CLARKE UNIVERSITY OF DUBUQUE, IOWANon-Profit

Student Financial Assistance Program Cluster – Department of Education Federal Financial Assistance Listing #84.268 Federal Direct Student Loans - 2024/2025 P268K251430 Federal Financial Assistance Listing #84.063 Federal Pell Grant Program - 2024/2025 P063P241430 Special Tests & Provisions: Return of Title IV Funds Material Weakness in Internal Control over Compliance and Noncompliance not Considered Material Criteria: The unearned amount of Title IV assistance to be returned is calculated by subtracting the amount of Title IV assistance earned by the student from the amount of Title IV aid that was disbursed to the student as of the date of the institution’s determination that the student withdrew (34 CFR 668.22(e)). Condition: Two instances were identified where the amount of funds to be returned was not remitted correctly, and two instances were identified where the funds were returned in the correct amount, but not timely. Cause: The University did not have a formal, documented control process to ensure all students who withdrew from courses had a return of Title IV calculation completed accurately and timely or a review of the return of Title IV calculation that was completed to ensure accuracy and reasonableness. Effect: Without a formal process to document the completion and review of return of Title IV calculations, there is a possibility that the calculation could be incorrect or not completed, and funds returned could be incorrect or not returned when required to be. Questioned Costs: None reported Context/Sampling: Of the 17 students who had an R2T4 calculation performed, 6 students were tested. Repeat Finding from Prior Years: Yes, prior year finding 2024-001 Recommendation: The University should review its established formal process and controls to ensure that a return of Title IV calculation is completed and documented for all withdrawn students and that the review process is also documented. Views of Responsible Officials: Management agrees. Management’s complete response can be found in the separately issued corrective action plan.

Student Financial Assistance Program Cluster – Department of Education Federal Financial Assistance Listing #84.268 Federal Direct Student Loans - 2024/2025 P268K251430 Federal Financial Assistance Listing #84.063 Federal Pell Grant Program - 2024/2025 P063P241430 Special Tests & Provisions: Enrollment Reporting Material Weakness in Internal Control over Compliance and Noncompliance not Considered Material Criteria: A student’s enrollment status determines eligibility for in-school status, deferment, and grace periods, as well as for the payment of interest subsidies to federal direct loan program loan holds by Education Department. Reporting in a timely and accurate manner is critical for effective management of the programs. An institution must submit student status changes to the National Student Clearing House, no later than 60 days after the Institution’s Determination Date. In addition, the enrollment effective date reported to the National Student Clearing House should be the same as the student’s last date of attendance for withdrawals. Condition: Fourteen instances were noted where enrollment status reported to the National Student Clearing House was not the same as the student’s actual enrollment status. Cause: The University changed the required credit hours for graduate students to be considered full time. The old requirement was used in the calculation of enrollment status to be submitted to National Student Clearing House instead of the new requirement. The University also did not include the intersession course in its calculation of enrollment status for the Spring semester to be submitted to National Student Clearing House. Effect: The enrollment status reported to the National Student Clearing House was not reflective of the student’s actual enrollment status. Questioned Costs: None Context/Sampling: Non-statistical sampling was performed. Fourteen instances were identified in 60 students tested. Over 250 students had status changes during the year. Repeat Finding from Prior Years: No Recommendation: The University should implement controls to ensure student status changes are correctly processed in the National Student Clearing House. Views of Responsible Officials: Management agrees. Management’s complete response can be found in the separately issued corrective action plan.

Student Financial Assistance Program Cluster – Department of Education Federal Financial Assistance Listing #84.268 Federal Direct Student Loans - 2023/2024 P268K241430 Federal Financial Assistance Listing #84.063 Federal Pell Grant Program - 2023/2024 P063P231430 Special Tests & Provisions: Return of Title IV Funds Material Weakness in Internal Control over Compliance Criteria: The unearned amount of Title IV assistance to be returned is calculated by subtracting the amount of Title IV assistance earned by the student from the amount of Title IV aid that was disbursed to the student as of the date of the institution’s determination that the student withdrew (34 CFR 668.22(e)). Condition: One instance was identified where there was no documented return of Title IV calculation, and fourteen instances were identified where there was no documented review of the return of Title IV calculation. Cause: The University did not have a formal, documented control process to ensure all students who withdrew from courses had a return of Title IV calculation completed or a review of the return of Title IV calculation that was completed to ensure accuracy and reasonableness. Effect: Without a formal process to document the completion and review of return of Title IV calculations, there is a possibility that the calculation could be incorrect or not completed and funds returned could be incorrect or not returned when required to be. Questioned Costs: None reported Context/Sampling: Of the 112 students withdrawn during the year, 22 students were tested. Repeat Finding from Prior Years: Yes, prior year finding 2023-003 Recommendation: The University should review its establish a formal process and controls to ensure that a return of Title IV calculation is completed and documented for all withdrawn students and that the review process is also documented. Views of Responsible Officials: Management agrees. Management’s complete response can be found in the separately issued corrective action plan.

Student Financial Assistance Program Cluster – Department of Education Federal Financial Assistance Listing #84.268 Federal Direct Student Loans - 2023/2024 P268K241430 Federal Financial Assistance Listing #84.063 Federal Pell Grant Program - 2023/2024 P063P231430 Special Tests & Provisions: Return of Title IV Funds Material Weakness in Internal Control over Compliance Criteria: The unearned amount of Title IV assistance to be returned is calculated by subtracting the amount of Title IV assistance earned by the student from the amount of Title IV aid that was disbursed to the student as of the date of the institution’s determination that the student withdrew (34 CFR 668.22(e)). Condition: One instance was identified where there was no documented return of Title IV calculation, and fourteen instances were identified where there was no documented review of the return of Title IV calculation. Cause: The University did not have a formal, documented control process to ensure all students who withdrew from courses had a return of Title IV calculation completed or a review of the return of Title IV calculation that was completed to ensure accuracy and reasonableness. Effect: Without a formal process to document the completion and review of return of Title IV calculations, there is a possibility that the calculation could be incorrect or not completed and funds returned could be incorrect or not returned when required to be. Questioned Costs: None reported Context/Sampling: Of the 112 students withdrawn during the year, 22 students were tested. Repeat Finding from Prior Years: Yes, prior year finding 2023-003 Recommendation: The University should review its establish a formal process and controls to ensure that a return of Title IV calculation is completed and documented for all withdrawn students and that the review process is also documented. Views of Responsible Officials: Management agrees. Management’s complete response can be found in the separately issued corrective action plan.

Student Financial Assistance Program Cluster – Department of Education Federal Financial Assistance Listing #84.038 Federal Perkins Loan Program Federal Financial Assistance Listing #84.033 Work‐Study Program ‐ 2022/2023 P063P201430 Reporting Significant Deficiency in Internal Control over Compliance Criteria: 34 CFR 673.3 requires institutions complete the Fiscal Operations Report and Application to Participate (FISAP) to participate in the Federal Perkins Loan Program. The Fiscal Operations Report includes the University’s financial information from the previous award year. Condition: Certain amounts within the FISAP filed during fiscal year 2022 FISAP were reported incorrectly in Part III, Section B, Line 13 and in Part VI, Section A, Lines 1‐23, columns e and f. Cause: The University recorded the first line noted above as the cumulative total instead of only the amount that related to the year ended May 31, 2022. The federal work‐study numbers included other student workers paid with nonfederal funds. Effect: Information reported on the FISAP was incorrect. Questioned Costs: None Context/Sampling: Key line items within the FISAP report were tested as required by the OMB Compliance Supplement. No statistical sampling was performed. Repeat Finding from Prior Years: Yes Recommendation: The University should review current processes to ensure that line items reported are accurate. The FISAP review process should include a detail review by an individual independent from the preparer to verify the numbers reported. Views of Responsible Officials: Management agrees. Management’s complete response can be found in the separately issued corrective action plan.

Student Financial Assistance Program Cluster – Department of Education Federal Financial Assistance Listing #84.268 Federal Direct Student Loans ‐ 2022/2023 P268K211430 Federal Financial Assistance Listing #84.063 Federal Pell Grant Program ‐ 2022/2023 P063P201430 Special Tests & Provisions: Return of Title IV Funds Material Weakness in Internal Control over Compliance Criteria: The unearned amount of Title IV assistance to be returned is calculated by subtracting the amount of Title IV assistance earned by the student from the amount of Title IV aid that was disbursed to the student as of the date of the institution’s determination that the student withdrew (34 CFR 668.22(e)). Condition: Eight instances were identified where there was no documented control over the Return of Title IV calculation. Cause: The University did not have a documented control over all of the Return of Title IV calculations. Effect: Without a secondary review and approval, there is a possibility that the Return of Title IV calculations could be incorrect. Questioned Costs: None Context/Sampling: Of the 16 students in which a Return of Title IV funds were calculated, 3 were tested. There were also 9 additional students that were tested based on a population of all withdrawn students or 46 students. The amount tested was $60,000 of the total population of funds received of $299,000. Repeat Finding from Prior Years: Yes Recommendation: The University should review its current controls over Return of Title IV calculations and ensure those controls are properly documented. Views of Responsible Officials: Management agrees. Management’s complete response can be found in the separately issued corrective action plan.

Student Financial Assistance Program Cluster – Department of Education Federal Financial Assistance Listing #84.268 Federal Direct Student Loans ‐ 2022/2023 P268K211430 Federal Financial Assistance Listing #84.063 Federal Pell Grant Program ‐ 2022/2023 P063P201430 Special Tests & Provisions: Verification Significant Deficiency in Internal Control over Compliance Criteria: The University is required to verify information in student aid applications selected by the Department of Education and the verified applications were in compliance with the verification requirements. Condition: Four instances were identified where there was no documented control over student verification. Cause: The University did not have a documented control over all of student verification. Effect: Without a secondary review and approval, there is a possibility that data corrections as a result of student verification could be incorrect. Questioned Costs: None Context/Sampling: Of the 22 students in which required student verification, 4 were tested. Repeat Finding from Prior Years: No Recommendation: The University should review its current controls over student verification and ensure those controls are properly documented. Views of Responsible Officials: Management agrees. Management’s complete response can be found in the separately issued corrective action plan.

Student Financial Assistance Program Cluster – Department of Education Federal Financial Assistance Listing #84.268 Federal Direct Student Loans ‐ 2022/2023 P268K211430 Federal Financial Assistance Listing #84.063 Federal Pell Grant Program ‐ 2022/2023 P063P201430 Special Tests & Provisions: Enrollment Reporting Significant Deficiency in Internal Control and Noncompliance Criteria: A student’s enrollment status determines eligibility for in‐school status, deferment, and grace periods, as well as for the payment of interest subsidies to federal direct loan program loan holds by Education Department. Reporting in a timely and accurate manner is critical for effective management of the programs. An institution must submit student status changes to the National Student Clearing House, no later than 60 days after the Institution’s Determination Date. In addition, the enrollment effective date reported to the National Student Clearing House should be the same as the student’s last date of attendance for withdrawals. Condition: One instance was noted where enrollment status reported to the National Student Clearing House was not the same as the student’s actual enrollment status. Cause: The University did not include the intersession course its calculation of enrollment status for the Spring semester to be submitted to National Student Clearing House. Effect: The enrollment status reported to the National Student Clearing House was not reflective of the student’s actual enrollment status. Questioned Costs: None Context/Sampling: Non‐statistical sampling was performed. One instance was identified in 60 students tested. 374 students had status changes during the year. Repeat Finding from Prior Years: Yes Recommendation: The University should implement controls to ensure student status changes are correctly processed in the National Student Clearing House. Views of Responsible Officials: Management agrees. Management’s complete response can be found in the separately issued corrective action plan.

COVID‐19 Higher Education Emergency Relief Funds – Institution Share – Department of Education Federal Financial Assistance Listing #84.425F Activities Allowed or Unallowed and Allowable Costs/Costs Principles Significant Deficiency in Internal Control Criteria: 2 CFR 200.303(a) establishes that the auditee must establish and maintain effective internal control over the federal award that provides assurance that they entity is managing the federal award in compliance with federal statutes, regulations, and conditions of the federal award. The University’s lost revenue calculation should be calculated on a reasonable and consistent method. Condition: The University’s calculated lost revenue was based on the average credit hours per semester prior to COVID‐19 as compared to fiscal years 2020, 2021 and 2022. There was a formula error in the credit hours used during COVID‐19 resulting in an understated amount of lost revenue from the intended methodology. Cause: The University’s internal control process did not detect that the lost revenue based on credit hours was improperly calculated. Effect: The lost revenue calculation was understated by approximately $750,000. Questioned Costs: None as the University’s lost revenue available only would have increased. Context/Sampling: Lost revenue for all applicable years and revenue streams were tested and reviewed. Repeat Finding from Prior Years: No Recommendation: The University should review controls in place to ensure lost revenue is calculated consistently. Views of Responsible Officials: Management agrees. Management’s complete response can be found in the separately issued corrective action plan.

2022-001 Student Financial Assistance Program Cluster ? Department of Education Federal Financial Assistance Listing/CFDA #84.038 Federal Perkins Loan Program Reporting Material Weakness in Internal Control over Compliance Criteria: 34 CFR 673.3 requires institutions complete the Fiscal Operations Report and Application to Participate (FISAP) to participate in the Federal Perkins Loan Program. The Fiscal Operations Report includes the University?s financial information from the previous award year. Condition: Certain amounts within the FISAP filed during fiscal year 2021 FISAP were reported incorrectly in Part III, Section C, Line 1.1 column (c). Cause: There was a clerical error when typing the number. Effect: Information reported on the FISAP was incorrect. Questioned Costs: None Context/Sampling: Key line items within the FISAP report were tested as required by the OMB Compliance Supplement. No statistical sampling was performed. Repeat Finding from Prior Years: Yes Recommendation: The University should review current processes to ensure that line items reported are accurate. The FISAP review process should include a detail review by an individual independent from the preparer to verify the numbers reported. Views of Responsible Officials: Management agrees. Management?s complete response can be found in the separately issued corrective action plan.

2022-002 Student Financial Assistance Program Cluster ? Department of Education Federal Financial Assistance Listing/CFDA #84.268 Federal Direct Student Loans - 2021/2022 P268K211430 Special Tests & Provisions: Return of Title IV Funds Material Weakness in Internal Control over Compliance and Noncompliance Criteria: The unearned amount of Title IV assistance to be returned is calculated by subtracting the amount of Title IV assistance earned by the student from the amount of Title IV aid that was disbursed to the student as of the date of the institution?s determination that the student withdrew (34 CFR 668.22(e)). Condition: One instance was identified where the Return of Title IV calculation was not completed. Another instance was identified where the Return of Title IV calculation was completed using the incorrect withdrawal date. Additionally, one instance was identified where the Return of Title IV calculation was completed, but the funds were returned late. Cause: The University did not perform a Return of Title IV calculation for students who completed an interim course and then withdrew during the spring semester. The incorrect withdrawal date was used to calculate the amount of aid to be returned. Process to ensure that funds were submitted in a timely manner were not followed. Effect: The University should return an additional $6,506 based on the corrected Return of Title IV calculations. Questioned Costs: None reported over $25,000 Context/Sampling: Of the 30 students in which a Return of Title IV funds were calculated, 11 were tested. There were also 14 additional students that were tested based on a population of all withdrawn students or 78 students. The amount tested was $25,000 of the total population of funds received of $416,000. Repeat Finding from Prior Years: Yes Recommendation: The University should review its current controls over Return of Title IV calculations to ensure that errors are detected and corrected timely. Views of Responsible Officials: Management agrees. Management?s complete response can be found in the separately issued corrective action plan.

2022-003 Student Financial Assistance Program Cluster ? Department of Education Federal Financial Assistance Listing/CFDA #84.268 Federal Direct Student Loans - 2020/2021 P268K211430 Federal Financial Assistance Listing/CFDA #84.063 Federal Pell Grant Program - 2020/2021 P063P201430 Reporting? Common Origination and Disbursement System Material Weakness in Internal Control over Compliance and Noncompliance Criteria: An institution must submit Pell Grant, Iraq and Afghanistan Service Grant, Direct Loan, and TEACH Grant disbursement records to COD, no later than 15 days after making the disbursement or becoming aware of the need to adjust a previously reported disbursement. In accordance with 34 CFR 668.164(a), Title IV, HEA program funds are disbursed on the date that the institution: (a) credits those funds to a student?s account in the institution?s general ledger or any subledger of the general ledger; or (b) pays those funds to a student directly. Title IV, HEA program funds are disbursed even if an institution uses its own funds in advance of receiving program funds from the Department. Condition: Three instances were noted where Title IV funds were applied to the student account but were not processed in COD within the required timeframe. Another two instances were noted where Title IV funds were applied to the student account but were not processed in COD at all. Cause: There was no process in place to monitor and correct denials from the COD system in a timely manner. Effect: COD data was not reflective of the date the aid was applied to the student account. Questioned Costs: None Context/Sampling: Non-statistical sampling was performed. Five instances were identified in 60 students tested. 290 students received Pell disbursements and 669 students received direct loan disbursements. Repeat Finding from Prior Years: Yes Recommendation: The University should implement controls to ensure loans applied to student accounts are processed in COD within required time frame and monitor and address denials in a timely manner. Views of Responsible Officials: Management agrees. Management?s complete response can be found in the separately issued corrective action plan.

2022-004 Student Financial Assistance Program Cluster ? Department of Education Federal Financial Assistance Listing/CFDA #84.268 Federal Direct Student Loans - 2021/2022 P268K211430 Federal Financial Assistance Listing/CFDA #84.063 Federal Pell Grant Program - 2021/2022 P063P201430 Special Tests & Provisions: Enrollment Reporting Significant Deficiency in Internal Control Criteria: A student?s enrollment status determines eligibility for in-school status, deferment, and grace periods, as well as for the payment of interest subsidies to federal direct loan program loan holds by Education Department. Reporting in a timely and accurate manner is critical for effective management of the programs. An institution must submit student status changes to the National Student Clearing House, no later than 60 days after the Institution?s Determination Date. In addition, the enrollment effective date reported to the National Student Clearing House should be the same as the student?s last date of attendance for withdrawals. Condition: Two instances were noted where enrollment effective date reported to the National Student Clearing House as first effective was not the same as the student?s last date of attendance. Cause: The University did not submit the correct last date of attendance to the National Student Clearing House. Effect: Status The enrollment effective date reported to the National Student Clearing House was not reflective of the student?s last date of attendance. Questioned Costs: None Context/Sampling: Non-statistical sampling was performed. Two instances were identified in 60 students tested. 450 students had status changes during the year. Repeat Finding from Prior Years: No Recommendation: The University should implement controls to ensure student status changes are correctly processed in the National Student Clearing House. Views of Responsible Officials: Management agrees. Management?s complete response can be found in the separately issued corrective action plan.

2021-001 Student Financial Assistance Program Cluster ? Department of Education Federal Financial Assistance Listing/CFDA #84.007 Federal Supplemental Educational Opportunity Grants ? 2020/2021 P007A201416 Federal Financial Assistance Listing/CFDA #84.033 Federal Work-Study Program - 2020/2021 P033A201416 Reporting Significant Deficiency in Internal Control over Compliance Criteria: 34 CFR 673.3 requires institutions complete the Fiscal Operations Report and Application to Participate (FISAP) to participate in the Federal Work Study or Federal Supplemental Education Opportunity Grants. The Fiscal Operations Report includes the University?s financial information from the previous award year. Condition: Certain amounts within the FISAP filed during fiscal year 2020 FISAP were reported incorrectly in Part VI, Section A, Line 26 between columns (c) through (f). Cause: There was an oversight for certain line items in reporting FSEOG recipients and funds in the Federal Work Study recipients and funds columns. Effect: Information reported on the FISAP was incorrect. Questioned Costs: None Context/Sampling: Key line items within the FISAP report were tested as required by the OMB Compliance Supplement. No statistical sampling was performed. Repeat Finding from Prior Years: No Recommendation: The University should review current processes to ensure that documents supporting the FISAP exist and that line items reported are accurate. The FISAP review process should include a detail review by an individual independent from the preparer to verify the numbers reported. Views of Responsible Officials: Management agrees. Management?s complete response can be found in the separately issued corrective action plan.

2021-002 Student Financial Assistance Program Cluster ? Department of Education Federal Financial Assistance Listing/CFDA #84.268 Federal Direct Student Loans - 2020/2021 P268K211430 Federal Financial Assistance Listing/CFDA #84.063 Federal Pell Grant Program - 2020/2021 P063P201430 Reporting? Common Origination and Disbursement System Significant Deficiency in Internal Control over Compliance Criteria: An institution must submit Pell Grant, Iraq and Afghanistan Service Grant, Direct Loan, and TEACH Grant disbursement records to COD, no later than 15 days after making the disbursement or becoming aware of the need to adjust a previously reported disbursement. In accordance with 34 CFR 668.164(a), Title IV, HEA program funds are disbursed on the date that the institution: (a) credits those funds to a student?s account in the institution?s general ledger or any subledger of the general ledger; or (b) pays those funds to a student directly. Title IV, HEA program funds are disbursed even if an institution uses its own funds in advance of receiving program funds from the Department. Condition: One instance was noted where Title IV funds were applied to the student account but were not processed in COD within the required timeframe. Cause: There was a hold placed on the student that prevented the funds from being applied in COD timely. Effect: COD data was not reflective of the date the aid was applied to the student account. Questioned Costs: None Context/Sampling: Non-statistical sampling was performed. One instance was identified in 68 students tested. 30 days elapsed between the disbursement date and the date processed in COD. 254 students received Pell disbursements and 682 students received direct loan disbursements. Repeat Finding from Prior Years: No Recommendation: The University should implement controls to ensure loans applied to student accounts are processed in COD within required time frame. Views of Responsible Officials: Management agrees. Management?s complete response can be found in the separately issued corrective action plan.

2021-003 Student Financial Assistance Program Cluster ? Department of Education Federal Financial Assistance Listing/CFDA #84.063 Federal Pell Grant Program - 2020/2021 P063P201430 Federal Financial Assistance Listing/CFDA #84.007 Federal Supplemental Educational Opportunity Grants ? 2020/2021 P007A201416 Eligibility Significant Deficiency in Internal Control over Compliance Criteria: 34 CFR 690.62(a) states that the amount of a student?s Pell Grant for an academic year is based upon the payment and disbursement schedules published by the Secretary for each Award year. 34 CFR 676.20 (a) states that an FSEOG may not be awarded for a full academic year that is less than $100 (34 CFR 676.20(a)(1)) or more than $4,000 (34 CFR 676.20(a)(2)). The limit of $4,000 may be increased to $4,400 in the instance the student is participating in a program of study abroad approved for credit by the home institution (34 CFR 676.20 (c)). Condition: One instance was identified where the student received more than the maximum allowable SEOG amount, and one instance was identified where the student was awarded Pell based on the 2019-2020 Pell Payment Schedule published by the Department of Education. Cause: Controls failed to detect and correct two instances where the student was awarded improper aid. Effect: Two students received federal assistance of an incorrect amount. Questioned Costs: $695 for Pell was under-awarded and $301 for FSEOG was over-awarded. Context/Sampling: Non-statistical sampling was performed. Two separate issues were identified in the sample of 68 students selected. 254 students received Pell awards of $1,153,648 and 116 students received FSEOG of $190,366. Repeat Finding from Prior Years: No Recommendation: The University should review its current controls to ensure that awards within the limits established for the type of aid awarded. Views of Responsible Officials: Management agrees. Management?s complete response can be found in the separately issued corrective action plan.

2021-004 Student Financial Assistance Program Cluster ? Department of Education Federal Financial Assistance Listing/CFDA #84.268 Federal Direct Student Loans - 2020/2021 P268K211430 Special Tests & Provisions: Return of Title IV Funds Significant Deficiency in Internal Control over Compliance Criteria: The unearned amount of Title IV assistance to be returned is calculated by subtracting the amount of Title IV assistance earned by the student from the amount of Title IV aid that was disbursed to the student as of the date of the institution?s determination that the student withdrew (34 CFR 668.22(e)). Condition: One instance was identified where the Return of Title IV calculation was completed using the incorrect withdrawal date. Cause: The incorrect withdrawal date was used to calculate the amount of aid to be returned. Effect: The University should return an additional $1,918 based on the corrected withdrawal date. Questioned Costs: $1,918 Context/Sampling: All students in which a Return of Title IV funds were calculated. The University returned funds totaling $57,884 for 10 students. Repeat Finding from Prior Years: No Recommendation: The University should review its current controls over Return of Title IV calculations to ensure that errors are detected and corrected timely. Views of Responsible Officials: Management agrees. Management?s complete response can be found in the separately issued corrective action plan.

2021-005 Student Financial Assistance Program Cluster ? Department of Education Federal Financial Assistance Listing/CFDA #84.033 Federal Work-Study Program - 2020/2021 P033A201416 Special Tests & Provisions: Disbursements to or on Behalf of Students Significant Deficiency in Internal Control over Compliance Criteria: The University is required to maintain internal control to ensure the student?s wages are earned when the work is performed, and the student is paid at least once per month. The federal share must be paid by check or similar instrument the student can cash on his or her endorsement, or as authorized by the student, by crediting FWS funds to a student?s account or by EFT to a bank account designated by the student. The institution may only credit the account for tuition, fees, institutional room and board, and other institution-provided goods and services (34 CFR 675.16). Condition: The spreadsheet utilized by the University included wages paid to a student, but there was no payment in the payroll system or supporting timesheet indicating that the student performed work. Cause: There were data entry errors made when compiling the spreadsheet. Effect: Failure to keep accurate records could result in compliance issues. Questioned Costs: None. The input errors did not result in incorrect aid being awarded. Context/Sampling: Non-statistical sampling was performed. 9 of the 68 students selected for purposes of eligibility testing received Federal Work Study. The University disbursed $83,358 of federal work study to 96 students. Repeat Finding from Prior Years: No Recommendation: The University should review its current controls over Federal Work Study tracking to ensure that spreadsheet is compare to data within the payroll system for accuracy. Views of Responsible Officials: Management agrees. Management?s complete response can be found in the separately issued corrective action plan.

2021-006 Strengthening Institutions Program ? Department of Education, # P031A090106 Federal Financial Assistance Listing/CFDA #84.031A P031A090106 Program Income Material Weakness in Internal Control over Compliance and Material Noncompliance Criteria: The University may withdraw and spend up to 50 percent of the total aggregated endowment fund income earned prior to the date of expenditures. The University may not withdraw or spend the remaining 50 percent of the endowment fund income without Department of Education permission if 34 CFR 628.45 (b) conditions are met. 34 CFR 628.45(c) requires repayment to the Department of Education of amounts spent in excess of 50 percent of the endowment fund income. Condition: The University spent more than 50 percent of the endowment fund income without explicit permission from the federal agency. Cause: The University had proposed a spending rate reduction plan to the Department of Education in 2017, but never received approval or acknowledgement of the spending plan reduction from the Department of Education. The University relied on verbal guidance at that time. Effect: The University continued to make quarterly distributions and failed to comply with 34 CFR 628.45. Questioned Costs: $19,436 was withdrawn from endowment fund income in fiscal year 2021. Cumulative withdraws in excess of 50 percent of endowment fund income are $66,971 as of May 31, 2021. Context/Sampling: Sampling was not used. Repeat Finding from Prior Years: No Recommendation: The University should contact the federal agency for repayment guidance related to the amount withdrawn in excess of 50 percent of endowment fund income and adjust future distributions from the endowment fund to comply with 34 CFR 628.46. Views of Responsible Officials: Management agrees. Management?s complete response can be found in the separately issued corrective action plan.

2020-001 Department of Education CFDA #84.268 Federal Direct Student Loan Program #84.268 Federal Direct PLUS Loan Program #84.007 Federal Supplemental Education Opportunity Grants #84.033 Federal Work-Study Program #84.038 Federal Perkins Loan Program #84.063 Federal Pell Grant Program #84.379 TEACH #93.264 Nurse Faculty Loan Program #93.364 Nursing Student Loans Special Tests and Provisions: Gramm-Leach-Bliley Act ? SFA ? Title IV Programs Significant Deficiency in Internal Control Over Compliance Criteria: The institution is required to follow the GRAMM-Leach-Bliley-Act since they participate in the Title IV Education Assistance Program. Schools are required to 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 (16 CFR 314.3; HEA 483(a)(3)(E) and HEA 485B(d)(2)). The schools are required to 1) designate an individual to coordinate the information security program 2) perform a risk assessment and 3) document the safeguards for each risk identified. Condition: The University did not formally document the identified risks and the associated safeguards for each of the risks identified. Cause: While risk assessments are periodically performed, there is not a formal process in place to document the University?s mitigation plans and associated safeguards in response to the risks identified. Effect: A lack of formal documentation of identified risks and mitigation plans related to safeguards to be implemented may result in a breakdown of controls which may allow unauthorized access to sensitive student information. Questioned Costs: N/A Context/Sampling: N/A Repeat Finding from Prior Year: No Recommendation: The University should formally document the identified risks and safeguards implemented in response to its risk assessments on an annual basis. Additionally, it is recommended that the documentation be reviewed by executive management and presented to the Board of Trustees or oversight committee. Views of Responsible Officials: The University performs regular risk assessments and implements safeguards in response, but has not formally documented this process. The University will document assessment results and safeguards implemented going forward.

Department of Education CFDA #84.268 Federal Direct Student Loan Program Award # P268K191430 Special Tests and Provisions: Disbursements to or on behalf of students Significant Deficiency in Internal Control Over Compliance Criteria: The institution must notify the student, or parent, in writing of (1) the date and amount of the disbursement; (2) the student?s right, or parent?s right, to cancel all or a portion of that loan or loan disbursement and have the loan proceeds returned to the holder of that loan or the TEACH Grant payments returned to ED; and (3) the procedure and time by which the student or parent must notify the institution that he or she wishes to cancel the loan, TEACH Grant, or TEACH Grant disbursement. The notification requirement for loan funds applies only if the funds are disbursed by EFT payment or master check (34 CFR 668.165). Institutions that implement an affirmative confirmation process (as described in 34 CFR 668.165 (a)(6)(i)) must make this notification to the student or parent no earlier than 30 days before, and no later than 30 days after, crediting the student?s account at the institution with Direct Loan or TEACH Grants. Institutions that do not implement an affirmative confirmation process must notify a student no earlier than 30 days before, but no later than 7 days after, crediting the student?s account and must give the student 30 days (instead of 14) to cancel all or part of the loan. Condition: A borrower received notification of the date and amount of the disbursement and their right to cancel the loan. However, the borrower declined the aid but was still disbursed the aid. Cause: The Financial Aid office has a process in place where students email the office to decline the aid. This does not automatically notify the system but requires staff to monitor and respond to the email. In this situation, the request did not get manually processed in the system. Effect: The University could improperly disburse aid which could lead to compliance issues regarding the disbursed aid. Questioned Costs: $2,000 Context/Sampling: We reviewed a nonstatistical sample of 60 students receiving direct loans out of 773 (approximately $715,000 of approximately $10,062,000 of direct loans) noting 2 improperly disbursed loans totaling $2,000. Repeat Finding from Prior Year: No Recommendation: The University should review its current processes to ensure all students who decline aid properly do not receive a disbursement or have their disbursement returned. Views of Responsible Officials: Management agrees with the finding.

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