Notre Dame of Maryland UniversityHigher Education

Compliance Area Special Tests and Provisions – Direct Loan Requirements Criteria or Requirement Pursuant to 34 CFR § 685.304(a) and the Federal Student Aid Handbook, Volume 8 (Direct Loans), Chapter 2, a borrower receiving a Direct Subsidized or Direct Unsubsidized Loan must complete entrance counseling prior to the first disbursement of the loan unless the borrower has previously completed entrance counseling for a prior loan period at the University. Condition Found, Including Perspective During our testing of 40 Direct Loan recipients, we noted that for one student selected for testing, the University did not maintain documentation evidencing that entrance counseling was completed prior to the first Direct Loan disbursement. No evidence of completion was observed within the student information system or the student's electronic file prior to the disbursement date. Possible Asserted Cause and Effect Based on discussions with management, the University makes entrance counseling available to students through the U.S. Department of Education's online platform; however, procedures were not in place to verify and document completion prior to the first disbursement of Direct Loan funds. As a result, Direct Loan funds were disbursed without documented evidence that the borrower satisfied entrance counseling requirements as required by federal regulations. Questioned Costs None. Statistical Validity Our sample of 40 students was selected using a nonstatistical sampling method. Therefore, results of our testing cannot be projected to the entire population. Identification of Whether the Audit Finding is a Repeat of a Finding in the Immediate Prior Audit Finding 2025-001 is not a repeat of a finding from the immediate prior audit. Recommendation We recommend the University implement procedures to verify and document completion of entrance counseling prior to the first Direct Loan disbursement. Controls should ensure that documentation of completion is retained in the student file or that system controls prevent disbursement until entrance counseling requirements are satisfied.

Compliance Area Special Tests and Provisions – Direct Loan Requirements Criteria or Requirement Pursuant to 34 CFR § 685.304(a) and the Federal Student Aid Handbook, Volume 8 (Direct Loans), Chapter 2, a borrower receiving a Direct Subsidized or Direct Unsubsidized Loan must complete entrance counseling prior to the first disbursement of the loan unless the borrower has previously completed entrance counseling for a prior loan period at the University. Condition Found, Including Perspective During our testing of 40 Direct Loan recipients, we noted that for one student selected for testing, the University did not maintain documentation evidencing that entrance counseling was completed prior to the first Direct Loan disbursement. No evidence of completion was observed within the student information system or the student's electronic file prior to the disbursement date. Possible Asserted Cause and Effect Based on discussions with management, the University makes entrance counseling available to students through the U.S. Department of Education's online platform; however, procedures were not in place to verify and document completion prior to the first disbursement of Direct Loan funds. As a result, Direct Loan funds were disbursed without documented evidence that the borrower satisfied entrance counseling requirements as required by federal regulations. Questioned Costs None. Statistical Validity Our sample of 40 students was selected using a nonstatistical sampling method. Therefore, results of our testing cannot be projected to the entire population. Identification of Whether the Audit Finding is a Repeat of a Finding in the Immediate Prior Audit Finding 2025-001 is not a repeat of a finding from the immediate prior audit. Recommendation We recommend the University implement procedures to verify and document completion of entrance counseling prior to the first Direct Loan disbursement. Controls should ensure that documentation of completion is retained in the student file or that system controls prevent disbursement until entrance counseling requirements are satisfied. View of Responsible Officials The University concurs with this finding and has implemented corrective actions to prevent recurrence. The entrance counseling loan processing rule parameters within the Colleague financial aid module have been updated to prevent loan authorization and disbursement if entrance counseling has not been received and posted to the student's loan record. The system update was implemented in February 2026. In addition, the University reviewed loans processed during the affected period to confirm no additional instances of noncompliance occurred. Financial aid staff have been reminded of federal entrance counseling requirements, and management will periodically monitor system controls to ensure continued compliance.

Compliance Area Special Tests and Provisions – Title IV Credit Balance Refunds Criteria or Requirement Pursuant to 34 CFR § 668.164(h), a school must pay a Title IV credit balance directly to the student (or parent borrower, as applicable) as soon as possible, but no later than 14 calendar days after the credit balance occurs. A Title IV credit balance occurs when Title IV funds are credited to a student's account and exceed allowable institutional charges. Condition Found, Including Perspective During testing of 40 students receiving Title IV funds, we noted that for three students, Title IV funds were credited to the student accounts in the University's student billing system, resulting in a Title IV credit balance. Refunds were issued more than 14 calendar days after the credit balance was created. One of the three refunds tested was issued 54 days after the credit balance occurred. The remaining two refunds were also issued beyond the required 14-day timeframe. Possible Asserted Cause and Effect Based on discussions with management, the University calculated the 14-day period based on subsequent changes to loan amounts in COD and/or drawdown timing rather than from the date the Title IV credit balance was created on the student account ledger. As a result, refunds were not issued within the timeframe required by federal regulations. Failure to timely disburse Title IV credit balances may result in noncompliance with federal student financial assistance regulations and may impact students' timely access to funds. Questioned Costs None. Refunds were ultimately issued to students; however, they were not issued within the required 14- day timeframe. Statistical Validity Our sample of 40 students was selected using a nonstatistical sampling method. Therefore, results of our testing cannot be projected to the entire population. Identification of Whether the Audit Finding is a Repeat of a Finding in the Immediate Prior Audit Finding 2025-002 is not a repeat of a finding from the immediate prior audit. Recommendation We recommend that the University revise its procedures to ensure that the 14-day requirement for Title IV credit balance refunds is calculated from the date the credit balance is created on the student account ledger. Management should implement monitoring controls to track credit balances and ensure timely refunds in accordance with federal regulations.

Compliance Area Special Tests and Provisions – Title IV Credit Balance Refunds Criteria or Requirement Pursuant to 34 CFR § 668.164(h), a school must pay a Title IV credit balance directly to the student (or parent borrower, as applicable) as soon as possible, but no later than 14 calendar days after the credit balance occurs. A Title IV credit balance occurs when Title IV funds are credited to a student's account and exceed allowable institutional charges. Condition Found, Including Perspective During testing of 40 students receiving Title IV funds, we noted that for three students, Title IV funds were credited to the student accounts in the University's student billing system, resulting in a Title IV credit balance. Refunds were issued more than 14 calendar days after the credit balance was created. One of the three refunds tested was issued 54 days after the credit balance occurred. The remaining two refunds were also issued beyond the required 14-day timeframe. Possible Asserted Cause and Effect Based on discussions with management, the University calculated the 14-day period based on subsequent changes to loan amounts in COD and/or drawdown timing rather than from the date the Title IV credit balance was created on the student account ledger. As a result, refunds were not issued within the timeframe required by federal regulations. Failure to timely disburse Title IV credit balances may result in noncompliance with federal student financial assistance regulations and may impact students' timely access to funds. Questioned Costs None. Refunds were ultimately issued to students; however, they were not issued within the required 14- day timeframe. Statistical Validity Our sample of 40 students was selected using a nonstatistical sampling method. Therefore, results of our testing cannot be projected to the entire population. Identification of Whether the Audit Finding is a Repeat of a Finding in the Immediate Prior Audit Finding 2025-002 is not a repeat of a finding from the immediate prior audit. Recommendation We recommend that the University revise its procedures to ensure that the 14-day requirement for Title IV credit balance refunds is calculated from the date the credit balance is created on the student account ledger. Management should implement monitoring controls to track credit balances and ensure timely refunds in accordance with federal regulations. View of Responsible Officials The University concurs with this finding. Management has reviewed its processes for monitoring and issuing Title IV credit balance refunds and has implemented procedures to ensure refunds are processed within the required 14-day timeframe. The Financial Aid and Student Accounts offices will review credit balance reports on a regular basis to identify students eligible for refunds and confirm timely disbursement. In addition, staff have been reminded of federal requirements related to credit balance refunds. Management will monitor this process periodically to ensure ongoing compliance.

Compliance Area Student Financial Assistance Cluster – Special Tests and Provisions – Return of Title IV Funds (R2T4) Criteria or Requirement In accordance with 34 CFR 668.22, institutions must accurately determine the percentage of the payment period completed using the correct payment period start and end dates to calculate earned and unearned Title IV assistance. If a student withdraws before completing 60% of the payment period, the institution must determine the amount of unearned Title IV funds and return those funds within 45 days of the date of determination. Condition Found, Including Perspective During testing of 10 students who withdrew during the year ended June 30, 2025, we recalculated the Return of Title IV Funds (R2T4) determinations. Differences were identified in three of the 10 selections tested. In two of the three instances, the institution used an incorrect Spring 2025 term end date in the Colleague system when calculating the percentage of the payment period completed. As a result, the students were calculated at or above the 60% completion threshold and determined to have earned 100% of their Title IV assistance, when recalculation using the official academic calendar dates indicated that a return of funds was required. One additional instance resulted in a de minimis difference. Possible Asserted Cause and Effect The term end date configured in the Colleague system did not align with the institution's official academic calendar, and procedures were not in place to verify that system-configured term dates agreed to the approved academic calendar prior to performing R2T4 calculations. As a result, R2T4 determinations were not calculated using the correct payment period dates, which resulted in failure to identify and return unearned Title IV funds in certain instances. If the issue is systemic, additional students who withdrew during the Spring 2025 term may have been similarly affected. Questioned Costs Questioned costs related to the two affected students totaled approximately $5,800, representing Title IV funds that should have been returned based on recalculation using the official term dates. Final questioned costs may change pending management's review of the full withdrawal population for the Spring 2025 term. Statistical Validity A nonstatistical sampling approach was used. Therefore, results cannot be projected to the population; however, the error rate identified indicates the potential for similar noncompliance within the population of students who withdrew during the Spring 2025 term. Identification of Whether the Audit Finding is a Repeat of a Finding in the Immediate Prior Audit Finding 2025-003 is not a repeat of a finding from the immediate prior audit. Recommendation We recommend the University reconcile system-configured term dates within Colleague to the officially approved academic calendar for all academic periods used for Title IV calculations. In addition, the University should perform a comprehensive review of students who withdrew during the Spring 2025 term to determine whether additional R2T4 recalculations and returns are required. Procedures should be implemented to periodically verify that system term dates align with official academic records prior to performing R2T4 calculations.

Compliance Area Student Financial Assistance Cluster – Special Tests and Provisions – Return of Title IV Funds (R2T4) Criteria or Requirement In accordance with 34 CFR 668.22, institutions must accurately determine the percentage of the payment period completed using the correct payment period start and end dates to calculate earned and unearned Title IV assistance. If a student withdraws before completing 60% of the payment period, the institution must determine the amount of unearned Title IV funds and return those funds within 45 days of the date of determination. Condition Found, Including Perspective During testing of 10 students who withdrew during the year ended June 30, 2025, we recalculated the Return of Title IV Funds (R2T4) determinations. Differences were identified in three of the 10 selections tested. In two of the three instances, the institution used an incorrect Spring 2025 term end date in the Colleague system when calculating the percentage of the payment period completed. As a result, the students were calculated at or above the 60% completion threshold and determined to have earned 100% of their Title IV assistance, when recalculation using the official academic calendar dates indicated that a return of funds was required. One additional instance resulted in a de minimis difference. Possible Asserted Cause and Effect The term end date configured in the Colleague system did not align with the institution's official academic calendar, and procedures were not in place to verify that system-configured term dates agreed to the approved academic calendar prior to performing R2T4 calculations. As a result, R2T4 determinations were not calculated using the correct payment period dates, which resulted in failure to identify and return unearned Title IV funds in certain instances. If the issue is systemic, additional students who withdrew during the Spring 2025 term may have been similarly affected. Questioned Costs Questioned costs related to the two affected students totaled approximately $5,800, representing Title IV funds that should have been returned based on recalculation using the official term dates. Final questioned costs may change pending management's review of the full withdrawal population for the Spring 2025 term. Statistical Validity A nonstatistical sampling approach was used. Therefore, results cannot be projected to the population; however, the error rate identified indicates the potential for similar noncompliance within the population of students who withdrew during the Spring 2025 term. Identification of Whether the Audit Finding is a Repeat of a Finding in the Immediate Prior Audit Finding 2025-003 is not a repeat of a finding from the immediate prior audit. Recommendation We recommend the University reconcile system-configured term dates within Colleague to the officially approved academic calendar for all academic periods used for Title IV calculations. In addition, the University should perform a comprehensive review of students who withdrew during the Spring 2025 term to determine whether additional R2T4 recalculations and returns are required. Procedures should be implemented to periodically verify that system term dates align with official academic records prior to performing R2T4 calculations. View of Responsible Officials The University concurs with this finding. Management has initiated a review of all relevant institutional academic calendars to ensure that the correct payment period start and end dates are accurately configured within the Colleague system. The Spring 2025 withdrawal population is being reviewed to determine whether additional R2T4 recalculations and returns of Title IV funds are required. Necessary corrections will be processed promptly. Going forward, the University will implement procedures to verify that system-configured term dates agree to the officially approved academic calendar prior to each academic term to ensure compliance with federal R2T4 requirements.

Compliance Area Special Tests and Provisions – Direct Loan Requirements Criteria or Requirement Pursuant to 34 CFR § 685.304(a) and the Federal Student Aid Handbook, Volume 8 (Direct Loans), Chapter 2, a borrower receiving a Direct Subsidized or Direct Unsubsidized Loan must complete entrance counseling prior to the first disbursement of the loan unless the borrower has previously completed entrance counseling for a prior loan period at the University. Condition Found, Including Perspective During our testing of 40 Direct Loan recipients, we noted that for one student selected for testing, the University did not maintain documentation evidencing that entrance counseling was completed prior to the first Direct Loan disbursement. No evidence of completion was observed within the student information system or the student's electronic file prior to the disbursement date. Possible Asserted Cause and Effect Based on discussions with management, the University makes entrance counseling available to students through the U.S. Department of Education's online platform; however, procedures were not in place to verify and document completion prior to the first disbursement of Direct Loan funds. As a result, Direct Loan funds were disbursed without documented evidence that the borrower satisfied entrance counseling requirements as required by federal regulations. Questioned Costs None. Statistical Validity Our sample of 40 students was selected using a nonstatistical sampling method. Therefore, results of our testing cannot be projected to the entire population. Identification of Whether the Audit Finding is a Repeat of a Finding in the Immediate Prior Audit Finding 2025-001 is not a repeat of a finding from the immediate prior audit. Recommendation We recommend the University implement procedures to verify and document completion of entrance counseling prior to the first Direct Loan disbursement. Controls should ensure that documentation of completion is retained in the student file or that system controls prevent disbursement until entrance counseling requirements are satisfied.

Compliance Area Special Tests and Provisions – Direct Loan Requirements Criteria or Requirement Pursuant to 34 CFR § 685.304(a) and the Federal Student Aid Handbook, Volume 8 (Direct Loans), Chapter 2, a borrower receiving a Direct Subsidized or Direct Unsubsidized Loan must complete entrance counseling prior to the first disbursement of the loan unless the borrower has previously completed entrance counseling for a prior loan period at the University. Condition Found, Including Perspective During our testing of 40 Direct Loan recipients, we noted that for one student selected for testing, the University did not maintain documentation evidencing that entrance counseling was completed prior to the first Direct Loan disbursement. No evidence of completion was observed within the student information system or the student's electronic file prior to the disbursement date. Possible Asserted Cause and Effect Based on discussions with management, the University makes entrance counseling available to students through the U.S. Department of Education's online platform; however, procedures were not in place to verify and document completion prior to the first disbursement of Direct Loan funds. As a result, Direct Loan funds were disbursed without documented evidence that the borrower satisfied entrance counseling requirements as required by federal regulations. Questioned Costs None. Statistical Validity Our sample of 40 students was selected using a nonstatistical sampling method. Therefore, results of our testing cannot be projected to the entire population. Identification of Whether the Audit Finding is a Repeat of a Finding in the Immediate Prior Audit Finding 2025-001 is not a repeat of a finding from the immediate prior audit. Recommendation We recommend the University implement procedures to verify and document completion of entrance counseling prior to the first Direct Loan disbursement. Controls should ensure that documentation of completion is retained in the student file or that system controls prevent disbursement until entrance counseling requirements are satisfied. View of Responsible Officials The University concurs with this finding and has implemented corrective actions to prevent recurrence. The entrance counseling loan processing rule parameters within the Colleague financial aid module have been updated to prevent loan authorization and disbursement if entrance counseling has not been received and posted to the student's loan record. The system update was implemented in February 2026. In addition, the University reviewed loans processed during the affected period to confirm no additional instances of noncompliance occurred. Financial aid staff have been reminded of federal entrance counseling requirements, and management will periodically monitor system controls to ensure continued compliance.

Compliance Area Special Tests and Provisions – Title IV Credit Balance Refunds Criteria or Requirement Pursuant to 34 CFR § 668.164(h), a school must pay a Title IV credit balance directly to the student (or parent borrower, as applicable) as soon as possible, but no later than 14 calendar days after the credit balance occurs. A Title IV credit balance occurs when Title IV funds are credited to a student's account and exceed allowable institutional charges. Condition Found, Including Perspective During testing of 40 students receiving Title IV funds, we noted that for three students, Title IV funds were credited to the student accounts in the University's student billing system, resulting in a Title IV credit balance. Refunds were issued more than 14 calendar days after the credit balance was created. One of the three refunds tested was issued 54 days after the credit balance occurred. The remaining two refunds were also issued beyond the required 14-day timeframe. Possible Asserted Cause and Effect Based on discussions with management, the University calculated the 14-day period based on subsequent changes to loan amounts in COD and/or drawdown timing rather than from the date the Title IV credit balance was created on the student account ledger. As a result, refunds were not issued within the timeframe required by federal regulations. Failure to timely disburse Title IV credit balances may result in noncompliance with federal student financial assistance regulations and may impact students' timely access to funds. Questioned Costs None. Refunds were ultimately issued to students; however, they were not issued within the required 14- day timeframe. Statistical Validity Our sample of 40 students was selected using a nonstatistical sampling method. Therefore, results of our testing cannot be projected to the entire population. Identification of Whether the Audit Finding is a Repeat of a Finding in the Immediate Prior Audit Finding 2025-002 is not a repeat of a finding from the immediate prior audit. Recommendation We recommend that the University revise its procedures to ensure that the 14-day requirement for Title IV credit balance refunds is calculated from the date the credit balance is created on the student account ledger. Management should implement monitoring controls to track credit balances and ensure timely refunds in accordance with federal regulations.

Compliance Area Special Tests and Provisions – Title IV Credit Balance Refunds Criteria or Requirement Pursuant to 34 CFR § 668.164(h), a school must pay a Title IV credit balance directly to the student (or parent borrower, as applicable) as soon as possible, but no later than 14 calendar days after the credit balance occurs. A Title IV credit balance occurs when Title IV funds are credited to a student's account and exceed allowable institutional charges. Condition Found, Including Perspective During testing of 40 students receiving Title IV funds, we noted that for three students, Title IV funds were credited to the student accounts in the University's student billing system, resulting in a Title IV credit balance. Refunds were issued more than 14 calendar days after the credit balance was created. One of the three refunds tested was issued 54 days after the credit balance occurred. The remaining two refunds were also issued beyond the required 14-day timeframe. Possible Asserted Cause and Effect Based on discussions with management, the University calculated the 14-day period based on subsequent changes to loan amounts in COD and/or drawdown timing rather than from the date the Title IV credit balance was created on the student account ledger. As a result, refunds were not issued within the timeframe required by federal regulations. Failure to timely disburse Title IV credit balances may result in noncompliance with federal student financial assistance regulations and may impact students' timely access to funds. Questioned Costs None. Refunds were ultimately issued to students; however, they were not issued within the required 14- day timeframe. Statistical Validity Our sample of 40 students was selected using a nonstatistical sampling method. Therefore, results of our testing cannot be projected to the entire population. Identification of Whether the Audit Finding is a Repeat of a Finding in the Immediate Prior Audit Finding 2025-002 is not a repeat of a finding from the immediate prior audit. Recommendation We recommend that the University revise its procedures to ensure that the 14-day requirement for Title IV credit balance refunds is calculated from the date the credit balance is created on the student account ledger. Management should implement monitoring controls to track credit balances and ensure timely refunds in accordance with federal regulations. View of Responsible Officials The University concurs with this finding. Management has reviewed its processes for monitoring and issuing Title IV credit balance refunds and has implemented procedures to ensure refunds are processed within the required 14-day timeframe. The Financial Aid and Student Accounts offices will review credit balance reports on a regular basis to identify students eligible for refunds and confirm timely disbursement. In addition, staff have been reminded of federal requirements related to credit balance refunds. Management will monitor this process periodically to ensure ongoing compliance.

Compliance Area Student Financial Assistance Cluster – Special Tests and Provisions – Return of Title IV Funds (R2T4) Criteria or Requirement In accordance with 34 CFR 668.22, institutions must accurately determine the percentage of the payment period completed using the correct payment period start and end dates to calculate earned and unearned Title IV assistance. If a student withdraws before completing 60% of the payment period, the institution must determine the amount of unearned Title IV funds and return those funds within 45 days of the date of determination. Condition Found, Including Perspective During testing of 10 students who withdrew during the year ended June 30, 2025, we recalculated the Return of Title IV Funds (R2T4) determinations. Differences were identified in three of the 10 selections tested. In two of the three instances, the institution used an incorrect Spring 2025 term end date in the Colleague system when calculating the percentage of the payment period completed. As a result, the students were calculated at or above the 60% completion threshold and determined to have earned 100% of their Title IV assistance, when recalculation using the official academic calendar dates indicated that a return of funds was required. One additional instance resulted in a de minimis difference. Possible Asserted Cause and Effect The term end date configured in the Colleague system did not align with the institution's official academic calendar, and procedures were not in place to verify that system-configured term dates agreed to the approved academic calendar prior to performing R2T4 calculations. As a result, R2T4 determinations were not calculated using the correct payment period dates, which resulted in failure to identify and return unearned Title IV funds in certain instances. If the issue is systemic, additional students who withdrew during the Spring 2025 term may have been similarly affected. Questioned Costs Questioned costs related to the two affected students totaled approximately $5,800, representing Title IV funds that should have been returned based on recalculation using the official term dates. Final questioned costs may change pending management's review of the full withdrawal population for the Spring 2025 term. Statistical Validity A nonstatistical sampling approach was used. Therefore, results cannot be projected to the population; however, the error rate identified indicates the potential for similar noncompliance within the population of students who withdrew during the Spring 2025 term. Identification of Whether the Audit Finding is a Repeat of a Finding in the Immediate Prior Audit Finding 2025-003 is not a repeat of a finding from the immediate prior audit. Recommendation We recommend the University reconcile system-configured term dates within Colleague to the officially approved academic calendar for all academic periods used for Title IV calculations. In addition, the University should perform a comprehensive review of students who withdrew during the Spring 2025 term to determine whether additional R2T4 recalculations and returns are required. Procedures should be implemented to periodically verify that system term dates align with official academic records prior to performing R2T4 calculations.

Compliance Area Student Financial Assistance Cluster – Special Tests and Provisions – Return of Title IV Funds (R2T4) Criteria or Requirement In accordance with 34 CFR 668.22, institutions must accurately determine the percentage of the payment period completed using the correct payment period start and end dates to calculate earned and unearned Title IV assistance. If a student withdraws before completing 60% of the payment period, the institution must determine the amount of unearned Title IV funds and return those funds within 45 days of the date of determination. Condition Found, Including Perspective During testing of 10 students who withdrew during the year ended June 30, 2025, we recalculated the Return of Title IV Funds (R2T4) determinations. Differences were identified in three of the 10 selections tested. In two of the three instances, the institution used an incorrect Spring 2025 term end date in the Colleague system when calculating the percentage of the payment period completed. As a result, the students were calculated at or above the 60% completion threshold and determined to have earned 100% of their Title IV assistance, when recalculation using the official academic calendar dates indicated that a return of funds was required. One additional instance resulted in a de minimis difference. Possible Asserted Cause and Effect The term end date configured in the Colleague system did not align with the institution's official academic calendar, and procedures were not in place to verify that system-configured term dates agreed to the approved academic calendar prior to performing R2T4 calculations. As a result, R2T4 determinations were not calculated using the correct payment period dates, which resulted in failure to identify and return unearned Title IV funds in certain instances. If the issue is systemic, additional students who withdrew during the Spring 2025 term may have been similarly affected. Questioned Costs Questioned costs related to the two affected students totaled approximately $5,800, representing Title IV funds that should have been returned based on recalculation using the official term dates. Final questioned costs may change pending management's review of the full withdrawal population for the Spring 2025 term. Statistical Validity A nonstatistical sampling approach was used. Therefore, results cannot be projected to the population; however, the error rate identified indicates the potential for similar noncompliance within the population of students who withdrew during the Spring 2025 term. Identification of Whether the Audit Finding is a Repeat of a Finding in the Immediate Prior Audit Finding 2025-003 is not a repeat of a finding from the immediate prior audit. Recommendation We recommend the University reconcile system-configured term dates within Colleague to the officially approved academic calendar for all academic periods used for Title IV calculations. In addition, the University should perform a comprehensive review of students who withdrew during the Spring 2025 term to determine whether additional R2T4 recalculations and returns are required. Procedures should be implemented to periodically verify that system term dates align with official academic records prior to performing R2T4 calculations. View of Responsible Officials The University concurs with this finding. Management has initiated a review of all relevant institutional academic calendars to ensure that the correct payment period start and end dates are accurately configured within the Colleague system. The Spring 2025 withdrawal population is being reviewed to determine whether additional R2T4 recalculations and returns of Title IV funds are required. Necessary corrections will be processed promptly. Going forward, the University will implement procedures to verify that system-configured term dates agree to the officially approved academic calendar prior to each academic term to ensure compliance with federal R2T4 requirements.

Compliance Area Reporting Criteria or Requirement The Coronavirus Aid, Relief, and Economic Security Act (CARES Act), Coronavirus Response and Relief Supplemental Appropriations Act (CRRSAA), and American Rescue Plan (ARP) Act institutional quarterly portion reporting requirements involved publicly posting completed forms on the institution?s website timely and accurately. Condition Found, Including Perspective During our compliance testing, we obtained and reviewed quarterly reports posted on the University?s primary website covering aggregate amounts spent. It was determined that, during the Department of Education?s transition to aggregate reporting of CARES Act, CRRSAA, and ARP institutional awards and spending, that the University did not post a final quarterly report that reflected full utilization of the CRRSAA award. Possible Asserted Cause and Effect The University did not understand the reporting compliance requirements of the COVID-19 Education Stabilization Fund with respect to reporting the utilization of funds and identifying the report as final when fully utilized. Questioned Costs None Statistical Validity Not applicable Identification of Whether the Audit Finding is a Repeat of a Finding in the Immediately Prior Audit Finding 2022-01 is not a repeat of a finding from the immediately prior audit. Recommendation We recommend the University identify a responsible individual to understand and verify that all aspects of new programs are complied with. View of Responsible Officials The University concurs with this finding and provides the following correction action plan. The University has spent the institutional portion of the CRRSAA funds in accordance with the requirements of the program and will update its website reporting to reflect full utilization.

Compliance Area Eligibility Criteria or Requirement Title 34, U.S. Code of Federal Regulators (CFR), Subpart C Student Eligibility, Section 668.32 Student Assistance General Provisions states that, for a student to be eligible to receive Title IV, HEA program assistance, the student must not have obtained loan amounts that exceed annual or aggregate loan limits under any Title IV, HEA loan program. Condition Found, Including Perspective During our compliance tests, it was determined that one student in a sample of 40 students received federal direct loans or federal Pell grants in excess of the aggregate loan or grant limits. The circumstances of the one student who received excess federal direct loans are as follows: a dependent first-year student received subsidized and unsubsidized loans of $3,500 and $4,000, respectively, that aggregated to a total of $7,500 of direct loans, which is $2,000 over the $5,500 combined subsidized and unsubsidized limit for a first-year student. The student received a PLUS loan and was, therefore, not eligible for the higher federal direct loan limits for students whose parents are unable to obtain a PLUS loan.Possible Asserted Cause and Effect The University experienced turnover in the Financial Aid Department and did not maintain adequate review controls to ensure amounts provided to or on behalf of eligible students were calculated in accordance with program requirements regarding federal direct loan limits. As a result, failure to maintain appropriate internal controls could result in noncompliance with eligibility compliance requirements (34 CFR Section 668.32). Questioned Costs There are known questioned costs of $2,000 related to this finding. Statistical Validity The sample was not intended to be, and was not, a statistically valid sample. Identification of Whether the Audit Finding Is a Repeat of a Finding in the Immediately Prior Audit A similar finding was reported in the prior year's audit as Finding 2018-002. Recommendation We recommend the University work to hire, develop, and retain competent individuals with knowledge of the program requirements, as well as develop and perform ongoing evaluations to ascertain whether the components of internal control are present and functioning to reasonably ensure amounts provided to or on behalf of eligible students are calculated in accordance with program requirements (34 CFR 668.32).

Compliance Area Pell Reporting Criteria or Requirement Higher education institutions must submit Pell grant disbursement data through the Common Origination and Disbursement System (COD) no later than 15 calendar days after disbursement or becoming aware of the need to adjust a previously reported disbursement (0MB Nos. 1845-0021 and 1845-0039). Condition Found, Including Perspective For our compliance test, we selected a sample of 25 students and reviewed the submission for the respective Fall 2018 and Spring 2019 disbursements, as applicable, for a total of 50 disbursements. It was determined that one disbursement related to a student was not reported to the COD within the 15 calendar days required time frame after disbursement. This student disbursement was reported to the COD in 22 days. Possible Asserted Cause and Effect The University experienced turnover in the Financial Aid Department and, as a result, its management review control over COD submissions was not operating effectively during fiscal year 2019. As a result, the University was not in compliance with Pell reporting requirements. Questioned Costs There are no questioned costs related to this finding. Statistical Validity The sample was not intended to be, and was not, a statistically valid sample. Identification of Whether the Audit Finding Is a Repeat of a Finding in the Immediately Prior Audit A similar finding was reported in the prior year's audit as Finding 2018-003. Recommendation We recommend the University work to hire, develop, and retain competent individuals with knowledge of the program requirements, as well as enhance its management review controls over reporting to the COD.

Compliance Area Special Tests: Disbursements to or on Behalf of Students Criteria or Requirement CFR, Subpart K Cash Management, Section 668.165 Notices and Authorizations requires that, for direct loan disbursements, the institution must notify the student, or parent, in writing of (1) the date and amount of the disbursement; (2) the student's right, or parent's right, to cancel all or a portion of the loan or loan disbursement and have the loan proceeds returned to the holder of that loan; and (3) the procedure and time by which the student or parent must notify the institution that he or she wishes to cancel the loan. The institution must provide the notice in writing no earlier than 30 days before, and no later than seven days after, crediting the student's account, if the institution does not obtain affirmative confirmation from the student. Condition Found, Including Perspective There were 30 students in a sample of 40 students who were not sent disbursement letters within the required time frame after crediting the student's account. Possible Asserted Cause and Effect The University experienced turnover in the Financial Aid Department, and the management review control over disbursement notifications was not operating effectively during fiscal year 2019 to ensure notifications were sent to all recipients of federal financial aid. As a result, the University was not in compliance with disbursement notification requirements. Questioned Costs There are no questioned costs related to this finding. Statistical Validity The sample was not intended to be, and was not, a statistically valid sample. Identification of Whether the Audit Finding Is a Repeat of a Finding in the Immediately Prior Audit A similar finding was reported in the prior year's audit as Finding 2018-004. Recommendation We recommend the University work to hire, develop, and retain competent individuals with knowledge of the program requirements, as well as enhance its management review controls over disbursement notifications.

Compliance Area Special Tests: Borrower Data Transmission and Reconciliation Criteria or Requirement Higher education institutions must report all loan disbursements and submit required records to the Direct Loan Servicing System (DLSS) via the COD within 15 days of disbursement (OMB 1845-0021). Each month, the COD provides institutions with a School Account Statement (SAS) data file which consists of a Cash Summary, Cash Detail, and (optional at the request of the school) Loan Detail records. The University is required to reconcile these files to its financial records. Since up to three Direct Loan program years may be open at any given time, schools may receive three SAS data files each month [34 CFR Sections 685.102(b), 685.301, and 303]. Condition Found, Including Perspective During our compliance test, it was determined that the University was not performing a monthly reconciliation of the COD SAS data file to its financial records. The University was unable to provide documentation that a direct loan reconciliation was prepared on a monthly basis. Possible Asserted Cause and Effect The University experienced turnover in the Financial Aid Department and, as a result, its management review control over required borrower data transmission and reconciliations was not operating effectively during fiscal year 2019. As a result, the University was not in compliance with borrower data transmission and reconciliation requirements. Questioned Costs There are no questioned costs related to this finding. Statistical Validity The sample was not intended to be, and was not, a statistically valid sample. Identification of Whether the Audit Finding Is a Repeat of a Finding in the Immediately Prior Audit A similar finding was reported in the prior year?s audit as Finding 2018-006. Recommendation We recommend the University work to hire, develop, and retain competent individuals with knowledge of the program requirements, as well as enhance its management review controls over borrower data transmission and reconciliations.

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