College Unbound

Finding number: 2025-002 Federal agency: U.S. Department of Education Programs: Federal Direct Student Loans Assistance listing #: 84.268 Award year: 2025 Compliance requirement: Eligibility Criteria According to 34 CFR 668.165(a) Notices and authorizations: (2) Except in the case of a post-withdrawal disbursement made in accordance with § 668.22(a)(5), if an institution credits a student ledger account with Direct Loan, Federal Perkins Loan, or TEACH Grant program funds, the institution must notify the student or parent of— (i) The anticipated date and amount of the disbursement; (ii) The student's or parent's right to cancel all or a portion of that loan, loan disbursement, TEACH Grant, or TEACH Grant disbursement and have the loan proceeds or TEACH Grant proceeds returned to the Secretary; and (iii) The procedures and time by which the student or parent must notify the institution that he or she wishes to cancel the loan, loan disbursement, TEACH Grant, or TEACH Grant disbursement. (3) The institution must provide the notice described in paragraph (a)(2) of this section in writing— (i) No earlier than 30 days before, and no later than 30 days after, crediting the student's ledger account at the institution, if the institution obtains affirmative confirmation from the student under paragraph (a)(6)(i) of this section; or (ii) No earlier than 30 days before, and no later than seven days after, crediting the student's ledger account at the institution, if the institution does not obtain affirmative confirmation from the student under paragraph (a)(6)(i) of this section. Condition The Federal Government requires institutions to notify students if the student’s ledger account is credited with a Direct Loan. This notification is to happen within 30 days before and after for affirmative confirmation and no later than seven days after without affirmative confirmation. During our testing, we noted 3 students, out of a sample of 40, whose notifications did not occur within the required time period. Our sample was not, and was not intended to be, statistically valid. Cause The College did not have adequate internal controls in place to ensure that all students or their parents were notified of credits on student accounts. Effect The College did not report student account ledger credits to students or parents within the required time frame. Questioned Costs Not applicable Identification as a Repeat Finding, if applicable See finding 2024-002 included in the summary schedule of prior year findings. Recommendation The College should update their procedures for notifying students when loan disbursements are credited to accounts. These procedures should include a timeline that will allow timely notification to students. View of Responsible Officials The College agrees with the finding.

Finding number: 2025-003 Federal agency: U.S. Department of Education Programs: Federal Direct Student Loans Assistance listing #: 84.268 Award year: 2025 Compliance requirement: Special Tests Criteria According to 34 CFR 685.309(b)(2): Unless it expects to submit its next updated enrollment report to the Secretary within the next 60 days, a school must notify the Secretary within 30 days after the date the school discovers that - (i) A loan under Title IV of the Act was made to or on behalf of a student who was enrolled or accepted for enrollment at the school, and the student has ceased to be enrolled on at least a half-time basis or failed to enroll on at least a half-time basis for the period for which the loan was intended; or (ii) A student who is enrolled at the school and who received a loan under Title IV of the Act has changed his or her permanent address. According to 2 CFR Part 200, Appendix XI Compliance Supplement updated April 2022: Under the Pell Grant and loan programs, institutions must complete and return within 15 days the Enrollment Reporting roster file placed in their Student Aid Internet Gateway mailboxes sent by ED via the National Student Loan Data System (“NSLDS”). An institution determines how often it receives the Enrollment Reporting roster file with the default set at a minimum of every 60 days. Once received, the institution must update for changes in the data elements for the Campus record and the Program Record, and submit the changes electronically through the batch method, spreadsheet submittal or the NSLDS website. Condition The Federal Government requires the College to report student enrollment changes to the NSLDS within 60 days. During our testing, 4 out of 14 students were reported late to the NSLDS by 72 days, 3 out of 14 students reported an incorrect effective date to the NSLDS, and 3 out of 14 students had a status change reported incorrectly as withdrawn instead of graduated. Our sample was not, and was not intended to be, statistically valid. Cause The College did not have appropriate internal controls in place to ensure enrollment status changes were being reported to the NSLDS timely and accurately. Effect Late or incorrect effective dates may impact the students’ loan grace periods. Questioned Costs Not applicable. Identification as a Repeat Finding, if applicable See finding 2024-004 included in the summary schedule of prior year findings. Recommendation The College should strengthen their internal controls surrounding the review of the NSLDS reporting process to ensure they are in compliance with federal regulations. View of Responsible Officials The College agrees with the finding.

Finding number: 2025-004 Federal agency: U.S. Department of Education Programs: Student Financial Assistance Cluster Assistance listing #: 84.063 Award year: 2025 Compliance requirement: Cash Management and Reporting Criteria According to 34 CFR 690.83(b): (1) An institution shall report to the Secretary any change in the amount of a grant for which a student qualifies including any related Payment Data changes by submitting to the Secretary the student's Payment Data that discloses the basis and result of the change in award for each student. The institution shall submit the student's Payment Data reporting any change to the Secretary by the reporting deadlines published by the Secretary in the Federal Register. (2) An institution shall submit, in accordance with deadline dates established by the Secretary, through publication in the Federal Register, other reports and information the Secretary requires and shall comply with the procedures the Secretary finds necessary to ensure that the reports are correct. Condition Federal regulations require the College to report the Federal Government’s COD Federal Pell Grant and Direct Loan disbursements made to students. During our testing, we noted 1 student, out of a sample of 40, in which the disbursed date in the student account did not align with the disbursed date in the COD. Our sample was not, and was not intended to be, statistically valid. Cause The College did not have adequate internal controls in place to validate that the disbursement date per the student's account statement matched the disbursement date reported to COD. Effect The College did not report the correct disbursement date to the COD. Questioned Costs Not applicable. Identification as a Repeat Finding, if applicable Not applicable. Recommendation The College should implement internal control procedures to ensure that COD disbursement information matches the College's records. View of Responsible Officials The College agrees with the finding.

Finding number: 2024-002 Federal agency: U.S. Department of Education Programs: Federal Direct Student Loans Assistance listing #: 84.268 Award year: 2024 Compliance requirement: Eligibility Criteria According to 34 CFR 668.165(a) Notices and authorizations: (2) Except in the case of a post-withdrawal disbursement made in accordance with § 668.22(a)(5), if an institution credits a student ledger account with Direct Loan, Federal Perkins Loan, or TEACH Grant program funds, the institution must notify the student or parent of— (i) The anticipated date and amount of the disbursement; (ii) The student's or parent's right to cancel all or a portion of that loan, loan disbursement, TEACH Grant, or TEACH Grant disbursement and have the loan proceeds or TEACH Grant proceeds returned to the Secretary; and (iii) The procedures and time by which the student or parent must notify the institution that he or she wishes to cancel the loan, loan disbursement, TEACH Grant, or TEACH Grant disbursement. (3) The institution must provide the notice described in paragraph (a)(2) of this section in writing— (i) No earlier than 30 days before, and no later than 30 days after, crediting the student's ledger account at the institution, if the institution obtains affirmative confirmation from the student under paragraph (a)(6)(i) of this section; or (ii) No earlier than 30 days before, and no later than seven days after, crediting the student's ledger account at the institution, if the institution does not obtain affirmative confirmation from the student under paragraph (a)(6)(i) of this section. Condition The Federal Government requires institutions to notify students if the student’s ledger account is credited with a Direct Loan. This notification is to happen within 30 days before and after for affirmative confirmation and no later than seven days after without affirmative confirmation. During our testing, we noted 18 students, out of a sample of 40, whose notifications did not occur within the required time period. Our sample was not, and was not intended to be, statistically valid. Cause The College did not have adequate internal controls in place to notify students or their parents of credits on the students’ accounts. As a result, the College did not send notifications to students during the Fall 2023 semester. Effect The College did not report student account ledger credits to students or parents within the required time frame. Questioned Costs Not applicable Identification as a Repeat Finding, if applicable Not applicable. Recommendation The College should update their procedures for notifying students when loan disbursements are credited to accounts. These procedures should include a timeline that will allow timely notification to students. View of Responsible Officials The College agrees with the finding.

Finding number: 2024-003 Federal agency: U.S. Department of Education Programs: Student Financial Assistance Cluster Assistance listing #: 84.063 and 84.268 Award year: 2024 Compliance requirement: Eligibility Criteria According to 34 CFR 685.303 Processing loan proceeds: (g) Treatment of excess loan proceeds. Before the disbursement of any Direct Subsidized Loan, Direct Unsubsidized Loan, or Direct PLUS Loan proceeds, if a school learns that the borrower will receive or has received financial aid for the period of enrollment for which the loan was intended that exceeds the amount of assistance for which the student is eligible (except for Federal Work-Study Program funds up to $300), the school must reduce or eliminate the overaward by either— (1) Using the student's Direct Unsubsidized Loan, Direct PLUS Loan, or State-sponsored or another non-Federal loan to cover the expected family contribution, if not already done; or (2) Reducing one or more subsequent disbursements to eliminate the overaward. Condition The Federal Government requires institutions to reduce aid given to students if they learn that a borrower will receive financial aid that exceeds the amount of assistance for which the student is eligible to eliminate the overaward. During our testing, we noted 1 student, out of a sample of 40, whose need-based aid exceeded students remaining need. Our sample was not, and was not intended to be, statistically valid. Cause The College did not have adequate internal controls in place to reduce need-based aid awarded below expected need. As a result, the College disbursed subsidized direct loans that exceeded eligible need. Effect The College disbursed loans that exceeded eligible need-based aid. Questioned Costs $5,500 Identification as a Repeat Finding, if applicable Not applicable. Recommendation The College should update their procedures for calculating need. These procedures should include a control to restrict need-based aid to eligible disbursements. View of Responsible Officials The College agrees with the finding.

Finding number: 2024-004 Federal agency: U.S. Department of Education Programs: Federal Direct Student Loans Assistance listing #: 84.268 Award year: 2024 Compliance requirement: Special Tests Criteria According to 34 CFR 685.309(b)(2): Unless it expects to submit its next updated enrollment report to the Secretary within the next 60 days, a school must notify the Secretary within 30 days after the date the school discovers that - (i) A loan under Title IV of the Act was made to or on behalf of a student who was enrolled or accepted for enrollment at the school, and the student has ceased to be enrolled on at least a half-time basis or failed to enroll on at least a half-time basis for the period for which the loan was intended; or (ii) A student who is enrolled at the school and who received a loan under Title IV of the Act has changed his or her permanent address. According to 2 CFR Part 200, Appendix XI Compliance Supplement updated April 2022: Under the Pell Grant and loan programs, institutions must complete and return within 15 days the Enrollment Reporting roster file placed in their Student Aid Internet Gateway mailboxes sent by ED via the National Student Loan Data System (“NSLDS”). An institution determines how often it receives the Enrollment Reporting roster file with the default set at a minimum of every 60 days. Once received, the institution must update for changes in the data elements for the Campus record and the Program Record, and submit the changes electronically through the batch method, spreadsheet submittal or the NSLDS website. Condition The Federal Government requires the College to report student enrollment changes to the NSLDS within 60 days. During our testing, 6 out of 16 students were reported late to the NSLDS by 19 to 116 days and 1 out of 16 students reported an incorrect effective date to the NSLDS. Our sample was not, and was not intended to be, statistically valid. Cause The College did not have appropriate internal controls in place to ensure enrollment status changes were being reported to the NSLDS timely and accurately. Effect Late or incorrect effective dates may impact the students’ loan grace periods. Questioned Costs Not applicable. Identification as a Repeat Finding, if applicable See finding 2023-006 included in the summary schedule of prior year findings. Recommendation The College should strengthen their internal controls surrounding the review of the NSLDS reporting process to ensure they are in compliance with federal regulations. View of Responsible Officials The College agrees with the finding.

Finding number: 2023-002 Federal agency: U.S. Department of Education Programs: Student Financial Assistance Cluster Assistance listing #: 84.268 Award year: 2023 Compliance requirement: Special Tests Criteria According to 34 CFR 668.164(h): Title IV, Higher Education Act (“HEA”) credit balances. (1) A Title IV, HEA credit balance occurs whenever the amount of Title IV, HEA program funds credited to a student's ledger account for a payment period exceeds the amount assessed the student for allowable charges associated with that payment period. (2) A Title IV, HEA credit balance must be paid directly to the student or parent as soon as possible, but no later than - (i) No later than 14 days after the balance occurred if the balance occurred after the first day of class of a payment period; or (ii) No later than 14 days after the first day of class of a payment period if the credit balance occurred on or before the first day of that payment period. Condition The Federal Government requires that whenever Title IV aid is disbursed on a student’s account, the account must be reviewed to determine if the disbursement caused a credit balance. If the credit balance was caused by Title IV funds, the College must refund the balance directly to the student within 14 days of the disbursement of funds. During our testing, we noted 1 student, out of a sample of 22, that was not refunded credit balances within the required timeframe by 14 days. Our sample was not, and was not intended to be, statistically valid. Cause The College did not implement appropriate internal controls related to disbursements over student's accounts to ensure that refunds were processed for credit balances within the required timeframe. Effect The College did not refund Title IV credit balances within the required 14-day time frame and therefore was not in compliance with federal requirements. Questioned Costs Not applicable Identification as a Repeat Finding, if applicable See finding 2022-009 included in the summary schedule of prior year findings. Recommendation The Business Office should continue to develop their procedures to identify credit balances caused by changes on students’ accounts as well as disbursements. This includes reviewing accounts after late disbursement of Title IV aid as well as tuition and fee adjustments, health insurance waivers and bookstore credits. View of Responsible Officials The College agrees with the finding.

Finding number: 2023-003 Federal agency: U.S. Department of Education Programs: Federal Pell Grants Assistance listing #: 84.063 Award year: 2023 Compliance requirement: Eligibility Criteria According to 34 CFR 690.80(b) Recalculation of a Federal Pell Grant award: (b) Change in enrollment status. (1) If the student's enrollment status changes from one academic term to another term within the same award year, the institution shall recalculate the Federal Pell Grant award for the new payment period taking into account any changes in the cost of attendance. (2) (i) If the student's projected enrollment status changes during a payment period after the student has begun attendance in all of his or her classes for that payment period, the institution may (but is not required to) establish a policy under which the student's award for the payment period is recalculated. Any such recalculations must take into account any changes in the cost of attendance. If such a policy is established, it must apply to all students. (ii) If a student's projected enrollment status changes during a payment period before the student begins attendance in all of his or her classes for that payment period, the institution shall recalculate the student's enrollment status to reflect only those classes for which the student actually began attendance. Condition The Federal Government requires Pell Grant awards to be recalculated when a student fails to begin attendance in each of their scheduled courses which causes a change in the student’s enrollment status. During our testing, we noted 1 student, out of a sample of 40, whose Pell Grant award was not recalculated after their enrollment status changed. Our sample was not, and was not intended to be, statistically valid. Cause The College did not have adequate internal controls in place to identify the change in the student’s enrollment status for recalculation of Pell award. As a result, the College did not properly recalculate the student’s Pell Grant award. Effect The College over-awarded Pell Grant funds. Questioned Costs $863 Identification as a Repeat Finding, if applicable Not applicable. Recommendation The College should update their procedures for identifying status changes due to student’s failure to begin attendance in all scheduled courses. These procedures should include a timeline for reporting students who fail to begin attendance by faculty that will allow for the timely recalculation of Pell Grant awards. The importance of accurate and timely reporting of attendance should be emphasized to the faculty. View of Responsible Officials The College agrees with the finding.

Finding number: 2023-004 Federal agency: U.S. Department of Education Programs: Student Financial Assistance Cluster Assistance listing #: 84.063 and 84.268 Award year: 2023 Compliance requirement: Cash Management and Reporting Criteria According to 34 CFR 690.83(b): (1) An institution shall report to the Secretary any change in the amount of a grant for which a student qualifies including any related Payment Data changes by submitting to the Secretary the student's Payment Data that discloses the basis and result of the change in award for each student. The institution shall submit the student's Payment Data reporting any change to the Secretary by the reporting deadlines published by the Secretary in the Federal Register. (2) An institution shall submit, in accordance with deadline dates established by the Secretary, through publication in the Federal Register, other reports and information the Secretary requires and shall comply with the procedures the Secretary finds necessary to ensure that the reports are correct. According to Common Origination and Disbursement (“COD”) 2022-2023 Technical Reference: Disbursement Date is the date the money was credited to the student’s account or paid to the student (or borrower, if PLUS loan) directly for a specific disbursement number. Disbursement Date is not the date of the adjustment transaction. The Disbursement Date is submitted on a Disbursement transaction as well as on an Adjusted Disbursement Amount transaction. Condition Federal regulations require the College to report the Federal Government’s COD Federal Pell Grant and Direct Loan disbursements made to students. During our testing, we noted for 6 students, out of a sample of 40, in which the disbursed date in the student account did not align with the disbursed date in the COD. Our sample was not, and was not intended to be, statistically valid. Cause The College did not have adequate internal controls in place to validate that the disbursement date per the student's account statement matched the disbursement date reported to COD. Effect The College did not report the correct disbursement date to the COD. Questioned Costs Not applicable. Identification as a Repeat Finding, if applicable See finding 2022-004 included in the summary schedule of prior year findings. Recommendation The College should implement internal control procedures to ensure that COD disbursement information matches the College's records. View of Responsible Officials The College agrees with the finding.

Finding number: 2023-005 Federal agency: U.S. Department of Education Programs: Federal Pell Grants Assistance listing #: 84.063 Award year: 2023 Compliance requirement: Cash Management and Reporting Criteria According to 34 CFR 690.83(b): (1) An institution shall report to the Secretary any change for which a student qualifies including any related Payment Data changes by submitting to the Secretary the student’s Payment Data that discloses the basis and result of the change in award for each student. The institution shall submit the student’s Payment Data reporting any to the Secretary by the reporting deadlines published by the Secretary in the Federal Register. (2) An institution shall submit, in accordance with the deadline dates established by the Secretary, through publication in the Federal Register, other reports and information the Secretary requires and shall comply with the procedures the Secretary finds necessary to ensure that the reports are correct. According to the Federal Register (Volume 87, Number 105): 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, Higher Education Act (“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 Federal regulations require the College to report to the Federal Government’s Common Origination and Disbursement System (“COD”) Federal Pell Grant disbursements made to students within 15 days of the funds being disbursed to the student. During our testing, we noted 1 student, out of a sample of 40, was not reported within the required timeframe by 139 days. Our sample was not, and was not intended to be, statistically valid. Cause The College has policies and procedures in place to report the disbursement records to the Department of Education through the COD system within the required fifteen calendar days, however, in this case the procedures were not completed properly. Effect The College did not report Pell Grant disbursements to COD within the required time frame. Questioned Costs Not applicable Identification as a Repeat Finding, if applicable Not applicable.   Recommendation We recommend that management of the College review, and if necessary, update the policies and procedures to ensure all Pell Grant funds are reported within the required timeframe. View of Responsible Officials The College agrees with the finding.

Finding number: 2023-006 Federal agency: U.S. Department of Education Programs: Student Financial Assistance Cluster Assistance listing #: 84.063 & 84.268 Award year: 2023 Compliance requirement: Special Tests Criteria According to 34 CFR 685.309(b)(2): Unless it expects to submit its next updated enrollment report to the Secretary within the next 60 days, a school must notify the Secretary within 30 days after the date the school discovers that - (i) A loan under Title IV of the Act was made to or on behalf of a student who was enrolled or accepted for enrollment at the school, and the student has ceased to be enrolled on at least a half-time basis or failed to enroll on at least a half-time basis for the period for which the loan was intended; or (ii) A student who is enrolled at the school and who received a loan under Title IV of the Act has changed his or her permanent address. According to 2 CFR Part 200, Appendix XI Compliance Supplement updated April 2022: Under the Pell Grant and loan programs, institutions must complete and return within 15 days the Enrollment Reporting roster file placed in their Student Aid Internet Gateway mailboxes sent by ED via the National Student Loan Data System (“NSLDS”). An institution determines how often it receives the Enrollment Reporting roster file with the default set at a minimum of every 60 days. Once received, the institution must update for changes in the data elements for the Campus record and the Program Record, and submit the changes electronically through the batch method, spreadsheet submittal or the NSLDS website. Condition The Federal Government requires the College to report student enrollment changes to the NSLDS within 60 days. During our testing, 2 out of 10 students were reported late to the NSLDS by 35 to 96 days and 4 out of 10 students reported an incorrect effective date to the NSLDS. Additionally, 1 out of 10 students had an incorrect status change reported to the NSLDS. Our sample was not, and was not intended to be, statistically valid. Cause The College did not have appropriate internal controls in place to ensure enrollment status changes were being reported to the NSLDS timely and accurately. Effect Late or incorrect effective dates may impact the students’ loan grace periods. Questioned Costs Not applicable. Identification as a Repeat Finding, if applicable See finding 2022-007 included in the summary schedule of prior year findings. Recommendation The College should strengthen their internal controls surrounding the review of the NSLDS reporting process to ensure they are in compliance with federal regulations. View of Responsible Officials The College agrees with the finding.

Finding number: 2023-007 Federal agency: U.S. Department of Education Programs: Student Financial Assistance Cluster Assistance listing #: 84.063 & 84.268 Award year: 2023 Compliance requirement: Special Tests Criteria According to 34 CFR 668.164(l): (1) Notwithstanding any State law (such as a law that allows funds to escheat to the State), an institution must return to the Secretary any Title IV, Higher Education Act (“HEA”) program funds, except Federal Work Study (“FWS”) program funds, that it attempts to disburse directly to a student or parent that are not received by the student or parent. For FWS program funds, the institution is required to return only the Federal portion of the payroll disbursement. (2) If an EFT to a student's or parent's financial account is rejected, or a check to a student or parent is returned, the institution may make additional attempts to disburse the funds, provided that those attempts are made not later than 45 days after the EFT was rejected or the check returned. In cases where the institution does not make another attempt, the funds must be returned to the Secretary before the end of this 45-day period. (3) If a check sent to a student or parent is not returned to the institution but is not cashed, the institution must return the funds to the Secretary no later than 240 days after the date it issued the check. Condition Federal regulations require an institution to return unclaimed Title IV funds issued by check or EFT within 240 days. During our testing, we noted 1 student, out of a sample of 2, that had unclaimed funds exceeding the federal day limit by 40 days. Our sample was not, and was not intended to be, statistically valid. Cause The College did not have appropriate internal controls in place to monitor the outstanding check aging to ensure that the 240-day timeframe was not exceeded. Effect The College did not return Title IV unclaimed funds to the Department of Education within the required 240-day time frame. Questioned Costs There was one outstanding check totaling $2,234, which pertained specifically to federal-sourced funds. Identification as a Repeat Finding, if applicable See finding 2022-006 included in the summary schedule of prior year findings. Recommendation The College should examine its policies and procedures and implement effective internal controls related to unclaimed funds including the process and time frame for identifying aged balances and the process for cancelling checks and returning funds to the Department of Education. View of Responsible Officials The College agrees with the finding.

Finding number: 2023-008 Federal agency: U.S. Department of Education Programs: Student Financial Assistance Cluster Assistance listing #: 84.268 Award year: 2023 Compliance requirement: Special Tests Criteria According to 34 CFR 685.300(b): In the program participation agreement, the school must promise to comply with the Act and applicable regulations and must agree to - (5) On a monthly basis, reconcile institutional records with Direct Loan funds received from the Secretary and Direct Loan disbursement records submitted to and accepted by the Secretary; An electronic announcement dated December 18, 2020, described the process by which the Department of Education defines Direct Loan Reconciliation. Direct reconciliation is the process by which Direct Loan funds received and disbursed as recorded on the Department of Education’s systems are reviewed and compared with a school’s internal records and discrepancies are identified and resolved. Condition Federal regulations require the College to reconcile their institutional records with their COD disbursement records monthly. This reconciliation includes identifying discrepancies and resolving them in a timely manner. Based on discussion with the College, we noted that the College relied on the third-party servicer to perform monthly reconciliation but did not review the reconciliation to resolve any discrepancies. Cause The College did not implement appropriate internal controls over monthly reconciliation completed by the third-party servicer to ensure that differences found in reconciliations between institutional records and COD's disbursement records were resolved in a timely basis. Effect Discrepancies are not identified and resolved in a timely manner. Questioned Costs Not applicable Identification as a Repeat Finding, if applicable See finding 2022-008 included in the summary schedule of prior year findings. Recommendation The College should implement internal controls to validate that reconciliations are performed monthly between the College's institutional records and disbursement records submitted to the COD and any discrepancies are identified and resolved in a timely manner. View of Responsible Officials The College agrees with the finding.

Finding number: 2023-009 Federal agency: U.S. Department of Education Programs: Student Financial Assistance Cluster Assistance listing #: 84.063 Award year: 2023 Compliance requirement: Special Tests Criteria According to 34 CFR 668.22(f)(2): (i) The total number of calendar days in a payment period or period of enrollment includes all days within the period that the student was scheduled to complete, except that scheduled breaks of at least five consecutive days are excluded from the total number of calendar days in a payment period or period of enrollment and the number of calendar days completed in that period. (ii) The total number of calendar days in a payment period or period of enrollment does not include - (A) Days in which the student was on an approved leave of absence; or (B) For a payment period or period of enrollment in which any courses in the program are offered in modules, any scheduled breaks of at least five consecutive days when the student is not scheduled to attend a module or other course offered during that period of time. Condition The Federal Government requires that when the student withdraws from all classes, the College calculate the student’s percentage of Title IV aid earned. This is calculated by dividing the number of days the student attended classes by the total number of days in the academic period. The total number of days in the academic period (semester) includes all calendar days between the start and end of academic activities. During our testing, we noted 1 student, out of a sample of 3, where the incorrect number of total days in the Spring semester were used to calculate the student’s percentage of Title IV earned. Our sample was not, and was not intended to be, statistically valid. Cause The College has policies and procedures to ensure compliance for calculating the Title IV funds to be returned. In this instance, the College incorrectly calculated the enrollment period as student’s last day of attendance was excluded form calculation, which resulted in rounding variance. Effect The College calculated the Return to Title IV (“R2T4”) forms incorrectly and returned an insufficient amount of Title IV funds to the Department of Education. Questioned Costs $33.25 Identification as a Repeat Finding, if applicable Not applicable. Recommendation The College should review their current policies and procedures regarding formal review process of the Return of Title IV calculations by an individual separate from preparer of Return of Title IV calculation to ensure that return of Title IV funds is properly calculated. View of Responsible Officials The College agrees with the finding.

Finding number: 2023-010 Federal agency: U.S. Department of Education Programs: Federal Direct Student Loans Assistance listing #: 84.268 Award year: 2023 Compliance requirement: Eligibility Criteria According to 34 CFR 685.304(b): (1) A school must ensure that exit counseling is conducted with each Direct Subsidized Loan or Direct Unsubsidized Loan borrower and graduate or professional student Direct PLUS Loan borrower shortly before the student borrower ceases at least half-time study at the school. (2) The exit counseling must be in person, by audiovisual presentation, or by interactive electronic means. In each case, the school must ensure that an individual with expertise in the Title IV programs is reasonably available shortly after the counseling to answer the student borrower's questions. As an alternative, in the case of a student borrower enrolled in a correspondence program or a study-abroad program approved for credit at the home institution, the student borrower may be provided with written counseling materials within 30 days after the student borrower completes the program. (3) If a student borrower withdraws from school without the school's prior knowledge or fails to complete the exit counseling as required, exit counseling must, within 30 days after the school learns that the student borrower has withdrawn from school or failed to complete the exit counseling as required, be provided either through interactive electronic means, by mailing written counseling materials to the student borrower at the student borrower's last known address, or by sending written counseling materials to an email address provided by the student borrower that is not an email address associated with the school sending the counseling materials. Condition The Federal Government requires that when the student ceases at least half-time study, withdraws from all classes or graduates, the college must provide exit counseling to students within 30 days. During our testing, we noted 5 students, out of a sample of 40, did not have evidence that exit counseling was performed. Our sample was not, and was not intended to be, statistically valid. Cause The College did not have adequate controls in place to ensure that exit counseling was conducted with Direct Loans borrowers following changes in enrollment which require administration of exit counseling for Direct Loans. Effect The College did not meet federal requirements and students did not complete exit counseling following graduation, cease of enrollment. Questioned Costs Not Applicable Identification as a Repeat Finding, if applicable Not applicable. Recommendation The College should implement internal control procedures to ensure exit counseling is completed for a student when student ceases enrollment at least half-time, withdraws, or graduates from the College. View of Responsible Officials The College agrees with the finding.

Finding number: 2023-011 Federal agency: U.S. Department of Education Programs: Student Financial Assistance Cluster Assistance listing #: 84.063 & 84.268 Award year: 2023 Compliance requirement: Eligibility Criteria According to 34 CFR 668.32: A student is eligible to receive Title IV, HEA program assistance if the student either meets all of the requirements in paragraphs (a) through (m) of this section or meets the requirement in paragraph (n) of this section as follows: (e) (1) Has a high school diploma or its recognized equivalent Condition The Federal Government requires that evidence of a high school diploma, its recognized equivalent, or an alternative educational requirement be provided by the student prior to their first disbursement. During our testing, we noted the College failed to retain a high school diploma or recognized equivalent for 2 students, out of a sample of 40. As a result, the College was unable to provide the necessary documentation to support the students’ eligibility. Our sample was not, and was not intended to be, statistically valid. Cause The College failed to have the proper internal controls in place to validate that students are eligible to receive Title IV prior to their first disbursement. Effect The students were awarded and disbursed federal student aid that they may not be eligible to receive. Questioned Costs $29,187 Identification as a Repeat Finding, if applicable See finding 2022-003 included in the summary schedule of prior year findings. Recommendation The College should implement internal control procedures to ensure all students are eligible to receive federal student aid before their first disbursement. View of Responsible Officials The College agrees with the finding.

Finding number: 2023-012 Federal agency: U.S. Department of Treasury Programs: COVID-19 - Coronavirus State and Local Fiscal Recovery Funds Assistance listing #: 21.027 Award year: 2023 Compliance requirement: Allowable Costs Criteria According to 2 CFR 200.403 Factors affecting allowability of costs: Except where otherwise authorized by statute, costs must meet the following general criteria in order to be allowable under Federal awards: (a) Be necessary and reasonable for the performance of the Federal award and be allocable thereto under these principles. (c) Be consistent with policies and procedures that apply uniformly to both federally-financed and other activities of the non-Federal entity. (g) Be adequately documented. See also §§ 200.300 through 200.309 of this part. (h) Cost must be incurred during the approved budget period. The Federal awarding agency is authorized, at its discretion, to waive prior written approvals to carry forward unobligated balances to subsequent budget periods pursuant to § 200.308(e)(3). Condition The Federal Government requires that costs must be adequately documented and must be incurred during the approved budget period. During our testing, we noted the College failed to provide a copy of check or ACH payment information for 1 expenditure, out of a sample of 5. As a result, the College was unable to provide the proof of payment to support the expenditure is an allowable cost. Our sample was not, and was not intended to be, statistically valid. Cause The College failed to have the proper internal controls in place to keep the proof of payment to support the expenditure that was reimbursed from the federal award. Effect The invoice that was reimbursed from the federal award may not be an allowable cost. Questioned Costs $1,655 Identification as a Repeat Finding, if applicable Not applicable. Recommendation The College should implement internal control procedures to verify that reimbursement requests are only submitted for invoices that have been paid. View of Responsible Officials The College agrees with the finding.

Finding number: 2022-002 Federal agency: U.S. Department of Education Programs: Student Financial Assistance Cluster Assistance Listing #: 84.268 Award year: 2022 Compliance Requirement: Eligibility Criteria According to 34 CFR Section 685.304 (a): 1. A school must ensure that entrance counseling is conducted with each Direct Subsidized Loan or Direct Unsubsidized Loan student borrower prior to making the first disbursement of the proceeds of a loan to a student borrower unless the student borrower has received a prior Direct Subsidized Loan, Direct Unsubsidized Loan, Subsidized or Unsubsidized Federal Stafford Loan, or Federal SLS loan. Condition The Federal Government requires that entrance counseling is conducted with Direct Loan borrowers prior to their first disbursement. During our testing, we noted 3 students, out of a sample of 40, did not have evidence that entrance counseling was performed prior to their first loan disbursement. Our sample was not, and was not intended to be, statistically valid. Cause The College did not have adequate internal controls in place to ensure that entrance counseling was conducted with Direct Loan borrowers prior to their first disbursement. Effect The College did not meet federal requirements and students did not complete entrance counseling before their first disbursements. Questioned Costs Not applicable Identification as a Repeat Finding, if applicable See finding 2021-002 included in the summary schedule of prior year findings. Recommendation The College should implement internal control procedures to ensure entrance counseling is completed for a student borrower before their first disbursement of their loan. View of Responsible Officials The College agrees with the finding.

Finding number: 2022-003 Federal agency: U.S. Department of Education Programs: Student Financial Assistance Cluster Assistance Listing #: 84.063, 84.007, and 84.268 Award year: 2022 Compliance Requirement: Eligibility Criteria According to 34 CFR 668.32: A student is eligible to receive Title IV, HEA program assistance if the student either meets all of the requirements in paragraphs (a) through (m) of this section or meets the requirement in paragraph (n) of this section as follows: (e) (1) Has a high school diploma or its recognized equivalent Condition The Federal Government requires that evidence of a high school diploma, its recognized equivalent, or an alternative educational requirement be provided by the student prior to their first disbursement. During our testing, we noted the College failed to retain a high school diploma or recognized equivalent for 4 students, out of a sample of 40. As a result, the College was unable to provide the necessary documentation to support the students’ eligibility. Our sample was not, and was not intended to be, statistically valid. Cause The College failed to have the proper internal controls in place to validate that students are eligible to receive Title IV prior to their first disbursement. Effect The students were awarded and disbursed federal student aid that they may not be eligible to receive. Questioned Costs Not applicable Identification as a Repeat Finding, if applicable Not applicable Recommendation The College should implement internal control procedures to ensure all students are eligible to receive federal student aid before their first disbursement. View of Responsible Officials The College agrees with the finding.

Finding number: 2022-004 Federal agency: U.S. Department of Education Programs: Student Financial Assistance Cluster Assistance Listing #: 84.063 and 84.268 Award year: 2022 Compliance Requirement: Cash Management and Reporting Criteria According to 34 CFR 690.83(b) (1) An institution shall report to the Secretary any change in the amount of a grant for which a student qualifies including any related Payment Data changes by submitting to the Secretary the student's Payment Data that discloses the basis and result of the change in award for each student. The institution shall submit the student's Payment Data reporting any change to the Secretary by the reporting deadlines published by the Secretary in the Federal Register. (2) An institution shall submit, in accordance with deadline dates established by the Secretary, through publication in the Federal Register, other reports and information the Secretary requires and shall comply with the procedures the Secretary finds necessary to ensure that the reports are correct. According to Common Origination and Disbursement (“COD”) 2021-2022 Technical Reference: Disbursement Date is the date the money was credited to the student’s account or paid to the student (or borrower, if PLUS loan) directly for a specific disbursement number. Disbursement Date is not the date of the adjustment transaction. The Disbursement Date is submitted on a Disbursement transaction as well as on an Adjusted Disbursement Amount transaction. Condition Federal regulations require the College to report the Federal Government’s COD Federal Pell Grant and Direct Loan disbursements made to students. During our testing, we noted for 1 student, out of a sample of 40, that the amount of the funds credited to the student's account did not match with the COD disbursed amount. Additionally, for 3 students, out of a sample of 40, the disbursed date in the student account did not align with the disbursed date in the COD by a range of 1-5 days. Our sample was not, and was not intended to be, statistically valid. Cause The College did not have adequate internal controls in place to validate that the disbursement amount and disbursement date per the student's account statement matched the disbursement amount and disbursement date reported to COD. Effect The College did not report the correct disbursement amount and date to the COD. Questioned Costs Not applicable Identification as a Repeat Finding, if applicable See finding 2021-003 included in the summary schedule of prior year findings. Recommendation The College should implement internal control procedures to ensure that COD disbursement information matches the College's records. View of Responsible Officials The College agrees with the finding.

Finding number: 2022-005 Federal agency: U.S. Department of Education Programs: Student Financial Assistance Cluster Assistance Listing #: 84.268 Award year: 2022 Compliance Requirement: Special Tests Criteria According to 34 CFR Section 685.303 (b)(5)(i): If a student is enrolled in the first year of an undergraduate program of study and has not previously received a Direct Subsidized Loan, a Direct Unsubsidized Loan, a Subsidized or Unsubsidized Federal Stafford Loan, or a Federal Supplemental Loan for Students, a school may not disburse the proceeds of a Direct Subsidized or Direct Unsubsidized Loan until 30 days after the first day of the student's program of study unless- (A) (1) Except as provided in paragraph (b)(5)(i)(A)(2) of this section, the school has a cohort default rate, calculated under subpart M of 34 CFR part 668, or weighted average cohort rate of less than 10 percent for each of the three most recent fiscal years for which data are available; or (2) For loans first disbursed on or after October 1, 2011, the school in which the student is enrolled has a cohort default rate, calculated under either subpart M or N of 34 CFR part 668 of less than 15 percent for each of the three most recent fiscal years for which data are available; (B) The school is an eligible home institution originating a loan to cover the cost of attendance in a study abroad program and has a Direct Loan Program cohort rate, FFEL cohort default rate, or weighted average cohort rate of less than 5 percent for the single most recent fiscal year for which data are available. Condition The Federal Government requires the College not to disburse the first installment of Direct loans to first-year undergraduates who are first time borrowers until 30 days after the student’s first day of classes. During our testing, we noted 3 students, out of a sample of 40, who had not previously received direct loans and were disbursed loans within the first 30 days after the student’s first day of classes. Our sample was not, and was not intended to be, statistically valid. Cause The College did not have adequate internal controls in place to validate that Direct loans were not disbursed to first-year undergraduates who are first time borrowers until 30 days after the student’s first day of classes. Effect The College disbursed loans to students before they were eligible to receive them. Questioned Costs Not applicable Identification as a Repeat Finding, if applicable Not applicable Recommendation The College should implement internal controls to ensure that Direct loans are not disbursed to first-year undergraduates who are first time borrowers until 30 days after the student’s first day of classes. View of Responsible Officials The College agrees with the finding.

Finding number: 2022-006 Federal agency: U.S. Department of Education Programs: Student Financial Assistance Cluster Assistance Listing #: 84.268 Award year: 2022 Compliance Requirement: Special Tests Criteria According to 34 CFR 668.164(l): (1) Notwithstanding any State law (such as a law that allows funds to escheat to the State), an institution must return to the Secretary any title IV, Higher Education Act (“HEA”) program funds, except Federal Work Study (“FWS”) program funds, that it attempts to disburse directly to a student or parent that are not received by the student or parent. For FWS program funds, the institution is required to return only the Federal portion of the payroll disbursement. (2) If an EFT to a student's or parent's financial account is rejected, or a check to a student or parent is returned, the institution may make additional attempts to disburse the funds, provided that those attempts are made not later than 45 days after the EFT was rejected or the check returned. In cases where the institution does not make another attempt, the funds must be returned to the Secretary before the end of this 45-day period. (3) If a check sent to a student or parent is not returned to the institution but is not cashed, the institution must return the funds to the Secretary no later than 240 days after the date it issued the check. Condition Federal regulations require an institution to return unclaimed Title IV funds issued by check or EFT within 240 days after the date issued. During our testing, we noted one student that had unclaimed funds exceeding the federal day limit by 53 days. Our sample was not, and was not intended to be, statistically valid. Cause The College did not have appropriate internal controls in place to monitor the outstanding check aging to ensure that the 240-day timeframe was not exceeded. Effect The College did not return Title IV unclaimed funds to the Department of Education within the required 240-day time frame. Questioned Costs There was one outstanding check that totaled $634, which pertained specifically to federal-sourced funds. Identification as a Repeat Finding, if applicable See finding 2021-004 included in the summary schedule of prior year findings. Recommendation The College should examine its policies and procedures and implement effective internal controls related to unclaimed funds including the process and time frame for identifying aged balances and the process for cancelling checks and returning funds to the Department of Education. View of Responsible Officials The Colleges agree with the finding.

Finding number: 2022-007 Federal agency: U.S. Department of Education Programs: Student Financial Assistance Cluster Assistance Listing #: 84.063 and 84.268 Award year: 2022 Compliance Requirement: Special Tests Criteria According to 34 CFR 685.309(b)(2): Unless it expects to submit its next updated enrollment report to the Secretary within the next 60 days, a school must notify the Secretary within 30 days after the date the school discovers that – (i) A loan under Title IV of the Act was made to or on behalf of a student who was enrolled or accepted for enrollment at the school, and the student has ceased to be enrolled on at least a half-time basis or failed to enroll on at least a half-time basis for the period for which the loan was intended; or (ii) A student who is enrolled at the school and who received a loan under Title IV of the Act has changed his or her permanent address. According to 2 CFR Part 200, Appendix XI Compliance Supplement updated April 2022: Under the Pell Grant and loan programs, institutions must complete and return within 15 days the Enrollment Reporting roster file placed in their Student Aid Internet Gateway mailboxes sent by ED via the National Student Loan Data System (“NSLDS”). An institution determines how often it receives the Enrollment Reporting roster file with the default set at a minimum of every 60 days. Once received, the institution must update for changes in the data elements for the Campus record and the Program Record, and submit the changes electronically through the batch method, spreadsheet submittal or the NSLDS website. Condition The Federal Government requires the College to report student enrollment changes to the NSLDS within 60 days. During our testing, 4 out of 6 students were reported late to the NSLDS by 4 to124 days and 2 out of 6 students reported an incorrect effective date to the NSLDS. Our sample was not, and was not intended to be, statistically valid. Cause The College did not have appropriate internal controls in place to ensure enrollment status changes were being reported to the NSLDS timely and accurately. Effect Late or incorrect effective dates may impact the students’ loan grace periods Questioned Costs Not applicable Identification as a Repeat Finding, if applicable See finding 2021-006 included in the summary schedule of prior year findings. Recommendation The College should strengthen their internal controls surrounding the review of the NSLDS reporting process to ensure they are in compliance with federal regulations. View of Responsible Officials The College agrees with the finding.

Finding number: 2022-008 Federal agency: U.S. Department of Education Programs: Student Financial Assistance Cluster Assistance Listing #: 84.268 Award year: 2022 Compliance Requirement: Special Tests Criteria According to 34 CFR 685.300(b): In the program participation agreement, the school must promise to comply with the Act and applicable regulations and must agree to - (5) On a monthly basis, reconcile institutional records with Direct Loan funds received from the Secretary and Direct Loan disbursement records submitted to and accepted by the Secretary; An electronic announcement dated December 18, 2020, described the process by which the Department of Education defines Direct Loan Reconciliation. Direct reconciliation is the process by which Direct Loan funds received and disbursed as recorded on the Department of Education’s systems are reviewed and compared with a school’s internal records and discrepancies are identified and resolved. Condition Federal regulations require the College to reconcile their institutional records with their COD disbursement records monthly. This reconciliation includes identifying discrepancies and resolving them in a timely manner. For a sample of 3 months, during our testing, 2 months had discrepancies that were not resolved in a timely manner. Our sample was not, and was not intended to be, statistically valid. We noted that the College relied on the third-party servicer to perform monthly reconciliation but did not review the reconciliation to resolve any discrepancies. However, we noted that the College performed the year end reconciliation and noted no discrepancies. Cause The College did not implement appropriate internal controls over monthly reconciliation completed by the third-party servicer to ensure that differences found in reconciliations between institutional records and COD's disbursement records were resolved in a timely basis. Effect Discrepancies are not identified and resolved in a timely manner. Questioned Costs Not applicable Identification as a Repeat Finding, if applicable See finding 2021-005 included in the summary schedule of prior year findings. Recommendation The College should implement internal controls to validate that reconciliations are performed monthly between the College's institutional records and disbursement records submitted to the COD and any discrepancies are identified and resolved in a timely manner. View of Responsible Officials The College agrees with the finding.

Finding number: 2022-009 Federal agency: U.S. Department of Education Programs: Student Financial Assistance Cluster Assistance Listing #: 84.063 and 84.268 Award year: 2022 Compliance Requirement: Special Tests Criteria According to 34 CFR 668.164(h): Title IV, Higher Education Act (“HEA”) credit balances. (1) A title IV, HEA credit balance occurs whenever the amount of title IV, HEA program funds credited to a student's ledger account for a payment period exceeds the amount assessed the student for allowable charges associated with that payment period. (1) A title IV, HEA credit balance must be paid directly to the student or parent as soon as possible, but no later than – (i) No later than 14 days after the balance occurred if the balance occurred after the first day of class of a payment period; or (ii) No later than 14 days after the first day of class of a payment period if the credit balance occurred on or before the first day of that payment period. Condition The Federal Government requires that whenever Title IV aid is disbursed on a student’s account, the account must be reviewed to determine if the disbursement caused a credit balance. If the credit balance was caused by Title IV funds, the College must refund the balance directly to the student within 14 days of the disbursement of funds. During our testing, we noted 15 students, out of a sample of 40, that were not refunded credit balances within the required timeframe by 1-14 days. Our sample was not, and was not intended to be, statistically valid. Cause The College did not implement appropriate internal controls related to disbursements over student's accounts to ensure that refunds were processed for credit balances within the required timeframe. Effect The College failed to refund Title IV credit balances within the required 14-day time frame and therefore was not in compliance with federal requirements. Questioned Costs Not applicable Identification as a Repeat Finding, if applicable Not applicable Recommendation The Business Office should implement effective internal controls to identify credit balances and refund federal aid to students within the required timeframes. This includes reviewing accounts after late disbursements of Title IV aid as well as tuition and fee adjustments, health insurance waivers and bookstore credits. View of Responsible Officials The College agrees with the finding.

Finding number: 2021-002 Federal agency: U.S. Department of Education Programs: Student Financial Assistance Cluster ALN #: 84.268 Award year: 2021 Criteria According to 34 CFR Section 685.304 (a): 1. A school must ensure that entrance counseling is conducted with each Direct Subsidized Loan or Direct Unsubsidized Loan student borrower prior to making the first disbursement of the proceeds of a loan to a student borrower unless the student borrower has received a prior Direct Subsidized Loan, Direct Unsubsidized Loan, Subsidized or Unsubsidized Federal Stafford Loan, or Federal SLS loan. Condition The Federal Government requires that entrance counseling is conducted with Direct Loan borrowers prior to their first disbursement. During our testing, we noted 3 students, out of a sample of 11, did not have entrance counseling prior to their first loan disbursement. Cause The College did not have procedures in place to ensure that entrance counseling was conducted with Direct Loan borrowers prior to their first disbursement. Effect The College did not meet federal requirements and students did not complete entrance counseling before their first disbursements. Questioned Costs Not applicable Perspective Our sample was not, and was not intended to be, statistically valid. Of the 11 students selected for testing, 3 students, or 27% of our sample, did not have entrance counseling completed before their first Direct Loan disbursements. Identification as a Repeat Finding, if applicable N/ARecommendation The College should implement procedures to ensure entrance counseling is completed for a student borrower before their first disbursement of their loan. View of Responsible Officials The College agrees with the finding.

Criteria According to Common Origination and Disbursement ("COD") 2020-2021 Technical Reference: The COD disbursement date is the date the money was credited to the student's account or paid to the student directly for a specific disbursement. Condition The Federal Government requires that the disbursement date reported to the COD match the date the funds were credited to the student's account. During our testing, we noted 10 students, out of a sample of 11, that the date the funds were credited to the student's account did not match the disbursement date reported to COD. Cause The College did not have procedures to ensure the disbursement date per the student's account statement matched the disbursement date reported to COD. Effect The College did not report the correct disbursement dates to the COD. Questioned Costs Not applicable Perspective Our sample was not, and was not intended to be, statistically valid. Of the 10 students selected for testing, 11 students, or 91% of our sample, did not report the correct disbursement date to COD by a range of 1-16 days. Identification as a Repeat Finding, if applicable See finding 2020-003 included in the summary schedule of prior year findings. Recommendation The College should have procedures to ensure that COD disbursement information matches the College's records. View of Responsible Officials The College agrees with the finding.

Finding number: 2021-004 Federal agency: U.S. Department of Education Programs: Student Financial Assistance Cluster Assistance Listing #: 84.063 and 84.268 Award year: 2021 Criteria According to 34 CFR 668.164(l): (1) Notwithstanding any State law (such as a law that allows funds to escheat to the State), an institution must return to the Secretary any title IV, Higher Education Act (?HEA?) program funds, except Federal Work Study (?FWS?) program funds, that it attempts to disburse directly to a student or parent that are not received by the student or parent. For FWS program funds, the institution is required to return only the Federal portion of the payroll disbursement. (2) If an EFT to a student's or parent's financial account is rejected, or a check to a student or parent is returned, the institution may make additional attempts to disburse the funds, provided that those attempts are made not later than 45 days after the EFT was rejected or the check returned. In cases where the institution does not make another attempt, the funds must be returned to the Secretary before the end of this 45-day period. (3) If a check sent to a student or parent is not returned to the institution but is not cashed, the institution must return the funds to the Secretary no later than 240 days after the date it issued the check. Condition Federal regulations require an institution to return unclaimed Title IV funds issued by check or EFT within 240 days. During our testing, we noted one student that had unclaimed funds exceeding the federal day limit by 19 days. Cause The College did not monitor the outstanding check aging to ensure that the 240-day timeframe was met. Effect The College did not return Title IV unclaimed funds to the Department of Education within the required 240-day time frame. Questioned Costs There was one outstanding check that totaled $565, which pertained specifically to federal-sourced funds.Perspective N/A Identification as a Repeat Finding, if applicable N/A Recommendation The College should examine its policies and procedures related to unclaimed funds including the process and time frame for identifying aged balances and the process for cancelling checks and returning funds to the Department of Education. View of Responsible Officials The Colleges agree with the finding.

Finding number: 2021-005 Federal agency: U.S. Department of Education Programs: Student Financial Assistance Cluster Assistance Listing #: 84.063 and 84.268 Award year: 2021 Criteria According to 34 CFR Section 665.300(b): In the program participation agreement, the school must promise to comply with the Act and applicable regulations and must agree to - On a monthly basis, reconcile institutional records with Direct Loan funds received from the Secretary and Direct Loan disbursement records submitted to and accepted by the Secretary; An electronic announcement dated December 18, 2020, described the process by which the Department of Education defines Direct Loan Reconciliation. Direct reconciliation is the process by which Direct Loan funds received and disbursed as recorded on the Department of Education?s systems are reviewed and compared with a school?s internal records and discrepancies are identified and resolved. Condition Federal regulations require the College to reconcile their institutional records with their COD disbursement records. This reconciliation includes identifying discrepancies and resolving them in a timely manner. During our testing, we noted that a variance of $595 from between the COD and the College?s records that was not resolved in a timely manner. Cause The College did not have procedures to ensure that differences found in reconciliations between institutional records and COD's disbursement records were resolved in a timely basis. Effect The College did not meet federal guidelines in performing reconciliations between federal funds disbursed through their institutional records and disbursement records submitted to the COD. Questioned Costs Not applicablePerspective N/A Identification as a Repeat Finding, if applicable See finding 2020-005 included in the summary schedule of prior year findings. Recommendation The College should have procedures in place to ensure that reconciliations are performed between the College's institutional records and disbursement records submitted to the COD. View of Responsible Officials The College agrees with the finding.

Finding number: 2021-006 Federal agency: U.S. Department of Education Programs: Student Financial Assistance Cluster Assistance Listing #: 84.063 and 84.268 Award year: 2021 Criteria According to 34 CFR 685.309(b)(2): Unless [the institution] it expects to submit its next updated enrollment report to the Secretary within the next 60 days, a school must notify the Secretary within 30 days after the date the school discovers that ? (i) A loan under Title IV of the Act was made to or on behalf of a student who was enrolled or accepted for enrollment at the school, and the student has ceased to be enrolled on at least a half-time basis or failed to enroll on at least a half-time basis for the period for which the loan was intended; or (ii) A student who is enrolled at the school and who received a loan under Title IV of the Act has changed his or her permanent address. The Dear Colleague Letter GEN-12-6 issued by the U.S. Department of Education (?ED?) on March 30, 2012, states that in addition to student loan borrowers, Enrollment Reporting files will include two additional groups of students: Pell Grant and Perkins Loan recipients. According to 2 CFR Part 200, Appendix XI Compliance Supplement updated June 2019: Under the Pell Grant and loan programs, institutions must complete and return within 15 days the Enrollment Reporting roster file placed in their Student Aid Internet Gateway mailboxes sent by ED via the National Student Loan Data System (?NSLDS?). The institution determines how often it receives the Enrollment Reporting roster file with the default set at a minimum of every 60 days. Once received, the institution must update for changes in student status, report the date the enrollment status was effective, enter the new anticipated completion date, and submit the changes electronically through the batch method or the NSLDS website. Institutions are responsible for timely reporting, whether they report directly or via a third-party servicer. Condition The Federal Government requires the Colleges to report student enrollment changes to the National Student Loan Data System (?NSLDS?) within 60 days. During our testing of 5 students with enrollment status changes who graduated or withdrew from the institution, we noted the following: 1. One student was reported with the incorrect effective date and reported late2. One student was never reported as withdrawn from the institution. Cause The College did not have procedures in place to ensure that students were reported with the correct enrollment status and within the required timeframe. Effect Student enrollment changes were not processed with the correct enrollment status and were not reported within the required timeframe. Questioned Costs N/A Perspective Our sample was not, and was not intended to be, statistically valid. Of the 5 students selected for testing, 2 students, or 40% of our sample, were either reported incorrectly or not reported within the federal required timeframe. Identification as a Repeat Finding, if applicable See finding 2020-008 included in the summary schedule of prior year findings. Recommendation The College should have procedures in place to ensure student enrollment statuses are reported correctly. View of Responsible Officials The College agrees with the finding.

Finding number: 2021-007 Federal agency: U.S. Department of Education Programs: Student Financial Assistance Cluster Assistance Listing #: 84.063 and 84.268 Award year: 2021 Criteria According to 34 CFR 668.22(e)(4): Total amount of unearned title IV assistance to be returned. The unearned amount of title IV assistance to be returned is calculated by subtracting the amount of title IV assistance earned by the student as calculated under paragraph (e)(1) of this section 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. Condition The Financial Aid Office is responsible for completing the Return of Title IV calculation to determine how much Title IV aid the student earned and how much must be returned to the Department of Education. Once the Return of Title IV calculation is completed, the College is responsible for adjusting the student?s billing statement and returning unearned Title IV funds through the U.S. Department of Education?s Grant Management System (?G5?). The College has 45 days from the date they determined the student withdrew to return any unearned portions of Title IV funds. During our testing, we noted one student, out of a sample of 4, where the aid returned was different than the amount correctly calculated on the Return to Title IV (?R2T4?) form. Cause The College did not ensure that the regulations were met in regard to refunding Title IV funds when calculating the amount of aid to be returned. Effect The College did not return the correct amount of Title IV funds to the Department of Education. Questioned Costs $48 Perspective Our sample was not, and was not intended to be, statistically valid. Of the 4 students selected for testing, one student, or 25% of our sample, had the incorrect amount of Title IV funds returned.Identification as a Repeat Finding, if applicable See finding 2020-007 included in the summary schedule of prior year findings. Recommendation The College should review their current policies and procedures to ensure the amount of federal aid returned agrees with the amount calculated on the R2T4 form. View of Responsible Officials The College agrees with the finding.

Finding number: 2021-008 Federal agency: U.S. Department of Education Programs: Student Financial Assistance Cluster Assistance Listing #: 84.063 and 84.268 Award year: 2021 Criteria According to Volume 5 Withdrawals and the Return of Title IV Funds of the 2020/2021 Federal Student Aid Handbook A school may not know that a student has dropped out ? unofficially withdrawn until it checks its records at the end of academic period. To ensure that Title IV funds are returned within a reasonable period of time, schools must have a procedure for determining when a student who began attendance and received or could have received an initial disbursement of Title IV funds unofficial withdrew (ceased to attend without providing official notification or beginning the official withdrawal process). When students fail to earn a passing grade in any class An institution must have a procedure for determining whether a Title IV recipient who began attendance during a period completed the period or should be treated as a a withdrawal Condition The College is responsible for ensuring there is procedures to determine whether a student who received Title IV aid actually completed the period or should have been treated as a withdrawal. During our testing, we noted two students who failed to earn a passing grade in any class and there was no procedure for determining whether they should be treated as a withdrawal. Cause The College did not have procedures in place to determine whether a student who received Title IV aid actually completed the period or should have been treated as a withdrawal. Effect Students could potentially be over-awarded federal funds if there are no procedures in place to determine whether a student who received Title IV aid actually completed the period or should have been treated as a withdrawal. Questioned Costs UnknownPerspective Our sample was not, and was not intended to be, statistically valid. Of the four students selected for testing, two students, or 50% of our sample, two students did not pass any courses during the semester Identification as a Repeat Finding, if applicable N/A Recommendation The College did not have procedures in place to determine whether a student who received Title IV aid actually completed the period or should have been treated as a withdrawal. View of Responsible Officials The College agrees with the finding.

Finding number: 2021-009 Federal agency: U.S. Department of Education Programs: Student Financial Assistance Cluster Assistance Listing #: 84.063 and 84.268 Award year: 2021 Criteria According to 34 CFR 668.59: a. For the subsidized student financial assistance programs, if an applicant's FAFSA information changes as a result of verification, the applicant or the institution must submit to the Secretary any changes to ? 1. A nondollar item; or 2. A single dollar item of $25 or more. b. For the Federal Pell Grant Program, if an applicant's FAFSA information changes as a result of verification, an institution must ? 1. Recalculate the applicant's Federal Pell Grant on the basis of the EFC on the corrected valid SAR or valid ISIR; and 2. i.Disburse any additional funds under that award only if the institution receives a corrected valid SAR or valid ISIR for the applicant and only to the extent that additional funds are payable based on the recalculation; ii.Comply with the procedures specified in ?668.61 for an interim disbursement if, as a result of verification, the Federal Pell Grant award is reduced; or ? iii.Comply with the procedures specified in 34 CFR 690.79 for an overpayment that is not an interim disbursement if, as a result of verification, the Federal Pell Grant award is reduced. c. For the subsidized student financial assistance programs, excluding the Federal Pell Grant Program, if an applicant's FAFSA information changes as a result of verification, the institution must ? 1. Adjust the applicant's financial aid package on the basis of the EFC on the corrected valid SAR or valid ISIR; and2. i.Comply with the procedures specified in ?668.61 for an interim disbursement if, as a result of verification, the financial aid package must be reduced; ii.Comply with the procedures specified in 34 CFR 673.5(f) for a Federal Perkins loan or an FSEOG overpayment that is not the result of an interim disbursement if, as a result of verification, the financial aid package must be reduced; and iii.Comply with the procedures specified in 34 CFR 685.303(e) for Direct Subsidized Loan excess loan proceeds that are not the result of an interim disbursement if, as a result of verification, the financial aid package must be reduced. Condition The financial aid award process includes consideration of financial and demographic data provided by the student applicant. To evaluate the reliability of this data, a participating institution is required by the Federal Government to select a sample from its student population and verify certain prescribed data. The selected students? files should be revised to incorporate any changes in the supplied data. The College?s policy is to verify the information of those students identified by the Federal Government?s processor. During our testing, we noted 1, out of a sample of 11 students, that had changes due to verification that were not properly updated on the students? ISIR. Cause The College failed to have the proper review procedures in place to ensure that all changes due to the verification process were properly reflected on the students? SAR or ISIR. Effect The students? EFC was calculated using incorrect data. Since the students? EFC is used to calculate the financial aid award, an incorrect EFC can result in an improper award. Questioned Costs N/A Perspective Our sample was not, and was not intended to be, statistically valid. Of the 11 students selected for testing, three were flagged for verification, of which, one students? ISIR or 33% were not updated for the results of the verification changes.Identification as a Repeat Finding, if applicable N/A Recommendation The College should continue to strengthen their controls surrounding verification. The College should implement policies that require all student ISIR?s subject to verification be reviewed once the verification process is complete. The reviewer should be well-versed in the verification process and requirements. Once reviewed, all verified ISIR?s should be re-submitted to the Federal Government?s processor for recalculation of the applicant?s EFC prior to awarding aid. View of Responsible Officials The College agrees with the finding.

Finding number: 2021-010 Federal agency: U.S. Department of Education Programs: Student Financial Assistance Cluster Assistance Listing #: 84.063 and 84.268 Award year: 2021 Criteria According to 34 CFR 668.162 (b): (1) Under the advance payment method, an institution submits a request for funds to the Secretary. The institution's request may not exceed the amount of funds the institution needs immediately for disbursements the institution has made or will make to eligible students and parents. (2) If the Secretary accepts that request, the Secretary initiates an EFT of that amount to the depository account designated by the institution. (3) The institution must disburse the funds requested as soon as administratively feasible but no later than three business days following the date the institution received those funds. Condition Federal requirements require that under the advance payment method, an institution must disburse the funds no later than three business days following the date the institution received those funds. During testing, we noted 10 students out of 11 who had funds disbursed later than three business days after the institution received the funds. Cause The College did not have procedures in place to ensure that federal required cash management regulations were followed. Effect The College did not comply with federal required cash management regulations. Questioned Costs N/A Perspective N/A Identification as a Repeat Finding, if applicable Not applicableRecommendation The College should have procedures to ensure that cash management regulations are followed. View of Responsible Officials The College agrees with the finding.

Criteria According to 34 CFR 668.164(h): Title IV, Higher Education Act (?HEA?) credit balances. (1) A title IV, HEA credit balance occurs whenever the amount of title IV, HEA program funds credited to a student's ledger account for a payment period exceeds the amount assessed the student for allowable charges associated with that payment period. (2) A title IV, HEA credit balance must be paid directly to the student or parent as soon as possible, but no later than ? (i) No later than 14 days after the balance occurred if the balance occurred after the first day of class of a payment period; or (ii) No later than 14 days after the first day of class of a payment period if the credit balance occurred on or before the first day of that payment period. Condition The Federal Government requires that whenever Title IV aid is disbursed on a student?s account, the account must be reviewed to determine if the disbursement caused a credit balance. If the credit balance was caused by Title IV funds, the College must refund the balance directly to the student within 14 days of the disbursement of funds. During our testing, we noted one student, out of a sample of 14, who was not refunded their credit balance within the required timeframe by one day. Cause The College failed to identify Title IV credit balances after federal aid was disbursed on the student's account. Effect The College did not refund Title IV credit balances within the required 14-day time frame and therefore was not in compliance with federal requirements. Questioned Costs $3,208 Perspective Our sample was not, and was not intended to be, statistically valid. Of the 14 students selected for testing, 13 students, or 93% of our sample, had credit balances caused by financial aid. Of these 13 students, one student?s credit balance caused by Title IV funds was not refunded within the required time frame (8% of students who had credit balances). Identification as a Repeat Finding, if applicable Not applicable Recommendation The Business Office should continue to develop their procedures to identify credit balances caused by changes on students? accounts as well as disbursements. This includes reviewing accounts after late disbursement of Title IV aid as well as tuition and fee adjustments, health insurance waivers and bookstore credits. View of Responsible Officials The College agrees with the finding.

Criteria According to Common Origination and Disbursement ("COD") 2019-2020 Technical Reference: The COD disbursement date is the date the money was credited to the student's account or paid to the student directly for a specific disbursement. Condition The Federal Government requires that the disbursement date reported to the COD match the date the funds were credited to the student's account. During our testing, we noted 14 students, out of a sample of 14, that the date the funds were credited to the student's account did not match the disbursement date reported to COD. Cause The College did not have procedures to ensure the disbursement date per the student's account statement matched the disbursement date reported to COD. Effect The College did not report the correct disbursement dates to the COD. Questioned Costs Not applicable Perspective Our sample was not, and was not intended to be, statistically valid. Of the 14 students selected for testing, 14 students, or 100% of our sample, did not report the correct disbursement date to COD by a range of 2-25 days. Identification as a Repeat Finding, if applicable Not applicable Recommendation The College should have procedures to ensure that COD disbursement information matches the College's records. View of Responsible Officials The College agrees with the finding.

Criteria According to 34 CFR Section 668.165(a): (1) Before an institution disburses title IV, HEA program funds for any award year, the institution must notify a student of the amount of funds that the student or his or her parent can expect to receive under each title IV, HEA program, and how and when those funds will be disbursed. If those funds include Direct Loan program funds, the notice must indicate which funds are from subsidized loans, which are from unsubsidized loans, and which are from PLUS loans. (2) Except in the case of a post-withdrawal disbursement made in accordance with ?668.22(a)(5), if an institution credits a student ledger account with Direct Loan, Federal Perkins Loan, or TEACH Grant program funds, the institution must notify the student or parent of ? (i) The anticipated date and amount of the disbursement; (ii) The student's or parent's right to cancel all or a portion of that loan, loan disbursement, TEACH Grant, or TEACH Grant disbursement and have the loan proceeds or TEACH Grant proceeds returned to the Secretary; and (iii) The procedures and time by which the student or parent must notify the institution that he or she wishes to cancel the loan, loan disbursement, TEACH Grant, or TEACH Grant disbursement. (3) The institution must provide the notice described in paragraph (a)(2) of this section in writing ? (i) No earlier than 30 days before, and no later than 30 days after, crediting the student's ledger account at the institution, if the institution obtains affirmative confirmation from the student under paragraph (a)(6)(i) of this section; or (ii) No earlier than 30 days before, and no later than seven days after, crediting the student's ledger account at the institution, if the institution does not obtain affirmative confirmation from the student under paragraph (a)(6)(i) of this section. Condition Federal regulations require the College to notify students, within the required timeframe, of Direct Loan disbursements to the student?s account. During our testing, we noted 12 students who received Direct Loans, out of a sample of 12, who were never notified of their Direct Loan disbursements to their student account. Cause The College did not have procedures in place to ensure that loan notifications were sent to students when loan disbursements were credited to the student's account. Effect The College did not meet federal guidelines in providing students notifications each time a loan disbursement was credited to the students' account. In addition, students were not made aware immediately before or after the loans were credited to their account. Questioned Costs Not applicable Perspective Our sample was not, and was not intended to be, statistically valid. Of the 14 students selected for testing, 12 students, or 86% of our sample, had Direct Loan disbursements. Of these 12 students, 12 of the students were not sent notifications. (100% of students who had Direct Loans) Identification as a Repeat Finding, if applicable Not applicable Recommendation The College should have procedures in place to ensure that loan notifications are sent to students. View of Responsible Officials The College agrees with the finding.

Criteria According to 34 CFR Section 665.300(b): In the program participation agreement, the school must promise to comply with the Act and applicable regulations and must agree to - On a monthly basis, reconcile institutional records with Direct Loan funds received from the Secretary and Direct Loan disbursement records submitted to and accepted by the Secretary; Condition Federal regulations require the College to reconcile their institutional records with their COD disbursement records. During our testing, we noted that no reconciliations were performed between the College's institutional records and COD?s disbursement records. Cause The College did not have procedures to ensure that reconciliations were performed between institutional records and COD's disbursement records. Effect The College did not meet federal guidelines in performing reconciliations between federal funds disbursed through their institutional records and disbursement records submitted to the COD. Therefore, on a monthly basis, the College could not be certain that its records matched with federal records. Questioned Costs Not applicable Perspective N/A Identification as a Repeat Finding, if applicable Not applicable Recommendation The College should have procedures in place to ensure that reconciliations are performed between the College's institutional records and disbursement records submitted to the COD. View of Responsible Officials The College agrees with the finding.

Criteria According to 34 CFR 668.22(b): Withdrawal date for a student who withdraws from an institution that is required to take attendance. For purposes of this section, for a student who ceases attendance at an institution that is required to take attendance, including a student who does not return from an approved leave of absence, as defined in paragraph (d) of this section, or a student who takes a leave of absence that does not meet the requirements of paragraph (d) of this section, the student's withdrawal date is the last date of academic attendance as determined by the institution from its attendance records. Condition When a recipient of Title IV funds withdraws from an institution during a payment period or period of enrollment in which the recipient began attendance, the institution should determine the proper amount of Title IV funds to be refunded as of the recipient?s withdrawal date. Once a recipient?s withdrawal date is determined, an institution should complete a Return of Title IV (?R2T4?) calculation. The R2T4 is used to calculate the percentage of the payment period or period of enrollment completed, establish the amount of Title IV funds earned by the recipient, and determine the amount required to be returned to the Department of Education. During our testing, we noted 2 students, out of a sample of 3, where the Return of Title IV calculations were completed using the incorrect withdrawal dates. Cause The College did not have procedures to ensure that procedures were in place to ensure withdrawal dates per the College's records matched the R2T4 form. Effect The withdrawal date per R2T4 form did not match the College's records. Questioned Costs $3,694 Perspective Our sample was not, and was not intended to be, statistically valid. Of the 3 students selected for testing, 2 students, or 67% of our sample, did not have a withdrawal date on their R2T4 form that matched the College's records. Identification as a Repeat Finding, if applicable Not applicable Recommendation The College should have procedures to ensure that the withdrawal date from the institution's records match the withdrawal date from the R2T4 form. View of Responsible Officials The College agrees with the finding.

Criteria According to 34 CFR 668.22(e)(4): Total amount of unearned title IV assistance to be returned. The unearned amount of title IV assistance to be returned is calculated by subtracting the amount of title IV assistance earned by the student as calculated under paragraph (e)(1) of this section 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. Condition The Financial Aid Office is responsible for completing the Return of Title IV calculation to determine how much Title IV aid the student earned and how much must be returned to the Department of Education. Once the Return of Title IV calculation is completed, the College is responsible for adjusting the student?s billing statement and returning unearned Title IV funds through the U.S. Department of Education?s Grant Management System (?G5?). The College has 45 days from the date they determined the student withdrew to return any unearned portions of Title IV funds. During our testing, we noted one student where the aid returned was different than the amount correctly calculated on the Return to Title IV (?R2T4?) form and one student who had unearned Title IV aid that was not returned to the Federal Government, within 45 days of the determined withdrawal date, by 20 days. Cause The College did not have procedures to ensure that aid returned on the student account statement matched the R2T4 form. Effect The aid returned on the student's records did not match the aid returned on the R2T4 form. Questioned Costs $1,273 Perspective Our sample was not, and was not intended to be, statistically valid. Of the 3 students selected for testing, 2 students, or 67% of our sample, had either their aid returned incorrectly or was not returned within the federal required timeframe. Identification as a Repeat Finding, if applicable Not applicable Recommendation The College should have procedures to ensure that the aid returned from the institution's records match the calculated amount to return on the R2T4 form. View of Responsible Officials The College agrees with the finding.

Criteria According to 34 CFR 685.309(b)(2): Unless [the institution] it expects to submit its next updated enrollment report to the Secretary within the next 60 days, a school must notify the Secretary within 30 days after the date the school discovers that ? (i) A loan under Title IV of the Act was made to or on behalf of a student who was enrolled or accepted for enrollment at the school, and the student has ceased to be enrolled on at least a half-time basis or failed to enroll on at least a half-time basis for the period for which the loan was intended; or (ii) A student who is enrolled at the school and who received a loan under Title IV of the Act has changed his or her permanent address. The Dear Colleague Letter GEN-12-6 issued by the U.S. Department of Education (?ED?) on March 30, 2012 states that in addition to student loan borrowers, Enrollment Reporting files will include two additional groups of students: Pell Grant and Perkins Loan recipients. According to 2 CFR Part 200, Appendix XI Compliance Supplement updated June 2019: Under the Pell Grant and loan programs, institutions must complete and return within 15 days the Enrollment Reporting roster file placed in their Student Aid Internet Gateway mailboxes sent by ED via the National Student Loan Data System (?NSLDS?). The institution determines how often it receives the Enrollment Reporting roster file with the default set at a minimum of every 60 days. Once received, the institution must update for changes in student status, report the date the enrollment status was effective, enter the new anticipated completion date, and submit the changes electronically through the batch method or the NSLDS website. Institutions are responsible for timely reporting, whether they report directly or via a third-party servicer. Condition The Federal Government requires the Colleges to report student enrollment changes to the National Student Loan Data System (?NSLDS?) within 60 days. During our testing of five students with enrollment status changes who graduated or withdrew from the institution, we noted the following: 1. One student was reported with the incorrect effective date. 2. One student was reported with the incorrect enrollment status and with an incorrect effective date. Cause The College did not have procedures in place to ensure that students were reported with the correct enrollment status and within the required timeframe. Effect Student enrollment changes were not processed with the correct enrollment status and were not reported within the required timeframe. Questioned Costs N/A Perspective Our sample was not, and was not intended to be, statistically valid. Of the 5 students selected for testing, 2 students, or 40% of our sample, were either reported incorrectly or not reported within the federal required timeframe. Identification as a Repeat Finding, if applicable Not applicable Recommendation The College should have procedures in place to ensure student enrollment statuses are reported correctly. View of Responsible Officials The College agrees with the finding.

Criteria According to Volume 3 Page 122 of the 2019-2020 Student Financial Aid Handbook: For these students [independent undergraduate], the annual loan limits are: ? $3,500 combined Direct Subsidized and/or Direct Unsubsidized plus $6,000 additional Direct Unsubsidized for independent first-year undergraduates; ? $4,500 combined Direct Subsidized and/or Direct Unsubsidized plus $6,000 additional Direct Unsubsidized for independent second-year undergraduates; and ? $5,500 combined Direct Subsidized and/or Direct Unsubsidized plus $7,000 additional Direct Unsubsidized for independent third-, fourth-, or fifth-year undergraduates. Condition Federal regulations require the College award Direct Loans based on a student?s grade level at the beginning of a semester. During our testing, we noted 2 students, out of a sample of 14, who were awarded more than the annual loan limits. Cause The College did not have procedures in place to ensure that students were not awarded above the federal required annual loan limits. Effect The College over-awarded direct loans to disbursements based on the student's grade level. Questioned Costs $1,500 Perspective Our sample was not, and was not intended to be, statistically valid. Of the 14 students selected for testing, 2 students, or 14% of the sample, were awarded over their annual loan limits. Identification as a Repeat Finding, if applicable Not applicable Recommendation The College should have procedures to ensure that students are not awarded above the federal required annual loan limits. View of Responsible Officials The College agrees with the finding.

Criteria According to 34 CFR 668.162 (b): (1) Under the advance payment method, an institution submits a request for funds to the Secretary. The institution's request may not exceed the amount of funds the institution needs immediately for disbursements the institution has made or will make to eligible students and parents. (2) If the Secretary accepts that request, the Secretary initiates an EFT of that amount to the depository account designated by the institution. (3) The institution must disburse the funds requested as soon as administratively feasible but no later than three business days following the date the institution received those funds. Condition Federal requirements require that under the advance payment method, an institution must disburse the funds no later than three business days following the date the institution received those funds. During testing, we noted 14 students out of 14 who had funds disbursed later than three business days after the institution received the funds by a range of 1 to 22 days. Cause The College did not have procedures in place to ensure that federal required cash management regulations were followed. Effect The College did not comply with federal required cash management regulations. Questioned Costs N/A Perspective N/A Identification as a Repeat Finding, if applicable Not applicable Recommendation The College should have procedures to ensure that cash management regulations are followed. View of Responsible Officials The College agrees with the finding.