and ED.  Questioned Costs: $31,830 of Direct Loans and $3,499 of Pell Grant  Repeat Finding: Yes Recommendations: The University should implement and document an overall quality assurance process including adequate controls to prevent overall noncompliance. Management's Response: Management agrees with the finding. See corrective action plan.

Federal Program: Student Financial Assistance Cluster Federal Assistance Listing Number: Federal Perkins Loan Program Federal Agency: Department of Education Award Year: 2024 Criteria: Universities participating in the Federal Perkins Loan Program must (1) obtain a properly executed promissory note for each loan made and (2) maintain loan records, including the original promissory note (or an imaged copy meeting regulatory standards) and repayment history/supporting documentation, until the loan is satisfied, assigned to the Department of Education (ED), or otherwise resolved. Condition: From a sample of 25 open Perkins loans selected for testing: • The signed Perkins promissory note was not available for 3 of 25 loans tested. • The original repayment documentation (e.g., repayment schedules, statements/correspondence evidencing conversion to repayment, deferment/forbearance approvals where applicable, and payment history artifacts) was not available for 24 of 25 loans tested. Cause: The University did not have adequate internal controls or monitoring procedures in place to ensure proper maintenance of Perkins documentation. Context: Controls were not in place for the University to properly maintain Perkins documentation. Effect: There is an increased risk that the University cannot enforce the loan in the event of dispute or default and may be unable to support amounts reported and collected, potentially resulting in liability for disallowance or required assignment to ED for affected loans.  Questioned Costs: None Repeat Finding: No Recommendations: The University should implement and document an overall quality assurance process including adequate controls to prevent overall noncompliance. Management's Response: Management agrees with the finding. See corrective action plan.

Federal Program: Student Financial Assistance Cluster and Trio Cluster Federal Assistance Listing Number: 84.063, 84.033, 84.038, 84.007, 84.268, 84.379, 84.047 Federal Agency: Department of Education Award Year: 2024 Criteria: Under 2 CFR §200.512 (Uniform Guidance), auditees must submit the reporting package and Data Collection Form (DCF) to the Federal Audit Clearinghouse within 30 calendar days after receipt of the auditor’s report, but no later than nine months after the end of the audit period. Condition: The University submitted the DCF after the required deadline: • DCF due date: March 31, 2025 • No documented extension or waiver was obtained. Cause: The University did not have adequate internal controls or monitoring procedures in place to timely submit the DCF. Context: Controls did operate properly for the University to timely submit the DCF. Effect: Increased risk of federal oversight or sanctions for repeated late filings. Questioned Costs: None Repeat Finding: No Recommendations: The University should implement and document an overall quality assurance process including adequate controls to prevent overall noncompliance. Management's Response: Management agrees with the finding. See corrective action plan.

Finding 2023-002 Federal Program: Student Financial Assistance Cluster Federal Assistance Listing Number: 84.063 and 84.268 Federal Agency: Department of Education Award Year: 2023 Criteria: The University is required to implement procedures to appropriately administer funding under the Student Financial Assistance Cluster to return Title IV funds in the appropriate time required by regulations. Condition: During the course of our testing, we identified three students from a sample of three whose return of Title IV aid was not calculated and returned in the appropriate time required. Cause: Administrative oversight by personnel in refund process. Context: Controls did not operate properly to refund students with Federal Direct loans or Pell grants. Effect: The University has not complied with certain requirements of FSA Handbook and Federal Code of Regulations to return aid properly to the students. Repeat Finding: No Recommendations: The University should implement and document an overall quality assurance process including adequate controls to prevent overall noncompliance. Views of responsible officials: Management agrees with the finding. See page 43 for Corrective Action Plan.

Finding 2022-001 Federal Program: Student Financial Assistance Cluster Federal Assistance Listing Number: 84.063 and 84.268 Federal Agency: Department of Education Award Year: 2022 Criteria: The University is required to implement procedures to appropriately administer funding under the Student Financial Assistance Cluster. ? Pell grants must be awarded based on the Public Law 115-141 appropriation schedule. ? The refund of Title IV aid should be calculated using the percentage of classes completed method. ? Credit balances related to Title IV federal aid funds, per regulations, must be refunded no later than 14 days after either the credit balance occurred on the student?s account or the first day of classes of the payment period. Condition: During the course of our testing: ? We identified one student from a sample of 40 who had a Pell grant calculated incorrectly. ? We identified one student from a sample of 2 who had their refund of Title IV incorrectly calculated. ? We identified one student from a sample of 25 whose credit was not refunded within 14 days. Cause: Administrative oversight by personnel in awarding and refund process. Context: Controls did not operate properly to award and refund students with Federal Direct loans or Pell grants. Effect: The University has not complied with certain requirements of FSA Handbook and Federal Code of Regulations to award or return aid properly to the students. Repeat Finding: No Recommendations: The University should implement and document an overall quality assurance process including adequate controls to prevent overall noncompliance. Corrective Action Plan: See management?s corrective action plan on page 44.

Finding 2022-002 Federal Program: Higher Education Emergency Relief Funding (HEERF) Reporting Federal Assistance Listing Number: 84.425E and 84.425F Federal Agency: Department of Education (DOE) Award Year: 2022 Criteria: Reporting requirements by the DOE state that institutions that received HEERF funds are required to submit a report on how the institution used its HEERF funds. Condition: For each required report, the University was unable to provide support for the submission or publication date. Cause: Administrative oversight by personnel in reporting of use of HEERF funds. Context: Controls did not operate properly to meet HEERF reporting requirements. Effect: Reporting requirements were not met and improper reporting could result in the DOE withholding payments to the University. Repeat Finding: No Recommendations: We recommend that the University complete the reporting requirements and each report be posted to the University?s website. We also recommend that the University implement a process to ensure the submission dates and publication dates are maintained to ensure compliance with the reporting due dates and that the data submitted in the reports is properly supported by institution records. Last, we recommend that each report be properly reviewed by someone other than the preparer. Corrective Action Plan: See management?s corrective action plan on page 45.

Finding 2021-001 ? Enrollment Reporting Federal Program: Student Financial Assistance Cluster Federal Assistance Listing Number: 84.063 and 84.268 Federal Agency: Department of Education Award Year: 2021 Criteria: FSA Handbook Volume 1, Chapter 3 ? Institutions are required to report enrollment information on a timely basis. Condition: The University did not notify the National Student Loan Data System (NSLDS) within the requirement timeframe. Cause: Administrative oversight by personnel in reporting status timely. Context: During the course of our special tests and provisions, we identified 15 students from a sample 25 where the number of days between the enrollment change and reporting to NSLDS was not within the required days. Effect: Change in student?s enrollment status was not reported timely and accurately. Repeat Finding: No Recommendations: We recommend that the University implement adequate procedures to ensure that all status changes are reported in a timely and accurate manner for students who receive federal loans. Views of responsible officials: Management agrees with the finding. See page 41 for Corrective Action Plan.

Federal Program: Student Financial Assistance Cluster CFDA: 84.063 and 84.268 Criteria: The University is required to implement procedures to appropriately administer funding under the Student Financial Assistance Cluster. ? The University must implement and document a Direct Loan program quality assurance process. Federal Direct loans and Pell grants must be awarded within the minimum or maximum allowable. ? Pell grants are required to be awarded based on the Public Law 115-141 appropriation schedule. ? The refund of Title IV aid should be calculated using the percentage of classes completed method. Condition: During the course of our eligibility testing we noted the following, ? We identified one student from a sample of 40 who had a Pell grant calculated incorrectly. ? We identified one student from a sample of 40 who had a Federal Direct Subsidized loan greater than allowable amount. ? We identified 2 students from a sample of 3 who had their refund of Title IV incorrectly calculated based on enrollment dates. Context: Controls did not operate properly to award or refund students with Federal Direct loans or Pell Grants. Effect: The University has not complied with certain requirements of FSA Handbook or Federal Code of Regulations to award or return aid properly to the students. Cause: Controls did not operate properly to award or refund students with Federal Direct loans or Pell Grants. Recommendations: The University should implement and document an overall quality assurance process including adequate controls to prevent overall noncompliance.

Federal Program: Student Financial Assistance Cluster CFDA: 84.063 and 84.268 Criteria: FSA Handbook Volume 4, Chapter 2 ? A school must submit Federal Pell, TEACH Grant, and Direct Loan disbursement records no later than 15 days after making a disbursement or becoming aware of the need to adjust a student?s disbursement. Condition: During the course of our eligibility testing, we identified 21 Federal Direct loan students and 5 Pell Grant students from a sample of 40 whose status was not reported to the US Department of Education Common Origination and Disbursement (COD) within the required 15 days. Context: Controls did not operate properly to notify the COD of student loan and grant disbursement within the allowable timeframe. Effect: The University has not complied with the time requirements of FSA Handbook and Federal Code of Regulations to send notification of student account disbursements. Cause: Controls did not operate properly to notify the COD of student loan and grant disbursement within the allowable timeframe. Recommendations: The University should institute a policy to timely notify COD when balances are applied to student accounts.

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