CENTRAL STATE UNIVERSITY

FINDING 2023-018 – MATCHING FOR ENDOWMENTS FROM GRANTS Federal Program Information: Title III, ALN #84.031B Criteria: The Title III grant requires a match for endowment funding. Condition: The required match did not occur during the fiscal year. Context: During the fiscal year 2021 a contribution was recorded to the endowment for $200,000. This was an allowable expenditure under the grant agreement. However, a match of $200,000 was required, and the match was not made during fiscal year 2021, 2022 or 2023. During the current year, there was no match made to the endowment. In addition, there were transfers made from the endowment investment account in the amount of $1,107,619 that was not for purposes outlined within the endowment agreement. The $1,107,619 was repaid to the account in April 2024. Questioned Cost: $1,307,619 Effect: The University was not in compliance with the grant agreement. Cause: The University did not follow up and make the transfer from local funds and inappropriately transferred funds from the investment endowment account. Repeat Finding: Yes, modified from the prior year. Recommendation: We recommend that when the original grant expenditure is recorded, that the grant match occurs at the same time. Additionally, we recommend that the University not transfer any funds from the investment endowment accounts unless the conditions meet the endowment agreement requirements. Response: The University acknowledges this finding and the importance of maintaining the accuracy and integrity of grant funds. The University will review the status of the matching funds and coordinate with the U.S. Department of Education if any adjustments are required. The questioned cost was resolved after June 30, 2023.

Federal Program Information: Federal Direct Loan Program, ALN #84.268, Federal Pell Grant Program, ALN #84.063, Federal Supplemental Educational Opportunity Grants, ALN #84.007 Criteria: 34 CFR 668.22 outlines when a recipient of the loan program withdraws during the year, the University must determine the amount of the loan that the student earned as of the student’s withdrawal date for a Return of Title IV Funds. Condition: The University did not comply with all requirements associated with the calculation and return of Title IV funds for students who withdrew during an academic term. The calculations were not formally reviewed by an independent individual. Context: During testing of the Return of Title IV) population, a sample of student records was selected to evaluate compliance with federal requirements. The following exceptions were identified within the sample tested: • For 19 students the University did not return Title IV funds within the required 45-day timeframe. The range was from 50 days to 453 days. • For 4 students where the calculations were performed correctly; the actual amounts returned differed from the calculated amounts by more than $10. The amount of the over-return was $1,149. • For 1 student where 100% of Title IV aid was returned, as management determined the student did not attend and assigned a withdrawal date of the first day of the term. Aid was disbursed in August and September 2022 and it was not returned until January 2023, exceeding the required timeframe. • For 4 students the Registrar did not maintain an Official Withdrawal Form or other supporting documentation to substantiate the withdrawal date used in the calculation. Questioned Cost: Unknown Effect: Aid was not returned timely, support was not maintained and incorrect amounts were returned. Cause: The Student Financial Aid office experienced turnover and the process to review the calculations was not completed. Repeat Finding: Yes Recommendation: We recommend that the University review and update its policies and procedures in place over processing and review of Return of Title IV Aid Calculations. Response: The University is actively reviewing and updating policies and procedures regarding Return to Title IV aid calculations. Data challenges are being addressed, and additional controls are now in place to ensure this is not a repeat finding moving forward. These include new personnel, additional training and system upgrades that ensure accurate and timely R2T4 processing. In addition, the University is recalculating R2T4 calculations covering this audit period as part of a separate engagement.

FINDING 2023-020 – STUDENT FINANCIAL AID DISBURSEMENTS Federal Program Information: Federal Direct Loan Program, ALN #84.268 Criteria: 34 CFR 685.203, Loan Limits Condition: Federal Direct Loans were incorrectly awarded and disbursed to students. Context: Five students incorrectly received unsubsidized loans that was above their eligibility amount. Questioned Cost: $3,754 Effect: Students were incorrectly awarded and disbursed student financial aid. Cause: Errors in management's packaging of the student financial aid resulted in inaccurate awards and disbursements to students. Repeat Finding: Yes Recommendation: We recommend implementing procedures that appropriately determines student financial aid to students and ensures the proper disbursements. Response: The University is actively reviewing and updating policies and procedures regarding eligibility and disbursement controls. The University has implemented various new reports for monitoring and correcting over/under award situations.

FINDING 2023-021 – STUDENT FINANCIAL AID REPORTING Federal Program Information: Federal Direct Loan Program, ALN #84.268, Federal Pell Grant Program, ALN #84.063, Federal Supplemental Educational Opportunity Grants, ALN #84.007 Criteria: Institutions participating in Title IV programs are required to submit accurate and complete reports to the U.S. Department of Education, including the Fiscal Operations Report and Application to Participate (FISAP) and Common Origination and Disbursement (COD) records. Per federal requirements, data reported must be supported by underlying records, reconciled to institutional systems, and reviewed for accuracy prior to submission. Condition: The University did not ensure the accuracy and completeness of information reported in the FISAP and COD systems. Context: Errors or lack of support related to the FISAP include: • The number of undergraduate and graduate students. • The total tuition and fees for undergraduate, graduate, and professional students. • The total number of students was misstated by 100 students for dependent undergraduate students. • The total number of students was misstated by 292 students for independent undergraduate students. • Areas missing support were the following sections: Fiscal Operations Report, Fiscal Operations Report Federal Supplemental Educational Opportunity Grant Program and Program Summary for Award Year. Errors related to the COD include: • The academic start date was incorrect for all students tested: o Fall term dates were off by 7 days o Spring term dates were off by 1 day • For 1 student, the cost of attendance reported did not agree to the student file. Questioned Cost: None Effect: Inaccurate and unsupported reporting may result in noncompliance with federal reporting requirements and reduced reliability of information used by the U.S. Department of Education. Cause: Inadequate internal controls over the preparation and review of FISAP and COD reporting. Repeat Finding: No Recommendation: We recommend the University establish a formal review and approval process for FISAP and COD submissions. Response: The University recognizes the importance of submitting an accurate FISAP and maintaining supporting documentation. Data challenges are being addressed, and additional controls are now in place to ensure this is not a repeat finding moving forward. These include new personnel, additional training and system upgrades that ensure accurate reporting. The University recognizes the importance of submitting accurate COD information. Data challenges are being addressed, and additional controls are now in place to ensure this is not a repeat finding moving forward. These include new personnel, additional training and system upgrades that ensure accurate reporting.

FINDING 2023-022 – ALLOWABLE COSTS FOR LAND GRANT Federal Program Information: Land Grant Program, ALN #10.512 Criteria: Costs charged to the grant need to relate to activities occurring within the applicable fiscal year and be supported by adequate documentation. Condition: The University recorded and claimed certain expenses in the current fiscal year even though the related service period extended beyond year-end. In addition, supporting documentation for certain expenses could not be provided. Context: Of 62 expenses tested, 2 related to periods subsequent to the fiscal year-end; however, the full invoice amounts were recorded and claimed in the current year rather than allocating the prepaid portion to the subsequent fiscal year. Additionally, supporting documentation for 2 of 62 expense invoices could not be located. Questioned Cost: $34,794 Effect: Current-year grant expenses were overstated, and the lack of supporting documentation increases the risk that unallowable or unsupported costs could be charged to the program. Cause: The University did not adjust grant expenses for an adjustment to prepaid amounts and due to turnover invoices could not be located. Repeat Finding: No Recommendation: We recommend that expenses be reviewed for recording in the proper period when the invoice is received and all invoices be maintained. Response: The University acknowledges this finding and recognizes the importance of reviewing and recording expenses in the proper period. To address the matter, the University will implement procedures to ensure expenses are charged to the correct program in a timely manner and all documentation is maintained.

FINDING 2023-023 – ALLOWABLE COSTS FOR TITLE III Federal Program Information: Title III, ALN #84.031B Criteria: Costs charged to the grant need to relate to activities occurring within the applicable fiscal year and endowment transfers should occur timely. Condition: The University recorded and claimed certain expenses in the current fiscal year even though the related service period extended beyond year-end. In addition, contributions to endowments did not occur when recorded as an expense. Context: Of 60 expenses tested, 4 related to periods subsequent to the fiscal year-end; however, the full invoice amounts were recorded and claimed in the current year rather than allocating the prepaid portion to the subsequent fiscal year. Additionally, there was 1 of 60 expense invoices for an endowment contribution that was recorded as an expense but not transferred to the endowment. Questioned Cost: $159,367 related to prepaid expenses and $100,000 related to endowments. Effect: Current-year grant expenses were overstated, and the lack of timely transferring of endowment contributions increases the risk that unallowable or unsupported costs could be charged to the program. Cause: The University did not adjust grant expenses for an adjustment to prepaid amounts and did not timely transfer endowment contributions. Repeat Finding: Yes Recommendation: We recommend that expenses be reviewed for recording in the proper period when the invoice is received and all endowment contributions be deposited upon expense. Response: The University acknowledges this finding and recognizes the importance of adjusting grant expenses and timely transferring endowment contributions. To address the matter, the University will implement procedures to ensure grant expenses are properly adjusted and endowment contributions are transferred in a timely manner.

FINDING 2023-024 – ALLOWABLE COSTS FOR CARES ACT Federal Program Information: Coronavirus Aid, Relief and Economic Security (Cares) Act, ALN #84.425J Criteria: Costs charged to the grant need to be supported by adequate documentation. Condition: The University recorded and claimed certain expenses in the current fiscal year, however, supporting documentation for certain expenses could not be provided. Context: Supporting documentation for 3 of 61 expense invoices could not be located. Questioned Cost: $187,185 Effect: Current-year grant expenses were overstated, and the lack of supporting documentation increases the risk that unallowable or unsupported costs could be charged to the program. Cause: Due to turnover invoices could not be located. Repeat Finding: No Recommendation: We recommend that all invoices be maintained. Response: The University agrees with this finding and recognizes the importance of ensuring all invoices can be located. To address the matter, the University will continue to strengthen documentation and retention procedures and internal controls to ensure invoices are properly maintained and readily accessible.

Federal Program Information: Title III, ALN #84.031B Criteria: The Title III grant requires a match for endowment funding. Condition: The required match did not occur during the fiscal year. Context: During the fiscal year 2021 a contribution was recorded to the endowment for $200,000. This was an allowable expenditure under the grant agreement. However, a match of $200,000 was required, and the match was not made during fiscal year 2021 or fiscal year 2022. During the current year, there was no match made to the endowment. Questioned Cost: None Effect: The University was not in compliance with the grant agreement. Cause: The University did not follow up and make the transfer from local funds. Repeat Finding: Yes Recommendation: We recommend that when the original grant expenditure is recorded, that the grant match occurs at the same time. Response: We agree with the intent of this finding but not the dollar amounts. The contribution of $100,000 was received via Title III and Central State matched the $100,000. The total of both amounts is $200,000. Central State matches with $100,000. We did have a time lag for execution of the check and transfer to the endowment. The controller’s office will establish the protocol of being timely in matching the payment and in depositing the funds in the appropriate investment account. Responsible Person: Controller (Trasenna Gray) Completion Date: January 2024 and ongoing Auditor Response: The documentation provided shows that the endowment was funded $200,000 from federal funds during fiscal year 2021 and there has been no supporting documentation provided to show any funds related to a match. The $200,000 was included in the schedule of federal expenditures in fiscal year 2021 and was requested for reimbursement from federal funds.

Federal Program Information: Title III, ALN #84.031B Criteria: Title III costs claimed as expenses need to have the underlying activity within the fiscal year. Condition: Expenses that were for a time period longer than the fiscal year were fully expensed and claimed in the current year. Context: 7 of 60 expenses tested were for a time period that was longer than the current fiscal year. The entire amount of the invoice, including the portion outside of the fiscal year was expensed and claimed in the current year. Questioned Cost: $42,375 Effect: Expenses for the current year were overstated. Cause: The University did not adjust grant expenses for an adjustment to prepaid amounts. Repeat Finding: No Recommendation: We recommend that expenses be reviewed for recording in the proper period when the invoice is received. Response: Views of responsible officials: Curtis Pettis Completion Date: Finding Challenged The University concurs with the finding. The University will put procedures in place within the Accounts Payable department to identify invoice payments which impact expenses beyond the current Fiscal Year. The University Controller will use this information to ensure the prepaid entries are completed as part of the monthly closing process. Responsible Person: Controller (Trasenna Gray) Completion Date: January 2024

Federal Program Information: Federal Direct Loan Program, ALN #84.268, Federal Pell Grant Program, ALN #84.063, Federal Supplemental Educational Opportunity Grants, ALN #84.007 Criteria: 34 CFR 668.22 outlines when a recipient of the loan program withdraws during the year, the University must determine the amount of the loan that the student earned as of the student’s withdrawal date for a Return of Title IV Funds. Condition: The University did not comply with all requirements associated with the calculation and return of Title IV funds for students who withdrew during an academic term. Context: a) The registrar did not maintain support for the withdraw slips for the individuals that had official withdrawals during the fiscal year. b) The University was unable to provide a complete population of those that had Return of Title IV funds returned during the fiscal year. c) Thirty-four students in our sample had calculations performed but the amount calculated for the school to return in the amount of $65,826 was not returned to the Department of Education within the 45 day requirement. d) Two students were entitled to post-withdrawal disbursement of Pell funds and the funds were not provided to them. Questioned Cost: Unknown Effect: Errors were made during the calculations, support was not maintained and calculations were not performed. Cause: The Student Financial Aid office experienced turnover and the process to review the calculations was not completed during fiscal year 2022. Repeat Finding: Yes Recommendation: We recommend that the University review and update its policies and procedures in place over processing and review of Return of Title IV Aid Calculations. Response: Due to high turnover within multiple departments tasked with administering Financial Aid and the time required for the training of new staff on the aid disbursement process, errors were made due to lack of knowledge of the rules. Training and verification of information at every level is a top priority. The staff now has a much better understanding of the process and rules concerning awards. In addition, the director’s are actively working on improvements to the ERP system, “Banner”, so that errors that were due to human activities are reduced or eliminated. Already several processes, such as confirming attendance for aid posting is automatic. Now, more than one staff member is trained and responsible for processes and the team has consistent scheduled follow-up meetings on key actions in this area. Responsible Person: Director of Financial Aid (Mitch Dedor) & Registrar (Amanda Koci) Completion Date: December 2023

Federal Program Information: Federal Direct Loan Program, ALN #84.268 Criteria: 34 CFR 685.203, Loan Limits Condition: Federal Direct Loans were incorrectly awarded and disbursed to students. Context: Three students incorrectly received unsubsidized loans based on independent limits instead of dependent limits. Questioned Cost: $9,250 Effect: Students were incorrectly awarded and disbursed student financial aid. Cause: Errors in management's packaging of the student financial aid resulted in inaccurate awards and disbursements to students. Repeat Finding: No Recommendation: We recommend implementing procedures that appropriately determines student financial aid to students and ensures the proper disbursements. Response: There is a myriad of activities and timing issues that can impact awards and ultimate disbursements. In some cases, the dependency status can change as FAFSA and corresponding loan forms are revised. The Financial Aid department is committed to review internal processes and system rules to ensure that the Banner packaging process is set up to catch changes in dependency status and awards accordingly. Responsible Person: Director of Financial Aid (Mitch Dedor) Completion Date: December 2023

FINDING 2021-004 ? RETURN OF TITLE IV FUNDS Federal Program Information: Federal Direct Loan Program, ALN #84.268, Federal Pell Grant Program, ALN #84.063, Federal Supplemental Educational Opportunity Grants, ALN #84.007 Criteria: 34 CFR 668.22 outlines when a recipient of the loan program withdraws during the year, the University must determine the amount of the loan that the student earned as of the student?s withdrawal date for a Return of Title IV Funds. Condition: The University did not comply with all requirements associated with the calculation and return of Title IV funds for students who withdrew during an academic term. Context: a) The registrar did not maintain support for the withdraw slips for the individuals that had official withdrawals during the fiscal year. b) The University was unable to provide a complete population of those that had Return of Title IV funds returned during the fiscal year. c) Six students tested had calculations performed but the amount calculated for the school to return in the amount of $13,424 was not returned to the Department of Education within the 45 day requirement. d) Six students tested did not have full calculations performed and aid was not returned to the Department of Education. Questioned Cost: Unknown Effect: Errors were made during the calculations, support was not maintained and calculations were not performed. Cause: The Student Financial Aid office experienced turnover and the process to review the calculations was not completed during fiscal year 2021. Repeat Finding: Yes Recommendation: We recommend that the University review and update its policies and procedures in place over processing and review of Return of Title IV Aid Calculations. Views of responsible officials and planned corrective actions: See separate corrective action plan document.

FINDING 2021-005 ? MATCHING FOR ENDOWMENTS FROM GRANTS Federal Program Information: Title III, ALN #84.031B Criteria: The Title III grant requires a match for endowment funding. Condition: The required match did not occur during the fiscal year. Context: During the year a contribution was recorded to the endowment for $200,000. This was an allowable expenditure under the grant agreement. However, a match of $200,000 was required, and the match was not made. Questioned Cost: None Effect: The University was not in compliance with the grant agreement. Cause: The University did not follow up and make the transfer from local funds. Repeat Finding: No Recommendation: We recommend that when the original grant expenditure is recorded, that the grant match occurs at the same time. Views of responsible officials and planned corrective actions: See separate corrective action plan document.

FINDING 2021-006 ? STUDENT FINANCIAL AID DISBURSEMENTS Federal Program Information: Federal Direct Loan Program, ALN #84.268, Federal Pell Grant Program, ALN #84.063, Criteria: 34 CFR 690.63, Calculation of a Federal Pell Grant for a Payment Period and 34 CFR 685.203, Loan Limits Condition: Federal Direct Loans and Federal Pell Grants were incorrectly awarded and disbursed to students. Context: a) Four students had Pell disbursement errors, both under award and over award, because Pell chart levels were not followed based on hours attended. Total amount of errors - $3,696. b) One student had a subsidized loan disbursement error due to the wrong class level utilized in awarding. Total under award of $1,000. c) One student had a subsidized loan disbursement error because the University understood aggregate levels had been met but the National Student Loan Database System showed it had not. Total $750 under award d) One student submitted a satisfactory academic progress policy appeal and gained approved during the semester, but the University did not award loans post approval of the appeal resulting in an under award of subsidized and unsubsidized loans of $2,250 and $2,000, respectively. e) One student had availability of subsidized loans that was below the annual loan limit. The University did not include that additional availability in the unsubsidized loans amount for a $163 under award. f) One student was awarded $6,000 in unsubsidized loans but as a a dependent student should have received $2,000. Additionally, the University incorrectly provided an additional $4,000 in unsubsidized loans instead of awarding a PLUS loan, for which the student had been approved for. Questioned Cost: $13,859 Effect: Students were incorrectly awarded and disbursed student financial aid. Cause: Errors in management's packaging of the student financial aid resulted in inaccurate awards and disbursements to students. Repeat Finding: No Recommendation: We recommend implementing procedures that appropriately determines student financial aid to students and ensures the proper disbursements. Views of responsible officials and planned corrective actions: See separate corrective action plan document.

FINDING 2021-007 ? DIRECT LOAN DISBURSEMENTS Federal Program Information: Federal Direct Loan Program, ALN #84.268 Criteria: 34 CFR 685.303(b)(5) requires that Direct Loans to a first-year, first-time borrower be delayed in disbursement for 30 days. Condition: First time direct loan borrowers received the first installment of their direct loans before the 30 day waiting period. Context: Five students had direct loan disbursements 15 days after the start of classes, one student had a direct loan disbursement 16 days after the start of classes and one student had a direct loan disbursement 29 days after the start of classes. Questioned Cost: None Effect: Students that were first time borrowers had direct loan first installment payments before the thirty day compliance requirement. Cause: The University's Banner system was set up with the original planned start date of classes, however the date was not updated in the system to the final start date of classes. Repeat Finding: No Recommendation: We recommend a review of internal packaging/disbursement information to ensure compliance. Views of responsible officials and planned corrective actions: See separate corrective action plan document.

Finding 2020-002 Federal Program Information: Federal Direct Loan Program, CFDA #84.268 Criteria: Loan limits are defined for the Federal Direct Loan Program based on academic year of study within 34 CFR 685.203. Condition: The University incorrectly awarded and disbursed subsidized loans to six students based on their class status or calculated eligibility. Context: a) One student with freshman level transcript credits was awarded based on sophomore standing resulting in a $1,000 overaward. b) One student was awarded $98 in excess of their subsidized loan eligibility. c) Two students received unsubsidized loans collectively representing $1,153 that should have been awarded as subsidized loans. d) Two graduate students received subsidized loans of $5,400 that they were ineligible for, representing an overaward of $11,000. Questioned Cost: $12,098 Effect: Students either did not receive the correct amount or type of Federal Direct Loans. Cause: Lack of controls during the packaging process to award the correct loan amounts or type based on the academic year of study. Repeat Finding: Yes Recommendation: We recommend the University implement procedures to ensure students are awarded loans based on the applicable eligibility requirements. Views of responsible officials and planned corrective actions: See separate correction action plan document.

Finding 2020-003 Federal Program Information: Federal Direct Loan Program, CFDA #84.268, Federal Pell Grant Program, CFDA #84.063 Criteria: 34 CFR 668.22 outlines when a recipient of the loan program withdraws during the year, the University must determine the amount of the loan that the student earned as of the student?s withdrawal date for a Return of Title IV Funds. Condition: The University did not comply with all requirements associated with the calculation and return of Title IV funds for students who withdrew during an academic term Context: a) Two students had loan amounts included as aid that could have been disbursed. Instead of calculated post-withdrawal disbursements (which were not made) the University should have returned $2,049 and $1,252 of the unsubsidized loans. b) One student's return of funds calculation used a withdrawal date one day later than the student's e-mail indicating their intent to withdraw and did not include the Pell amount of $1,549 as disbursed aid. The discrepancy impacted the calculation and an additional $22 in unsubsidized loans should have been returned. c) For three students, a $127 charge that was subsequently reversed from their account was used to determine the institutional charges. For two of these three students, the unsubsidized lon amounts returned by the University was collectively $172 too high d) The University did not perform calculations for unofficial withdrawals during Spring Term as all calculations were exempt from having funds returned due to the COVID-19 pandemic. However, the University was still required to perform the calculations in order to quantify the amount of funds that were not required to be sent back to the Department of Education. Questioned Cost: $3,323 Effect: The University did not return the correct amounts of unsubsidized loans. Additionally, the University did not calculate the unofficial withdrawals. Cause: The Student Financial Aid office experienced turnover and the process to review the calculations was not completed during fiscal year 2020. Repeat Finding: Yes Recommendation: We recommend that the University review and update its policies and procedures in place over processing and review of Return of Title IV Aid Calculations. Views of responsible officials and planned corrective actions: See separate corrective action plan document.

Finding 2020-004 Federal Program Information: Coronavirus Aid, Relief and Economic Security Act, CFDA #84.425 Criteria: Lost revenue is an allowable use of funds under the Coronavirus Aid, Relief and Economic Security Act. The calculation of the lost revenue needs to be consistent with the cost principles of the Uniform Guidance (2 CFR part 200 subpart E). Condition: The University did not provide adequate support for some of the lost revenue amounts claimed under CFDA #84.425J. Context: The University utilized estimates to determine certain lost revenue amounts that were claimed as a result of spring and summer activities not taking place due to the COVID-19 pandemic. For some activities, no supporting documentation was provided and in other activities, the documentation that was provided was not consistent with the amounts recorded by the University. Other items claimed as lost revenue did have adequate supporting documentation. Questioned Cost: $289,277 Effect: The University recorded unallowable lost revenue amounts against the federal grant and received reimbursement for these claims. Cause: The University recorded its lost revenue amounts associated with the program when guidance was in process of being released and in certain instances made estimates that were not able to be supported. Repeat Finding: No Recommendation: The University should formally review all guidance provided by the awarding agency to ensure that lost revenues being claimed are accurate and supported. Views of responsible officials and planned corrective actions: See separate corrective action plan document.

Finding 2020-005 Federal Program Information: Student Financial Aid Cluster, CFDA #84.007, 84.033, 84.063, 84.268, and 84.379 Criteria: The Uniform Guidance (2 CFR part 200 subpart F) defines the basis for Federal awards that should be included within the Schedule of Expenditures of Federal Awards (SEFA). Condition: The University did not identify the correct amounts to be presented on the SEFA for the Student Financial Aid Cluster. Context: The University included amounts within the Student Financial Aid Cluster that did not relate to current year expenses. Questioned Cost: $0 Effect: The SEFA contained incorrect amounts. Cause: The SEFA was not fully reviewed for completeness due to turnover in various departments. Repeat Finding: No Recommendation: The University should formally review the SEFA to ensure that all amounts presented are accurate and supported. Views of responsible officials and planned corrective actions: See separate corrective action plan document.

Federal Program Information: Federal Direct Loan Program, CFDA #84.268 and Federal Pell Grant Program, CFDA #84.063 Criteria: 34 CFR 690.63, Calculation of a Federal Pell Grant for a Payment Period and 34 CFR 685.203, Loan Limits Condition: Federal Direct Loans and Federal Pell Grants were incorrectly awarded and disbursed for a number of students sampled. Context: a) Five students in our sample received an incorrect amount of Pell funds due to incorrect enrollment data being utilized during the awarding process. One of these students also did not receive the subsidized loans they were eligible for during Spring semester. In total, $3,067 of Pell funds and $1,750 of subsidized loans were underawarded and $1,524 of Pell funds were overawarded. b) Two students in our sample were awarded aid based on an incorrect expected family contribution (EFC). While there was no impact to the amounts on one student, one student did not receive $6,095 in Pell funds that they were eligible for and subsequently borrowed more in an outside alternative loan than they were eligible for. c) Two students in our sample were awarded federal loans based on the incorrect grade level status. This resulted in one student receiving $2,500 less in subsidized loans that they were eligible for and one student receiving $2,000 less in subsidized loans that they were eligible for. d) One student in our sample did not receive $3,500 of subsidized loans and $2,000 of unsubsidized loans that they were eligible for and instead were awarded institutional funds. e) One student in our sample was packaged based on the previous year?s budgeted tuition and fees, however there was no impact on this student?s federal aid. Questioned costs: Over awarded: $1,524 Under awarded: $17,864 Effect: In all instances above, the student did not receive the amount of federal aid that they were eligible for. Cause: a) In several instances, the attendance was not updated within Banner to show the correct enrollment status. In other instances, it was not clear as to what caused the discrepancy. b) In one instance, an update was not made as a result of the verification process and in the other the University was unable to determine why the most updated ISIR did not load into the system for packaging purposes. c) The issues were caused by packaging errors with one specifically relating to the University neglecting to consider transfer credits. d) The issue was caused by an internal system error that the University is working with the provider?s help desk to resolve e) The issue was caused by a manual budget update. Repeat Finding: Yes Recommendation: We recommend the University implement procedures to ensure students are awarded Federal Student Aid based on all applicable eligibility requirements. Views of responsible officials and planned corrective actions: See separate corrective action plan document.

Federal Program Information: Federal Direct Loan Program, CFDA #84.268 Criteria: 34 CFR 668.165, Notifications Condition: The University did not send loan notifications to recipients of Federal Direct Loans for all disbursements during spring semester. Context: All students in our sample who received Federal Direct Loans in the spring semester did not have a loan notification sent to them. Questioned costs: $0 Effect: The students did not receive the required notifications. Cause: The University did not setup the automated process in the system that generates the loan notifications upon disbursement. Repeat Finding: No Recommendation: We recommend the University implement a process to automatically send out notifications upon disbursing federal loans to students. Views of responsible officials and planned corrective actions: See separate corrective action plan document.

Federal Program Information: Federal Direct Loan Program, CFDA #84.268, Federal Pell Grant Program, CFDA #84.063 and Federal Supplemental Opportunity Grant Program, CFDA #84.008 Criteria: 34 CFR 668.22, Return of Title IV Funds Condition: The University did not comply with all requirements associated with the calculation and return of Title IV funds for students who withdrew during an academic term. Context: a) The University did not perform any evaluation of unofficial withdrawals to determine if students who received a 0.0 GPA required a Return of Title IV calculation. b) One student in our sample had an incorrect withdrawal date utilized in their calculation. c) One student in our sample had funds returned 287 days after determination of withdrawal. The calculation was not originally performed timely. d) One student in our sample did not have $1,000 of FSEOG funds that were disbursed included as part of the Return of Title IV funds calculation. Questioned costs: $1,065 Effect: a) The University did not determine if any Title IV aid disbursed to the 71 students who received a 0.0 GPA was required to be returned. b) The University did not return $65 in unsubsidized loans. c) The University was not in compliance with the requirement to return funds within 45 days of the determination of withdrawal. d) The University overawarded FSEOG funds in the amount of $1,000, but upon correcting the award, the Return of Title IV Funds calculation was accurate. Cause: The Student Financial Aid office experienced turnover and the process to review calculations as well as to consider the impact of unofficial withdrawals was not completed during fiscal year 2019. Repeat Finding: Yes Recommendation: We recommend that the University review and update its policies and procedures in place over processing and review of Return of Title IV aid calculations. Views of responsible officials and planned corrective actions: See separate corrective action plan document.

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