Edgerton Retirement Apartments Inc.Non-Profit

Federal Agency: U.S. Department of Agriculture Federal Program Title: Rural Development Multi-Family Housing Revitalization Demonstration Program Assistance Listing Number: 10.447 Award Period: 2025 Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: Procurement standards require a policy in place to be followed to endure entities are properly procuring goods and services and to ensure vendors and contractors are not suspended or debarred. Condition: During procurement and suspension and debarment testing, it was noted that the Organization does not have federal procurement policy that included a conflict of interest policy and other federal requirements. Questioned costs: None Context: Procurement transactions tested followed Rural Development’s policies Cause: The Organization does not have an approved federal procurement policy. Effect: It could cause the Organization to be out of compliance with federal requirements over procurement. Repeat finding: Yes Recommendation: We recommend that Organization approve a federal procurement policy and implement controls to ensure it is being followed. Views of responsible officials and planned corrective actions: There is no disagreement with the finding.

Federal Agency: U.S. Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Number: 84.063 and 84.268 Federal Award Identification Number and Year: P063P232982-2025 | P268K242982-2025 Award Period: July 1, 2024 through June 30, 2025 Type of Finding:  Significant Deficiency in Internal Control over Compliance  Other Matters Criteria or specific requirement: Institutions are required to report enrollment information under the Pell Grant and the Direct Loan via NSLDS as required by 34 CRF 690.83(b)(2) and 34 CFR 685.309, respectively. Institutions must review, update, and certify student enrollment statuses, program information, and effective dates that appear on the Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS Professional Access (NSLDSFAP) website. Condition: The District processes failed to report the correct campus and program enrollment status for a student to NSLDS in accordance with the stated criteria. Questioned costs: None Context: We noted one (1) out of forty (40) students selected for testing, where the District failed to report the campus and program level enrollment data accurately to NSLDS. Cause: The District’s internal controls failed to detect the inaccurate enrollment status being reported to NSLDS in accordance with the stated criteria. Effect: The District has not complied with the stated criteria for one (1) student. Repeat Finding: No Recommendation: We recommend that the District review its processes and internal controls designed to mitigate the risk of noncompliance with the stated criteria. Views of responsible officials: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Aid FALN Number: Student Financial Aid Cluster Award Period: June 01, 2024 through May 31, 2025 Type of Finding: • Significant Deficiency in Internal Control Over Compliance • Other Matters Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 685.309(b), states schools must have some arrangement to report student enrollment data to the National Student Loan Data System (NSLDS) through an enrollment roster file. The school is required to report changes in the student’s enrollment status, the effective date of the status, and an anticipated completion date as well as program enrollment effective date. 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. Condition: During our testing, we noted 40 out of the 40 students tested where the student was not reported in a timely manner after the school determined the students change in status. In addition, we noted for 1 out of the 40 students tested, the enrollment effective date per NSLDS did not match the enrollment effective date per the University’s records. Questioned costs: None Context: During our testing, it was noted the University does not have a process in place to ensure timeliness and accuracy of NSLDS reporting. Cause: The University did not have a process in place to ensure the effective dates reported matched the University’s records as well as that these changes were reported timely. Effect: The enrollment effective date reported to NSLDS is used to determine when the student’s grace period should begin. By not reporting an incorrect effective date, the grace period begin date for the student will be incorrect. In addition, the University did not comply with Department of Education (ED) regulations by reporting student enrollment status changes timely. Repeat finding: Yes, see finding 2024-002 Recommendation: We recommend the University reevaluate its procedures and review policies surrounding reporting status changes to NSLDS to put a process in place to ensure the enrollment effective date reported to NSLDS on the campus and program level is aligning with the University. Views of responsible officials: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Aid FALN Number: Student Financial Aid Cluster Award Period: June 01, 2024 through May 31, 2025 Type of Finding: • Significant Deficiency in Internal Control Over Compliance • Other Matters Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 674.16 states that before an institution makes its first disbursement to a student, the student shall sign the promissory note and the institution shall provide the student with certain repayment information. Condition: During our testing of the Student Financial Aid Cluster, we noted that 1 student out of 30 tested in the Perkins loan program could not be supported as having completed a promissory note or entrance counseling. Questioned costs: None Context: During our testing, it was noted the University does not have a process in place to ensure MPN’s are retained. Cause: The University did not have a process in place to ensure they retained a copy of the MPN for at least three years after the loans were satisfied. Effect: The University was not in compliance with the Perkins recordkeeping regulations. Repeat finding: No Recommendation: We recommend the University implements procedures moving forward to ensure that all necessary MPN’s are retained in accordance with the Perkins recordkeeping regulations. Views of responsible officials: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Aid FALN Number: Student Financial Aid Cluster Award Period: June 01, 2024 through May 31, 2025 Type of Finding: • Material Weakness in Internal Control Over Compliance • Other Matters Criteria or specific requirement: Federal regulations require institutions to award and disburse Title IV aid accurately and in accordance with student eligibility: Pell Grant: 34 CFR § 690.75 – Payment determination based on enrollment status and cost of attendance. FSEOG: 34 CFR § 676.10 – Must be awarded to students with exceptional financial need. Subsidized and Unsubsidized Stafford Loans: 34 CFR § 685.301 – Loan amounts must be based on grade level, dependency status, and cost of attendance. General Disbursement Requirements: 34 CFR § 668.164 – Institutions must disburse funds for the correct amount and payment period. Condition: A review of student financial aid records revealed that although students were accurately awarded federal financial aid—including Pell Grants, FSEOG, Subsidized Stafford Loans, and Unsubsidized Stafford Loans—based on documented eligibility and financial need, the actual disbursements were less than the awarded amounts. In several cases, students did not receive the full aid they were eligible for during the designated payment period, resulting in underdisbursement of funds. Questioned costs: $49,565 Context: During our testing, it was noted that 4 of 40 students were underdisbursed Pell, 12 of 40 students were underdisbursed SEOG, 7 of 40 students were underdisbursed Subsidized Stafford Loans, and 5 of 40 students were underdisbursed Unsubsidized Stafford Loans. Cause: The University did not have a process in place to ensure the student were disbursed in accordance with their federal awards. Effect: The University was not in compliance with Title IV aid regulations. Repeat finding: No Recommendation: We recommend the University enhance system controls to ensure disbursements match awards. Views of responsible officials: There is no disagreement with the audit finding.

2024-003 Federal Agency: U.S. Department of the Treasury Federal Program Name: Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number: 21.027 Federal Award Identification Number and Year: 2024; FAIN not available. Award Period: January 1, 2024 through December 31, 2024 Compliance Requirement: Procurement, Suspension and Debarment Type of Finding: Material weakness in internal control over compliance Criteria or Specific Requirement: The United States Code of Federal Regulations (CFR) Title 2, Part 200.319 indicates procurement transactions under the Federal award must be conducted in a manner that provides full and open competition. Additionally, 2 CFR Part 200.320 indicates that for any allowable method chosen, the recipient or subrecipient must maintain and use documented procurement procedures, consistent with the requirements of 2 CFR Part 200, Subpart D. When a non-federal entity enters into a covered transaction with an entity at a lower tier, the nonfederal entity must verify that the entity, as defined in 2 CFR Part 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. This verification may be accomplished by (1) checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration (GSA), (2) collecting a certification from the entity, or (3) adding a clause or condition to the covered transaction with that entity (2 CFR Part 180.300). 2 CFR Part 200.303 indicates that non-Federal entities receiving Federal awards must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition: The Borough did not maintain documentation to support the suspension and debarment procedures performed for covered transactions in order to demonstrate compliance with 2 CFR Part 180 and 2 CFR Part 200. Questioned Costs: None. Context: One (1) of two (2) selections subject to suspension and debarment compliance requirements did not include adequate documentation to demonstrate that the Borough properly verified the vendor was not suspended or debarred prior to entering into the services agreement. Cause: Procedures were not implemented to maintain documentation to support compliance with the standards of suspension and debarment contained in 2 CFR Part 180 and 2 CFR Part 200. Effect: Compliance with the requirements of the federal award could not be demonstrated. Repeat Finding: No Recommendation: We recommend management enhance procedures and controls to ensure documentation is maintained to support all suspension and debarment verifications related to expenditures from federal award programs. Such documentation should be consolidated and maintained in a secure, accessible location. Views of Responsible Officials: Management agrees with the finding.

2024 – 001 Federal Agency: U.S. Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Number: 84.063 and 84.268 Federal Award Identification Number and Year: P063P232982-2024 | P268K242982-2024 Award Period: July 1, 2023 through June 30, 2024 Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matters Criteria or specific requirement: 34 CFR 685.309(b)(2) requires schools must report status changes within 30 days of determination. If a student did not make the roster report cut off and another roster is being updated within the next 60 days, the school may report the student change on that next roster. At a minimum, schools are required to certify enrollment every 60 days. Verify by reviewing Certification Date column in NSLDS and ensure student was reported at least every 60 days during the fiscal year. Condition: The District processes failed to timely report the appropriate status for a student to NSLDS in accordance with the stated criteria. Questioned costs: Known: None Context: We noted four (4) out of (40) forty students selected for testing, where the District failed to comply with the stated criteria. Cause: The District's internal control failed to detect the noncompliance with respect to compliance with the stated criteria. Effect: The District has not complied with the stated criteria for the four (4) students. Repeat Finding: No Recommendation: We recommend that the District review its processes and internal controls designed to mitigate the risk of noncompliance with the stated criteria. Views of responsible officials: There is no disagreement with the audit finding.

Federal Agency: Department of Education Federal Program Title: Student Financial Assistance Cluster Assistance Listing Number: 84.038, 84.268, 84.033, 84.007, 84.063, 84.268, 93.264 Award Period: July 1, 2023 through June 30, 2024 Type of Finding: • Significant Deficiency in Internal Control Over Compliance • Other Matter Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 685.309 requires that enrollment status changes for students be reported to NSLDS within 30 days or within 60 days if the student with the status change will be reported on a scheduled transmission within 60 days of the change in status. Condition: During our testing of the Direct Loan and Pell Grant programs, we selected a sample of students to test for timeliness of reporting student status changes to the National Student Loan Data System (NSLDS). During our testing, we noted that 4 out of 40 students did not have their enrollment status timely reported. Questioned Costs: None reported Context: The students did not notify the University of their intent not to return, so they were not identified until the start of the next semester. Cause: The University does not have a process in place to identify non-returning students timely. Effect: The NSLDS system is not updated with the student information which can cause over awarding should the student transfer to another institution and the students may not properly enter the repayment period. Repeat Finding: Yes Recommendation: We recommend the Institute review its reporting procedures to ensure that students’ statuses are accurately and timely reported to NSLDS as required by regulations. Views of Responsible Officials: There is no disagreement with the audit finding.

Federal Agency: Department of Education Federal Program Title: Student Financial Assistance Cluster Assistance Listing Number: 84.038, 84.268, 84.033, 84.007, 84.063, 84.268, 93.264 Award Period: July 1, 2023 through June 30, 2024 Type of Finding: • Significant Deficiency in Internal Control Over Compliance • Other Matter Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 674.19(e) states that Institutions must retain original, true and exact copies of promissory and master promissory notes (MPN), repayment records, and cancellation and deferment requests for each Perkins loan made. An original electronically signed MPN must be retained by the institution for three years after all the loans made on the MPN are satisfied. Condition: During our testing, we noted for 3 out of 49 Perkins files tested, the MPN was not retained on file. These files were paid in full and the original MPN was sent to the borrower with the paid in full communication. Questioned Costs: None reported Context: The MPNs for the three students were not kept for at least three years as required by the regulation. Cause: The loans were paid in full, and the University was not aware of the requirement to retain a copy of the MPN for at least three years after the loan was satisfied. Effect: The University was not in compliance with the Perkins recordkeeping regulations. Repeat Finding: Yes Recommendation: We recommend the University implement a procedure moving forward to ensure that all necessary MPN’s are retained for at least three years after payment in accordance with the federal regulation. Views of Responsible Officials: There is no disagreement with the audit finding.

Federal Agency: Department of Education Federal Program Title: Student Financial Assistance Cluster Assistance Listing Number: 84.038, 84.268, 84.033, 84.007, 84.063, 84.268, 93.264 Award Period: July 1, 2023 through June 30, 2024 Type of Finding: • Significant Deficiency in Internal Control Over Compliance • Other Matter Criteria or Specific Requirement: The Gramm-Leach-Bliley Act (GLBA) requires financial institutions to explain their information-sharing practices to their customers and to safeguard sensitive data (16 CFR 314). Institutions are required to develop, implement, and maintain a comprehensive information security program that is written in one or more readily accessible parts. The regulations require the written information security program to include nine elements for institutions with 5,000 or more customers, (16 CFR 314.3(a)). The written information security program (WISP) for institutions with fewer than 5,000 customers must address seven elements (16 CFR 314.3(a) and 16 CFR 314.6). The elements that an institution must address in its written information security program are at 16 CFR 314.4. At a minimum, the institution’s written information security program must address the implementation of the minimum safeguards identified in 16 CFR 314.4(c)(1) through (8) including: Assess apps developed by the institution. In addition, the written security program provides for the institution to regularly test or otherwise monitor the effectiveness of the safeguards it has implemented (16 CFR 314.4(d)). Condition: Under a University’s Program Participation Agreement with the Department of Education and the Gramm-Leach-Bliley Act, schools must protect student financial aid information, with particular attention to information provided to institutions by the Department or otherwise obtained in support of the administration of the federal student financial aid programs. Questioned Costs: None reported Context: During our audit procedures, it was noted that the University’s Written Information Security Program was not evaluated and adjusted based on monitoring results, risk assessments and penetration tests within the audit period. Cause: The University has not created appropriate policies that address all GLBA Safeguard Rules. Effect: The students’ personal information could be vulnerable. Repeat Finding: Yes Recommendation: We recommend that the University review each element of GLBA to ensure compliance with all necessary requirements. Views of Responsible Officials: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Health and Human Services Federal Program Title: COVID-19: Provider Relief Fund Assistance Listing Number: 93.498 Award Period: Payments received between April 10, 2020 to June 30, 2020 Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: 2 CFR Section 200.303 requires nonfederal entities receiving federal awards to establish and maintain internal controls designed to reasonably ensure compliance with federal statutes, regulations, and terms and conditions of the federal award. These controls should be designed and implemented to ensure that only allowable costs are reimbursed. Condition: During our testing, we noted that there was insufficient third-party documentation to support a transaction that was charged to this grant. Questioned costs: $229. Context: For one (1) of sixty (60) transactions selected for testing there was insufficient documentation to support the existence of the expense. Documentation provided was limited to internal email correspondence. Cause: Due to turnover in the culinary and finance departments, documentation to support the actual cost of this transaction was misplaced and could not be located by other personnel. Effect: The amount which was reimbursed by the Provider Relief Fund may be different from the actual cost incurred. Repeat Finding: No. Recommendation: We recommend that management design controls to ensure that all reimbursable transactions have a sufficient level of supporting documentation and that it can be easily located and accessed by the appropriate current and future individuals at the Corporations. Views of responsible officials: There is no disagreement with the audit finding.