North Central UniversityNon-Profit

Federal Program – Department of Education, Student Financial Assistance Cluster, Federal Pell Grant Program, Assistance Listing Number 84.063; Federal Direct Loan Program, Assistance Listing Number 84.268. Program Year – June 1, 2024 – May 31, 2025 Criteria or Specific Requirement – Special Tests and Provisions – Enrollment Reporting – The Code of Federal Regulations, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless of 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. This includes the enrollment effective date and related enrollment status, which must be reported for both the Campus-Level and the Program-Level. In addition, at a minimum, schools are required to certify enrollment every 60 days, and respond within 15 days of the date that the National Student Loan Data System (NSLDS) sends a Roster file to the school or its third-party servicer. In addition, regulations require that an institution make necessary corrections and return the records within 10 days for any roster files that do not pass the NSLDS enrollment reporting edits. Condition – The published program date reported to the NSLDS did not match institutional records. Questioned Costs – None Context – During our testing, we noted for 19 out of 19 students tested, the published program date reported to the NSLDS does not match the program length per the institution’s records. Our sample was not intended to be statistically valid. Cause – Updates for the program length were not sufficient and secondary checks were not performed. Effect – NSLDS did not contain current and accurate information with respect to published program length. Identification as a Repeat Finding – Yes, see 2024-001. Recommendation – We recommend that the University review its policies and procedures around reporting status changes and other enrollment information to NSLDS to ensure timely and accurate reporting. Views of Responsible Officials and Planned Corrective Action – There is no disagreement with the finding. The program length will be corrected for all students.

Federal Program – Department of Education, Student Financial Assistance Cluster, Federal Supplemental Educational Opportunity Grants, Assistance Listing Number 84.007; Federal Work-Study Program, Assistance Listing Number 84.033; Federal Pell Grant Program, Assistance Listing Number 84.063; Federal Direct Loan Program, Assistance Listing Number 84.268. Program Year – June 1, 2024 – May 31, 2025 Criteria or Specific Requirement – Special Tests - Return of Funds – When a recipient of Title IV grant or loan assistance withdraws from an institution during a payment period of enrollment in which the recipient began attendance, the institution must determine the amount of Title IV aid earned by the student as of the student’s withdrawal date. If the total amount of Title IV assistance earned by the student is less than the amount that was disbursed to the student on his or her behalf as of the date of the institution’s determination that the student withdrew, the difference must be returned to the Title IV programs as outlined in this section and no additional disbursements may be made to the student for the payment period or period of enrollment (34 CFR Sections 668.22(a)(1)-(3)). Condition – The earned percentage, based upon the enrollment period determined and the amount of aid to return, was calculated incorrectly. The University over-returned funds to the Department of Education because of the error in the calculation. Questioned Costs – $11, CFDA 84.268 Context – Of a sample of four return of funds tested from a population of ten performed during the examination period, one calculation was not performed correctly. Our sample was not, and was not intended to be, statistically valid. Cause – The enrollment period was calculated incorrectly. Effect – The University returned the incorrect amount of funds to the Department of Education. Identification as a Repeat Finding – No Recommendation – We recommend the University be diligent in performing secondary reviews to ensure the calculations are performed correctly along with review of inputs into the system to ensure the proper number of days are included in each term. Views of Responsible Officials and Planned Corrective Action – There is no disagreement with the audit finding. There will be review of the return of funds calculation.

Federal Program – Department of Education, Student Financial Assistance Cluster, Federal Pell Grant Program, Assistance Listing Number 84.063; Federal Direct Loan Program, Assistance Listing Number 84.268. Program Year –June 1, 2023 – May 31, 2024 Criteria or Specific Requirement – Special Tests and Provisions – Enrollment Reporting – The Code of Federal Regulations, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless of 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. This includes the enrollment effective date and related enrollment status, which must be reported for both the Campus-Level and the Program-Level. In addition, at a minimum, schools are required to certify enrollment every 60 days, and respond within 15 days of the date that the National Student Loan Data System (NSLDS) sends a Roster file to the school or its third-party servicer. In addition, regulations require that an institution make necessary corrections and return the records within 10 days for any roster files that do not pass the NSLDS enrollment reporting edits. Condition – The published program date reported to the NSLDS did not match institutional records. Questioned Costs – None Context – During our testing, we noted for 21 out of 21 students tested, the published program date reported to the NSLDS does not match the program length per the institution’s records. Our sample was not intended to be statistically valid. Effect – NSLDS did not contain current and accurate information with respect to published program length. Identification as a Repeat Finding – Yes, see 2023-001. Recommendation – We recommend that the University review its policies and procedures around reporting status changes and other enrollment information to NSLDS to ensure timely and accurate reporting. Views of Responsible Officials and Planned Corrective Action – There is no disagreement with the finding. The program length will be corrected for all students.

Federal Program – Department of Education, Student Financial Assistance Cluster, Federal Supplemental Educational Opportunity Grants, Assistance Listing Number 84.007; Federal Work-Study Program, Assistance Listing Number 84.033; Federal Pell Grant Program, Assistance Listing Number 84.063; Federal Direct Loan Program, Assistance Listing Number 84.268. Program Year - June 1, 2023 - May 31, 2024 Criteria or Specific Requirement – Cash Management – Under the advance payment method, the University’s request must not exceed the amount immediately needed to disburse funds to students. A disbursement of funds occurs on the date the University credits a student’s account or pays a student or parent directly with either SFA funds or its own funds. Under the advance payment method, the University must make the disbursement as soon as administratively feasible, but no later than three business days following the receipt of funds. (34 CFR 668.162) Condition – An additional draw of approximately $112,574 was made in excess of the amount disbursed and not returned within three business days. Questioned Costs – CFDA 84.268 - $112,574 Context - The University was overdrawn at fiscal year end on direct loan funding. Cause - Proper reconciliations were not timely performed to identify the error prior to the draw and at year end. Effect - Federal funding pertaining to Direct Loans was overdrawn at year end. Identification as a Repeat Finding - No Recommendation - We recommend the University perform reconciliations timely and prior to drawing the related federal funding. Views of Responsible Officials and Planned Corrective Action - There is no disagreement with the audit finding. Corrections to the drawdown process will be made.

Federal Program – Department of Education, Student Financial Assistance Cluster, Federal Pell Grant Program, Assistance Listing Number 84.063; Federal Direct Loan Program, Assistance Listing Number 84.268. Program Year –June 1, 2022 – May 31, 2023 Criteria or Specific Requirement – Special Tests and Provisions – Enrollment Reporting – The Code of Federal Regulations, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless of 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. This includes the enrollment effective date and related enrollment status, which must be reported for both the Campus-Level and the Program-Level. In addition, at a minimum, schools are required to certify enrollment every 60 days, and respond within 15 days of the date that the National Student Loan Data System (NSLDS) sends a Roster file to the school or its third-party servicer. In addition, regulations require that an institution make necessary corrections and return the records within 10 days for any roster files that do not pass the NSLDS enrollment reporting edits. Condition – The published program date reported to the NSLDS did not match institutional records. Questioned Costs – None Context – During our testing, we noted for 21 out of 21 students tested, the published program date reported to the NSLDS does not match the program length per the institution’s records. Our sample was not intended to be statistically valid. Effect – NSLDS did not contain current and accurate information with respect to published program length. Identification as a Repeat Finding – Yes, see 2022-003. Recommendation – We recommend that the University review its policies and procedures around reporting status changes and other enrollment information to NSLDS to ensure timely and accurate reporting. Views of Responsible Officials and Planned Corrective Action – There is no disagreement with the finding. All program lengths have been corrected in our NSLDS reporting cycle. Unfortunately, the implementation went beyond the May 31, 2023, fiscal year. During a recent internal audit of 20 students we can now see the published length correctly reporting in NSLDS for all investigated students.Federal Program – Department of Education, Student Financial Assistance Cluster, Federal Pell Grant Program, Assistance Listing Number 84.063; Federal Direct Loan Program, Assistance Listing Number 84.268. Program Year –June 1, 2022 – May 31, 2023 Criteria or Specific Requirement – Special Tests and Provisions – Enrollment Reporting – The Code of Federal Regulations, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless of 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. This includes the enrollment effective date and related enrollment status, which must be reported for both the Campus-Level and the Program-Level. In addition, at a minimum, schools are required to certify enrollment every 60 days, and respond within 15 days of the date that the National Student Loan Data System (NSLDS) sends a Roster file to the school or its third-party servicer. In addition, regulations require that an institution make necessary corrections and return the records within 10 days for any roster files that do not pass the NSLDS enrollment reporting edits. Condition – The published program date reported to the NSLDS did not match institutional records. Questioned Costs – None Context – During our testing, we noted for 21 out of 21 students tested, the published program date reported to the NSLDS does not match the program length per the institution’s records. Our sample was not intended to be statistically valid. Effect – NSLDS did not contain current and accurate information with respect to published program length. Identification as a Repeat Finding – Yes, see 2022-003. Recommendation – We recommend that the University review its policies and procedures around reporting status changes and other enrollment information to NSLDS to ensure timely and accurate reporting. Views of Responsible Officials and Planned Corrective Action – There is no disagreement with the finding. All program lengths have been corrected in our NSLDS reporting cycle. Unfortunately, the implementation went beyond the May 31, 2023, fiscal year. During a recent internal audit of 20 students we can now see the published length correctly reporting in NSLDS for all investigated students.

Federal Agency – Department of Education, Student Financial Assistance Cluster, Federal Pell Grant Program, Assistance Listing Number 84.063; Federal Direct Loan Program, Assistance Listing Number 84.268. Program Year – June 1, 2022 – May 31, 2023 Criteria or Specific Requirement – Special Tests and Provisions – Borrower Data Transmission – Per the Uniform Guidance 2 CFR 200.303, non-federal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Condition – During our testing, we noted no documentation of review or completion for the monthly reconciliations for Direct Loans, Pell and SEOG. Questioned Costs – None Context – During our testing, it was noted that necessary review and approval to maintain internal controls were not being done. Cause – Per the Uniform Guidance 2 CFR 200.303, non-federal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations and program compliance requirements. Effect – It is possible for errors to occur and not be caught in a timely manner. Identification as a Repeat Finding – Yes, see 2022-004. Recommendation –The University has put into place the required reconciliation process. We recommend the University continue this practice. Views of Responsible Officials and Planned Corrective Action – There is no disagreement with the audit finding. Corrections for this finding started in January 2023. Initial months selected were prior to that date. Additional months were provided, tested and complied. NCU will continue to do our monthly reconciliations in the same manner.

Federal Agency –Department of Education, Student Financial Assistance Cluster, Federal Supplemental Educational Opportunity Grants, Assistance Listing Number 84.007; Federal Work Study Program, Assistance Listing Number 84.033; Federal Pell Grant Program, Assistance Listing Number 84.063; Federal Direct Loan Program, Assistance Listing Number 84.268. Federal Award Program Year – June 1, 2022 – May 31, 2023 Criteria or Specific Requirement – When a recipient of Title IV grant or loan assistance withdraws from an institution during a payment period of enrollment in which the recipient began attendance, the institution must determine the amount of Title IV aid earned by the student as of the student’s withdrawal date. If the total amount of Title IV assistance earned by the student is less than the amount that was disbursed to the student on his or her behalf as of the date of the institution’s determintation that the student withdrew, the difference must be returned to the Title IV programs as outlined in this section and no additional disbursements may be made to the student for the payment period or period of enrollment (34 CFR Sections 668.22(a)(1)-(3)). Condition – The earned percentage, based upon the enrollment period determined and the amount of aid to return, was calculated incorrectly. The University over-returned funds to the Department of Education because of the error in the calculation. Questioned Costs – None Context – Of a sample of two return of funds tested from a population of four performed during the examination period, one calculation was not performed correctly. Our sample was not, and was not intended to be, statistically valid. Cause – The enrollment period was calculated incorrectly. Effect – The University returned the incorrect amount of funds to the Department of Education. Identification as a Repeat Finding – N/A Recommendation – We recommend that the University be diligent in performing secondary reviews to endure the calculations are performed correctly along with review of inputs into the system to ensure the proper number of days are included in each term. Views of Responsible Officials and Planned Corrective Action – There is no disagreement with the audit finding. We have diligently reviewed our procedures and implemented robust measures to ensure strict adherence to the regulations governing Return of Title IV Funds. Our efforts have focused on establishing comprehensive double checks throughout the process to mitigate any potential errors or oversights. This includes enhanced annual training, dual verification process - every Return of Title IV fund calculation must now be calculated first by our Financial Aid Data and Reporting Analyst and then re-calculated and reviewed by the Executive Director of One Stop. We now have a robust documentation process for each return and prior to the end of the fiscal implemented internal audits of all withdrawn students. We are confident these measures will maintain compliance and ensure accuracy.

Federal Agency: Department of Education Federal Program Title: Student Financial Assistance Cluster Assistance Listing Number: Various Award Period: June 1, 2021 to May 31, 2022 Type of Finding: ? Significant Deficiency in Internal Control Over Compliance; Other Matter Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 668.25(e) states that an institution must notify the Department of Education by way of the ECAR within 10 days of a change in position of an official at the University. Condition: During our testing, we noted that the change in Director of Student Financial Services was not reported timely to the Department of Education. Questioned Costs: None Context: During our testing, we noted the Director of Student Financial Services had a change in position and it was not updated within 10 days. Cause: The Director of Student Financial Services left in January 2021. The ECAR was not updated for the new Director of Student Financial Services at the time of testing in July. Effect: The University is not in compliance with Department of Education requirements that state the ECAR must have accurately reported information. Repeat Finding: No Auditors? Recommendation: We recommend the University review its reporting procedures surrounding updating the ECAR to ensure reporting is accurate and completed. Views of Responsible Officials: No Disagreement

Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Aid Assistance Listing Number: 84.063 ? Federal Pell Grant Program 84.268 ? Federal Direct Loans 84.007 ? Federal Supplemental Educational Opportunity Grants 84.033 ? Federal Work Study Program Award Period: June 1, 2021 to May 31, 2022 Type of Finding: ? Significant Deficiency in Internal Control Over Compliance; Other Matter Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless of 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. This includes the enrollment effective date and related enrollment status, which must be reported for both the Campus-Level and the Program-Level. In addition, at a minimum, schools are required to certify enrollment every 60 days, and respond within 15 days of the date that NSLDS sends a Roster file to the school or its third-party servicer. In addition, regulations require that an institution make necessary corrections and return the records within 10 days for any roster files that do not pass the NSLDS enrollment reporting edits. Condition: During our testing, we noted for 36 out of the 40 students tested, the published program date reported to NSLDS does not match the program length per the institution?s records. Questioned Costs: None Context: During our testing, it was noted the University does not have a process in place to ensure accuracy of NSLDS reporting. Cause: Error in reporting program length to NSLDS. Effect: The University did not comply with Department of Education?s regulations regarding enrollment reporting as well as the NSLDS system is not updated with the student information. Repeat Finding: Yes Auditors? Recommendation: We recommend the University reevaluate its procedures and review policies surrounding reporting status changes and other enrollment information to NSLDS to ensure timely and accurate reporting. Views of Responsible Officials: No Disagreement

Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Aid Assistance Listing Number: 84.063 ? Federal Pell Grant Program 84.268 ? Federal Direct Loans 84.007 ? Federal Supplemental Educational Opportunity Grants 84.033 ? Federal Work Study Program Award Period: June 1, 2021 to May 31, 2022 Type of Finding: ? Significant Deficiency in Internal Control Over Compliance Criteria or Specific Requirement: Per the Uniform Guidance 2 CFR 200.303, non-Federal entities receiving Federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations and program compliance requirements. Condition: During our review of internal controls, we noted no documentation of review of the monthly reconciliations for Direct Loans, Pell, and SEOG. Questioned Costs: None Context: During our testing it was noted that necessary review and approval to maintain internal controls were not being done. Cause: Per the Uniform Guidance 2 CFR 200.303, non-Federal entities receiving Federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations and program compliance requirements. Effect: It is possible for errors to occur and not be caught in a timely manner. Repeat Finding: Yes Auditors? Recommendation: We recommend that the University document completion of approval and reviews. Views of Responsible Officials: No Disagreement

Federal Agency: U.S. Department of Education Federal Program Title: Higher Education Emergency Relief Funds Assistance Listing Number: 84.425 Award Period: June 1, 2021 to May 31, 2022 Type of Finding: ? Significant Deficiency in Internal Control Over Compliance ? Other Matters Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, federal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations and program compliance requirements. The initial reporting for this grant requires the report to be submitted to the college or university?s website within 30 days of the signed Certification Agreement or 30 days after the electronic announcement dated May 6, whichever is later. Colleges and universities were then required to update their websites every 45 days after initial upload. This was changed to quarterly on August 31, 2020. In addition, an annual report is required. Condition: During our testing, we noted: ? For the December 31, 2021, and March 31, 2022 student quarterly reports, proper supporting documentation was not retained for the number of students paid and total amount paid and number of eligible students. ? For the December 31, 2021 annual report there was no support of the annual report saved. Questioned Costs: None Context: A control system to prevent and detect errors in the reporting process was not created at the time the reports were filed and the University did not have a process to track the reporting requirements. In addition, there was a general lack of guidance from ED on reporting requirements. Cause: The University did not have someone tracking the requirements to ensure that they posted the reporting timely and accurately. Effect: The University did not comply with ED regulations by reporting accurate information as well as retaining support for the information reported to ensure accuracy. Repeat finding: No Recommendation: We recommend the University review their reporting procedures to ensure all required steps are included as well as the supporting documentation to prepare the report is retained. The reports should be reviewed by someone other than the preparer of the report and this review should be documented. Views of responsible officials: There is no disagreement with the audit finding.

2021-001 Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Aid CFDA Number: 84.063 ? Federal Pell Grant Program 84.268 ? Federal Direct Loans Award Period: 2020-2021 Type of Finding: ? Significant Deficiency in Internal Control Over Compliance; Other Matter Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 668.22(f)(2)(i), states that scheduled breaks of at least five consecutive days are excluded from the total number of calendar days in a payment period or period of enrollment and the number of calendar days completed in that period. Condition: It was noted during our testing of R2T4 calculations that the University did not use the correct course begin date for students enrolled in online sessions. Thus, all calculations performed for online students for both the 2020 fall and 2021 spring terms were determined to be inaccurate. Questioned Costs: $181 Context: Error in term begin date. Cause: Incorrect enrollment dates were used in the calculation due to an error in the entering of enrollment information into the Banner system, resulting in incorrect dates being used in the manual preparation of refund calculations. Effect: The students? return of funds calculation was not done correctly and the return of funds back to the federal government was for the incorrect amount. Repeat Finding: No Auditors? Recommendation: We recommend the University review the R2T4 requirements and implement procedures to ensure the R2T4 calculations are using the correct amount of term days and are accurately completed. Views of Responsible Officials: No Disagreement

2021-002: Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Aid CFDA Number: 84.063 ? Federal Pell Grant Program 84.268 ? Federal Direct Loans 84.007 ? Federal Supplemental Educational Opportunity Grants 84.033 ? Federal Work Study Program Award Period: 2020-2021 Type of Finding: ? Significant Deficiency in Internal Control Over Compliance; Other Matter Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless of 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. This includes the enrollment effective date and related enrollment status, which must be reported for both the Campus-Level and the Program-Level. In addition, at a minimum, schools are required to certify enrollment every 60 days, and respond within 15 days of the date that NSLDS sends a Roster file to the school or its third-party servicer. In addition, regulations require that an institution make necessary corrections and return the records within 10 days for any roster files that do not pass the NSLDS enrollment reporting edits. Condition: During our testing, we noted for 40 out of the 40 students tested, the published program date reported to NSLDS does not match the program length per the institution?s records. Questioned Costs: None Context: During our testing, it was noted the University does not have a process in place to ensure accuracy of NSLDS reporting. Cause: Error in reporting program length to NSLDS. Effect: The University did not comply with Department of Education?s regulations regarding enrollment reporting as well as the NSLDS system is not updated with the student information. Repeat Finding: No Auditors? Recommendation: We recommend the University reevaluate its procedures and review policies surrounding reporting status changes and other enrollment information to NSLDS to ensure timely and accurate reporting. Views of Responsible Officials: No Disagreement

2021-003: Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Aid CFDA Number: 84.063 ? Federal Pell Grant Program 84.268 ? Federal Direct Loans 84.007 ? Federal Supplemental Educational Opportunity Grants 84.033 ? Federal Work Study Program Award Period: 2020-2021 Type of Finding: ? Significant Deficiency in Internal Control Over Compliance; Other Matter Criteria or Specific Requirement: Per the Uniform Guidance 2 CFR 200.303, non-Federal entities receiving Federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations and program compliance requirements. Condition: During our review of internal controls, we noted no documentation of review of professional judgement determinations and the monthly reconciliations for Direct Loans, Pell, and SEOG. Questioned Costs: None Context: During our testing it was noted that necessary review and approval to maintain internal controls were not being done. Cause: Per the Uniform Guidance 2 CFR 200.303, non-Federal entities receiving Federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations and program compliance requirements. Effect: It is possible for errors to occur and not be caught in a timely manner. Repeat Finding: No Auditors? Recommendation: We recommend that the University document completion of approval and reviews. Views of Responsible Officials: No Disagreement

2021-004 Reporting Federal Agency: U.S. Department of Education Federal Program Title: Higher Education Emergency Relief Funds ALN Number: 84.425 Award Period: 2020-2021 Type of Finding: ? Significant Deficiency in Internal Control Over Compliance ? Other Matters Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, federal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations and program compliance requirements. The initial reporting for this grant requires the report to be submitted to the college or university?s website within 30 days of the signed Certification Agreement or 30 days after the electronic announcement dated May 6, whichever is later. Colleges and universities were then required to update their websites every 45 days after initial upload. This was changed to quarterly on August 31, 2020. In addition, an annual report is required. Condition: During our testing, we noted: ? For the September 30, 2020, December 31, 2020, and March 31, 2021 student quarterly reports, there was no documentation saved for the website upload, so there was no way to test if they were uploaded timely. The reports were also not reviewed and approved prior to submission. ? For the September 30, 2020, December 31, 2020, and March 31, 2021 student quarterly reports, proper supporting documentation was not retained for the number of students paid and total amount paid. ? For the September 30, 2020, December 31, 2020, and March 31, 2021 institutional quarterly reports, there was no documentation saved for the website upload, so there was no way to test if they were uploaded timely. The reports were also not reviewed and approved prior to submission. ? For the December 31, 2020 annual report, proper supporting documentation was not retaied for the count of eligible students reported and the funding amounts disbursed. Questioned Costs: None Context: A control system to prevent and detect errors in the reporting process was not created at the time the reports were filed and the University did not have a process to track the reporting requirements. In addition, there was a general lack of guidance from ED on reporting requirements. Cause: The University did not have someone tracking the requirements to ensure that they posted the reporting timely and accurately. Effect: The University did not comply with ED regulations by reporting accurate information as well as retaining support for the information reported to ensure accuracy. Repeat finding: No Recommendation: We recommend the University review their reporting procedures to ensure all required steps are included as well as the supporting documentation to prepare the report is retained. The reports should be reviewed by someone other than the preparer of the report and this review should be documented. Views of responsible officials: There is no disagreement with the audit finding.

2020-001: Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Aid CFDA Number: 84.063 Pell Grant Award Period: 2019-2020 Type of Finding: Significant Deficiency in Internal Control Over Compliance; Other Matter Criteria or Specific Requirement: According to 34 CFR 690.62 Calculation of a Federal Pell Grant, the amount of a student?s Pell Grant for an academic year is based upon the payment and disbursement schedule published by the Department of Education for each award year. A Pell Grant is calculated based on a student?s expected family contribution (EFC) and enrollment status. Condition: During our testing of Pell Grants we noted four of 20 students tested were under awarded Pell Grants by $100 each. Questioned Costs: $400 Context: Pell Grants are improperly awarded. Cause: An incorrect EFC was used to determine the Pell Grant. Effect: Students are being awarded and disbursement a grant amount that is less than the amount they are eligible for. Repeat Finding: No Auditors? Recommendation: We recommend the University implements a process in which all Pell awards are reviewed in conjunction with the enrollment status and EFC of the student to ensure no under awards exist. Views of Responsible Officials: No Disagreement

2020-002: Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Aid CFDA Number: 84.038 Perkins Loan Program Award Period: 2019-2020 Type of Finding: Significant Deficiency in Internal Control Over Compliance; Other Matter Criteria or Specific Requirement: The Code of Federal Regulation, 34 CFR 674.43 requires first overdue notice to a borrower within 15 days after the due date of the payment if the servicer has not received a payment, a request for deferment or a request for postponement or for cancellation. Further, a borrower shall receive a second overdue notice within 30 days after the first overdue notice is sent and a final demand letter within days after the second overdue notice. The University at this time must inform the borrower that unless the institution receives a payment or a request for deferment, postponement, or cancellation within 30 days of the later, it will refer the account for collection or litigation and will report the default to a credit bureau. Condition: The University utilizes University Accounting Service, LLC (UAS) for its third party Perkins Loan servicing. This is a very common practice for colleges and universities in order to provide the most efficient and effective means to not only collect loans but meet the federal regulations for servicing student Perkins Loans. In auditing the compliance features for the loan servicing, CLA utilizes the external compliance report performed for UAS by other auditors. We noted within the UAS compliance audit report for the year ended June 30, 2020, there was a finding for not sending past due notices within the required timeframes or not sending past due notices at all. The audit did not specify the students that were not contacted within the required guidelines and UAS is one of the largest third party servicer for federal student loans. Therefore, we do not know if there were any North Central University students that were impacted by the non-compliance noted at UAS. Questioned Costs: None Context: We noted the University?s third party servicer, UAS, failed to comply with notifying students of past due notices nothing 2 of 50 students were sent past due notices late and one of 50 were not sent proper past due notice. Cause: UAS, the third-party servicer, did not have controls in place to ensure they complied with Department of Education Rules and Regulations in regards to timely notice of past due payments. Given the University relies on UAS to meet their compliance responsibilities and there was not testing completed specifically for the University to determine if the non-compliance is specific to them, this is a finding for the University. Effect: UAS is not in compliance with all statutory or regulatory provisions as it pertains to the notification of students with past due payments. Any finding UAS receives that is not mitigated with additional testing (with results of no errors specific to the college or university), that finding becomes a finding of the institutions they service. Repeat Finding: No Auditors? Recommendation: We recommend that the University implement a thorough review process of all third-party servicer contracts to make sure they comply with all Department of Education Rules and Regulations. Views of Responsible Officials: No Disagreement

2019-001: Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Aid CFDA Number: 84.268 Federal Direct Loan Program Award Period: 2018-2019 Type of Finding: ? Significant Deficiency in Internal Control over Compliance Criteria or Specific Requirement: 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. Condition: During our review of Title IV refunds, we noted 1 of 8 students tested had an inaccurate number of break days in R2T4 calculation which resulted in overpayment of $12 of Title IV Funds as a post-withdrawal disbursement. Questioned Costs: $12 of unsubsidized direct loan Context: Error in return of Title IV funds calculation. Cause: An inaccurate number of break days in refund calculation. Effect: The student received more than eligible amount of unsubsidized loans. This amount needs to be returned to the Department of Education. Repeat Finding: No Auditors? Recommendation: We recommend that the University ensure all staff who prepares refund calculations receives proper training on how to complete the form. Views of Responsible Officials: No Disagreement

2019-002: Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Aid CFDA Number: Various Award Period: 2018-2019 Type of Finding: ? Significant Deficiency in Internal Control over Compliance Criteria or Specific Requirement: The Department of Education requires the College to report to NSLDS the correct Enrollment Status Effective Date, which is the date that the current enrollment status reported for a student was first effective. Condition: We noted 5 students out of 40 tested, had the incorrect effect date reported to NSLDS. Questioned Costs: None Context: The correct effective date was not reported. Cause: Lack of formal policy to determine last date of attendance and lack of communication between the Registrar and Student Financial Aid Department. Effect: Students have an incorrect effective date reported to NSLDS. Repeat Finding: No Auditors? Recommendation: We recommend that the registrar and the student financial aid department work together to ensure they have the correct effective date of changes in status for each student. Views of Responsible Officials: There is no disagreement with the audit finding.

2019-003: Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Aid CFDA Number: 84.063 Pell Grant Award Period: 2018-2019 Type of Finding: ? Significant Deficiency in Internal Control over Compliance Criteria or Specific Requirement: Section 401(b)(8) of the Higher Education Act of 1965 (HEA), as added by section 310 of the Department of Education Appropriations Act, 2017 (Title III of Division H of P.L. 115-31, the Consolidated Appropriations Act, 2017), allows a student to receive Federal Pell Grant (Pell Grant) funds for up to 150 percent of the student?s Pell Grant Scheduled Award for an award year. To be eligible for the additional Pell Grant funds, the student must be otherwise eligible to receive Pell Grant funds for the payment period and must be enrolled at least half-time, in accordance with 34 CFR 668.2(b), in the payment period(s) for which the student receives the additional Pell Grant funds in excess of 100 percent of the student?s Pell Grant Scheduled Award. Condition: During our testing of Pell eligibility, we noted 1 of 16 students tested were awarded 150% of the Pell annual limit. However, the student was only enrolled less than half time for the summer semester and therefore, not eligible to receive 150% of the annual limit. Questioned Cost: $1,523 Context: Improper awarding of Pell Cause: Error in awarding Pell for the summer 2019 semester Effect: Student over award of Pell Repeat Finding: No Auditors? Recommendation: We recommend the University implements a process in which all Summer Pell awards are reviewed in conjunction with the enrollment status of the student to ensure no over awards exist. Views of Responsible Officials: There is no disagreement with the audit finding.

2019-004: Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Aid CFDA Number: 84.038 Federal Perkins Loan Program Award Period: 2018-2019 Type of Finding: ? Significant Deficiency in Internal Control over Compliance Criteria or Specific Requirement: The Code of Federal Regulation, 34 CFR 674.42 requires contact to a borrower for the first time 90 days after the commencement of any grace period. The University at this time shall remind the borrower of his or her responsibility to comply with the terms of the loan. The University is then required at 150 days and 240 days to send subsequent notices to notify the borrower of the first required payment. Condition: The University utilizes University Accounting Service, LLC (UAS) for its third party Perkins Loan servicing. This is a very common practice for colleges and universities in order to provide the most efficient and effective means to not only collect loans but meet the federal regulations for servicing student Perkins Loans. In auditing the compliance features for the loan servicing, CLA utilizes the external compliance report performed for UAS by other auditors. We noted within the UAS compliance audit report for the year ended June 30, 2019, there was a finding for not contacting the student within the required time frames. The audit did not specify the students that were not contacted within the required guidelines and UAS is one of the largest third=party servicer for federal student loans. Therefore, we do not know if there were any North Central University students that were impacted by the noncompliance noted at UAS. Questioned Costs: None Context: We noted the University?s third-party servicer, UAS, failed to comply with notifying students of their grace period as required noting 2 of 50 students were noncompliant. Cause: UAS, the third-party servicer, did not have controls in place to ensure they complied with Department of Education Rules and Regulations in regards to timely engagement with students with federal loans. Given North Central University relies on UAS to meet their compliance responsibilities and there was not testing completed specifically for North Central University to determine if the noncompliance is specific to them, this is a finding for the University. Effect: UAS is not in compliance with all statutory or regulatory provisions as it pertains to the notification of students exiting its grace period. Any finding UAS receives that is not mitigated with additional testing (with results of no errors specific to the college or university), that finding becomes a finding of the institutions they service. Repeat Finding: No Auditors? Recommendation: We recommend that the University implement a thorough review process of all third-party servicer contracts to make sure they comply with all Department of Education Rules and Regulations. Views of Responsible Officials: There is no disagreement with the audit finding.

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