GOD'S BIBLE SCHOOL, COLLEGE, AND MISSIONARY TRAINING HOMEHigher Education

Federal Agency:U.S. Department of Education; Office ofFederalStudentAidPassthroughEntity:NotapplicableProgramName:FederalPellGrantProgramAL#andProgramExpenditures:84.063($848,787)Award Number:P063P243976Federal Award Year:July 1, 2024 to June 30, 2025Questioned Costs:$37Condition Found:The incorrect number of days in the semester was used for one of the eight R2T4s reviewed during the audit. The incorrect start date was used for a student taking an on-line course through the College’s IWU Partnership. Criteria:The total number of days in the semester for the purposes of R2T4 calculation is the sum of the start and end dates noted in the academic calendar less any scheduled breaks of five or more days Cause:The Director of Financial Aid miscalculated the number of days in the semester. Due to miscommunication between Registrar and Financial Aid, the incorrect start was used for one student taking an online class through the College’s IWU Partnership. Possible Asserted Effect:The amount of Federal Pell Grant funds awarded to the student was incorrect. $37 of Federal Pell Grant funds should be returned to the Department of Education. Repeat Finding:See Finding 2024-004 for a finding related to R2T4 calculations in the prior year.Recommendation:$37 of Pell Grant Funds should be returned to the Department of Education. Communication between the registrar and financial aid should be improved, and financial aid office should be made aware of start and end dates for the College’s IWU Partnership classes. In addition, all eight R2T4s calculated during the year were reviewed during the audit. The correct semester start date was used in those calculations. Management Response:Management agrees with the auditor’s finding and their recommendation. The School returned $37 of Pell Grant Funds on November 25, 2025. Communication will be improved between the financial aid office and the registrar. Procedures will be improved to ensure that R2T4s are calculated correctly.

Condition Found: During our search for unrecorded liabilities, we noted that the cost of numerous services performed during the year ended June 30, 2024 were not recorded in accounts payable. In addition, prior year accruals were not properly reversed. Criteria: Internal controls around the cutoff of payables are critical for the accuracy of the accrual basis of accounting. Under the accrual basis of accounting, expenses are recorded when then they occur or transferred to the buyer, rather than at the time expenses are paid. Cause: Expenses relating to the 2024 fiscal year were not recorded in the proper period. Possible Asserted Effect: Due to inappropriate cutoff procedures established at year-end, the School did not record accruals for printing and utilities services totaling approximately $48,228. In addition, the School did not book the accruals for payables of approximately $13,000 and credit card payable of approximately $24,000. Lastly, $153,000 of accounts payable from the end of the prior year were still included in payables at June 30, 2024. Overall, accounts payable was adjusted by approximately $86,000. Future years will likely experience similar errors if proper internal controls are not designed and implemented. Repeat Finding: See Finding 2023-001 for a similar finding in the prior year. Recommendation: We recommend that the School prepare written instructions to be included in the School’s accounting policies and procedures manual that indicate basic procedures to achieve proper cutoff and completeness of accounts payable, accrued liabilities and prepaid expenses in the financial closing process, as well as specific positions/staff responsible for performing such procedures and controls. Management Response: Management acknowledges the auditors’ recommendation regarding the need to strengthen the accounts payable policy to improve operational efficiency and minimize risks. We will ensure segregation of duties so that no single employee has control over the entire payment process. Responsibility for Accounts Payable is assigned to the Business Manager with oversight from and approval by the Internal Auditor. We are committed to strengthening internal controls and ensuring the accounts payable function operates effectively, aligns with best practices, and mitigates risks.

Condition Found: During our testing, we noted that there was an unaccounted discrepancy between the bank statement and the reconciliation performed by the School. In addition, we noted material differences between contributions traced in the donor database and the records of the accounting department, which are recorded in the general ledger. Criteria: The School should reconcile cash accounts accurately and on a timely basis using the bank balance and the balance per the general ledger. In addition, there should be a reconciliation between the donor database and the general ledger. Reconciliations should be reviewed by a member of management who is knowledgeable in such matters. Cause: During the audit, it appeared that a proper bank reconciliation was not performed throughout the year that led to the material differences between contributions tracked in the donor database and the records of the accounting department. Possible Asserted Effect: This resulted in cash being understated by approximately $29,000 at year-end. In addition, there could potentially be future material adjustments to cash due to the improper method used to reconcile cash. There was also an approximately $100,000 difference between the donor database and the general ledger. Repeat Finding: See Finding 2023-002 for a similar finding in the prior year. Recommendation: We recommend that all bank accounts be reconciled monthly and in a timely manner. The School should pursue adding the bank reconciliation module to their accounting software. In addition, reconciliations should be prepared using the bank balance and the balance per the general ledger instead of the check register balance. Lastly, we suggest that a member of management review the bank reconciliations for any unusual items, investigate and fully resolve any such items, and document his or her approval. We also recommend that management review the cash receipts process. From review of the process of the daily cash receipts log, it includes both cash receipts received in hand along with cash receipts from credit cards. Cash receipts received are deposited either the same day or the next day. However, cash receipts from credit cards are not received until a few days or even a week after. Therefore, the cash receipts log does not agree to bank statements on a daily basis. We strongly suggest that the cash receipts log match the bank statements on a daily basis. This will assist in bank reconciliation process at the end of the month. Lastly, we suggest that as part of the School’s normal close and reporting process, the donor database be reconciled to the general ledger on a monthly basis. Any differences should be investigated, resolved, and documented on a timely basis. Management Response: Proper cash reconciliations are now occurring. In addition, a new donor processing software has been implemented as of July 1, 2024, and a separate bank account has been opened as of October 1, 2024 to track donations.

Federal Agency: U.S. Department of Education; Office of Federal Student Aid Pass through Entity: Not applicable Program Name: Federal Pell Grant Program AL# and Program Expenditures: 84.063 ($679,498) Award Number: P063P233976 Federal Award Year: July 1, 2023 to June 30, 2024 Questioned Costs: $591.50 Condition Found: The amount of Pell grant awarded was calculated incorrectly for one of the twenty-one students who received Pell in our sample. The student in question was subjected to the lifetime eligibility used limitation. The College calculated the percentage of the Pell grant funds the student was eligible to receive correctly, but the percentage was applied to the full-time Pell award when the student was only enrolled ¾ time. Criteria: Federal Pell Grant eligibility is determined by a student’s expected family contribution (“EFC”), cost of attendance, and enrollment status. If a student has used between 500% and 600% of his or her Pell Lifetime Eligibility, the amount of Pell grant funds awarded should be prorated. Cause: The financial aid office was not informed of the change in the student’s enrollment status. Possible Asserted Effect: The amount of Pell grant funds awarded to the student was incorrect. $591.50 of Pell grant funds should be returned to the Department of Education. Repeat Finding: There was not a similar finding in the prior year. Recommendation: $591.50 of Pell grant funds should be returned to the Department of Education. Communication between the registrar and financial aid should be improved. The financial aid office should be made aware of enrollment status changes timely. Management Response: The School returned $591.50 of Pell grant funds on February 4, 2025. Communication will be improved between the financial aid office and the registrar.

Federal Agency: U.S. Department of Education; Office of Federal Student Aid Pass through Entity: Not applicable Program Name: Federal Pell Grant Program AL# and Program Expenditures: 84.063 ($679,498) Award Number: P063P233976 Federal Award Year: July 1, 2023 to June 30, 2024 Questioned Costs: $2,376.25 Condition Found: The R2T4 was not calculated correctly for two of the twenty-five students in the compliance testing sample. A separate sample was selected to test additional R2T4 calculations. The R2T4 was not calculated correctly for four of the six students in the R2T4 testing sample. Between the two samples, all of the R2T4s completed during the year were reviewed. Criteria: Institutional charges used in the R2T4 calculation are always the institutional charges that were initially assessed to the student for the period of enrollment unless the School made a change to the charges before the student withdrew from the institution. Scheduled breaks of five or more consecutive days should be subtracted from the number of days in the semester. Cause: The Director of Financial Aid misunderstood how to calculate institutional charges. The Director thought a standard amount for tuition and fees were used no matter what a student’s actual charges were. One institutional schedule break of five consecutive days during the spring semester was not subtracted from the number of days in the semester. Possible Asserted Effect: The R2T4 calculations were not completed accurately. Between the six students, $2,384.57 of Federal Pell Grant Funds was awarded to students on February 4, 2025 and $8.32 was returned to the Department of Education on February 4, 2025. Repeat Finding: There was not a similar finding in the prior year. Recommendation: The R2T4s that were not calculated correctly should be recalculated. A total of $2,384.57 of additional Federal Pell Grant Funds should be awarded to students and $8.32 of Federal Pell Grant Funds should be returned to the Department of Education. Procedures should be improved to ensure that R2T4s are calculated correctly. Management Response: All of the R2T4s completed during the year were recalculated in January 2025. On February 4, 2025, $2,384.57 of Federal Pell Grant Funds were awarded to students and $8.32 of Federal Pell Grant Funds were returned to the Department of Education. Procedures will be improved to ensure that R2T4s are calculated correctly.

Condition Found: During our search for unrecorded liabilities, we noted that the cost of numerous services performed during the year ended June 30, 2023, were not recorded in accounts payable. In addition, there was a credit card overpayment that was improperly netted with expenditures made during the period. Further, prior year accruals were not properly reversed. Criteria: Internal controls around the cutoff of payables are critical for the accuracy of the accrual basis of accounting. Under the accrual basis of accounting, expenses are recorded when then they occur or transferred to the buyer, rather than at the time when expenses are paid. Cause: Management overlooked the service periods associated with certain invoices at year-end. Possible Asserted Effect: Due to inappropriate cutoff procedures established at year-end, the School did not record accruals for utilities services totaling $11,621. In addition, the School did not book healthcare services in the correct period and the accruals for payable was decreased by $12,987. Overall, accounts payable was adjusted by $93,504 on a net basis. Future years will likely experience similar errors if proper internal controls are not designed and implemented. Repeat Finding: See Finding 2022-001 for a similar finding in the current year. Recommendation: We recommend that the School prepare written instructions to be included in the School’s accounting policies and procedures manual that indicate basic procedures to achieve proper cutoff and completeness of accounts payable, accrued liabilities and prepaid expenses in the financial closing process, as well as specify the positions/staff responsible for performing such procedures and controls. Management Response: Contributing to the discrepancies with these accrual entries is the timing of the audit. Preliminary audit field work began before the end of the fiscal year and official on-campus fieldwork was completed on August 4 and we had not yet closed our July financial statements. The School made the required adjustments to their accounting records. The School will prepare written instructions to be included in the School’s accounting policies and procedures manual that indicate basic procedures to achieve proper cutoff and completeness of accounts payable, accrued liabilities and prepaid expenses in the financial closing process, as well as specify the positions/staff responsible for performing such procedures and controls. This will be completed in time to improve the cutoff procedures for the year ending June 30, 2024 (FY 2024).

Condition Found: During our testing, we noted that a true bank reconciliation was not prepared for certain bank accounts. Reconciliations were prepared using the bank balance and the check register balance. The School rolled forward each month’s ending check register balance to the beginning balance on the following month’s bank reconciliation and netted monthly bank activity and outstanding transactions from the check register to arrive at the ending balance. Criteria: The School should reconcile cash accounts accurately and on a timely basis using the bank balance and the balance per the general ledger instead of the check register balance. Reconciliations should be reviewed by a member of management who is knowledgeable in such matters. Cause: The accounting software the School uses did not have a bank reconciliation module. Therefore, management resorted using an alternative solution. Management used the check register balance, which is a transaction detail report, to reconcile to the bank statement without observing and reviewing the ending cash balance in the general ledger. Possible Asserted Effect: This resulted in cash being understated by $98,800 at year-end. In addition, there could potentially be future material adjustments to cash due to the improper method used to reconcile cash. Repeat Finding: There was not a similar finding in the prior year. Recommendation: We recommend that all bank accounts be reconciled monthly and in a timely manner. The School should purse adding the bank reconciliation module to their accounting software. In addition, reconciliations should be prepared using the bank balance and the balance per the general ledger instead of the check register balance. Lastly, we suggest that a member of management review the bank reconciliations for any unusual items, investigate and fully resolve any such items, and document his or her approval. Management Response: The School made the required adjustments to its accounting records. The School is reviewing its accounting policies and procedures and the recommendations above. The School will update its procedures during FY 2024.

Condition Found: During our testing, we noted that the School was not reconciling the accounts receivable subsidiary ledger to the general ledger throughout year. Criteria: The accounts receivable subsidiary ledger should be reconciled to the general ledger on a monthly basis. This practice serves as a check on the accuracy of the record-keeping process and the validity of account balances. Any differences should be investigated and resolved as soon as possible. Lastly, the reconciliation should be reviewed by a member of management who is knowledgeable in such matters. Cause: During the year, the School had significant issues with their student management system capturing all transactions associated with student accounts. In addition, management did not perform a proper reconciliation of the ending account balance within the general ledger. Possible Asserted Effect: This resulted in adjusting the receivable and corresponding tuition revenue of $58,573 as of June 30, 2023. Repeat Finding: There was not a similar finding in the prior year. Recommendation: We strongly suggest that procedures be established to ensure that accounts receivable balances are reconciled between the general ledger and the accounts receivable subsidiary system in a consistent and timely manner to prevent further discrepancies. Management Response: The School made the required adjustments to its accounting records. The School is reviewing its accounting policies and procedures and the recommendations above. The School will update its procedures during fiscal year 2024.

Condition Found: During the year, we noted that journal entries were being recorded within the general ledger without a consistent review process. Without complete separation of duties, particularly between the approval and recording of adjusting journal entries, transactions may be inaccurately recorded in the general ledger through a journal entry and not be detected. Criteria: Nonstandard journal entries should be approved on their own merit monthly, if not semi-annually, by an individual one level above the person making the journal entries to ensure their appropriateness. Cause: In the past, management has noted that its review of the financial statements is a sufficient review of the effect of journal entries posted during the year. However, this alone does not appear to be enough to prevent, detect, and correct misstatements in the financial statements, material or otherwise. Possible Asserted Effect: In the current year, there was approximately $243,000 in journal entry adjustments due to inappropriately reversing the prior year’s adjusting journal entries prepared by the auditors. There was approximately $72,000 in journal entry adjustments due to duplicate entries made during the year. In addition, there could be other potential misstatements in the financial statements in current and future years that may not be detected. Repeat Finding: There was not a similar finding in the prior year. Recommendation: We recommend that management develop a policy that all nonstandard journal entries be numbered, reviewed, and approved by the Director of Finance or another appropriate individual other than the individual responsible for recording the journal entries in the general ledger. Management Response: The School made the required adjustments to its accounting records. The School is reviewing its accounting policies and procedures and the recommendations above. The School will update its procedures during fiscal year 2024.

Federal Agency: U.S. Department of Education; Office of Federal Student Aid Pass through Entity: Not applicable Program Name: Federal Pell Grant and Federal Work Study ALN and Program Expenditures: 84.063 ($557,058) and 84.033 ($ 12,366) Award Number: P268K223976 and P033A226456 Federal Award Year: July 1, 2022 to June 30, 2023 Questioned Costs: $542 (ALN 84.033) Condition Found: There was an overaward of $542 for one of the twenty-five students in our sample. Criteria: The total amount of aid a student receives cannot be greater than his or her cost of attendance. Cause: The School made adjustments to its new tuition scholarship offered last fall which prohibited the scholarship funds from being reduced. Possible Asserted Effect: The student in question received $542 of Federal Work Study funds that the student was ineligible to receive. Repeat Finding: There was not a similar finding in the prior year. Statistical Sampling: The sample was not intended to be, and was not, a statistically valid sample. Recommendation: $542 of Federal Work Study funds should be returned and replaced with payroll funds from the School’s general budget. Policies and procedures should be updated to ensure that institutional and federal aid do not exceed a student’s need. Management Response: Management agrees with the auditors’ finding. Federal Pell Grant funds are entitlement funds and cannot be returned. The student in question also worked the hours in which Federal Work Study funds were awarded. Going forward, the School has made changes to the provisions of the institutional scholarship to avoid overawards. All state and federal aid and endowed scholarships are applied first and then the scholarship covers the remaining tuition cost.

Federal Agency: U.S. Department of Education; Office of Federal Student Aid Pass through Entity: Not applicable Program Name: Federal Pell Grant and Federal Supplemental Educational Opportunity Grant ALN and Program Expenditures: 84.063 ($557,058) and 84.007 ($ 9,616) Award Number: P063P223976 and P007A226456 Federal Award Year: July 1, 2022 to June 30, 2023 Questioned Costs: None Condition Found: For two of the twenty-five students in our sample, the School held Title IV credit balances for longer than fourteen days without written authorization. Criteria: An institution may not hold a credit balance, which is caused by federal student financial aid funds, on a student’s account for more than fourteen days without written authorization from the student. Cause: With the changing of the schedule during the holiday/final weeks on campus, the need for the return of funds was missed. Possible Asserted Effect: The Title IV credit balance was not returned timely to the student. Repeat Finding: See Finding 2022-006 for a similar finding in the prior year. Statistical Sampling: The sample was not intended to be, and was not, a statistically valid sample. Recommendation: The credit balances were returned to the students in question before the end of the academic year. Communication should be improved between the offices involved in the disbursement process to ensure that credit balances are refunded timely. Management Response: The credit balances were returned to the students in question before the end of the academic year. The financial aid office will follow-up with the cashier to ensure that, in the absence of a signed authorization to hold credit balances, the credit balance refunds are processed timely.

Federal Agency: U.S. Department of Education; Office of Federal Student Aid Pass through Entity: Not applicable Program Name: Federal Direct Student Loan Program ALN and Program Expenditures: 84.268 ($154,808) Award Number: P268K233976 Federal Award Year: July 1, 2022 to June 30, 2023 Questioned Costs: None Condition Found: A Federal Direct Loan exit interview was not completed by nor were instructions sent to the student on how to complete an exit interview when the student dropped to a less than half-time enrollment status. This omission occurred for one of the twenty-five students in our sample. Criteria: Federal Direct Loan recipients must receive exit interview counseling when the student graduates, leaves the institution, or drops below a half-time enrollment status. If in-person counseling is not completed, the school may mail written counseling materials to the student’s last known address. Cause: The financial aid office was unaware of the requirement to send an exit interview to a student who drops below half-time enrollment status. Possible Asserted Effect: The student was not aware of his or her responsibilities related to the Federal Direct Loan program, including repayment options and when repayment on the loan begins. Repeat Finding: There was not a similar finding in the prior year. Statistical Sampling: The sample was not intended to be, and was not, a statistically valid sample. Recommendation: Federal Direct Loan exit interview information should be sent to the student in question. Procedures should be improved to ensure that Federal Direct exit interviews are completed or information is sent to a student when a student drops below half-time attendance. Management Response: Federal Direct Loan exit interview information was sent to the student in question on October 27, 2023. Procedures will be improved to ensure Federal Direct Loan exit interviews are completed or information is sent to students when they drop below a half-time enrollment status at the School.

Federal Agency: U.S. Department of Education; Office of Federal Student Aid Pass through Entity: Not applicable Program Name: Federal Pell Grant Program ALN and Program Expenditure: 84.063 ($557,058) Award Number: P063P223976 Federal Award Year: July 1, 2022 to June 30, 2023 Questioned Costs:$2,585.50 Condition Found: For one of the twenty-five students in our sample, Federal Pell Grant funds were disbursed when the student did not begin attendance. Cause: The student was enrolled in on-line courses and the financial aid office did not realize the student never began attending the courses. Possible Asserted Effect: $2,585.50 needs to be returned to the Department of Education. Communication between offices should be improved to ensure that the financial aid office is informed when students make changes to their enrollment status. Repeat Finding: There was not a similar finding in the prior year. Statistical Sampling: The sample was not intended to be, and was not, a statistically valid sample. Recommendation: The School should return $2,585.50 of Federal Pell Grant funds to the Department of Education. Communication between the offices should be improved so that the financial aid office is promptly made aware of changes in a student’s enrollment status. The financial aid office should verify that the student completed an academic activity in an on-line class before disbursing aid. Management Response: The School returned the $2,585.50 in question to the Department of Education on September 6, 2023. Communication will be improved between the various offices on campus. Policies and procedures are being reviewed and updated, as needed, for the students participating in on-line courses.

FINDING 2022-001 ? Completeness and Recording of Liabilities Condition Found: During our search for unrecorded liabilities, we noted that the cost of numerous services performed during the year ended June 30, 2022 were not recorded in accounts payable. In addition, there was an overpayment on credit card purchases that was improperly netted with expenditures made during the period. Criteria: Internal controls around the cutoff of payables are critical for the accuracy of the accrual basis of accounting. Under the accrual basis of accounting, expenses are recorded when then they occur or transferred to the buyer, rather than at the time when expenses are paid. Cause: The School did not have adequate cutoff procedures in place at June 30, 2022. Possible Asserted Effect: Due to inappropriate cutoff procedures established at year-end, the School failed to record accruals for utilities services and various professional services totaling approximately $251,000. In addition, there was an overpayment on credit card purchases that caused accounts payable to be overstated by approximately $27,000. Repeat Finding: There was not a similar finding in the prior year. Recommendation: We recommend that the School prepare written instructions to be included in the School?s accounting policies and procedures manual that indicate basic procedures to achieve proper cutoff and completeness of accounts payable, accrued liabilities and prepaid expenses in the financial closing process, as well as specify the positions/staff responsible for performing such procedures and controls. Management Response: The School made the required adjustments to their accounting records. The School will prepare written instructions to be included in the School?s accounting policies and procedures manual that indicate basic procedures to achieve proper cutoff and completeness of accounts payable, accrued liabilities and prepaid expenses in the financial closing process, as well as specify the positions/staff responsible for performing such procedures and controls. This will be completed in time to improve the cutoff procedures for the year ending June 30, 2023 (FY 2023).

FINDING 2022-002 ? Capitalizing Property and Equipment Condition Found: During our testing of property and equipment, we noted multiple expenditures related to property and equipment that were not recorded properly. In one instance, a residence was purchased through a financing arrangement in which the disbursement was recorded as the total cost. In other instances, the School capitalized purchases based on what was disbursed instead of the total invoice received. In addition, there was an issue in correctly capitalizing improvements of buildings and donated assets. Lastly, there were disposals of vehicles that were improperly recorded by lowering depreciation expense instead of accumulated depreciation. Criteria: Property and equipment expenditures should be scrutinized by management to ensure that the proper amounts are capitalized, including reviewing the total invoice instead of the amount disbursed. In addition, donated property should be valued at the fair value on the date of the donation using third party appraisals when appropriate. Lastly, disposal of assets should decrease the accumulated depreciation balance and the gain/loss account, without affecting the depreciation expense. Cause: The School did not have adequate procedures in place to identify and record transactions related to property and equipment. Possible Asserted Effect: This resulted in numerous adjustments totaling approximately $995,000. Repeat Finding: There was not a similar finding in the prior year. Recommendation: We recommend the following: ? Property and equipment purchased under a financing arrangement should be reviewed thoroughly by management, and the total cost and related debt should be recorded on the purchase date. The asset cost should be depreciated over the estimated useful life, and subsequent payments on the debt should be recorded as reductions of the liability accrued. ? Property and equipment should be recorded based on the invoice and not that based on the disbursement made. Management should review the invoice along with the disbursement made. ? A written policy should be developed for recognizing in-kind contributions of goods and services. This policy will be most beneficial in that it will allow for easier and more consistent accounting treatment for contributed goods and services. Management Response: The School made the required adjustments to their accounting records. The School is reviewing their accounting policies and procedures and the recommendations above. The School will update their procedures during the FY 2023.

FINDING 2022-003 ? Recognizing Government Grants and Contributions Condition Found: During our testing of government grants, it was noted that the School filed for the employee retention tax credit (ERC) in February 2022. However, the amounts filed not yet received by June 30, 2022 were not recorded properly as a receivable and revenue as of year-end. Criteria: According to U.S. GAAP, contributions and grants should be recorded when received, if both a right of release and barrier do not exist. With the expenditure of qualified expenses and the filing for funding, there are no additional barriers with which the School needs to satisfy in order to recognize the grant related revenue. Therefore, a receivable and revenue should have been recorded as of year-end. Cause: The School was unaware of the U.S. GAAP requirements related to the recording of the ERC. Possible Asserted Effect: This resulted in an adjustment totaling $1,142,855. Repeat Finding: There was not a similar finding in the prior year. Recommendation: We recommend that all correspondence whether from an individual, corporation, foundation, or government entity (including government agreements/grants), be evaluated for whether the School has satisfied all conditions necessary to recognize contribution revenue. In the not-for-profit industry, ?received? generally means ?communicated? and is not necessarily synonymous with ?collected.? A donee may receive a contribution well before it is ever actually collected and deposited into the bank. For such timing differences, a contribution should be recognized immediately for the total amount promised, instead of when collected. Management Response: The School made the required adjustments to their accounting records The School is reviewing their accounting policies and procedures and the recommendations above. The School will update their procedures during the FY 2023.

FINDING 2022-004 ? Calculation of Allowance for Doubtful Accounts for Receivables Condition Found: During our testing of accounts and notes receivable, it was noted that there were no calculation, schedule, analysis, policy or other supporting documentation for the allowances that are noted within the financial statements. In fact, the allowances as of June 30, 2022 have remained at the same level for the past few years. Criteria: The allowance for doubtful accounts should represent management?s estimate of the amounts that might not be paid by customers. If actual experience differs, then management adjusts its estimation methodology to bring the reserve more into alignment with actual results. In accrual-basis accounting, adjusting the allowance for doubtful accounts at year-end improves the accuracy of financial reports representing a net realizable value for receivables. Cause: Due to staffing changes over past few years, the allowance for doubtful accounts had not been reviewed. Possible Asserted Effect: This resulted in an adjustment totaling $17,000 for the Schell notes receivable allowance. In addition, there could be potentially future material adjusting journal entry to the allowance balances for both tuition and Schell notes receivable if a policy and proper analyses are not performed by management. Repeat Finding: There was not a similar finding in the prior year. Recommendation: We recommend that management develop a method to determine an appropriate allowance for doubtful accounts estimation process methodology and consistently use it on a periodic basis, at least annually, to analyze whether an allowance should be recorded. There are several methods for management to use as an analysis to determine the appropriate allowance. We recommend that management consider the following methods: ? Management should develop an accounts receivable schedule that is categorized or based on days the receivable has been outstanding (30 days, 60 days, 90 days, 120+ days, one year, two, years, etc.). This will assist management to evaluate collectability based on how long the receivable has been outstanding. ? Comparing bad debt expense each year to write-offs during that year. Using this ratio over multiple years, rather than a single year could provide an useful method to calculate an accurate allowance. It is reasonable to expect the ratio of bad debt expense to write-offs to be close to 1.0 over an extended period. ? Comparing the beginning allowance for doubtful accounts to subsequent write-offs determines the adequacy of the existing allowance. Lower ratios indicate the allowance may be too low, while higher ratios may signify the accumulation of excessive allowances. Management Response: The School made the required adjustments to their accounting records The School is reviewing their accounting policies and procedures and the recommendations above. The School will update their procedures during the FY 2023.

FINDING 2022-005 ? Overaward Federal Agency: U.S. Department of Education; Office of Federal Student Aid Pass through Entity: Not applicable Program Name: Federal Direct Student Loan Program ALN and Program Expenditures: 84.268 ($149,449) Award Number: P268K223976 Federal Award Year: July 1, 2021 to June 30, 2022 Questioned Costs: $4,237 Condition Found: There was a combined total of $4,237 of overawards given to four of the twenty-eight students in our sample. Criteria: The total amount of aid a student receives cannot be greater than his or her cost of attendance. Cause: The incorrect cost of attendance was input into the School?s loan spreadsheet that determined the remaining need and loan eligibility for the students in question. Possible Asserted Effect: There was a total of $4,237 in overawards between the four students: ? The first student received $55 of unsubsidized loans that he or she was not eligible to receive. ? The second student received $1,429 of unsubsidized loans that he or she was not eligible to receive. ? The third student received $2,105 of unsubsidized loans that he or she was not eligible to receive. ? The fourth student received $648 of subsidized loans that he or she was not eligible to receive. Repeat Finding: See Finding 2021-004 for a similar finding in the prior year. Statistical Sampling: The sample was not intended to be, and was not, a statistically valid sample. Recommendation: One student who received subsidized loans has unsubsidized loan eligibility left after completing the needs analysis calculation. A total of $648 of subsidized loans should be reclassified to unsubsidized loans. The School should return a total $3,589 of unsubsidized loans for the remaining three students associated with this finding. Going forward, the School should limit subsidized and unsubsidized, plus, and private loan borrowing to the student?s cost of attendance. The Financial Aid Director should verify the correct cost of attendance is used on internally created spreadsheets. Management Response: Management agrees with the auditors? finding and their recommendation. The School will reclassify $648 of subsidized funds as unsubsidized funds. The School will return $3,589 of unsubsidized loan funds to the Department of Education. The Financial Aid Director will limit the total amount of aid a student receives to his or her cost of attendance and verify the cost of attendance used on internally created spreadsheets is correct.

FINDING 2022-006 ? Authorization to Hold Credit Balances Federal Agency: U.S. Department of Education; Office of Federal Student Aid Pass through Entity: Not applicable Program Name: Federal Pell Grant ALN and Program Expenditures: 84.063 ($484,684) Award Number: P063P213976 Federal Award Year: July 1, 2021 to June 30, 2022 Questioned Costs: None Condition Found: For three of the twenty-eight students in our sample, the School held Title IV credit balances for longer than fourteen days without written authorization. Criteria: An institution may not hold a credit balance, which is caused by federal student financial aid funds, on a student?s account for more than fourteen days without written authorization from the student. Cause: Staffing changes at the School lead to the authorization to hold credit balance forms not being completed. Possible Asserted Effect: The Title IV credit balance was not returned timely to the student. Repeat Finding: There was not a similar finding in the prior year. Statistical Sampling: The sample was not intended to be, and was not, a statistically valid sample. Recommendation: The credit balances were returned to the students in question before the end of the academic year. Communication should be improved between the offices involved in the disbursement process to ensure that credit balances are refunded timely. Management Response: The credit balances were returned to the students in question before the end of the academic year. The financial aid office will follow-up with the cashier to ensure that, in the absence of a signed authorization to hold credit balances, the credit balance refunds are processed timely.

FINDING 2022-007 ? NSLDS Reporting Federal Agency: U.S. Department of Education; Office of Federal Student Aid Pass through Entity: Not applicable Program Name: Federal Direct Student Loan Program ALN and Program Expenditures: 84.268 ($149,449) Award Number: P268K223976 Federal Award Year: July 1, 2021 to June 30, 2022 Questioned Costs: None Condition Found: The incorrect effective date of an enrollment status change was reported to the National Student Loan Database System (?NSLDS?) for one of the twenty-eight students selected for testing. Criteria: NSLDS informs loan servicers of changes in a student?s enrollment status that indicate when the repayments or interest accrual begins and ends. The date a student enrolls, withdraws, graduates, or drops below half-time status should be reported accurately. This information must be reported within sixty days of the status change. Cause: The student withdrew from the School in April 2021 and enrolled in the School again in August 2021. The student attended until March 22, 2022. The NSLDS withdrawal date was reported as April 2021. Possible Asserted Effect: The loan servicers were not aware of the correct deferral, repayment, and interest calculation dates. Repeat Finding: There was not a similar finding in the prior year. Statistical Sampling: The sample was not intended to be, and was not, a statistically valid sample. Recommendation: The Financial Aid Director should update the withdrawal date for the student in question in NSLDS. Procedures should be improved to ensure that the correct withdrawal date is reported in NSLDS. Management Response: The Financial Aid Director updated the withdrawal date in NSLDS for the student in question in November 2022. Procedures will be improved to ensure that the correct withdrawal date is reported in NSLDS.

FINDING 2022-008 ? Pell Award Calculation Federal Agency: U.S. Department of Education; Office of Federal Student Aid Pass through Entity: Not applicable Program Name: Federal Pell Grant Program ALN and Program Expenditure: 84.063 ($484,684) Award Number: P063P213976 Federal Award Year: July 1, 2021 to June 30, 2022 Questioned Costs: $181 Condition Found: The amount of Pell grant awarded was calculated incorrectly for one of the twenty-nine students who received Pell in our sample. The student was awarded Pell grant funds as if the student was enrolled full-time when the student was enrolled ? time. Cause: The Financial Aid Office was not informed that the student decided to take nine hours (3/4 time) instead of twelve hours (full-time). Possible Asserted Effect: $181 needs to be returned to the Department of Education. Communication between offices should be improved to ensure that the financial aid office is informed when a student makes changes to their enrollment status. Repeat Finding: See Finding 2021-006 for a similar finding in the prior year. Statistical Sampling: The sample was not intended to be, and was not, a statistically valid sample. Recommendation: The School should return $181 of Federal Pell Grant funds to the Department of Education. Communication between the offices should be improved so that the financial aid office is promptly made aware of changes in a student?s enrollment status. Management Response: The School returned the $181 in question to the Department of Education in December 2022. Communication will be improved between the various offices on campus.

FINDING 2022-009 ? R2T4 Calculations Federal Agency: U.S. Department of Education; Office of Federal Student Aid Pass through Entity: Not applicable Program Name: Federal Pell Grant Program Federal Direct Student Loan Program ALN and Program Expenditure: 84.063 ($484,684) 84.268 ($149,449) Award Number: P063P203976 P268K223976 Federal Award Year: July 1, 2021 to June 30, 2022 Questioned Costs: 84.063 ($1,167.43) Condition Found: All seven of the R2T4s completed by the School during the fiscal year were reviewed. The following items were noted: ? One R2T4 was calculated correctly, but $1,533.02 of Federal Grant funds were returned instead of $1,617.45 as required by the R2T4 calculation. ? One R2T4 was calculated correctly; however Federal Pell Grant funds totaling $1,083 were not returned to the Department of Education as required by the R2T4 calculation. ? One R2T4 was calculated correctly, but the funds were not returned timely. The correct amount of funds were returned before audit fieldwork began. Criteria: A R2T4 calculation is required when a student withdraws from all courses during an enrollment period. Funds are required to be returned to the Department of Education or lender within forty-five days of the date of determination. Cause: ? The incorrect amount was returned to the Department of Education. ? Due to a miscommunication between the financial aid and business offices, the School missed returning the R2T4 funds. ? Due to a miscommunication between the financial aid and business offices, the School returned the R2T4 funds after forty-five days from the date of determination. Possible Asserted Effect: ? An additional $84.43 of Federal Pell Grant funds should be returned to the Department of Education. ? $1,083 of Federal Pell Grant funds should be returned to the Department of Education. ? The R2T4 funds were not returned within forty-five days from the date of determination. Repeat Finding: See Finding 2021-005 for a similar finding in the prior year. Statistical Sampling: The sample was not intended to be, and was not, a statistically valid sample. Recommendation: The School should return at total of $1,167.43 of Federal Pell Grant funds. The Financial Aid Office should double check the data entry on the R2T4s. Procedures should be improved to ensure that R2T4 funds are returned timely. Management Response: The Student Financial Aid Director returned $84.43 of Federal Pell funds for the first student in question in November 2022. $1,083 of Federal Pell Grant funds were returned for the second student in question on November 4, 2022. Procedures will be improved to ensure that the R2T4 funds are returned timely.

FINDING 2021-001 ? Notification of Loan Disbursements Federal Agency: U.S. Department of Education; Office of Federal Student Aid Pass through Entity: Not applicable Program Name: Federal Direct Student Loan Program CFDA# and Program Expenditures: 84.268 ($225,658) Award Number: P268K213976 Federal Award Year: July 1, 2020 to June 30, 2021 Questioned Costs: N/A Condition Found: The School could not provide documentation that the required loan disbursement notifications were made to the student at the time disbursement for the eight students who received Federal Direct Student Loans in our sample. Criteria: Since the School uses passive acceptance, the School is required to report to the students in writing the anticipated date and amount of the disbursement, the student?s or parents? right to cancel all or a part of the loan and have the loan proceeds returned to the Department of Education, and procedures and deadlines by which the student or parent must notify the institution that want to cancel the loan no earlier than thirty days before the disbursement is made or seven days after. Cause: As part of the transition to a new Financial Aid Director, the email address used for sending notifications was changed. Access to any notifications sent prior to the change were lost. The new email disclosure did not contain the required information. Possible Asserted Effect: The students were not aware of the option to cancel a Federal Direct Loan disbursement and the procedures and deadlines for canceling the loan disbursement. Repeat Finding: There was not a similar finding in the prior year. Statistical Sampling: The sample was not intended to be, and was not, a statistically valid sample. Recommendation: The requirements for loan disbursement notifications should be reviewed. The School should make any necessary changes to the notification itself and the timing of the notification. Documentation of the notifications should be kept. Management Response: Management agrees with the auditors? finding and their recommendation. The School has already updated its loan disbursement notification e-mail and procedures to comply with the requirements.

FINDING 2021-002 ? Subsidized Loan Eligibility Federal Agency: U.S. Department of Education; Office of Federal Student Aid Pass through Entity: Not applicable Program Name: Federal Direct Student Loan Program CFDA# and Program Expenditures: 84.268 ($225,658) Award Number: P268K213976 Federal Award Year: July 1, 2020 to June 30, 2021 Questioned Costs: None Condition Found: One of the eight Federal Direct Loan recipients tested was awarded a subsidized loan at the sophomore level, when the student was eligible to receive subsidized loans at the junior/senior level. Criteria: The annual subsidized Federal Direct Loan limit is $3,500 for freshmen, $4,500 for sophomores, and $5,500 for juniors and seniors. Cause: The School used the grade year the student reported on the ISIR. The student?s transfer credits were not considered when the subsidized loan eligibility was determined. Possible Asserted Effect: The student was eligible for $5,500 of subsidized Federal Direct Loans and only received $4,500. The student received an additional unsubsidized loan of $545 when the student was eligible to receive the additional funds as a subsidized loan. Repeat Finding: There was not a similar finding in the prior year. Statistical Sampling: The sample was not intended to be, and was not, a statistically valid sample. Recommendation: The Financial Aid Director should reallocate $545 of unsubsidized Federal Direct Loans to subsidized Federal Direct Loans. Management Response: The Financial Aid Director reallocated $545 of the unsubsidized Federal Direct Loans to subsidized Federal Direct Loans in March 2022.

FINDING 2021-003 ? Exit Interview Federal Agency: U.S. Department of Education; Office of Federal Student Aid Pass through Entity: Not applicable Program Name: Federal Direct Student Loan Program CFDA# and Program Expenditures: 84.268 ($225,658) Award Number: P268K213976 Federal Award Year: July 1, 2020 to June 30, 2021 Questioned Costs: None Condition Found: Four of the thirty students selected for testing did not complete an exit, The School could not provide documentation that instructions for completing an exit interview were sent to the students when the students either withdrew, graduated, or was enrolled less than half-time. Criteria: An exit interview should be completed or mailed to a student to complete within thirty days from when a student withdraws, graduates from school, or is enrolled less than half-time for Federal Direct Loans. Cause: During the transition in financial aid directors, the e-mail address used for correspondence with students was changed. The School could not provide documentation that exit interview instructions were sent to the students in question. Possible Asserted Effect: The students were unaware of the loan repayment responsibilities at the time the students withdrew from the School. Repeat Finding: There was not a similar finding in the prior year. Statistical Sampling: The sample was not intended to be, and was not, a statistically valid sample. Recommendation: An exit interview was sent to the students in question in March 2022.. Procedures should be improved to ensure that an exit interview is completed when a student withdraws from the School. Management Response: An exit interview was sent to the students in question in March 2022. Procedures will be improved to ensure exit interviews are completed by or sent to students within thirty days of the date the student withdraws from the School.

FINDING 2021-004 ? Overaward Federal Agency: U.S. Department of Education; Office of Federal Student Aid Pass through Entity: Not applicable Program Name: Federal Direct Student Loan Program CFDA# and Program Expenditures: 84.268 ($225,658) Award Number: P268K213976 Federal Award Year: July 1, 2020 to June 30, 2021 Questioned Costs: $150 Condition Found: There was a $150 overaward given to one of the thirty students selected for testing. Criteria: The total amount of aid a student receives cannot be greater than his or her cost of attendance. Cause: The Financial Aid Director certified unsubsidized loans and private loans for the amount the student requested without limiting the amount of aid awarded to the student?s overall cost of attendance. Possible Asserted Effect: The student received $150 of unsubsidized loans that he or she was not eligible to receive. Repeat Finding: See Finding 2020-001 for a similar finding in the prior year. Statistical Sampling: The sample was not intended to be, and was not, a statistically valid sample. Recommendation: The School should return the $150. Going forward, the School should limit subsidized and unsubsidized, plus, and private loan borrowing to the student?s cost of attendance. Management Response: Management agrees with the auditors? finding and their recommendation. The School will return $150 of unsubsidized loan funds to the Department of Education. The Financial Aid Director will limit the total amount of aid a student receives to his or her cost of attendance.

FINDING 2021-005 ? R2T4 Calculations Federal Agency: U.S. Department of Education; Office of Federal Student Aid Pass through Entity: Not applicable Program Name: Federal Pell Grant Program CFDA# and Program Expenditure: 84.063 ($33,877) Award Number: P063P203976 Federal Award Year: July 1, 2020 to June 30, 2021 Questioned Costs: 84.063 ($1,939) Condition Found: The three R2T4s completed by the School during the fiscal year were reviewed. The following items were noted: ? The incorrect number of days for the fall semester was used for two of the R2T4 calculations. ? The required Federal Pell Grant funds were not returned to the Department of Education for one R2T4. ? An incorrect post withdrawal disbursement was made for one student after the R2T4 was calculated correctly. Criteria: A R2T4 calculation is required when a student withdraws from all courses during an enrollment period. The number of days in the semester is determined by taking the day classes start and end and subtracting any break days. Funds are required to be returned to the Department of Education or lender within thirty days of the date of determination. Cause: ? A data input error caused the start date of the fall semester to be August 26th instead August 24th in the R2T4 calculation. ? There was a change in financial aid directors and the School missed returning the R2T4 funds. ? The student was awarded the full amount of Federal Pell Grant funds instead of being limited to the amount computed in the R2T4 calculation. Possible Asserted Effect: ? After correcting the start date of the semester on the first R2T4, $656 of Federal Pell Grant funds are due to the Department of Education. Funds were not returned with the original R2T4 calculation so the full $656 should be returned. ? Correcting the start date on the second R2T4 did not change the outcome because the student in question still completed more than sixty percent of the semester, and therefore, earned the full amount of the aid awarded. ? The third R2T4 was calculated accurately and timely. However, the amount of the post withdrawal disbursement made to the student was incorrect. $1,283 of Federal Pell Grant funds are due to the Department of Education. Repeat Finding: See Finding 2020-003 for a similar finding in the prior year. Statistical Sampling: The sample was not intended to be, and was not, a statistically valid sample. Recommendation: The School should return at total of $1,939 of Federal Pell Grant funds. The Financial Aid Office should double check the data entry on the R2T4?s. Procedures should be improved to ensure that R2T4 funds are returned timely and that post withdrawal disbursements are accurate. Management Response: The Student Financial Aid Director returned a total of $1,939 of Federal Pell Grant funds to the Department of Education in March 2022. Procedures will be improved to ensure that the R2T4 data entry is accurate, funds are returned timely, and post withdrawal disbursements are correct.

FINDING 2021-006 ? Pell Award Calculation Federal Agency: U.S. Department of Education; Office of Federal Student Aid Pass through Entity: Not applicable Program Name: Federal Pell Grant Program CFDA# and Program Expenditure: 84.063 ($33,877) Award Number: P063P203976 Federal Award Year: July 1, 2020 to June 30, 2021 Questioned Costs: $793 Condition Found: The amount of Pell grant awarded was calculated incorrectly for one out of the twenty-nine students who received Pell in our sample. The student was awarded Pell grant funds as if the student was enrolled ? time when the student was enrolled half-time. Cause: The Pell disbursement on the student account did not agree with amount disbursed for the student from the Common Origination and Disbursement (?COD?). The student account shows the correct amount of $1,586 while COD shows the student received $2,379. We believe the School discovered the Pell calculation error, but never returned the funds to the Department of Education. Possible Asserted Effect: $793 needs to be returned to the Department of Education and the COD Pell disbursement records should be updated for the student to reflect the actual amount of Pell disbursed. Repeat Finding: There was not a similar finding in the prior year. Statistical Sampling: The sample was not intended to be, and was not, a statistically valid sample. Recommendation: The School should return $793 of Federal Pell Grant funds to the Department of Education and update the COD records for the student in question. Management Response: The School returned the $793 in question to the Department of Education and updated the COD records for the student in question in March 2022.

FINDING 2020-001 ? Overaward Federal Agency: U.S. Department of Education; Office of Federal Student Aid Pass through Entity: Not applicable Program Name: Federal Direct Student Loan Program CFDA# and Program Expenditures: 84.268 ($214,655) Award Number: P268K203976 Federal Award Year: July 1, 2019 to June 30, 2020 Questioned Costs: $1,115 Condition Found: There was a $1,115 overaward given to one of the thirty-seven students selected for testing. Criteria: The total amount of aid a student receives cannot be greater than his or her cost of attendance. Cause: The Financial Aid Director certified subsidized and unsubsidized loans and private loans for the amount the student requested without limiting the amount of aid awarded to the student?s overall cost of attendance. Possible Asserted Effect: The student received $1,115 of unsubsidized loans that he or she was not eligible to receive. Repeat Finding: This finding was not reported in the immediately prior audit. Statistical Sampling: The sample was not intended to be, and was not, a statistically valid sample. Recommendation: Since the overaward occurred because of an unsubsidized Federal Direct loan and was discovered after the funds had been disbursed, the School is not required to return the funds unless notified, otherwise, by the Department of Education. Going forward, the School should limit subsidized and unsubsidized, plus, and private loan borrowing to the student?s cost of attendance. Management Response: Management agrees with the auditors? finding and their recommendation. The School will wait for further guidance from the Department of Education on returning the $1,115 of unsubsidized loan funds. The Financial Aid Director will limit the total amount of aid a student receives to his or her cost of attendance.

FINDING 2020-002 ? Verification Federal Agency: U.S. Department of Education; Office of Federal Student Aid Pass through Entity: Not applicable Program Name: Federal Pell Grant CFDA# and Program Expenditures: 84.063 ($560,260) Award Number: P063P193976 Federal Award Year: July 1, 2019 to June 30, 2020 Questioned Costs: Unknown Condition Found: The incorrect family size and number of family members in college was incorrect for one of the thirty-seven students in our sample. Criteria: If a student is in the V1 verification group, the following items must be verified: adjusted gross income, U.S. income taxes paid, untaxed portions of IRA distributions, untaxed portions or pensions, IRA deductions and payments, tax exempt interest income, education credits, household size, the number in college, SNAP benefits, and child support paid. Cause: A sibling who was not a dependent and did not receive more than fifty percent of his support from the parents was included in the household size and number of family members in college. Possible Asserted Effect: The Expected Family Contribution could change which could cause an over or under award of federal aid, especially the Federal Pell Grant. Repeat Finding: This finding was not reported in the immediately prior audit. Statistical Sampling: The sample was not intended to be, and was not, a statistically valid sample. Recommendation: The Financial Aid Office should correct the number of family members and the number of family members in college and recalculate the Expected Family Contribution (?EFC?). Aid should be adjusted if the EFC changes. Procedures should be improved to ensure that discrepancies found in the verification process are reviewed and corrected. Management Response: Management agrees with the auditors? finding and their recommendation. The Financial Aid Director attempted to update the number of family members and the number of family in college. However, the Department of Education was not accepting changes to 2019-2020 information since it was after September 30, 2020. The School will wait for further guidance from the Department of Education on how to correct the information for the student in question. Procedures will be improved to ensure that verification process are reviewed and corrected.

FINDING 2020-003 ? R2T4 Calculations Federal Agency: U.S. Department of Education; Office of Federal Student Aid Pass through Entity: Not applicable Program Name: Federal Pell Grant Program CFDA# and Program Expenditure: 84.063 ($560,260) Award Number: P063P193976 Federal Award Year: July 1, 2019 to June 30, 2020 Questioned Costs: 84.063 ($335) Condition Found: Students were administratively withdrawn from the School and the required R2T4 was not completed. This occurred for two of the thirty-seven students in our sample. Criteria: A R2T4 calculation is required when a student withdrawals from all courses during an enrollment period. Cause: The students in question were administratively withdrawn from the School due to lack of attendance in the ADEP (on-line) program. This information was not provided to the student financial aid office. Possible Asserted Effect: An R2T4 was not completed to determine if the student was eligible for the full amount of federal financial aid disbursed. $335 of Federal Pell Grant funds is due to the Department of Education for one of the students in question. The Financial Aid Office believes the second student withdrew due to COVID-19 and has contacted the student to verify the reason for the withdrawal. If the student was a COVID-19 withdrawal, no funds will need to be returned. However, if the School determines the student withdrew for other reasons, the R2T4 calculation will be made and the required funds returned to the Department of Education. Repeat Finding: There was not a similar finding in the prior year. Statistical Sampling: The sample was not intended to be, and was not, a statistically valid sample. Recommendation: The Student Financial Director should complete the R2T4 calculation for the students in question. Based on the R2T4 calculation, one student received $335 of Federal Pell Grant funds that the student was ineligible to receive. $335 should be returned to the Department of Education. The School should determine if the second student withdrew due to COIVD-19. If the student was a COVID-19 withdrawal, the R2T4 should be completed, but funds will not need to be returned. If the student withdrew for other reasons, the funds required to be returned as a result of the R2T4 calculation will be returned to the Department of Education. Management Response: The Student Financial Aid Director confirmed the date of the withdrawal with the registrar?s office and completed the R2T4 calculation for the first student in question. $335 of Federal Pell Grant funds was due to the Department of Education. The funds were returned on December 1, 2020. The Student Financial Aid Director is in the process of contacting the second student to determine if he was a COVID-19 withdrawal. After the response is received, the Student Financial Aid Director will complete the R2T4 and return funds, if necessary.

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