CALVARY UNIVERSITYHigher Education

Reporting Federal Agency: U.S. Department of Education; Office of Federal Student Aid Pass through Entity: Not Applicable Program Name: Federal Direct Student Loan Program ALN and Program Expenditure: 84.268 ($561,518) Award Number: P268K251726 Federal Award Year: July 1, 2024 to June 30, 2025 Questioned Costs: N/A Condition Found: The bi-monthly National Student Loan Database System (“NSLDS”) Enrollment Reporting Summary Reports were not updated and returned to NSLDS during the year ended June 30, 2025. Therefore, student enrollment status changes were not reported timely to NSLDS. Criteria: NSLDS informs loan servicers of changes in a student’s enrollment status that indicate when the repayments or interest accrual begins and ends. The date a student enrolls, withdraws, graduates, or drops below half-time status should be reported accurately. The University is required to report the change in a student’s enrollment status to NSLDS within sixty days of the change.Cause:The University staff struggled to gain access to the NSLDS system and file the reports. A report was able to be filed in July 2025. However, the CFO had to manually enter all of the changes and effective dates. Possible Asserted Effect:The loan services were not aware of the correct deferral, repayment, and interest calculation dates. Repeat Finding: See Finding 2024-001 for a similar finding in the prior year. Statistical Sampling: The sample was not intended to be, and was not, a statistically valid sample. Recommendation: The NSLDS enrollment status roster report should be filed every approximately every sixty days. Manual adjustments to an individual student’s enrollment status should be input as needed. Management Response: Management agrees with the auditors’ finding and their recommendation. The CFO has worked with the registrar and other University personnel to file the NSLDS reports. Eventually, the CFO updated enrollment status manually. A report was filed in July 2025. Going forward, the NSLDS enrollment status roster reports will be filed timely. If there is a technology issue, enrollment status changes will be input manually by University personnel.

Federal Agency:U.S. Department of Education; Office of Federal Student Aid Pass through Entity: Not Applicable Program Name: Federal Direct Student Loan Program Federal PELL Grant ALN and Program Expenditure: 84.268 ($561,518) 84.063 ($423,936) Award Number P268K251726 P063P241726 Federal Award Year: July 1, 2024 to June 30, 2025 Questioned Costs: $902 Condition Found:The R2T4 calculations were incorrect for three of the fifteen students in our sample. All of the R2T4s prepared by the University were reviewed during our audit. The following details the errors for the students in question:For the first student: The last date of the semester used in the calculation was incorrect.Institutional charges were not included in the calculation. Funds were not returned within 45 days of the date the University determined the student withdrew. For the second student: A scheduled break of 5 days or more was not subtracted from the number of days in the semester. Funds were not returned within 45 days of the date the University determined the student withdrew .For the third student: The last date of the semester used in the calculation was incorrect. The amount of subsidized Federal Direct Loans that could have been disbursed used in the calculation was incorrect. Criteria:Per the Student Financial Aid Handbook, an institution must disburse any Title IV grant funds a student is due as part of the PWD within 45 days of the date the institution determined the student withdrew. Per the Student Financial Aid Handbook, any scheduled break of five days or more should be subtracted from the total number of days in the semester. If a student withdraws before a scheduled break, the break days are not subtracted from the number of days attended. The last date of the semester in the R2T4 calculation should be the date published in the academic calendar.Per the Student Financial Aid Handbook, the amount of aid that could have been disbursed should equal the amount that was awarded to the student unless Pell is adjusted for a module that was not begun. Federal Direct Loans must be originated to be included as aid that could have been disbursed. Per the Student Financial Aid Handbook, institutional charges include tuition and fees that were posted to the student’s account at the time of the withdraw.Cause:The University uses a third-party administrator to calculate R2T4s. The incorrect break days and last date of the semester were reported to the TPA. The remaining errors oversights during the R2T4 preparation process and were not caught by the TPA or University. Possible Asserted Effect:For the first student, the original R2T4 calculated stated that $2,858 of subsidized and unsubsidized Federal Direct Loans should be returned. Those funds were not returned within 45 days from the date the University withdrew. After the R2T4 was corrected, only $2,179 should have been returned. The student is due an additional $679 of subsidized Federal Direct Loans.For the second student, the original R2T4 calculated stated that $312 of Federal Pell Grant funds should be returned. Those funds were not returned within 45 days from the date the University withdrew. After the R2T4 was corrected, only $309 should have been returned. The student is due an additional $3 of Federal Pell Grant funds. The third student is due an additional $220 of Federal Pell Grant funds. Repeat Finding: There was not a similar finding in the previous year. Statistical Sampling: The sample was not intended to be, and was not, a statistically valid sample. Recommendation: The CFO should work with the TPA to correct the R2T4 calculations make the necessary changes to the student awards detailed in the Possible Asserted Effect section. Procedures should be improved with TPA and University to ensure the R2T4 are returned timely. Management Response:Management agrees with the auditors’ finding and their recommendation. The CFO is working with the TPA to recalculate the R2T4s. The necessary changes detailed in the Possible Asserted Effect section were made in November 2025.

Federal Agency:U.S. Department of Education; Office of Federal Student AidPass throughEntity:Not ApplicableProgram Name:Federal Work StudyALN and Program Expenditure:84.033 ($10,000)Award Number:P033A246494 Federal Award Year:July 1, 2024 to June 30, 2025 Questioned Costs:N/A Condition Found:Seven percent (7%) of Federal Work Study funds were not spent on students working in community service jobs. Criteria:Institutions that participate in the Federal Work Study program are required to spend 7% of Federal Work Study funds on wages for students working in community service jobs. Cause:The University had a student lined-up to work in a community service job. The student decided not to participate in the Federal Work Study program. The University could not find another student willing to work a community service job.Possible Asserted Effect:7% of the Federal Work Study funds were not spent on students working in community service jobs. Repeat Finding:There was not a similar finding in the prior year. Statistical Sampling:The sample was not intended to be, and was not, a statistically valid sample.Recommendation:The University should consider applying for waiver of the community service job requirement. The University could also work with the local school district or other agencies to identify community service jobs for students.Management Response:Management agrees with the auditors’ finding and their recommendation. The CFO will request a waiver for the 2025-2026 school year.

Federal Agency: U.S. Department of Education; Office of Federal Student Aid Pass through Entity: Not Applicable Program Name: Federal Direct Student Loan Program ALN and Program Expenditure: 84.268 ($528,346) Award Number: P268K241726 Federal Award Year: July 1, 2023 to June 30, 2024 Questioned Costs: N/A Condition Found: The bi-monthly National Student Loan Database System (“NSLDS”) Enrollment Reporting Summary Reports were not updated and returned to NSLDS during the year ended June 30, 2024. Therefore, student enrollment status changes were not reported timely to NSLDS. Criteria: NSLDS informs loan servicers of changes in a student’s enrollment status that indicate when the repayments or interest accrual begins and ends. The date a student enrolls, withdraws, graduates, or drops below half-time status should be reported accurately. The University is required to report the change in a student’s enrollment status to NSLDS within sixty days of the change. Cause: The former Financial Aid Director resigned in August 2023. NSLDS was updated on August 2, 2023 before the Financial Aid Director left the University. The Business Office took over several financial aid duties. The Business Office thought the third-party financial aid administrator was responsible for updating NSLDS. However, updating NSLDS was the responsibility of the University. Possible Asserted Effect: The loan services were not aware of the correct deferral, repayment, and interest calculation dates. Repeat Finding: There was not a similar finding in the previous year. Statistical Sampling: The sample was not intended to be, and was not, a statistically valid sample. Recommendation: The newly hired Financial Aid Director and business office staff should review and update the enrollment status, as necessary, for all students attending the University and receiving financial aid. The contract with the third-party administrator should be reviewed so the University understands which tasks they are responsible to complete. Management Response: Management agrees with the auditors’ finding and their recommendation. The Director of Financial Aid or business office staff will update the enrollment status for all students who obtained Federal Direct Student Loans from the University. The University will review its contract with their third-party financial aid administrator. The University will update their policies and procedures as needed.

Federal Agency: U.S. Department of Education; Office of Federal Student Aid Pass through Entity: Not Applicable Program Name: Federal Direct Student Loan Program Federal PELL Grant ALN and Program Expenditure: 84.268 ($528,346) 84.063 ($332,540) Award Number: P268K241726 P063P231726 Federal Award Year: July 1, 2023 to June 30, 2024 Questioned Costs: N/A Condition Found: The University has an adequate Satisfactory Academic Progress policy. Student GPAs and completion rates are reviewed at the end of each academic year. However, the University is not informing students when they are placed on financial aid suspension and how to appeal the decision. Criteria: The University is required to notify students of the financial aid ramifications of being placed on financial aid suspension, including the ability to appeal the decision and the steps that need to be taken to improve their GPA and/or completion percentage. Cause: The University issues academic suspension letters. However, the letters do not include the financial aid ramifications related to being placed on suspension. Possible Asserted Effect: The students were not aware that they were placed on financial aid suspension and thus ineligible to receive federal financial aid from the University. Repeat Finding: There was not a similar finding in the previous year. Statistical Sampling: The sample was not intended to be, and was not, a statistically valid sample. Recommendation: The Financial Aid Office staff should create a Financial Aid Suspension Letter outlining the financial aid ramifications related to being placed on suspension and include instructions on how to appeal the decision. Management Response: Management agrees with the auditors’ finding and their recommendation. The Business Office and the Director of Financial Aid is in the process of creating a Financial Aid Suspension Letter to notify students of the financial aid ramifications of being placed on financial aid suspension.

Condition Found: During our audit, we noted the following: The right-of-use asset and lease liability was not recorded. Repair and maintenance expenses were incorrectly capitalized. Grants given to students using HEERF funds was not correctly recorded. Allowance for uncollectible accounts receivable should have been adjusted. Criteria: The design and implementation of policies and procedures should be sufficient enough for the reconciliation of significant financial accounts and transaction classes to prevent and detect material misstatements in the financial statements. Cause: The end of year closing process was lacking the procedures necessary to identify the adjustments needed. Possible Asserted Effect: In fiscal year 2023, we proposed several adjustments to general ledger accounts. The potential effect could be significant to the financial statements since without these adjustments, the financial statements of the University would have been materially misleading. Repeat Finding :A similar finding was reported in the prior year’s audit as Finding 2022-001.Recommendation:We recommend that the University put in place necessary controls and procedures to ensure that all transactions, especially at year-end, are properly classified. Management Response: We will continue to increase the review of general ledger entries and strive to record all necessary adjustments prior to the beginning of the audit.  The accountant will review the prior year adjusting journal entries made to ensure that if similar adjustments are needed that they are made before the audit begins. In addition, the CFO will review the end of year trial balance to make sure the general ledger accounts are correct.

Condition Found: A Federal Direct Loan exit interview was not completed by, nor were instructions sent to, students on how to complete an exit interview when the students graduated from the University or dropped below a halftime enrollment status. This omission occurred for seven of the eighteen students in our sample. Criteria: Federal Direct Loan recipients must receive exit interview counseling. If in-person counseling is not completed, the University may mail written counseling materials to a student’s last known address. Cause: Federal Direct Loan exit counseling was not provided when students withdrew from the University or dropped below a halftime enrollment status. This was an oversight on the part of the financial aid office staff. Effect The students were not aware of their responsibilities related to the Federal Direct Loan program, including repayment options and when repayment on the loan begins. Repeat Finding: There was not a similar finding in the previous year. Statistical Sampling: The sample was not intended to be, and was not, a statistically valid sample. Recommendation: Federal Direct Loan exit interview information should be sent to the students in question. Procedures should be improved to ensure that Federal Direct exit interviews are completed or information is sent to a student when a student ceases attendance at the University or drops below a halftime enrollment status. Management Response: Federal Direct Loan exit interview information was sent to the students in question in August 2023. Procedures will be improved to ensure Federal Direct Loan exit interviews are completed or information is sent to students when they cease enrollment at the University.

FINDING 2022-001 ? Material Adjustments Condition Found: During the course of the audit for the University, we proposed journal entries to adjust accounts payable due to an amount owed at year-end to a vendor who was assisting with determining the employee retention credit among other expenses that should have been recorded as accounts payable, fixed assets for amounts that were originally expensed to repair and maintenance, and we also adjusted deferred revenue, scholarship expense, and grant income to the correct balances. Criteria: Based on professional standards, identification by an auditor of a material misstatement in the financial statements under audit that was not initially identified by the entity's internal control is a strong indicator of a material weakness. Cause: This occurred because the University did not identify and make all necessary adjustments to the financial statements before the audit began. Over the past several years, the number of adjustments we have had to make has been decreasing, and we applaud the accounting staff and management for this. We also understand that there were some extenuating circumstances. However, unfortunately, these circumstances do not rectify the situation of the trial balance not being correct when presented for audit. Possible Asserted Effect: Because the aforementioned adjustments would have materially misstated the statement of financial position and statement of activities, we believe that this matter is a material weakness in the controls and practices of the University. Repeat Finding: A similar finding was reported in the prior year?s audit as Finding 2021-001. Recommendation: We recommend that the University develop and implement procedures to properly record transactions before the records are submitted for audit. We understand from the accounting staff and management that changes have already occurred to rectify this going forward. Management Response: We will continue to increase the review of general ledger entries and strive to record all necessary adjustments prior to the beginning of the audit. Also, the processing flow of certain transactions has been changed so that the accounting department is the first to engage these transactions. Finally, an effort is being made to close the books monthly so that events are still fresh when that takes place.

FINDING 2022-002 ? Verification Federal Agency: U.S. Department of Education; Office of Federal Student Aid Pass through Entity: Not applicable Program Name: Federal Pell Grant Program ALN and Program Expenditure: 84.063 ($339,284) Award Number: P063P211726 Federal Award Year: July 1, 2021 to June 30, 2022 Questioned Costs: $300 Condition Found: The information on the verification worksheet and tax transcript for Parents? AGI, Parents? Taxes Paid, Parent 1 and 2 Earned Income, and Parents? Military/Clergy Housing Allowance did not agree to the amounts reported on the ISIR for one of the twenty-five students sampled. Criteria: If a student is in the V1 verification group, the following items must be verified: adjusted gross income, U.S. income taxes paid, untaxed portions of IRA distributions, untaxed portions or pensions, IRA deductions and payments, tax exempt interest income, education credits, household size, the number in college, SNAP benefits, and child support paid. If discrepancies are found when reviewing these documents and amounts, the information should be updated and the student?s financial aid eligibility should be recalculated. Cause: For the student in question, the financial aid office requested and collected the required documentation and information. However, the financial aid office did not make the necessary corrections to the parents income and recalculate the student?s financial aid eligibility. Possible Asserted Effect: The Expected Family Contribution could change which could cause an over or under award of federal aid, especially the Federal Pell Grant. The student in question received $300 of Federal Pell Grant funds that the student was not eligible to receive. Repeat Finding: There was not a similar finding in the previous year. Statistical Sampling: The sample was not intended to be, and was not, a statistically valid sample. Recommendation: The Financial Aid Office should correct the income items in question and recalculate the EFC. The new EFC and Pell award should be calculated. $300 in Pell Grant funds should be returned to the Department of Education. Management Response: The Financial Aid Office updated the income items and recalculated the EFC for the student in question. The amount of Pell the student was eligible to receive was calculated based on the new EFC. $300 was returned to the Department of Education in August 2022

FINDING 2022-003 ? Authorization to Hold Credit Balances Federal Agency: U.S. Department of Education; Office of Federal Student Aid Pass through Entity: Not applicable Program Name: Federal Pell Grant Program Federal Direct Loan Program Federal Supplemental Educational Opportunity Grant ALN and Program Expenditure: 84.063 ($339,284) 84.268 ($506,590) 84.007 ($ 10,703) Award Number: P063P211726 P268K211726 P007A216494 Federal Award Year: July 1, 2021 to June 30, 2022 Questioned Costs: $-0- Condition Found: For three of the twenty-five students in our sample, the University held Title IV credit balances for longer than fourteen days without written authorization. Criteria: An institution may not hold a credit balance, which is caused by federal student financial aid funds, on a student?s account for more than fourteen days without written authorization from the student. Cause: Miscommunication between the cashier, student financial aid office, and accounts payable clerk caused a delay with issuing the credit balance refund check to the student. Possible Asserted Effect: The Title IV credit balances were not returned timely to the students. Repeat Finding: There was not a similar finding in the previous year. Statistical Sampling: The sample was not intended to be, and was not, a statistically valid sample. Recommendation: The credit balances were returned to all three students in question before the end of the academic year. Communication should be improved between the offices involved in the disbursement process to ensure that credit balances are refunded timely. Management Response: The credit balances were returned to the students in question before the end of the academic year. Several changes in staffing have occurred. The financial aid office will follow-up with the cashier and accounts payable clerk to ensure that the credit balance refunds requested are processed timely.

NG 2021-001 ? Material Adjustments Condition Found: During the course of the audit for the University, we proposed journal entries to adjust accounts receivable, accounts payable, deferred income, unrealized appreciation/loss, sale of assets, and fixed assets. Criteria: Based on professional standards, identification by an auditor of a material misstatement in the financial statement under audit that was not initially identified by the entity's internal control is an indicator of a material weakness or significant deficiency. Cause: This occurred because the University did not identify and make all necessary adjustments to the financial statements before the audit began. Over the past several years, the number of adjustments we have had to make has been decreasing, and we applaud the accounting staff and management for this. We also understand that there were some extenuating circumstances. However, unfortunately, these circumstances do not rectify the situation of the trial balance not being correct when presented for audit. Possible Asserted Effect: Because the aforementioned adjustments would have materially misstated the statement of financial position and statement of activities, we believe that this matter is a material weakness in the controls and practices of the University. Repeat Finding: A similar finding was reported in the prior year?s audit as Finding 2020-001. Recommendation: We recommend that the University develop and implement procedures to properly record transactions before the records are submitted for audit. We understand from the accounting staff and management that changes have already occurred to rectify this going forward. Management Response: This fiscal year presented a lot of new and challenging situations. Populi has been a learning curve for the cashier, IT department, and the staff accountant and numbers had to be verified intensively. Unfortunately, this took some time; the deferred income/accounts receivable had to be adjusted late in the audit due to a flaw in the new student management program. There was also a hold up regarding the balance of the HEERF money received/spent which affected deferred income. Once the updated information was received, and once the HEERF figures were received, they were sent to Keller & Owens to be updated. Fixed assets and sale of assets were processed after the audit due to the time spent correcting accounts receivable. When the staff accountant was asked to assist with the cashier and human resources departments, it was supposed to be short term and it happened prior to learning how big the problem was. We now have people and systems in place to keep this from happening again next year.

FINDING 2021-002 ? Account Reconciliation Condition Found: During our testing, we noted that certain schedules presented for audit did not agree with the underlying accounting records. We also noted that there is inadequate oversight over this function. For instance, the University had a difficult time preparing a complete and accurate accounts receivable listing. In addition, the University was unable to produce an aged listing of accounts receivable. Criteria: We noted that balance sheet account reconciliations had not been completed in a timely fashion. The schedules presented for audit did not agree with the underlying accounting records. We believe that all ?balance sheet accounts? should be reconciled to the subsidiary detail on a monthly basis in order to mitigate the risk of error or fraud. Cause: The University switched to a new student management program and was unaware of how the system posted certain transactions. Possible Asserted Effect: Failing to properly control and review the financial reporting process can lead to errors in the financial statements, and fraud or abuse by management, employees, and others involved. It was also difficult to determine compliance with Title IV Credit Balances and disbursement dates. Repeat Finding: There was not a similar finding in the prior year. Management Response: Calvary switched to a new student management program this fiscal year and the Fall 2021 tuition and fees were posted in fiscal year 20-21 instead of postdating them for July 1. We now have a system in place to prevent that from happening in the future. Also, we were unaware that reversing a charge for tuition and fees for a particular term (cycle) in Populi didn?t reverse those charges in the term that it was originally charged. This caused our reports that were run for Fall 2021 totals to show inaccurate figures and we had to discover the problem. We now know about this flaw in the system and will void transactions instead of reversing them, thus solving the problem.

FINDING 2020-001 ? Material Adjustments Condition Found: During the course of the audit, we proposed material adjustments to certain accounting transactions. The material adjustments proposed were related to accounts receivable, accounts payable, and investments. Criteria: Based on professional standards, identification by an auditor of a material misstatement in the financial statement under audit that was not initially identified by the entity's internal control is an indicator of a material weakness or significant deficiency. Cause: This occurred because the University did not identify and make all necessary adjustments to the financial statements before the audit began. Over the past several years, the number of adjustments we have had to make has been decreasing, and we applaud the accounting staff and management for this. We also understand that there were some extenuating circumstances However, unfortunately, these circumstances do not rectify the situation of the trial balance not being correct when presented for audit. Possible Asserted Effect: Because the aforementioned adjustments would have materially misstated the statement of financial position and statement of activities, we believe that this matter is a material weakness in the controls and practices of the University. Repeat Finding: A similar finding was reported in the prior year?s audit as Finding 2019-001. Recommendation: We recommend that the University develop and implement procedures to properly record transactions before the records are submitted for audit. We understand from the accounting staff and management that changes have already occurred to rectify this going forward. Management Response: The University will continue to increase review of the general ledger and record all necessary adjustments prior to the audit. We have already implemented procedures to ensure that accounts payable are recorded and that investment statements are provided timely so that the records can be updated on a timely basis.

FINDING 2020-002 ? Authorization to Hold Credit Balances Federal Agency: U.S. Department of Education; Office of Federal Student Aid Pass through Entity: Not applicable Program Name: Federal Pell Grant Program Federal Direct Loan Program Federal Supplemental Educational Opportunity Grant CFDA# and Program Expenditure: 84.063 ($490,393) 84.268 ($982,861) 84.007 ($ 13,400) Award Number: P063P183629 P268K201726 P007A196494 Federal Award Year: July 1, 2019 to June 30, 2020 Questioned Costs: $-0- Condition Found: For one of the thirty-eight students in our sample, the University held Title IV credit balances for longer than fourteen days without written authorization. Criteria: An institution may not hold a credit balance, which is caused by federal student financial aid funds, on a student?s account for more than fourteen days without written authorization from the student. Cause: The Student Financial Aid Office identified the credit balance and gave the information to the cashier timely. Miscommunication between the cashier and accounts payable clerk caused a delay with issuing the credit balance refund check to the student. Possible Asserted Effect: The Title IV credit balance was not returned timely to the student. Repeat Finding: There was not a similar finding in the previous year. Statistical Sampling: The sample was not intended to be, and was not, a statistically valid sample. Recommendation: The credit balance was returned to the student on December 2, 2019. Communication should be improved between the offices involved in the disbursement process to ensure that credit balances are refunded timely. Management Response: The credit balance was refunded to the student in question on December 2, 2019. The financial aid office will follow-up with the cashier and accounts payable clerk to ensure that the credit balance refunds requested are processed timely.

FINDING 2020-003 ? Verification Federal Agency: U.S. Department of Education; Office of Federal Student Aid Pass through Entity: Not applicable Program Name: Federal Pell Grant Program CFDA# and Program Expenditure: 84.063 ($490,393) Award Number: P063P183629 Federal Award Year: July 1, 2019 to June 30, 2020 Questioned Costs: $3,381 Condition Found: The information on the verification worksheet for family size and the number of family members in college did not agree with the number reported on the ISIR for two of the thirty-eight students sampled. In addition, one of these students was awarded a full-time Pell award when the student was only enrolled half-time for one semester. Criteria: If a student is in the V1 verification group, the following items must be verified: adjusted gross income, U.S. income taxes paid, untaxed portions of IRA distributions, untaxed portions or pensions, IRA deductions and payments, tax exempt interest income, education credits, household size, the number in college, SNAP benefits, and child support paid. The Pell amount awarded is calculated using the Pell payment charts and is based on enrollment status, expected family contribution (EFC), and cost of attendance. Cause: For one student, a nephew, for which the family was no longer providing more than fifty percent of his support, was included in the family size. For the second student, the ISIR showed 3 family members in college while the verification worksheet only listed two. The Financial Aid Office did not make the change to the ISIR information. In regard to the Pell amount awarded, the student only enrolled half-time in the Spring semester when the aid was awarded based on an anticipated full-time enrollment status. Possible Asserted Effect: The Expected Family Contribution could change which could cause an over or under award of federal aid, especially the Federal Pell Grant. In addition to the EFC changing the Pell amount for one student, the student was overwarded Pell due to an enrollment status in the Spring semester. Repeat Finding: There was not a similar finding in the previous year. Statistical Sampling: The sample was not intended to be, and was not, a statistically valid sample. Recommendation: The Financial Aid Office should correct the number of family members and the number in college for the two students in question. The new EFC and Pell award should be calculated. Pell Grant funds should be returned to the Department of Education. In addition the Spring Pell award should be reduced to half-time status based off of the new EFC for one of the students in question. Management Response: The Financial Aid Office updated the family status and number of family members in college and determined the new EFC for the students in question. The amount of Pell each student was eligible to receive was calculated based on the new EFC and the students? enrollment status. A total of $3,381 was returned to the Department of Education in August 2020.

FINDING 2020-004? NSLDS Reporting Federal Agency: U.S. Department of Education; Office of Federal Student Aid Pass through Entity: Not applicable Program Name: Federal Direct Student Loan Program CFDA# and Program Expenditures: 84.268 ($982,861) Award Number: P268K201726 Federal Award Year: July 1, 2019 to June 30, 2020 Questioned Costs: $-0- Condition Found: The incorrect enrollment status was reported to the National Student Loan Database System for one of the thirty-eight students selected for testing. Criteria: NSLDS informs loan servicers of changes in a student?s enrollment status that indicate when the repayments or interest accrual begins and ends. The date a student enrolls, withdraws, graduates, or drops below half-time status should be reported accurately. Cause: The student did not begin courses in the March enrollment cycle. The professors reported this information to the financial aid office in May. The May date was used as the last date of attendance instead of the beginning of the enrollment period when the student did not begin attendance. Possible Asserted Effect: The loan services were not aware of the correct deferral, repayment, and interest calculation dates. Repeat Finding: This finding was not reported in the immediately prior audit. Statistical Sampling: The sample was not intended to be, and was not, a statistically valid sample. Recommendation: The Financial Aid Director should update the withdrawal dates in NSLDS. Procedures should be improved to ensure that the enrollment status change dates entered into NSLDS are accurate. Management Response: Management agrees with the auditors? finding and their recommendation. The Financial Aid Director updated the enrollment status for the student in question in August 2020. Procedures will be improved to ensure that a student?s enrollment status is updated when a student re-enrolls at least half-time at the University.

FINDING 2019-001 ? Material Adjustments Condition Found: During the course of the audit, we proposed material adjustments to certain accounting transactions. The material adjustments proposed were related to fixed assets, receivables, and also a prior period adjustment. Criteria: Based on professional standards, identification by an auditor of a material misstatement in the financial statement under audit that was not initially identified by the entity's internal control is an indicator of a material weakness or significant deficiency. Cause: This occurred because the University did not identify and make all necessary adjustments to the financial statements before the audit began. Possible Asserted Effect: Because the aforementioned adjustments would have materially misstated the statement of financial position and statement of activities, we believe that this matter is a material weakness in the controls and practices of the University. Repeat Finding: A similar finding was reported in the prior year?s audit as Finding 2018-001. Recommendation: The University should develop and implement procedures to properly record transactions before its records are submitted for audit. Management Response: The University will continue to increase the review of the general ledger and record all necessary adjustments prior to the audit.

GSA_MIGRATION

GSA_MIGRATION

GSA_MIGRATION

GSA_MIGRATION

GSA_MIGRATION

GSA_MIGRATION

GSA_MIGRATION

GSA_MIGRATION

GSA_MIGRATION

GSA_MIGRATION

GSA_MIGRATION

GSA_MIGRATION