OTTAWA UNIVERSITYHigher Education

Finding 2025-001 – Significant Deficiency, Compliance and Control Federal Award No. 84.268, 84.063 U.S. Department Of Education Student Financial Aid Cluster – Special Tests and Provisions Criteria: According to 34 CFR Section 685.309(b), upon receipt of an enrollment report from the Secretary, a school must update all information included in the report and return it to the Secretary in the manner and format prescribed by the Secretary and with the timeframe prescribed by the Secretary. According to the Federal Student Aid Handbook, Volume 2, Chapter 3, a university must report changes in student’s enrollment status, the effective date of the status, and an anticipated completion date to NSLDS. Changes in enrollment to less than half-time, graduated, or withdrawn must be reported within 60 days of the withdrawal determination date for schools that submit roster files to NSLDS. Condition: In our nonstatistical sample of 40 students, it was noted for 8 individuals the students’ reported status within NSLDS was not updated as withdrawn or graduated within 60 days of the date of withdrawal or graduation. Context: When degrees were conferred after initial reporting, then the Registrar's office needed to manually update the Clearinghouse with the correct information. This manual process did not take place for these students. Effect: Students may not enter repayment or their grace period within the appropriate timeframe from their exit from the University or students may not receive adequate notice of the timing of their grace period. The Department of Education may not have the correct data to utilize. Questioned Costs: There were no questioned costs to report as the finding relates only to enrollment reporting and is not related to eligibility. Cause: The University does not have proper processes and related controls in place to complete the required updates to NSLDS for reporting changes in enrollment status within the 60 day requirement. Indication Of Repeat Finding: This is not a repeat finding. Recommendation: The Registrar department should review and consider revisions to its processes and related controls in place to ensure completion of updates to NSLDS within the required 60 day timeframe Views Of Responsible Officials/Corrective Action Plan (Unaudited): The Registrar and the IT department are working together to ensure timely and accurate data is being transmitted on a regular schedule to the Clearinghouse as needed. When date determination exceptions occur (e.g., degrees being conferred after initial reporting or withdrawal dates being retroactively determined for administrative purposes), the Registrar’s Office, IT, and Financial Aid will work together to determine the appropriate date adjustments needed to manually update the Clearinghouse with the correct information if needed as quickly as possible. Anticipated Completion Date: June 30, 2026 Contact Person: Julie McAdoo, University Registrar

Finding 2025-002 – Significant Deficiency, Compliance and Control Federal Award No. 84.268 & 84.063 U.S. Department of Education Student Financial Aid Cluster – Special Tests and Provisions Criteria: According to the Federal Student Aid Handbook, Volume 4, Chapter 2, a University must disburse a Title IV credit balance to a student no later than 14 days after the date it was created or no later than 14 days after the first day of class. Condition: In our nonstatistical sample of 40 students, it was noted for 11 individuals that the credit balances generated by the federal funding were paid to the students in 15 days or more after the credit balance was created. Context: For the 11 students noted, loan disbursements including PLUS Loans generated a credit balance when disbursed separately from the individual awards which were then paid to the students in 15 days or more after the credit balance was created. Effect: Funds are held by the University that should be paid to the student. Questioned Costs: There were no questioned costs to report as this finding relates to the timing of disbursements and is not related to eligibility. Cause: Ottawa University did not have proper processes and related controls in place to complete the disbursement within 14 days from the date the credit balance was created. Indication As Repeat Finding: This is a repeat finding. See the Summary Schedule for Prior Audit Findings. Recommendation: The Financial Aid department should review and consider revisions to its processes and related controls in place to complete the disbursement requirements for all students who have a credit balance no later than 14 days after the date it was created or no later than 14 days after the first day of class. Views Of Responsible Officials (Unaudited): This finding is related to the transition to a new Jenzabar One (J1) ERP system. The Jenzabar Financial Aid (JFA) module, while now integrated into the broader J1 suite, remains a stand-alone solution rather than a fully native component. As a result, Ottawa University needed to modify its financial aid refund disbursement processes to ensure accurate and efficient data flow between systems. These adjustments created challenges in achieving the timely distribution of student refunds. The primary issue involved the timely processing of PLUS Loan refunds. Parent IDs for these refunds were extracted from financial aid data in JFA and established as individual vendors in J1. These IDs then needed to be properly linked to the corresponding student before any parent refunds could be issued. To address this, Financial Aid has designated staff to oversee the creation and linking of parent IDs in J1 to ensure timely processing. Additionally, reports have been developed to identify accounts eligible for refunds, helping to ensure compliance with the 14-day requirement. The Accounting Department also encountered challenges related to vendor setup and the ability to process student refunds in batches. To address these issues, we collaborated with the J1 support team and IT to customize the system, ensuring that student refund checks could be processed and formatted in accordance with bank specifications. While we were not initially prepared for these challenges and had to adapt throughout the process, a solution has since been implemented. As a result, check printing has become an efficient and streamlined operation. The Student Accounts Receivable Office, Controller’s Office, Financial Aid, and IT departments are actively collaborating to establish a more structured and efficient process for managing Federal Student Aid. The first step has been to implement a weekly workflow with clearly defined responsibilities and completion timelines as follows: Financial Aid posts all activity at the beginning of the week, followed by Student Accounts generating credit balance refund reports and initiating student refunds. Accounting then completes the process by issuing refunds to students via check or direct deposit. In addition, Student Accounts and IT are working to develop a date-specific report to identify students with current financial aid disbursements who have outstanding credit balances. This detective control report will be reviewed weekly, and refunds will be processed in accordance with the established workflow. The departments are also developing a detailed Accounts Receivable Aging Report to help the Receivables team more effectively identify any students who have a credit balance. This effort is intended to ensure full compliance with the 14-day requirement outlined in the Federal Student Aid Handbook. Anticipated Completion Date: June 30, 2026 Contact Person: Heather Long, Director Student Accounts

Finding 2025-003 – Significant Deficiency, Compliance and Control Federal Award No. 84.268, 84.063 U.S. Department of Education Student Financial Aid Cluster – Special Tests and Provisions Criteria: According to the Federal Student Aid Handbook, Federal regulations require institutions to maintain accounting records that accurately reflect the receipt and disbursement of Title IV funds on a current basis and provide a clear audit trail from drawdown through disbursement. Condition: In our nonstatistical sample of 40 students, it was noted for 30 individuals that the institution reported disbursements to the Common Origination and Disbursement (COD) system on dates that did not agree to the dates the disbursements were recorded in the general ledger. Context: Differences noted were between 1 and 5 days, except for one student where the difference was 8 days. Effect: The University’s accounting records did not consistently support the disbursement dates reported to COD. Questioned Costs: None Cause: Ottawa University did not have proper processes and related controls in place to complete COD documentation in the COD system on dates that agreed to the dates the disbursements were recorded in the general ledger. Indication As Repeat Finding: Not a repeat finding. Recommendation: The University should ensure that disbursement dates reported to COD agree with the actual disbursement dates recorded in the general ledger or are fully supported by subsidiary records. Views Of Responsible Officials (Unaudited): Student Financial Aid and Accounts Receivable will work in coordination to sync the process of importing files and posting to accounts on the same day. Our new ERP has streamlined reporting to COD and catches and corrects any date discrepancies between the two systems. This finding was directly related to the migration from our old system and the disruption of data flow. Additionally, a review for matching COD disbursement dates will now be included during the monthly reconciliation process moving forward as a second layer of quality control. Anticipated Completion Date: June 30, 2026 Contact Person: Mary Reed, Director of Financial Aid & Advising

Finding 2025-004 – Significant Deficiency, Compliance and Control Federal Award No. 84.116z U.S. Department of Education Fund for the Improvement of Postsecondary Education – Procurement Criteria: Under 2 CFR Part 200 Subpart D – Procurement Standards, entities must use competitive bidding to promote full and open competition and entities must verify that vendors in covered transactions are not suspended or debarred by checking SAM.gov, obtaining certification, or including an appropriate contract clause. Condition: The University did not document price or rate quotations for an adequate number of qualified sources for procurement transactions that were higher than the micro-purchase threshold and that did not exceed the simplified acquisition threshold. The University did not document verification that a vendor receiving federal funds was not suspended or debarred. For all vendors tested, no SAM.gov check, vendor certification, or contract clause was on file. Context: For the three vendors tested, there was no documentation retained to confirm the vendors were not suspended or debarred at the time of the transaction or evidence of price or rate quotations from an adequate number of qualified sources for procurement transactions that were higher than the micro-purchase threshold and that did not exceed the simplified acquisition threshold. Effect: Federal funds could be spent with limited competition on ineligible vendors. No suspended or debarred vendors were identified during audit procedures. Questioned Costs: There were no questioned costs to report as the vendors selected for testing were verified by the auditor to be eligible at the time of the transaction. Cause: Ottawa University did not have proper processes and related controls in place to consistently require or document suspension/debarment checks or perform and document price or rate quotations. Indication As Repeat Finding: This is not a repeat finding. Recommendation: Implement controls to ensure suspension and debarment checks and price or rate quotations are completed and documented before awarding federally funded contracts. Views Of Responsible Officials (Unaudited): Management agrees with the finding. The University will update its procurement procedures to require documented verification of vendor eligibility prior to award and when using the simplified acquisition procedure and to obtain price or rate quotations from an adequate number of qualified sources. Anticipated Completion Date: June 30, 2026 Contact Person: Tom Corley, Controller

Finding 2023-001 - Significant Deficiency, Compliance and Control Federal Assistance Listing No. 84.425E U.S. Department Of Education ESF Section 2 - Higher Education (Higher Education Emergency Relief Fund (HEERF)) - Reporting Criteria: 2 CFR section 200.328 and 2 CFR section 200.329 requires grantees to submit quarterly reports for both student and institutional portions along with an annual report to the Department of Education. Condition: In our nonstatistical testing of 2 quarterly reports and 1 annual report, it was noted that for the one student report selected, the appropriate form was not used for reporting the current period activity and the report was not posted timely to the Ottawa University website as required. Cause: Management based the reporting requirement on previous guidance that did not require the use of a specific form to report the required data. Updated guidance required a specific form to use. The University did not use the required form, and the information was uploaded to the Ottawa University website 344 days after the deadline. Effect: Information on student disbursements was not available in the required format or required timeframe. Questioned Costs: Not applicable Context: One student report from our sample was not reported in conformity with the guidance. Identification As A Repeat Finding: Not a repeat finding. Recommendation: We recommend that management develop a system with appropriate controls that allows for implementing the most recent guidance on HEERF reporting.Views Of Responsible Officials: See Corrective Action Plan. Completion Date: March 2024 Contact Person: Donna Ferguson, Controller and Director of Fiscal Operations, and Carrie Stevens, Associate Vice President of Compliance

Finding 2022-001 ? Significant Deficiency, Compliance and Control Federal Award No. 84.268, 84.007, 84.033, 84.038, 84.063 & 84.379 U.S. Department Of Education Student Financial Aid Cluster ? Special Tests and Provisions Criteria: According to 34 CFR Section 685.309(b), upon receipt of an enrollment report from the Secretary, a school must update all information included in the report and return it to the Secretary in the manner and format prescribed by the Secretary and with the timeframe prescribed by the Secretary. According to the Federal Student Aid Handbook, Volume 2, Chapter 3, a university must report changes in student?s enrollment status, the effective date of the status, and an anticipated completion date to NSLDS. Changes in enrollment to less than half-time, graduated, or withdrawn must be reported within 60 days of the withdrawal determination date for schools that submit roster files to NSLDS. Condition: In our nonstatistical sample of 40 students, it was noted for 4 individuals the students? reported status within NSLDS was not updated as withdrawn or graduated within 60 days of the date of withdrawal or graduation. In our nonstatistical sample of 45 students, it was noted for 4 other individuals the students? reported status within NSLDS was timely updated to ?Withdrawn? but was not updated to ?Graduated? status. Context: When degrees were conferred after initial reporting, then the Registrar's office needed to manually update the Clearinghouse with the correct information. This manual process did not take place for these students. Effect: Students may not enter repayment or their grace period within the appropriate timeframe from their exit from the University or students may not receive adequate notice of the timing of their grace period. The Department of Education may not have the correct data to utilize. Questioned Costs: There were no questioned costs to report as the finding relates only to enrollment reporting and is not related to eligibility. Cause: The University does not have proper processes and related controls in place to complete the required updates to NSLDS for reporting changes in enrollment status within the 60 day requirement. Indication Of Repeat Finding: Enrollment Reporting is a repeat finding from the immediate prior year; see Summary Schedule of Prior Audit Findings 2021-001. Recommendation: The Registrar department should review and consider revisions to its processes and related controls in place to ensure completion of updates to NSLDS within the required 60 day timeframe. Views Of Responsible Officials/Corrective Action Plan (Unaudited): The Registrar and the IT department are working together to ensure timely and accurate data is being transmitted on a regular schedule to the Clearinghouse as needed. When date determination exceptions occur (e.g., degrees being conferred after initial reporting or withdrawal dates being retroactively determined for administrative purposes), the Registrar?s Office, IT, and Financial Aid will work together to determine the appropriate date adjustments needed to manually update the Clearinghouse with the correct information if needed as quickly as possible. Completion Date: June 30, 2023 Contact Person: Julie McAdoo, University Registrar

Finding 2022-002 ? Significant Deficiency, Compliance and Control Federal Award No. 84.268, 84.007, 84.033, 84.038, 84.063 & 84.379 U.S. Department of Education Student Financial Aid Cluster ? Special Tests and Provisions Criteria: According to the Federal Student Aid Handbook, Volume 4, Chapter 2, a University must disburse a Title IV credit balance to a student no later than 14 days after the date it was created or no later than 14 days after the first day of class. Condition: In our nonstatistical sample of 40 students, it was noted for three individuals that the credit balances generated by the federal funding were paid to the students between 15 and 33 days after the credit balance was created. Context: For the three students noted, loan disbursements including PLUS Loans generated a credit balance when disbursed separately from the individual awards which were then paid to the students between 15 and 33 days after the credit balance was created. Effect: Funds are held by the University that should be paid to the student. Questioned Costs: There were no questioned costs to report as this finding relates timing of disbursements and is not related to eligibility. Cause: Ottawa University did not have proper process and related controls in place to complete the return within 14 days from the date the credit balance was created. Indication As Repeat Finding: This is a not a repeat finding. Recommendation: The Financial Aid department should review and consider revisions to its processes and related controls in place to complete the disbursement requirements for all students who have a credit balance no later than 14 days after the date it was created or no later than 14 days after the first day of class. Views Of Responsible Officials (Unaudited): Student Accounts Receivable, Controller?s Office, and IT are working together to develop more real-time reporting and tracking for student account refund balances to identify student accounts with refund balances that remain undistributed more than seven days after being created to prioritize those accounts for refund processing. Completion Date: June 30, 2023 Contact Person: Heather Long, Director Student Accounts

Finding 2022-003 ? Significant Deficiency, Compliance and Control Federal Assistance Listing No. 84.425E U.S. Department Of Education ESF Section 2 ? Higher Education (Higher Education Emergency Relief Fund (HEERF)) - Reporting Criteria: 2 CFR section 200.328 and 2 CFR section 200.329 requires grantees to submit quarterly reports for both student and institutional portions along with an annual report to the Department of Education. Condition: In our nonstatistical testing of 2 quarterly reports and 1 annual report, it was noted that for the one student report selected, the University excluded a subset of non-Title IV eligible students from the estimated total number of students at the institution that are eligible to receive Emergency Financial Aid Grants to Students under the CARES (a)(1) subprogram and the CRRSAA and ARP (a)(1) subprograms. Cause: Management based the reporting requirement on the HEERF 1 guidance, which had more stringent eligibility requirements, in reporting the estimated total number of students at the institution that are eligible to receive Emergency Financial Aid Grants to Students under the CARES (a)(1) subprogram and the CRRSAA and ARP (a)(1) subprograms. Effect: The estimated total number of students at the institution eligible to receive emergency financial aid grants to students reported was less than the actual by approximately 400 students. Questioned Costs: Not applicable Context: One item on the selected student report was not reported in conformity with the guidance. Identification As A Repeat Finding: Not a repeat finding. Recommendation: We recommend that management develop a system with appropriate controls that allows for implementing the most recent guidance on HEERF reporting. Views Of Responsible Officials/Corrective Action Plan (Unaudited): The Controller and Compliance Officers are working together to correct the previously filed reports to update the estimated total number of students at the institution that are eligible to receive Emergency Financial Aid Grants to Students under the CARES (a)(1) subprogram and the CRRSAA and ARP (a)(1) subprograms. Completion Date: April 2023 Contact Person: Tom Corley, Controller and Director of Fiscal Operations and Carrie Stevens, Associate Vice President of Compliance

Finding 2021-001 ? Enrollment Reporting Federal Award No. 84.268, 84.007, 84.033, 84.038, 84.063 & 84.379 U.S. Department Of Education Student Financial Aid Cluster Criteria: According to 34 CFR Section 685.309(b), upon receipt of an enrollment report from the Secretary, a school must update all information included in the report and return it to the Secretary in the manner and format prescribed by the Secretary and with the timeframe prescribed by the Secretary. According to the Federal Student Aid Handbook, Volume 2, Chapter 3, a university must report changes in student?s enrollment status, the effective date of the status, and an anticipated completion date to NSLDS. Changes in enrollment to less than half-time, graduated, or withdrawn must be reported within 60 days of the withdrawal determination date for schools that submit roster files to NSLDS. Condition: In our nonstatistical sample of 45 students, it was noted for 3 individuals the students? reported status within NSLDS was not updated in accordance with the guidelines. Context: We noted for the three students included above that the University initially submitted information through its agent, the National Student Clearinghouse (Clearinghouse), timely, however the information submitted for the three students noted did not follow the Clearinghouse convention for their social security numbers. Ultimately, the students? data did not pass through the Clearinghouse and the statuses of the students were not updated to graduated within NSLDS within 60 days of the students? graduation dates. Effect: Students may not enter repayment or their grace period within the appropriate timeframe from their exit from the University or students may not receive adequate notice of the timing of their grace period. The Department of Education may not have the correct data to utilize. Questioned Costs: There were no questioned costs to report as the finding relates only to enrollment reporting and is not related to eligibility. Cause: The University does not have proper processes and related controls in place to complete the required updates to NSLDS for reporting changes in enrollment status within the 60 day requirement. Indication Of Repeat Finding: Enrollment Reporting is a repeat finding from the immediate prior year; see Summary Schedule of Prior Audit Findings 2020-002. Recommendation: The Registrar department should review and consider revisions to its processes and related controls in place to ensure completion of updates to NSLDS within the required 60 day timeframe. Views Of Responsible Officials/Corrective Action Plan (Unaudited): The Registrar and the IT department have worked together to ensure that timely and accurate data is being transmitted on a regular schedule to the Clearinghouse. When exceptions like these occur (e.g. degrees being conferred after initial reporting), the Registrar?s office will manually update the Clearinghouse with the correct information as quickly as possible. Completion Date: December 31, 2021 Contact Person: Margaret Herron, University Registrar

Finding 2020-001 - Significant Deficiency Federal Award No. 84.268 & 84.379 U.S. Department Of Education Student Financial Aid Cluster Criteria: According to the Federal Student Financial Aid Handbook, Volume 4, Chapter 2, ?Except in the case of loan funds made as a part of a post-withdrawal disbursement, when Direct Loan or TEACH funds are being credited to a student?s account, the school must also notify the borrower in writing (paper or electronically) of the: anticipated date and amount of the disbursement; borrower?s right to cancel all or a part of the loan, loan disbursement, TEACH Grant, or TEACH Grant disbursement; and procedures for canceling a Direct Loan or TEACH Grant including the time by which the borrower must notify the school that he or she wishes to cancel the loan, loan disbursement, TEACH Grant, or TEACH Grant disbursement.? Due to the University obtaining affirmative confirmation, the notification must be sent ?no earlier than 30 days before and no later than 30 days after crediting the student?s account.? Condition: In our nonstatistical sample of 40 students, it was noted that 1 student did not receive written notification of their loan disbursement within 30 days of the loan disbursement date in Spring 2020, and 1 student did not receive written notification of the student?s Fall 2019 or Spring 2020 TEACH Grant disbursement within 30 days of the respective disbursement dates. Context: We noted that both exceptions were missed due to automated processes not including these two students in the notification listings. Subsequent follow-up was completed once it was determined notifications were not sent. Effect: Students may not be properly notified of their rights and responsibilities with regard to loans being credited to their accounts. Questioned Costs: Since students were not properly notified of their right to cancel loans on a timely basis, it is possible that eligible students may have chosen to cancel their disbursements/loans. It is not possible at this time to estimate the number of students that might have considered this option had they been properly notified; therefore, we cannot estimate a monetary amount of questioned costs. No exceptions related to student eligibility were noted. Cause: The University does not have proper processes and related controls in place to notify students (or parents) of the required information, within the proper timeframe, when crediting the student accounts with loan funds. Recommendation: The Financial Aid department should review and consider revisions to its processes and related controls in place to notify students (or parents) of the required information, within the proper timeframe, when crediting student accounts with loan funds. Views Of Responsible Officials/Corrective Action Plan (Unaudited): The software used to create the list of email recipients resets date parameters when generating data from multiple months. This is now a known issue and we will be more cautious when running the report to ensure that this does not continue to be a problem. Completion Date: October 31, 2020 Contact Person: Howard Fischer, Director of Financial Aid

Finding 2020-002 ? Significant Deficiency Federal Award No. 84.268, 84.007, 84.033, 84.038, 84.063 & 84.379 U.S. Department Of Education Student Financial Aid Cluster Criteria: According to the Federal Student Aid Handbook, Volume 2, Chapter 3, a university must report changes in student?s enrollment status, the effective date of the status, and an anticipated completion date to NSLDS. Changes in enrollment to less than half-time, graduated, or withdrawn must be reported within 60 days of the withdrawal determination date for schools that submit roster files to NSLDS. Condition: In our nonstatistical sample of 46 students, it was noted for 5 individuals the students? reported status within NSLDS was not updated to graduated within 60 days of the students? graduation dates. Context: We noted for three students that the University had reported the students properly as withdrawn once the student ceased attendance but before graduation had been conferred. Once graduation had been conferred for these students, the students? statuses were not updated to graduated within NSLDS within 60 days of the students? graduation dates. We noted for one student, the student had been reported as graduated within NSLDS from an undergraduate program effective April 15, 2018; however, the student re-enrolled in a graduate program at least half-time in Fall 2018 and graduated from the graduate program on September 30, 2019. This student was never reported as enrolled in the graduate program and was therefore also not reported as graduated within NSLDS. We noted for one student that the student graduated in May 2020 and the University failed to update the student?s status in NSLDS as graduated within 60 days of the student?s graduation with the student still being reported as enrolled full-time. Effect: Students may not enter repayment or their grace period within the appropriate timeframe from their exit from the University or students may not receive adequate notice of the timing of their grace period. The Department of Education may not have the correct data to utilize. Questioned Costs: There were no questioned costs to report as the finding relates only to enrollment reporting and is not related to eligibility. Cause: The University does not have proper processes and related controls in place to complete the required updates to NSLDS for reporting changes in enrollment status within the 60 day requirement. Indication of Repeat Finding: This is a repeat finding from the immediate prior year; see Summary Schedule of Prior Audit Findings 2019-001. Recommendation: The Registrar department should review and consider revisions to its processes and related controls in place to ensure completion of updates to NSLDS within the required 60 day timeframe. Views Of Responsible Officials/Corrective Action Plan (Unaudited): The Registrar and the IT department have worked together to ensure that timely and accurate data is being transmitted on a regular schedule to the Clearinghouse. When exceptions like these occur (e.g. degrees being conferred after initial reporting), the Registrar?s office will manually update the Clearinghouse with the correct information as quickly as possible. Completion Date: October 31, 2020 Contact Person: Margaret Herron, University Registrar

Finding 2019-001 ? Significant Deficiency Federal Award No. 84.268, 84.007, 84.033, 84.038, 84.063 & 84.379 U.S. Department Of Education Student Financial Aid Cluster Criteria: According to the Federal Student Aid Handbook, Volume 2, Chapter 3, a university must report changes in a student?s enrollment status, the effective date of the status, and an anticipated completion date to NSLDS. Changes in enrollment to less than half-time, graduated, or withdrawn must be reported within 60 days of the withdrawal determination date for schools that submit roster files to NSLDS. The withdrawal determination date for an official withdrawal is the date that the student begins the school?s withdrawal process, or the date the student otherwise provides official notification to the school of the intent to withdraw. Condition: In our nonstatistical sample of 49 students, it was noted for 10 individuals who were graduated or were withdrawals that the status updates were not made to NSLDS within the 60 day requirement from the withdrawal determination date which is the date the student began the official withdrawal process. Context: The enrollment status was updated anywhere from 64 days after the withdrawal date to 158 days after the withdrawal date. Effect: Students may not enter repayment or their grace period within the appropriate timeframe from their exit from the University or students may not receive adequate notice of the timing of their grace period. Questioned Costs: There were no questioned costs to report as the finding relates only to enrollment reporting and is not related to eligibility. Cause: Ottawa University does not have proper processes and related controls in place to complete the required updates to NSLDS for reporting changes in enrollment status within the 60 day requirement in relation to official withdrawals. Identification As Repeat Finding: This is a repeat of a finding in the immediately prior year; see Summary Schedule of Prior Audit Findings 2018-001. Recommendation: The Registrar department should review and consider revisions to its processes and related controls in place to ensure completion of updates to NSLDS within the required 60 day timeframe for official withdrawals. SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) For The Year Ended June 30, 2019 Views Of Responsible Officials/Corrective Action Plan (Unaudited): The University acknowledges the finding and recommendation of the Auditing Team. An Associate Registrar in the Registrar?s Office has been working closely with our IT department and the National Student Clearinghouse over the last year to identify known bugs with NSC?s transmissions to NSLDS. The Registrar?s Office will continue to review their processes and related controls to try and identify if/when data is not transmitted from the Clearinghouse and to NSLDS. Completion Date: December 31, 2019 Contact Person: Margaret Herron, University Registrar

Finding 2019-002 ? Significant Deficiency Federal Award No. 84.268 U.S. Department Of Education Student Financial Aid Cluster Criteria: According to 34 CFR 668.164(a)(1), ??a disbursement of title IV, HEA program funds occurs on the date that the institution credits the student?s ledger account or pays the student or parent directly?? According to the 2018-2019 COD Technical Reference, Volume II- Common Record Technical Reference, section ?Business Rules for Adjusting Disbursements,? it is stated, ??The school does NOT upwardly adjust the first disbursement date since the additional funds were disbursed on a different date.? Condition: In our nonstatistical sample of 40 students, it was noted for two individuals who received additional funds that their additional disbursement was recorded within COD as having a disbursement date of 55 days earlier and 48 days earlier than the actual disbursement date. Context: Two students who received an upward adjustment to their unsubsidized loan had a disbursement date recorded with COD that was earlier than the actual disbursement. Effect: The disbursement date initiates the interest charges for unsubsidized loans, so students could be charged interest prior to receiving funds. Questioned Costs: There are no questioned costs to report. Cause: Ottawa University does not have proper processes and related controls in place to complete reporting of disbursement dates in accordance with the CFR and COD. Identification As Repeat Finding: Not a repeat finding. SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) For The Year Ended June 30, 2019 Recommendation: The Student Financial Aid Director should review and consider revisions to its processes and related controls in place to ensure appropriate recording of disbursement dates within COD. Views Of Responsible Officials/Corrective Action Plan (Unaudited): The University concurs with the finding and recommendation. The Financial Aid Department has reviewed and, where appropriate, made updates to the processes used. Completion Date: October 31, 2019 Contact Person: Howard Fischer, Director of Financial Aid

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