Millikin University

2025-001 - Student Financial Aid Cluster - (a) Federal Supplemental Educational Opportunity Grants (b) Federal Work Study Program (c) Federal Perkins Loan Program - Federal Capital Contributions (d) Federal Pell Grant Program (e) Federal Direct Student Loans (f) Teacher Education Assistance for College and Higher Education (TEACH), Assistance Listing No. (a) 84.007 (b) 84.033 (c) 84.038 (d) 84.063 (e) 84.268 (f) 84.379 - Year Ended June 30, 2025 Criteria: 34 CFR 675.20 (d)(1) notes “A student may be employed under the FWS program and also receive academic credit for the work performed. Those jobs include, but are not limited to, work performed when the student is - (i) Enrolled in an internship; (ii) Enrolled in practicum; or (iii) Employed in a research, teaching, or other assistantship.” Further, 34 CFR 675.20 (d)(2) states “A student employed in a FWS job and receiving academic credit for that job may not be - … (ii) Paid for receiving instruction in a classroom, laboratory, or other academic setting.” Volume 6, Chapter 2 of the 2024-2025 Federal Student Aid Handbook page 7 notes, “In general, students are not permitted to work in FWS positions during scheduled class times. Exceptions are permitted if an individual class is cancelled, if the instructor has excused the student from attending for a particular day, and if the student is receiving credit for employment in an internship, externship, or community work-study experience. Any such exemptions must be documented.” Volume 6, Chapter 2 of the 2024-2025 Federal Student Aid Handbook page 11 notes, “You must maintain adequate timesheets or records of hours worked for FWS students. These timesheets must show, separately for each day worked, the hours a student worked, and the total hours worked during the job’s payment cycle (i.e., twice a month, every week, every two weeks, etc., but not less than once a month). These amounts and hours recorded must match the hours for which the student is paid. Condition: During our testing of forty individuals receiving federal work study, we noted four individuals (10%) working during scheduled class hours. We consider this condition to be an instance of noncompliance relating to Activities Allowed or Unallowed compliance requirement and is not a repeat finding. Statistical sampling was not used in making sample selections. Questioned Costs: $45 Cause & Effect: Without proper review of hours worked against class hours scheduled, federal work study recipients could receive compensation that is not allowed under the Code of Federal Regulations. Recommendation: We recommend the University evaluate policies and procedures to ensure work study recipients do not receive compensation for hours worked when they have scheduled class hours. Views of Responsible Officials: Management agrees with this Single Audit Finding and response is included in the Corrective Action Plan.

2025-001 - Student Financial Aid Cluster - (a) Federal Supplemental Educational Opportunity Grants (b) Federal Work Study Program (c) Federal Perkins Loan Program - Federal Capital Contributions (d) Federal Pell Grant Program (e) Federal Direct Student Loans (f) Teacher Education Assistance for College and Higher Education (TEACH), Assistance Listing No. (a) 84.007 (b) 84.033 (c) 84.038 (d) 84.063 (e) 84.268 (f) 84.379 - Year Ended June 30, 2025 Condition: During our testing of forty individuals receiving federal work study, we noted four individuals (10%) working during scheduled class hours. We consider this condition to be an instance of noncompliance relating to Activities Allowed or Unallowed compliance requirement and is not a repeat finding. Statistical sampling was not used in making sample selections. Management Response: We accept this finding. Corrective Action Plan: Additional planning is ongoing to correct timecards to not allow students to clock work hours during their scheduled classes. Additional training will also be provided to timecard approval staff for departments with student workers receiving Federal Work Study. Responsible Person: Student Employment/Financial Aid Implementation Date: January 2026

2025-002 - Student Financial Aid Cluster - (a) Federal Supplemental Educational Opportunity Grants (b) Federal Work Study Program (c) Federal Perkins Loan Program - Federal Capital Contributions (d) Federal Pell Grant Program (e) Federal Direct Student Loans (f) Teacher Education Assistance for College and Higher Education (TEACH), Assistance Listing No. (a) 84.007 (b) 84.033 (c) 84.038 (d) 84.063 (e) 84.268 (f) 84.379 - Year Ended June 30, 2025 Criteria: 34 CFR 668.22 (a)(1) states “When a recipient of title IV grant or loan assistance withdraws from an institution during a payment period or period of enrollment in which the recipient began attendance, the institution must determine the amount of title IV grant or loan assistance that the student earned as of the student's withdrawal date in accordance with paragraph (e) of this section.” 34 CFR 668.22 (e)(2) states, “The percentage of title IV grant or loan assistance that has been earned by the student is - (i) Equal to the percentage of the payment period or period of enrollment that the student completed (as determined in accordance with paragraph (f) of this section) as of the student's withdrawal date, if this date occurs on or before - (A) Completion of 60 percent of the payment period or period of enrollment for a program that is measured in credit hours; or…” 34 CFR 668.22(j) notes, “(1) An institution must return the amount of title IV funds for which it is responsible under paragraph (g) of this section as soon as possible but no later than 45 days after the date of the institution's determination that the student withdrew as defined in paragraph (l)(3) of this section. The timeframe for returning funds is further described in § 668.173(b).” Condition: The University did not accurately complete refund calculations for official withdrawals. In review of the Fall 2024 official calculations the number of days in the break was not calculated correctly, resulting in the incorrect number of days in the calculation. The Title IV amounts for all withdrawn students were incorrectly calculated and returned for 5 out of the population of 5 (100%) Fall official withdrawal calculations. However, the No Passing Grade Sample for Fall unofficial withdrawals total number of days was calculated correctly. A sample of Spring official withdrawal calculations identified 2 calculation errors however the total days were calculated correctly. We noted 2 out of 4 (50%) Spring students tested in the Return of Title IV sample had incorrect calculations. Additionally, a sample of No Passing Grades students for unofficial withdrawals noted 2 out of 9 (22%) students tested did not have refund calculations completed timely. We consider this finding to be a material weakness in relation to Special Tests and Provisions and a repeat of prior year finding 2024-001. Statistical sampling was not used. Questioned Costs: $5,251 Cause and Effect: The cause was due to error and turnover in the Financial Aid Department. The effect is Return of Title IV funds calculations resulted in incorrect amounts returned by the College and untimely refund calculations. Recommendation: We recommend the University continually educate themselves on the requirements for the return of Title IV funds and ensure the proper controls are implemented to timely and accurately return unearned aid for official and unofficial withdrawals. Views of Responsible Officials: Management agrees with this Single Audit Finding and response is included in the Corrective Action Plan.

2025-002 - Student Financial Aid Cluster - (a) Federal Supplemental Educational Opportunity Grants (b) Federal Work Study Program (c) Federal Perkins Loan Program - Federal Capital Contributions (d) Federal Pell Grant Program (e) Federal Direct Student Loans (f) Teacher Education Assistance for College and Higher Education (TEACH), Assistance Listing No. (a) 84.007 (b) 84.033 (c) 84.038 (d) 84.063 (e) 84.268 (f) 84.379 - Year Ended June 30, 2025 Condition: The University did not accurately complete refund calculations for official withdrawals. In review of the Fall 2024 official calculations the number of days in the break was not calculated correctly, resulting in the incorrect number of days in the calculation. The Title IV amounts for all withdrawn students were incorrectly calculated and returned for 5 out of the population of 5 (100%) Fall official withdrawal calculations. However, the No Passing Grade Sample for Fall unofficial withdrawals total number of days was calculated correctly. A sample of Spring official withdrawal calculations identified 2 calculation errors however the total days were calculated correctly. We noted 2 out of 4 (50%) Spring students tested in the Return of Title IV sample had incorrect calculations. Additionally, a sample of No Passing Grades students for unofficial withdrawals noted 2 out of 9 (22%) students tested did not have refund calculations completed timely. We consider this finding to be a material weakness in relation to Special Tests and Provisions and a repeat of prior year finding 2024-001. Statistical sampling was not used. Management Response: We agree with this finding. Corrective Action Plan: This error was caused in a staff interpretation of a Saturday course being offered for one program. However, Saturday's are not on the academic calendar as a class day prior to the Thanksgiving break. Due to staff turnover, this was a change made in calculations in January 2025 that does not count that Saturday as a course day in regards to the length of Thanksgiving break. The change in days per semester calculation is now in line wiht the academic calendar posted by the institution. Responsible Person: Financial Aid Director/Registrar Implementation Date: January 2025

2024-001

2025-003 - Student Financial Aid Cluster - (a) Federal Supplemental Educational Opportunity Grants (b) Federal Work Study Program (c) Federal Perkins Loan Program - Federal Capital Contributions (d) Federal Pell Grant Program (e) Federal Direct Student Loans (f) Teacher Education Assistance for College and Higher Education (TEACH), Assistance Listing No. (a) 84.007 (b) 84.033 (c) 84.038 (d) 84.063 (e) 84.268 (f) 84.379 - Year Ended June 30, 2025 Criteria: Institutions are required to provide enrollment update responses to the Enrollment Reporting Roster File within fifteen days of receipt (34 CFR 685.309). Condition: We tested forty files and enrollment statuses were incorrectly reported to the National Student Loan Data System (NSLDS) for three students (7.5%). We consider this to be an instance of noncompliance relating to Special Tests and Provisions compliance requirement and is not a repeat finding. Statistical sampling was not used in making sample selections. Questioned Costs: N/A Cause and Effect: The condition was caused by the University starting a new program and due to not reporting students as three-quarter time status. The result is that the students’ enrollment statuses were reported to NSLDS inaccurately. Recommendation: We recommend the University update the student statuses in NSLDS and increase controls over enrollment reporting. Views of Responsible Officials: Management agrees with this Single Audit Finding and response is included in the Corrective Action Plan.

2025-003 - Student Financial Aid Cluster - (a) Federal Supplemental Educational Opportunity Grants (b) Federal Work Study Program (c) Federal Perkins Loan Program - Federal Capital Contributions (d) Federal Pell Grant Program (e) Federal Direct Student Loans (f) Teacher Education Assistance for College and Higher Education (TEACH), Assistance Listing No. (a) 84.007 (b) 84.033 (c) 84.038 (d) 84.063 (e) 84.268 (f) 84.379 - Year Ended June 30, 2025 Condition: We tested forty files and enrollment statuses were incorrectly reported to the National Student Loan Data System (NSLDS) for three students (7.5%). We consider this to be an instance of noncompliance relating to Special Tests and Provisions compliance requirement and is not a repeat finding. Statistical sampling was not used in making sample selections. Management Response: We agree with this finding. Corrective Action Plan: Review of new academic programs that allow graduate courses for undergraduate credit will be complete to ensure that enrollment is reported correctly. This specific case was for our MSAT program. The students involved were in their transition year from undergrad to grad. Graduate courses were not coded to report as undergrad towards full time status. Responsible Person: Registrar Implementation Date: January 2026

2024-001 – Student Financial Aid Cluster – (a) Federal Supplemental Educational Opportunity Grants (b) Federal Work Study Program (c) Federal Perkins Loan Program – Federal Capital Contributions (d) Federal Pell Grant Program (e) Federal Direct Student Loans (f) Teacher Education Assistance for College and Higher Education (TEACH), Assistance Listing No. (a) 84.007 (b) 84.033 (c) 84.038 (d) 84.063 (e) 84.268 (f) 84.379 – Year Ended June 30, 2024 Criteria: 34 CFR 668.22 (a)(1) states “When a recipient of title IV grant or loan assistance withdraws from an institution during a payment period or period of enrollment in which the recipient began attendance, the institution must determine the amount of title IV grant or loan assistance that the student earned as of the student's withdrawal date in accordance with paragraph (e) of this section.” 34 CFR 668.22 (e)(2) states, “The percentage of title IV grant or loan assistance that has been earned by the student is - (i) Equal to the percentage of the payment period or period of enrollment that the student completed (as determined in accordance with paragraph (f) of this section) as of the student's withdrawal date, if this date occurs on or before - (A) Completion of 60 percent of the payment period or period of enrollment for a program that is measured in credit hours; or…” 34 CFR 668.22(j) notes, “(1) An institution must return the amount of title IV funds for which it is responsible under paragraph (g) of this section as soon as possible but no later than 45 days after the date of the institution's determination that the student withdrew as defined in paragraph (l)(3) of this section. The timeframe for returning funds is further described in § 668.173(b).” 2024-001 – Student Financial Aid Cluster – (a) Federal Supplemental Educational Opportunity Grants (b) Federal Work Study Program (c) Federal Perkins Loan Program – Federal Capital Contributions (d) Federal Pell Grant Program (e) Federal Direct Student Loans (f) Teacher Education Assistance for College and Higher Education (TEACH), Assistance Listing No. (a) 84.007 (b) 84.033 (c) 84.038 (d) 84.063 (e) 84.268 (f) 84.379 – Year Ended June 30, 2024 (Continued) Condition: The University did not properly calculate the refunds for withdrawal students for 1 out of the 8 students tested (12.5%) due to using incorrect student status for Pell. We consider this finding to be an instance of noncompliance in relation to Special Tests and Provisions and a repeat of prior year finding 2023-002. Statistical sampling was not used. Questioned Costs: $302 Cause and Effect: Without proper review of student status, withdrawal students may return the incorrect amount of Title IV aid. The result is the University did not return funds to the Department of Education that should have been returned by the University. Recommendation: We recommend the University refund $302 to the Department of Education and increase controls over refund calculations. Views of Responsible Officials: Management agrees with this Single Audit Finding and response is included in the Corrective Action Plan.

2024-001 - Student Financial Aid Cluster - (a) Federal Supplemental Educational Opportunity Grants (b) Federal Work Study Program (c) Federal Perkins Loan Program - Federal Capital Contributions (d) Federal Pell Grant Program (e) Federal Direct Student Loans (f) Teacher Education Assistance for College and Higher Education (TEACH), Assistance Listing No. (a) 84.007 (b) 84.033 (c) 84.038 (d) 84.063 (e) 84.268 (f) 84.379- Year Ended June 30, 2024 Condition: The College did not properly calculate the refunds for withdrawal students for 1 out of the 8 students tested (12.5%) due to using incorrect student status for Pell. We consider this finding to be an instance of noncompliance in relation to Special Tests and Provisions and a repeat of prior year finding 2023-002. Statistical sampling was not used. Management Response: The incident identified above was made due to a system error which caused one course to appear twice on the student resulting in incorrect full-time status, which in tum resulted in the SIS calculating the return of title IV funds incorrectly. Corrective Action Plan: Each student will be manually reviewed and verified for accuracy for credit hours enrolled and credit hours billed to cross check student enrollment status prior to completing R2T4. In addition, moving forward all R2T4 calculations will be done in COD to ensure accuracy of the funds required to be returned. Responsible Person: Chilwana Thompson, Director Implementation Date: 10/25/2024

2023-002

2023-001 – Student Financial Aid Cluster – (a) Federal Supplemental Educational Opportunity Grants (b) Federal Work Study Program (c) Federal Perkins Loan Program – Federal Capital Contributions (d) Federal Pell Grant Program (e) Federal Direct Student Loans (f) Teacher Education Assistance for College and Higher Education (TEACH), Assistance Listing No. (a) 84.007 (b) 84.033 (c) 84.038 (d) 84.063 (e) 84.268 (f) 84.379 – Year Ended June 30, 2023 Criteria: 34 CFR 685.101 (b)(1) notes, “an eligible undergraduate student who is enrolled at a school participating in the Direct Loan Program may borrow under the Direct Subsidized Loan and Direct Unsubsidized Loan programs.” The order of dispersing aid requires that grants and subsidized loans be considered first. 34 CFR 685.200(a)(iii) “In the case of an undergraduate student who seeks a Direct Subsidized Loan or a Direct Unsubsidized Loan at a school that participates in the Federal Pell Grant Program, the student has received a determination of Federal Pell Grant eligibility for the period of enrollment for which the loan is sought.” Condition: In two of the 40 student files tested (5%), Subsidized and Unsubsidized Direct loans we not properly awarded. The University over awarded one student by $500 in Unsubsidized loans. Another student was under awarded $938 in Subsidized loans and under awarded $562 in Unsubsidized loans.We consider this condition to be an instance of noncompliance relating to the Eligibility compliance requirement and a repeat of prior year finding 2022-001. Statistical sampling was not used in making sample selections. Questioned Costs: $0 Cause and Effect: Without proper review of eligibility of financial aid, students may receive an incorrect amount of Title IV aid. Students should receive the proper amount of aid. Recommendation: We recommend the University evaluate policies and procedures to ensure students receive the proper amount of Title IV aid. Views of Responsible Officials: Management agrees with this Single Audit Finding and response is included in the Corrective Action Plan.

2023-001 – Student Financial Aid Cluster – (a) Federal Supplemental Educational Opportunity Grants (b) Federal Work Study Program (c) Federal Perkins Loan Program – Federal Capital Contributions (d) Federal Pell Grant Program (e) Federal Direct Student Loans (f) Teacher Education Assistance for College and Higher Education (TEACH), Assistance Listing No. (a) 84.007 (b) 84.033 (c) 84.038 (d) 84.063 (e) 84.268 (f) 84.379 – Year Ended June 30, 2023 Condition: In two of the 40 student files tested (5%), Subsidized and Unsubsidized Direct loans we not properly awarded. The University over awarded one student by $500 in Unsubsidized loans. Another student was under awarded $938 in Subsidized loans and under awarded $562 in Unsubsidized loans. Management Response: Student Identifier 22 - The student's loan limits were determined automatically by our student information system during the awarding process expecting the student to successfully complete the hours in which they were enrolled and progress to the next class level for the subsequent term. The student failed one course and missed progressing to the next academic level. When the manual adjustment was made to the student's awarded loan amounts after the end of the term, the subsidized loan was adjusted and the unsubsidized loan was missed, causing the over-award of $500 for one term. Student Identifier 23 - A pro-ration of loan limits was required for this student due to graduation at mid-term. Instead of using the full annual loan limit to calculate the pro-rated amount, the remaining aggregate eligibility was used as the amount from which the pro-ration was calculated. The manual mis-calculation resulted in the student being offered $938 less Subsidized loan and $562 less in Unsubsidized loan funds than they were eligible to receive. Corrective Action Plan: Student Identifier 22 - The $500 unsubsidized direct loan over payment was corrected and returned on July 31, 2023. Student Identifier 23 - The miscalculation of total loan eligibility was realized after the payment period ended and the student had completed their program of study/graduated with a zero account balance. No additional loan eligibility was offered. Additional staff has been trained to provide secondary verification of revised and pro-rated loan calculations. Responsible Person: Director, Student Financial Services Asst. Director/Loan Coordinator, Student Financial Services Implementation Date: Fall 2023 academic term.

2022-001

2023-002 – Student Financial Aid Cluster – (a) Federal Supplemental Educational Opportunity Grants (b) Federal Work Study Program (c) Federal Perkins Loan Program – Federal Capital Contributions (d) Federal Pell Grant Program (e) Federal Direct Student Loans (f) Teacher Education Assistance for College and Higher Education (TEACH), Assistance Listing No. (a) 84.007 (b) 84.033 (c) 84.038 (d) 84.063 (e) 84.268 (f) 84.379 – Year Ended June 30, 2023 Criteria: 34 CFR 668.22 (a)(1) states “When a recipient of title IV grant or loan assistance withdraws from an institution during a payment period or period of enrollment in which the recipient began attendance, the institution must determine the amount of title IV grant or loan assistance that the student earned as of the student's withdrawal date in accordance with paragraph (e) of this section.” 34 CFR 668.22 (e)(2) states, “The percentage of title IV grant or loan assistance that has been earned by the student is - (i) Equal to the percentage of the payment period or period of enrollment that the student completed (as determined in accordance with paragraph (f) of this section) as of the student's withdrawal date, if this date occurs on or before - (A) Completion of 60 percent of the payment period or period of enrollment for a program that is measured in credit hours; or…” 34 CFR 668.22(j) notes, “(1) An institution must return the amount of title IV funds for which it is responsible under paragraph (g) of this section as soon as possible but no later than 45 days after the date of the institution's determination that the student withdrew as defined in paragraph (l)(3) of this section. The timeframe for returning funds is further described in § 668.173(b).” Condition: The University did not properly calculate the refunds for no passing grades withdrawal students for 1 out of the 16 students tested (6.3%) due to excluding SEOG Grant from the calculation. We consider this finding to be an instance of noncompliance in relation to Special Tests and Provisions. Statistical sampling was not used. Questioned Costs: $127 Cause and Effect: Without proper review of refund amounts returned, withdrawal students may return the incorrect amount of Title IV aid. Students should return the same amount as their Return of Title IV calculation. Recommendation: We recommend the University implement controls to help accurately track that Return of Title IV withdrawal calculations contain all awards disbursed and to be disbursed and that proper documentation is in the file when refunds are made. Views of Responsible Officials: Management agrees with this Single Audit Finding and response is included in the Corrective Action Plan.

2023-002 – Student Financial Aid Cluster – (a) Federal Supplemental Educational Opportunity Grants (b) Federal Work Study Program (c) Federal Perkins Loan Program – Federal Capital Contributions (d) Federal Pell Grant Program (e) Federal Direct Student Loans (f) Teacher Education Assistance for College and Higher Education (TEACH), Assistance Listing No. (a) 84.007 (b) 84.033 (c) 84.038 (d) 84.063 (e) 84.268 (f) 84.379 – Year Ended June 30, 2023 Condition: The University did not properly calculate the refunds for no passing grades withdrawal students for 1 out of the 16 students tested (6.3%) due to excluding SEOG Grant from the calculation. We consider this finding to be an instance of noncompliance in relation to Special Tests and Provisions. Statistical sampling was not used. Management Response: Student Identifier 6 - The student was identified after the conclusion of the term to have earned no passing grades and a determination was made as to when the student stopped attending classes for the term. The determined last date of attendance required a manual return of Title IV funds to be calculated. The calculation and subsequent return of funds was performed timely, however, an SEOG award of $250 was not included in error when the calculation was made. Corrective Action Plan: Student Identifier 6 - When notified of the finding by auditors, the return of Title IV funds calculation was performed with the $250 SEOG funds included. The corrected calculation resulted in an additional $127 in PELL grant funds to return. The return was corrected and completed on October 12, 2023. A secondary review of all manual Return of Title IV calculations has been implemented to mitigate manual errors. Responsible Person: Director, Student Financial Services Implementation Date: Fall 2023 term.

2023-003 – Student Financial Aid Cluster – (a) Federal Supplemental Educational Opportunity Grants (b) Federal Work Study Program (c) Federal Perkins Loan Program – Federal Capital Contributions (d) Federal Pell Grant Program (e) Federal Direct Student Loans (f) Teacher Education Assistance for College and Higher Education (TEACH), Assistance Listing No. (a) 84.007 (b) 84.033 (c) 84.038 (d) 84.063 (e) 84.268 (f) 84.379 – Year Ended June 30, 2023 Criteria: 34 CFR 675.19 (b)(2) notes “The institution must also establish and maintain program and fiscal records that (i) Include a certification by the student’s supervisor, an official of the institution or off-campus agency, that each student has worked and earned the amount being paid. The certification must include or be supported by, for students paid on an hourly basis, a time record showing the hours worked in clock time sequence, or the total hours worked per day…” Condition: During our testing of forty individuals receiving federal work study, we noted 2 individuals (5%) that either had timecards for hours worked that were not approved by a supervisor or had incorrect time entry. We consider this condition to be an instance of noncompliance relating to the Activities Allowed or Unallowed compliance requirement. Statistical sampling was not used in making sample selections. Questioned Costs: $154 Cause and Effect: Without proper review of hours worked, federal work study recipients could receive compensation that is not allowed under the Code of Federal Regulations. Recommendation: We recommend the College evaluate policies and procedures to ensure work study recipients are being paid for hours worked that have been certified by the recipients’ supervisor. Views of Responsible Officials: Management agrees with this Single Audit Finding and response is included in the Corrective Action Plan.

2023-003 – Student Financial Aid Cluster – (a) Federal Supplemental Educational Opportunity Grants (b) Federal Work Study Program (c) Federal Perkins Loan Program – Federal Capital Contributions (d) Federal Pell Grant Program (e) Federal Direct Student Loans (f) Teacher Education Assistance for College and Higher Education (TEACH), Assistance Listing No. (a) 84.007 (b) 84.033 (c) 84.038 (d) 84.063 (e) 84.268 (f) 84.379 – Year Ended June 30, 2023 Condition: During our testing of forty individuals receiving federal work study, we noted 2 individuals (5%) that either had timecards for hours worked that were not approved by a supervisor or had incorrect time entry. We consider this condition to be an instance of noncompliance relating to the Activities Allowed or Unallowed compliance requirement. Statistical sampling was not used in making sample selections. Management Response: There were 2 individuals improperly paid. In the first incident an electronic student timecard was submitted in error and not approved by the supervisor. The payroll administrator erroneously paid the employee for the time in the amount of $82 without supervisor approval. In the second incident the employee submitted a manual timecard with the incorrect number of hours indicated per shift. The supervisor and the payroll administrator both missed the incorrect calculation in the amount of $72. Corrective Action Plan: The University has implemented electronic timecards that will mitigate manual errors in calculation. A new payroll administrator has been hired and the University is focused on documentation of student-payroll procedures and supervisor training. Responsible Person: Student Payroll Accounting Specialist Implementation Date: September 5, 2023.

2022-001 ? Student Financial Aid Cluster ? (a) Federal Supplemental Educational Opportunity Grants (b) Federal Work Study Program (c) Federal Perkins Loan Program ? Federal Capital Contributions (d) Federal Pell Grant Program (e) Federal Direct Student Loans (f) Teacher Education Assistance for College and Higher Education (TEACH), Assistance Listing No. (a) 84.007 (b) 84.033 (c) 84.038 (d) 84.063 (e) 84.268 (f) 84.379 ? Year Ended June 30, 2022 Criteria: 34 CFR 685.101 (b)(1) notes, ?an eligible undergraduate student who is enrolled at a school participating in the Direct Loan Program may borrow under the Direct Subsidized Loan and Direct Unsubsidized Loan programs.? The order of dispersing aid requires that grants and subsidized loans be considered first. 34 CFR 685.200(a)(iii) ?In the case of an undergraduate student who seeks a Direct Subsidized Loan or a Direct Unsubsidized Loan at a school that participates in the Federal Pell Grant Program, the student has received a determination of Federal Pell Grant eligibility for the period of enrollment for which the loan is sought.? Condition: In three of the 40 student files tested (7.5%), Subsidized and Unsubsidized Direct loans we not properly awarded. The University under awarded one student $1,000 in Subsidized loans and over awarded the student by $1,000 in Unsubsidized loans. A second student was under awarded $2,560 in Subsidized loans and over awarded $2,560 in Unsubsidized loans. The third student was under awarded $862 in Unsubsidized loans. We consider this condition to be an instance of noncompliance relating to the Eligibility compliance requirement and a repeat of prior year finding 2021-002. Statistical sampling was not used in making sample selections. Questioned Costs: $862 Cause and Effect: Without proper review of eligibility of financial aid, students may receive an incorrect amount of Title IV aid. Students should receive the proper amount of aid. Recommendation: We recommend the University evaluate policies and procedures to ensure students receive the proper amount of Title IV aid. Views of Responsible Officials: Management agrees with this Single Audit Finding and response is included in the Corrective Action Plan. See chart/table in report

2022-001 ? Student Financial Aid Cluster ? (a) Federal Supplemental Educational Opportunity Grants (b) Federal Work Study Program (c) Federal Perkins Loan Program ? Federal Capital Contributions (d) Federal Pell Grant Program (e) Federal Direct Student Loans (f) Teacher Education Assistance for College and Higher Education (TEACH), Assistance Listing No. (a) 84.007 (b) 84.033 (c) 84.038 (d) 84.063 (e) 84.268 (f) 84.379 ? Year Ended June 30, 2022 Condition: In three of the 40 student files tested (7.5%), Subsidized and Unsubsidized Direct loans were not properly awarded. The University under awarded one student $1,000 in Subsidized loans and over awarded the student by $1,000 in Subsidized loans. A second student was under awarded $2,560 in Subsidized loans and over awarded $2,560 in Unsubsidized loans. The third student was under awarded $862 in Unsubsidized loans. Management Response: All of the errors identified by the auditors were a direct result of manual miscalculation of loan eligibility. In two of the instances cited, the students had previous additional unsubsidized loans issued as a result of parent PLUS loan denials. When we received ISIR data these students were flagged with a reject due to aggregate loan limits. In order to calculate each student?s loan eligibility, a manual review of loan information via the U.S. Department of Education?s Common Origination and Disbursement (COD) portal is necessary. The additional unsubsidized loans disbursed as a result of PLUS denial, were manually removed from each student?s loan total to determine current year eligibility. In both instances, the total loan eligibility was correct, however the manual calculation of the subsidized versus unsubsidized split of the loan funds were miscalculated. In the last instance a student was under awarded $862 in unsubsidized loans, the miscalculation occurred due to receipt of an outside scholarship. In the Fall term the scholarship check was received with documentation indicating the disbursement was to be applied to the Fall term in it?s entirety and the Spring disbursement would follow. The outside scholarship caused the student to be over awarded and the student loans were adjusted to remain within cost of attendance limits. Subsequently the Spring term disbursement of the scholarship was received for $862 less than the Fall disbursement. At that time, the student should have been offered the additional $862 in unsubsidized loan funds to bring their total aid back up to cost of attendance. The staff person entering the scholarship payment on the student?s account failed to notify the loan coordinator an adjustment was warranted. Corrective Action Plan: The loan coordinator who made the errors has been in the position for just over a year. In order to prevent future issues in calculating a student?s loan limits and eligibility, the employee attended a loan regulation and processing overview course produced by the National Association of Financial Aid Administrators (NASFAA). Further, a form was developed to help calculate aggregate limits when an ISIR reject occurs in order to avoid missed steps in the calculation process. 2022-001 ? Student Financial Aid Cluster ? (a) Federal Supplemental Educational Opportunity Grants (b) Federal Work Study Program (c) Federal Perkins Loan Program ? Federal Capital Contributions (d) Federal Pell Grant Program (e) Federal Direct Student Loans (f) Teacher Education Assistance for College and Higher Education (TEACH), Assistance Listing No. (a) 84.007 (b) 84.033 (c) 84.038 (d) 84.063 (e) 84.268 (f) 84.379 ? Year Ended June 30, 2022 (Continued) As a result of the outside scholarship error, our procedures for entering an scholarship payment have been adjusted to include a final review of all outside scholarship disbursements entered by the loan coordinator. Responsible Person: Lynette Lambert, Assistant Director/Loan Coordinator Implementation Date: August 1, 2022

2021-002

2022-002 ? Student Financial Aid Cluster ? (a) Federal Supplemental Educational Opportunity Grants (b) Federal Work Study Program (c) Federal Perkins Loan Program ? Federal Capital Contributions (d) Federal Pell Grant Program (e) Federal Direct Student Loans (f) Teacher Education Assistance for College and Higher Education (TEACH), Assistance Listing No. (a) 84.007 (b) 84.033 (c) 84.038 (d) 84.063 (e) 84.268 (f) 84.379 ? Year Ended June 30, 2022 Criteria: 34 CFR 668.22 (a)(1) states ?When a recipient of title IV grant or loan assistance withdraws from an institution during a payment period or period of enrollment in which the recipient began attendance, the institution must determine the amount of title IV grant or loan assistance that the student earned as of the student's withdrawal date in accordance with paragraph (e) of this section.? 34 CFR 668.22 (e)(2) states, ?The percentage of title IV grant or loan assistance that has been earned by the student is - (i) Equal to the percentage of the payment period or period of enrollment that the student completed (as determined in accordance with paragraph (f) of this section) as of the student's withdrawal date, if this date occurs on or before - (A) Completion of 60 percent of the payment period or period of enrollment for a program that is measured in credit hours; or?? 34 CFR 668.22(j) notes, ?(1) An institution must return the amount of title IV funds for which it is responsible under paragraph (g) of this section as soon as possible but no later than 45 days after the date of the institution's determination that the student withdrew as defined in paragraph (l)(3) of this section. The timeframe for returning funds is further described in ? 668.173(b).? Condition: The University did not properly return loan funds subsequent to the R2T4 calculation for no passing grades withdrawal students for 1 out of the 12 students tested (8.3%) due to failing to return the required PLUS loans based on the calculation. Further, the amount of direct student loan funds returned was later disbursed to the student again due to lack of documentation in the University?s system of the unofficial withdrawal. We consider this finding to be an instance of noncompliance in relation to Special Tests and Provisions and a repeat of prior year finding 2021-001. Statistical sampling was not used. Questioned Costs: $5,151 Cause and Effect: Without proper review of refund amounts returned, withdrawal students may return the incorrect amount of Title IV aid. Students should return the same amount as their Return of Title IV calculation. Recommendation: We recommend the University implement controls to help accurately track that Return of Title IV withdrawal calculations contain all awards disbursed and to be disbursed and that proper documentation is in the file when refunds are made. Views of Responsible Officials: Management agrees with this Single Audit Finding and response is included in the Corrective Action Plan. See chart/table in report

2022-002 ? Student Financial Aid Cluster ? (a) Federal Supplemental Educational Opportunity Grants (b) Federal Work Study Program (c) Federal Perkins Loan Program ? Federal Capital Contributions (d) Federal Pell Grant Program (e) Federal Direct Student Loans (f) Teacher Education Assistance for College and Higher Education (TEACH), Assistance Listing No. (a) 84.007 (b) 84.033 (c) 84.038 (d) 84.063 (e) 84.268 (f) 84.379 ? Year Ended June 30, 2022 Condition: The University did not properly return loan funds subsequent to the R2T4 calculation for no passing grades withdrawal students for 1 out of the 12 students tested (8.3%) due to failing to return the required PLUS loans based on the calculation. Further, the amount of direct student loan funds returned was later disbursed to the student again due to lack of documentation in the University?s system of the unofficial withdrawal. We consider this to be an instance of noncompliance in relation to Special Tests and Provisions. Statistical sampling was not used. Management Response: The error identified above was made on a student?s record who did not officially withdraw from the University. As required by federal regulation, an ?all F?s? report is pulled at the end of each term and a determination is made for all students included on the report whether or not they attended classes until the end of the term. The student identified by the auditors was determined to have not attended the full Fall term. A return of title IV calculation was promptly processed by the Associate Director on the Department of Education?s website. The R2T4 calculation could not be processed via the SIS since the student did not have an official withdrawal date entered. The student loans were returned timely, however, the parent PLUS loan was missed in returning the funds. Subsequently the student contacted our office to challenge the withdrawal date and claimed he had attended classes all term and earned all of the loan funds that were disbursed for the term. There was no documentation in our SIS so the loans were reinstated in error. Corrective Action Plan: R2T4 procedures were updated to include a secondary confirmation of the return of loan funds according to the calculation. This secondary review will be scheduled at the time the R2T4 calculation is processed. Further, the procedure was updated to include entry of notes on the student?s electronic record to avoid reversal if challenged by the student. Responsible Person: Chilwana Thompson, Associate Director Implementation Date: August 1, 2022

2021-001

2021-001 ? Student Financial Aid Cluster ? (a) Federal Supplemental Educational Opportunity Grants (b) Federal Work Study Program (c) Federal Perkins Loan Program ? Federal Capital Contributions (d) Federal Pell Grant Program (e) Federal Direct Student Loans (f) Teacher Education Assistance for College and Higher Education (TEACH), Assistance Listing No. (a) 84.007 (b) 84.033 (c) 84.038 (d) 84.063 (e) 84.268 (f) 84.379 ? Year Ended June 30, 2021 Criteria: 34 CFR 668.22 (a)(1) states ?When a recipient of title IV grant or loan assistance withdraws from an institution during a payment period or period of enrollment in which the recipient began attendance, the institution must determine the amount of title IV grant or loan assistance that the student earned as of the student's withdrawal date in accordance with paragraph (e) of this section.? 34 CFR 668.22 (e)(2) states, ?The percentage of title IV grant or loan assistance that has been earned by the student is - (i) Equal to the percentage of the payment period or period of enrollment that the student completed (as determined in accordance with paragraph (f) of this section) as of the student's withdrawal date, if this date occurs on or before - (A) Completion of 60 percent of the payment period or period of enrollment for a program that is measured in credit hours; or?? 34 CFR 668.22(j) notes, ?(1) An institution must return the amount of title IV funds for which it is responsible under paragraph (g) of this section as soon as possible but no later than 45 days after the date of the institution's determination that the student withdrew as defined in paragraph (l)(3) of this section. The timeframe for returning funds is further described in ? 668.173(b).? See Schedule of Findings and Questioned Costs for chart/table Condition: The University did properly calculate the Return of Title IV (R2T4) refunds for R2T4 testing however they did not actually return the correct direct loan amounts for 3 out of 7 students tested (42.9%) due to differences with loan origination fees. The University did properly calculate the refunds for no passing grades withdrawal students however they did not actually return the correct direct loan amounts for 2 out of 12 students tested (16.7%) due to differences with loan origination fees. We consider this finding to be an instance of noncompliance in relation to Special Tests and Provisions. Statistical sampling was not used. Questioned Costs: $190 Cause and Effect: Without proper review of refund amounts returned, withdrawal students may return the incorrect amount of Title IV aid. Students should return the same amount as their Return of Title IV calculation. Recommendation: We recommend the University implement controls to help accurately track that Return of Title IV refund payments agree to the withdrawal calculation. Views of Responsible Officials: Management agrees with this Single Audit Finding and response is included in the Corrective Action Plan.

2021-001 ? Student Financial Aid Cluster ? (a) Federal Supplemental Educational Opportunity Grants (b) Federal Work Study Program (c) Federal Perkins Loan Program ? Federal Capital Contributions (d) Federal Pell Grant Program (e) Federal Direct Student Loans (f) Teacher Education Assistance for College and Higher Education (TEACH), Assistance Listing No. (a) 84.007 (b) 84.033 (c) 84.038 (d) 84.063 (e) 84.268 (f) 84.379 ? Year Ended June 30, 2021 Condition: The University did properly calculate the Return of Title IV (R2T4) refunds for R2T4 testing however they did not actually return the correct direct loan amounts for 3 out of 7 students tested (42.9%) due to differences with loan origination fees. The University did properly calculate the refunds for no passing grades withdrawal students however they did not actually return the correct direct loan amounts for 2 out of 12 students tested (16.7%) due to differences with loan origination fees. We consider this finding to be an instance of noncompliance in relation to Special Tests and Provisions. Statistical sampling was not used. Management Response: In September of 2020 the University?s longstanding personnel responsible for processing student loans retired. A replacement was hired and trained for 30 days by the outgoing staff member. At the time of training, very few withdrawals had been processed for the academic term causing the new loan coordinator to rely on notes and written processes for returning loan funds after a R2T4 calculation had been determined. The R2T4 calculation is performed by our Associate Director and grant monies are returned immediately. The R2T4 calculation is then shared with the Assistant Director ? Loan Coordinator and the loan funds are returned through the loan disbursement and reporting channels in place. Since there are two amounts with every disbursement of a student loan ? the gross loan amount and the net amount after the loan origination fee has been removed ? the process of returning loan funds is not a simple one. The complexity of this process compounded with the newness of the staff person, although funds were returned timely, mistakes were made in processing that did not appropriately consider the origination fee. At the end of each term a ?no passing grades? report is generated to determine students who did not officially withdraw from the University but may have stopped attendance during the term and thus an unofficial withdrawal should be calculated. After the report is run, each student?s attendance is confirmed for the entirety of their schedule. This evaluation could result in a date in which a student stopped attending courses altogether. If this date was prior to the point within the term when financial aid was fully earned, an unofficial withdrawal is performed retroactive to the date of last attendance and a R2T4 calculation is performed. Much like the R2T4 comments above, the process was performed and due to a change in staff and lack of explicit policy on the return of gross loan amount vs. net loan amount, mistakes were made in returning loan funds. Corrective Action Plan: When the incorrect amounts were noted in the audit sample, the University reviewed every R2T4 case for errors in processing the return of loan funds and took corrective action for any other incorrect amounts. To prevent the issue from happening in future R2T4 processing, staff referred to the Student Financial Aid Handbook and updated policy and procedure notes for this process to specifically address when to use the gross vs. net loan amount. Further, a double check has been instituted for all R2T4 calculations. The Associate Director will perform the R2T4 calculation upon learning of the withdrawal and will return any applicable scholarship and grant funding. The R2T4 calculation will be shared with the Assistant Director ? Loan Coordinator who will perform the return of loan funds. After the return of loan funds, the Associate Director will then review the student?s account and confirm the correct amount was returned before filing the withdrawal calculation in the student?s file. This added oversight of the process should increase the likelihood of errors being identified within the required return timeframe and corrected accordingly. Responsible Person: Stacey Hubbard, Director of Student Financial Services Implementation Date: August 2021 2021-001 ? Student Financial Aid Cluster ? (a) Federal Supplemental Educational Opportunity Grants (b) Federal Work Study Program (c) Federal Perkins Loan Program ? Federal Capital Contributions (d) Federal Pell Grant Program (e) Federal Direct Student Loans (f) Teacher Education Assistance for College and Higher Education (TEACH), Assistance Listing No. (a) 84.007 (b) 84.033 (c) 84.038 (d) 84.063 (e) 84.268 (f) 84.379 ? Year Ended June 30, 2021 (Continued) Corrective Action Plan: When the incorrect amounts were noted in the audit sample, the University reviewed every R2T4 case for errors in processing the return of loan funds and took corrective action for any other incorrect amounts. To prevent the issue from happening in future R2T4 processing, staff referred to the Student Financial Aid Handbook and updated policy and procedure notes for this process to specifically address when to use the gross vs. net loan amount. Further, a double check has been instituted for all R2T4 calculations. The Associate Director will perform the R2T4 calculation upon learning of the withdrawal and will return any applicable scholarship and grant funding. The R2T4 calculation will be shared with the Assistant Director ? Loan Coordinator who will perform the return of loan funds. After the return of loan funds, the Associate Director will then review the student?s account and confirm the correct amount was returned before filing the withdrawal calculation in the student?s file. This added oversight of the process should increase the likelihood of errors being identified within the required return timeframe and corrected accordingly. Responsible Person: Stacey Hubbard, Director of Student Financial Services Implementation Date: August 2021

2021-002 ? Student Financial Aid Cluster ? (a) Federal Supplemental Educational Opportunity Grants (b) Federal Work Study Program (c) Federal Perkins Loan Program ? Federal Capital Contributions (d) Federal Pell Grant Program (e) Federal Direct Student Loans (f) Teacher Education Assistance for College and Higher Education (TEACH), Assistance Listing No. (a) 84.007 (b) 84.033 (c) 84.038 (d) 84.063 (e) 84.268 (f) 84.379 ? Year Ended June 30, 2021 Criteria: 34 CFR 685.101 (b)(1) notes, ?an eligible undergraduate student who is enrolled at a school participating in the Direct Loan Program may borrow under the Direct Subsidized Loan and Direct Unsubsidized Loan programs.? The order of dispersing aid requires that grants and subsidized loans be considered first. 34 CFR 685.200(a)(iii) ?In the case of an undergraduate student who seeks a Direct Subsidized Loan or a Direct Unsubsidized Loan at a school that participates in the Federal Pell Grant Program, the student has received a determination of Federal Pell Grant eligibility for the period of enrollment for which the loan is sought.? Condition: In two of the 40 student files tested (5%), Subsidized and Unsubsidized Direct loans we not properly awarded. The University under awarded both students $1,000 in Subsidized loans and over awarded both students by $1,000 in Unsubsidized loans. See Schedule of Findings and Questioned Costs for chart/table We consider this condition to be an instance of noncompliance relating to the Eligibility compliance requirement and a repeat of prior year finding 2020-001. Statistical sampling was not used in making sample selections. Questioned Costs: $2,000 Cause and Effect: Without proper review of eligibility of financial aid, students may receive an incorrect amount of Title IV aid. Students should receive the proper amount of aid. Recommendation: We recommend the University evaluate policies and procedures to ensure students receive the proper amount of Title IV aid. Views of Responsible Officials: Management agrees with this Single Audit Finding and response is included in the Corrective Action Plan.

2021-002 ? Student Financial Aid Cluster ? (a) Federal Supplemental Educational Opportunity Grants (b) Federal Work Study Program (c) Federal Perkins Loan Program ? Federal Capital Contributions (d) Federal Pell Grant Program (e) Federal Direct Student Loans (f) Teacher Education Assistance for College and Higher Education (TEACH), Assistance Listing No. (a) 84.007 (b) 84.033 (c) 84.038 (d) 84.063 (e) 84.268 (f) 84.379 ? Year Ended June 30, 2021 Condition: In two of the 40 student files tested (5%), Subsidized and Unsubsidized Direct loans we not properly awarded. The University under awarded both students $1,000 in Subsidized loans and over awarded both students by $1,000 in Unsubsidized loans. Management Response: A student?s annual loan limit for direct loan funding is determined by their actual class noted with the University ? Freshman, Sophomore, Junior/Senior ? and on their determined financial need for subsidized versus unsubsidized loan amounts. Since students are awarded/offered financial aid prior to the start of an academic term, their class level and financial need can change prior to the actual loan disbursement. If a student makes changes to their FAFSA resulting in an EFC change, their eligibility for need-based financial aid can fluctuate. We have several reports and processes in place to catch these fluctuations in eligibility. Since this is the first full year our Assistant Director ? Loan Coordinator has performed the loan revision processes it was not readily apparent in either instance that the loan amounts were incorrect since the overall loan limit was appropriate. Corrective Action Plan: Reports showing class level fluctuations and negative unmet need calculations are developed. A review of frequency for review and oversight of these reports was conducted and they will be reviewed at more frequent intervals during the academic term to identify any adjustments that need to be made. Further, the process for identifying changes in EFC due to subsequent FAFSA/ISIR data has been reviewed to include a review of validity for the new information and an overview of any change in eligibility as a result of the new information. Both policy/processing changes will minimize errors in subsidized versus unsubsidized loan eligibility for students. Responsible Person: Stacey Hubbard, Director of Student Financial Services Implementation Date: August 2021

2020-001

Criteria: 34 CFR 685.101 (b)(1) notes, ?an eligible undergraduate student who is enrolled at a school participating in the Direct Loan Program may borrow under the Direct Subsidized Loan and Direct Unsubsidized Loan programs.? The order of dispersing aid requires that grants and subsidized loans be considered first. 34 CFR 685.200(a)(iii) ?In the case of an undergraduate student who seeks a Direct Subsidized Loan or a Direct Unsubsidized Loan at a school that participates in the Federal Pell Grant Program, the student has received a determination of Federal Pell Grant eligibility for the period of enrollment for which the loan is sought.? Condition: One of the 40 student files we examined, we noted one student (2.5%) who was not properly awarded Subsidized Direct loans. The University awarded a student only Unsubsidized Direct Loans who was eligible to receive $2,750 in Subsidized Direct loans. See Schedule of Findings and Questioned Costs for chart/table We consider this condition to be an instance of noncompliance relating to the Eligibility compliance requirement. Statistical sampling was not used in making sample selections. Questioned Costs: $2,750 Cause and Effect: Without proper review of eligibility of financial aid, students may receive an incorrect amount of Title IV aid. Students should receive the proper amount of aid. Recommendation: We recommend the University evaluate policies and procedures to ensure students receive the proper amount of Title IV aid. Views of Responsible Officials: Management agrees with this Single Audit Finding and response is included in the Corrective Action Plan

Condition: One of the 40 student files we examined, we noted one student (2.5%) who was not properly awarded Subsidized Direct loans. The University awarded a student only Unsubsidized Direct Loans who was eligible to receive $2,750 in Subsidized Direct loans. Corrective Action Plan: Since this issue stemmed from a change in the student's status and budget, we have implemented a new process for reviewing mid-year graduates/transfers. The student identified in this issue was originally packaged as a full-time/full-year student in April of 2019. She was packaged correctly and her loans were calculated correctly. During the summer term of 2019, it was realized that the student would only be attending in the Fall term due to graduating in December 2019. When the student's financial aid was revised, her budget was changed to Fall term only but her gift aid was not corrected/reduced for only one term. This reduced her financial need and her loan was incorrectly awarded for the Fall term as fully unsubsidized. New procedure for mid-term graduates will begin with the loan coordinator. Once the graduation list is received from the registrar, the loan coordinator will review all students graduating midyear and will adjust budgets and financial aid packages. The Associate Director will then review the changes before loans are processed to catch any errors. Responsible Person for Corrective Action Plan: Lynette Lambert, Loan Coordinator and Chilwana Thompson, Associate Director Implementation Date of Corrective Action Plan: Implemented in November of 2020 for the 20-21 academic year.

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