THE YOUNG AMERICANS INC.Non-Profit

2020 ? 001: Special Tests and Provisions: NSLDS Certification of Roster File Submissions Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Aid Cluster CFDA Number: 84.033 and 84.268 Award Period: July 1, 2019 through June 30, 2020 Type of Finding: ? Significant Deficiency in Internal Control over Compliance ? Other Matters Criteria or Specific Requirement: As noted in the student financial aid handbook, roster file submissions from the National Student Loan Database System (NSLDS) are required to have the information certified and returned within 15 days of receiving it. Condition: We noted, during our testing, that 3 out of 12 months did not have roster distributions that were responded to within the required 15 days. In addition, there were two roster distributions that were not updated and returned to NSLDS. Questioned Costs: None noted Context: Three exceptions was noted of the 12-month population. Cause: The Organization?s processes and controls did not ensure that the roster file submissions were responded to within a timely manner and within the required timeline. Effect: Roster file submissions, and therefore student status changes, were not reported timely. Repeat Finding: This is not a repeat finding. Recommendation: We recommend the Organization review its reporting procedures to ensure that roster file submissions are reported on time. Views of Responsible Officials: Please refer to the attached Corrective Action Plan.

2020 ? 002: Special Tests and Provisions Gramm-Leach-Bliley Act Federal Agency: Department of Education Federal Program Title: Student Federal Assistance Cluster CFDA Number: 84.063 and 84.268 Award Period: July 1, 2019 to June 30, 2020 Type of Finding: ? Significant Deficiency in Internal Control over Compliance ? Other Matters Criteria or Specific Requirement: The Gramm-Leach-Bliley Act (Public Law 106-102) requires financial institutions to explain their information-sharing practices to their customers and to safeguard sensitive data. (16 CFR 314) The Federal Trade Commission considers Title IV-eligible institutions that participate in Title IV Educational Assistance Programs as ?financial institutions? and subject to the Gramm-Leach-Bliley Act (16 CFR 313.3(k)(2)(vi). Under an institution?s Program Participation Agreement with the Department of Education and the Gramm-Leach-Bliley Act, schools must protect student financial aid information, with particular attention to information provided to institutions by the Department or otherwise obtained in support of the administration of the federal student financial aid programs. Condition / Context: During our audit procedures, we noted that the Organization did not perform a risk assessment that addresses two of the three areas noted in 16 CFR 314.4 (b) which are (Area 1) Employee training and management; (Area 3) Detecting, preventing and responding to attacks, intrusions, or other systems failures and document safeguards for identified risks. Questioned Costs: None Cause: The Organization did not perform an IT risk assessment to identify risks and address risks identified as required by the Gramm-Leach-Bliley Act. Effect: The case identified resulted in noncompliance with the applicable Title IV regulations. The student personal information could be vulnerable. Repeat Finding: This is not a repeat finding. Recommendation: We recommend that the Organization engage a third party or perform the risk assessment to address the areas required by the Gramm-Leach-Bliley Act and ensure that there are documented safeguards for identified risks. Views of Responsible Officials: Please refer to the attached Corrective Action Plan

2020 ? 003: Special Tests and Provisions-Return of Funds on Behalf of Students Federal Agency: Department of Education Federal Program Title: Student Federal Assistance Cluster CFDA Number: 84.063 and 84.268 Award Period: July 1, 2019 to June 30, 2020 Type of Finding: ? Significant Deficiency in Internal Control over Compliance ? Other Matters Criteria or Specific Requirement: According to 34 CFR Section 668.173 (b), the institutional portion of unearned aid must be returned to the appropriate Title IV, HEA program or Federal Family Education Loan (?FFEL?) lender no later than 45 days after the date of the institution?s determination that the student withdrew. Condition / Context: During our testing we noted that the Organization did not return the unearned portion of the Title IV programs for certain students. Furthermore, we were not able to verify if the ascertain refund calculations were performed for all the students that withdrew during the Fall 2020 semester. Questioned Costs: None Cause: The Organization?s internal controls for the College did not ensure compliance with the criteria mentioned above. Effect: The cause identified resulted in noncompliance with the applicable Title IV regulation. Repeat Finding: This is not a repeat finding. Recommendation: We recommend that the Organization implements procedures and controls to ensure compliance with the criteria referenced above. Views of Responsible Officials: Please refer to the attached Corrective Action Plan.

2020 ? 004: Special Tests and Provisions-Enrollment Reporting Federal Agency: Department of Education Federal Program Title: Student Federal Assistance Cluster CFDA Number: 84.063 and 84.268 Award Period: July 1, 2019 to June 30, 2020 Type of Finding: ? Material Weakness in Internal Control over Compliance ? Other Matters Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 685.309(b), states schools must have some arrangement to report student enrollment data to National Student Loan Database Student (?NSLDS?) through an enrollment roster file. The school is required to report changes in the student?s enrollment status, the effective date of the status, and an anticipated completion date. Also, the Code of Federal Regulations, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless if they receive aid from the institution or not. Changes to said status are required to be reported within 30 days of becoming aware of the status change, or with the next scheduled transmission of statuses if the scheduled transmission is within 60 days. Regulations require the status include an accurate effective date. There are two categories of enrollment information ?Campus Level? and ?Program Level? both of which need to be reported accurately. In addition, 2 CFR 200.303 requires nonfederal entities to, among other things, establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Effective internal controls should include establishing procedures to ensure student enrollment status changes are accurately and timely reported to the NSLDS. Condition / Context: Our audit procedures resulted in the following conditions: 1. For 4 out of 8 students, the Enrollment Status was not reported correctly, which is a statistically valid sample. 2. For 7 out of 8 students, the Enrollment Effective Date was not reported correctly, which is a statistically valid sample. 3. For 6 out of 8 students, Student's change in enrollment status determined by the school was not reported to NSLDS within 60 days, which is a statistically valid sample. 4. For 8 out of 8 students, Enrollment is not Certified every 60 days, which is a statistically valid sample.5. For 1 out of 8 students, The Program Begin Date was not reported correctly. The Program Begin Date from Institution's Records does not match NSLDS's record, which is a statistically valid sample. 6. For 5 out of 8 students, NSLDS Campus Level Record Enrollment Status and Effective Date was not reported correctly, which is a statistically valid sample. Questioned Costs: None Cause: The College did not report the enrollment status of the students on a timely and accurate basis. Effect: The NSLDS database did not include accurate information. A student?s enrollment status determines eligibility for in-school status, deferment, and grace periods. Enrollment reporting in a timely and accurate manner is critical for effective management of the programs. Repeat Finding: This is not a repeat finding. Recommendation: We recommend the College improve existing procedures and controls at to ensure timely reporting of student status changes to NSLDS as required by regulations. Views of Responsible Officials: Please refer to the attached Corrective Action Plan.