Washington Adventist UniversityHigher Education

2025 – 002: Internal Controls and Segregation of Duties Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Aid Cluster ALN Number: 84.063, 84.007, 84.033, 84.038, 84.268, 93.364 Award Period: July 1, 2024 – June 30, 2025 Type of Finding: Material Weakness in Internal Control over Compliance Criteria or specific requirement: Internal Control – Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: Internal controls are not designed and operating effectively with no appropriate segregation of duties in the following areas: 1. Drawdowns for All Federal Awards – There was no control in place specifically designating the appropriate personnel who is responsible to perform the review of all drawdowns to ensure the information and amount are accurate. 2. Reconciliations of Pell Grants, Supplemental Educational Opportunity Grants (SEOG), Federal Work-Study, and Direct Loans between COD, Bank Accounts, and G5 – Reconciliations are prepared by the Associate Director of Financial Aid and reviewed by the Director of Financial Aid. There was no documentation of the review to verify that these controls are operating effectively. 3. Federal Aid Packages – The Director of Financial Aid prepares and reviews all Federal aid packages. There was no adequate and proper segregation of duties. 4. Professional Judgement Determinations – There was not proper documentation of review or approval. 5. R2T4 Calculations - The Director of Financial Aid prepares and reviews the R2T4 calculations. There was no adequate and proper segregation of duties. 6. Credit Balances - There is no control in place over the review of payment of credit balances to the student within 14 days. 7. Incentive Compensation – We were unable to verify whether the control to ensure that no incentive compensation is made to employees in the student recruiting and admission, and financial aid departments, is designed and operating effectively. 8. Eligibility – We identified instances in which the Cost of Attendance (COA) used to calculate financial need was inaccurate due to insufficient review and oversight over COA calculations. Questioned costs: None Context: This condition occurred in our various testing all throughout the audit of the Student Financial Aid cluster. Cause: Internal controls are not adequately and properly designed to address the risks. Additionally, some controls in place are not operating effectively. Effect: 1. Internal Control deficiencies can lead to non-compliance with laws and regulations, operational inefficiencies and inaccuracies in financial reporting. 2. Improper or lack of segregation of duties can lead to increased risk of errors, fraud, and inefficiencies, as there is insufficient oversight and control. Repeat Finding: Yes Recommendation: We recommend the University review its internal controls over compliance as these are crucial in protecting the University’s assets, ensuring the accuracy of financial reporting, promoting operational efficiency, and ensuring compliance with laws and regulations. Views of responsible officials: There is no disagreement with the audit finding.

2025 – 003: Gramm-Leach-Bliley Act Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Aid Cluster ALN Numbers: 84.063, 84.033, 84.007, 84.268, 84.038, 93.364 Award Period: July 1, 2024 – June 30, 2025 Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or Specific Requirement: The Gramm-Leach-Bliley Act (Public Law 106-102) requires financial institutions to explain their information-sharing practices to their customers and to safeguard sensitive data. (16 CFR 314) The Federal Trade Commission considers Title IV-eligible institutions that participate in Title IV Educational Assistance Programs as “financial institutions” and subject to the Gramm-Leach-Bliley Act (16 CFR 313.3(k)(2)(vi). Institutions are required to develop, implement, and maintain a comprehensive information security program that is written in one or more readily accessible parts. The regulations require the written information security program to include eight elements for institutions with 5,000 or more customers (16 CFR 314.3(a)). The elements that an institution must address in its written information security program are at 16 CFR 314.4. Additionally, institutions must conduct penetration testing and vulnerability assessments to ensure the effectiveness of their safeguards. Condition: The University has not implemented key components of the GLBA Safeguards Rule, including maintaining a formal data inventory and performing a periodic risk assessment of information. Questioned costs: None Context: 1. The University has not identified their process in how they identify and manage data, personnel, devices, systems, and facilities within a defined data inventory. 2. The University has not performed a risk assessment within the audit period to assist in the adjustment of their managerial, technical, and operational controls. Cause: The underlying cause of these conditions is the absence of formal data governance practices and a structured, recurring risk assessment process. Effect: As a result of the lack of a defined data inventory and a current risk assessment, the Organization may not effectively identify, assess, or mitigate risks to information, increasing the risk of inadequate safeguards, data compromise, and noncompliance with GLBA requirements. Repeat Finding: Yes Recommendation: We recommend that management establish and document a formal process to identify and maintain an inventory of data, personnel, devices, systems, and facilities that support or process customer information. Additionally, we recommend that management implement a formal, documented risk assessment process that is performed at least annually and updated as needed. Views of responsible officials: There is no disagreement with the audit finding.

2025 – 004: Enrollment Reporting Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Aid Cluster ALN Numbers: 84.063, 84.268 Award Period: July 1, 2024 – June 30, 2025 Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or Specific Requirement: Internal Control – Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Compliance – The Code of Federal Regulations, 34 CFR 685.309 requires that enrollment status changes for students be reported to NSLDS within 30 days or within 60 days if the student with the status change will be reported on a scheduled transmission within 60 days of the change in status. Condition: During testing of NSLDS enrollment reporting, we identified multiple instances of noncompliance related to timely and accurate enrollment reporting and certification. Specifically, the following issues were noted: 1. Enrollment date discrepancies The enrollment date per campus level institutional records does not match the enrollment date per NSLDS. 2. Program start date discrepancies The program start date per institutional records does not match program start date per NSLDS. 3. Untimely reporting of enrollment status changes The enrollment status change was not timely reported to NSLDS. 4. Missed enrollment certification One student was not certified within the required 60‑day period. 5. Enrollment status discrepancies The enrollment status change per institutional records does not match the status per NSLDS. Section III –Findings and Questions Costs – Major Federal Programs (Continued) 2025 – 004: Enrollment Reporting (Continued) 6. Inaccurate institutional records Institutional records did not accurately reflect the student’s enrollment status, despite NSLDS and email communication reflecting the withdrawal. Questioned costs: None Context: 1. This condition occurred in 4 out of 26 students tested. 2. This condition occurred in 9 out of 26 students tested. 3. This condition occurred in 2 out of 26 students tested. 4-6 This condition occurred in 1 out of 26 students tested. Cause: The University did not have sufficient controls in place to ensure enrollment information submitted to NSLDS was complete, accurate, and reviewed for consistency with institutional records, nor adequate monitoring procedures to ensure enrollment status changes and required certifications were submitted timely. Effect: Failure to accurately and timely report enrollment information to NSLDS may result in inaccurate federal student aid records, which could impact student loan repayment status, deferment eligibility, and other Title IV determinations made by the Department of Education. Repeat Finding: Yes Recommendation: We recommend the institution strengthen internal controls over NSLDS enrollment reporting by implementing formal review and reconciliation procedures to ensure: 1. Enrollment dates, program start dates, and enrollment statuses reported to NSLDS agree with institutional records; 2. Enrollment status changes are identified and reported timely; and 3. Enrollment certifications are completed at least every 60 days in accordance with federal requirements. Views of responsible officials: There is no disagreement with the audit finding.

Criteria or specific requirement: Internal Control – Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: Internal controls are not designed and operating effectively with no appropriate segregation of duties in the following areas: 1. Drawdowns for All Federal Awards – There was no control in place specifically designating the appropriate personnel who is responsible to perform the review of all drawdowns to ensure the information and amount are accurate. 2. Reconciliations of Pell Grants, Supplemental Educational Opportunity Grants (SEOG), Federal Work-Study, and Direct Loans between COD, Bank Accounts, and G5 – Reconciliations are prepared by the Associate Director of Financial Aid and reviewed by the Director of Financial Aid. There were no documentations of reviews to verify that these controls are operating effectively. 3. Federal Aid Packages – The Director of Financial Aid prepares and reviews all Federal aid packages. There was no adequate and proper segregation of duties. 4. Professional Judgement Determinations – The Director of Financial Aid prepares and reviews all professional judgement determinations. There was no adequate and proper segregation of duties. 5. Community Service Calculations for Federal-Work Study Program – The community service calculation is reviewed by the Associate Director of Financial Aid. There was no documentation of review to verify that these controls are operating effectively. 6. FISAP Report – The Director of Financial Aid prepares and reviews the FISAP report. There was no adequate and proper segregation of duties. 7. R2T4 Calculations - The Director of Financial Aid prepares and reviews the R2T4 calculations. There was no adequate and proper segregation of duties. 8. NSLDS Reporting – There is no control in place in relation to the review of the student status changes reported to NSLDS and to ensure that these are accurate and submitted timely in accordance with requirements set forth by the Department of Education. 9. Credit Balances - There is no control in place over the review of payment of credit balances to the student within 14 days. Questioned costs: None Context: This condition occurred in our various testing all throughout the audit of the Student Financial Aidt cluster. Cause: Internal controls are not adequately and properly designed to address the risks. Additionally, some controls in place are not operating effectively. Effect: 1. Internal Control deficiencies can lead to non-compliance with laws and regulations, operational inefficiencies and inaccuracies in financial reporting. 2. Improper or lack of segregation of duties can lead to increased risk of errors, fraud, and inefficiencies, as there is insufficient oversight and control. Repeat Finding: No Recommendation: We recommend the University review its internal controls over compliance as these are crucial in protecting the University’s assets, ensuring the accuracy of financial reporting, promoting operational efficiency, and ensuring compliance with laws and regulations. Views of responsible officials: There is no disagreement with the audit finding.

Criteria or Specific Requirement: Internal Control – Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Compliance – The Code of Federal Regulations, 34 CFR 668.34(d)(1) requires that an institution that evaluates satisfactory academic progress annually or less frequently than at the end of each payment period and determines that a student is not making progress under its policy may nevertheless disburse Title IV, HEA program funds to the student under the provisions of 34 CFR 668.34(d)(2) or 34 CFR 668.34(d)(3). Condition: As stated in the Financial Aid SAP policy, to successfully make and maintain SAP, a student must maintain a cumulative grade point average of 2.0 or higher for undergraduate students. A student who does not meet the minimum requirements for the rate of completion or cumulative GPA will be sent an SAP Warning and will have one semester to meet SAP requirements. If the student does not meet the required minimum GPA or credit hour completion rate at the end of the warning term, their financial aid will be suspended. During our testing of students’ eligibility for financial aid, 1 out of 40 students who received financial aid did not meet the satisfactory academic progress requirements as stated in the SAP policy. Additionally, 1 out of 40 students who did not meet the SAP cumulative GPA requirement was marked incorrectly as “Satisfactory SAP” instead of “Warning”. Questioned costs: $12,847 Context: This condition occurred in 2 out of 40 students tested. Cause: Students’ GPA was not reviewed closely enough to determine if students meet the requirements to received financial aid. Effect: Students who did not meet the SAP requirements and ineligible to receive financial aid were granted aid. Repeat Finding: No Recommendation: We recommend the University evaluate its procedures around the review and determination of students’ eligibility to receive financial aid. Views of responsible officials: There is no disagreement with the audit finding.

Criteria or Specific Requirement: Internal Control – Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Compliance – The Code of Federal Regulations, 34 CFR 674.16 states that before an institution makes its first disbursement to a student, the student shall sign the promissory note and the institution shall provide the student with certain repayment information. Condition: There is no Perkins loam promissory note on file for certain students with open and retired loans. These promissory notes could not be located. Questioned costs: $12,159 Context: This condition occurred in 5 out of 40 students tested with open loans and for 3 out of 8 students tested with retired loans. Cause: The University was not able to locate these promissory notes. Effect: The University cannot provide documentation showing proper completion of promissory note as required by DOE requirements. Repeat Finding: No Recommendation: We recommend that the University implement a procedure be put in place to ensure proper record retention documenting the completion of promissory notes. Views of responsible officials: There is no disagreement with the audit finding.

Criteria or Specific Requirement: Internal Control – Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Compliance – The Code of Federal Regulations, 34 CFR 668.22(g)(ii)(2) institutional charges are tuition, fees, room and board (if the student contracts with the institution for the room and board) and other educationally-related expenses assessed by the institution. Condition: Incorrect institutional charges were utilized as inputs in the calculation of R2T4 for these students. Questioned costs: None Context: This condition occurred in 2 out of 5 students tested. Cause: The University does not have policies and procedures in place to ensure calculations are properly performed. Effect: The University is not completing accurate R2T4 calculations as defined by the regulations. Repeat Finding: Yes Recommendation: We recommend the University review the R2T4 requirements and implement procedures to ensure the R2T4 calculations are using the correct institutional charges and are accurately completed. Views of responsible officials: There is no disagreement with the audit finding.

Criteria or Specific Requirement: The Gramm-Leach-Bliley Act (Public Law 106-102) requires financial institutions to explain their information-sharing practices to their customers and to safeguard sensitive data. (16 CFR 314) The Federal Trade Commission considers Title IV-eligible institutions that participate in Title IV Educational Assistance Programs as “financial institutions” and subject to the Gramm-Leach-Bliley Act (16 CFR 313.3(k)(2)(vi). Institutions are required to develop, implement, and maintain a comprehensive information security program that is written in one or more readily accessible parts. The regulations require the written information security program to include eight elements for institutions with 5,000 or more customers (16 CFR 314.3(a)). The elements that an institution must address in its written information security program are at 16 CFR 314.4. Additionally, institutions must conduct penetration testing and vulnerability assessments to ensure the effectiveness of their safeguards. Condition: Certain elements of the College’s information security program were not meeting GLBA requirements. Questioned costs: None Context: The College’s written information security program did not cover the following requirements: 1. The requirement to have the written information security program be approved by an appropriate individual. 2. The requirement to provide for the design and implementation of safeguards to control the risks the institution identifies through its risk assessment (16 CFR 314.4(c)). At a minimum, the institution’s written information security program must address the implementation of the minimum safeguards identified in 16 CFR 314.4(c)(1) through (8). a. The element missing is the requirement to encrypt customer information on the institution’s system and when it’s in transit. 3. The requirement to provide for the institution to regularly test or otherwise monitor the effectiveness of the safeguards it has implemented (16 CFR 314.4(d) Cause: The College has not fully implemented its written information security program to meet all GLBA requirements. Effect: The College's written information security program is non-compliant with GLBA requirements, potentially exposing customer information to risks due to inadequate approval, missing safeguards, and lack of regular testing or monitoring. Repeat Finding: No Recommendation: We recommend the College ensure its written information security program addresses the required minimum elements as outlined in 16 CFR 314.4. Views of responsible officials: There is no disagreement with the audit finding.

Criteria or Specific Requirement: Internal Control – Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Compliance – The Code of Federal Regulations, 34 CFR 685.309 requires that enrollment status changes for students be reported to NSLDS within 30 days or within 60 days if the student with the status change will be reported on a scheduled transmission within 60 days of the change in status. Condition: For students participating in the Federal Direct Loan and Pell Grant programs, the enrollment status change to withdrawal was not timely reported to NSLDS. Questioned costs: None Context: This condition occurred in 1 out of 17 students tested. Cause: The University’s processes and controls did not ensure that student status changes were properly and timely reported to NSLDS. Effect: The NSLDS system is not updated with the student information which can cause overawarding should the student transfer to another institution and the students may not properly enter the repayment period. Repeat Finding: No Recommendation: We recommend the University review its reporting procedures to ensure that students’ statuses are accurately and timely reported to NSLDS as required by regulations. Views of responsible officials: There is no disagreement with the audit finding.

SIGNIFICANT DEFICIENCY (SD) 2023-001- Special Tests and Provisions- Return to Title IV Based on a population of 7 Return to Title IV students Condition: It appears that the University is not performing the R2T4 calculations accurately and timely. We found 2 instances where the withdrawal date for the students was not determined within the required time, 2 instances where the R2T4 calculation was performed incorrectly, 2 instances where funds were not returned timely and students were over-awarded, and 1 instance where a student was under-awarded. Criteria When a recipient of Title IV grant or loan assistance withdraws from an institution during a payment period or period of enrollment in which the recipient began attendance, the institution must determine the amount of Title IV aid earned by the student as of the student’s withdrawal date. If the total amount of Title IV assistance earned by the student is less than the amount that was disbursed to the student or on his or her behalf as of the date of the institution’s determination that the student withdrew, the difference must be returned to the Title IV programs as outlined in this section and no additional disbursements may be made to the student for the payment period or period of enrollment. If the amount the student earned is greater than the amount disbursed, the difference between the amounts must be treated as a post-withdrawal disbursement (34 CFR 668.22(a)(1) through (a)(5)) . The unearned amount of Title IV assistance to be returned is calculated by subtracting the amount of Title IV assistance earned by the student from the amount of Title IV aid that was disbursed to the student as of the date of the institution’s determination that the student withdrew (34 CFR 668.22(e)). Returns of Title IV funds are required to be deposited or transferred into the SFA account or electronic fund transfers initiated to ED as soon as possible, but no later than 45 days after the date the institution determines that the student withdrew. An institution that is not required to take attendance must determine the withdrawal date for a student who withdraws without providing notification to the institution no later than 30 days after the end of the earlier of the (1) payment period or period of enrollment, (2) academic year in which the student withdrew, or (3) educational program from which the student withdrew (34 CFR 668.22(j)). The institution must also notify the recipient of Title IV loans returned (34 CFR 685.306(a)(2)). Cause: There have been several departmental transitions during the evaluated period which has led to the noncompliance of RT24 requirements, including over-award findings. This transition includes the onboarding of a new Director of Financial aid. Effect: Noncompliance of R2T4 requirements, including over-awards for two students in the amounts of $1,687 and $1,724 in Pell Grant, $300 and $4,202 in Direct Loan and $8 in SEOG. One student was under-awarded earned Pell grant in the amount of $1,225. Recommendation: We recommend for the University to put in place a plan of action to ensure that the registrar’s office and the financial aid office perform timely processes to capture unofficial withdrawals and that proper communication between departments is effective to ensure that R2T4 calculations are performed timely. We recommend that individuals involved in performing the R2T4 procedures be properly trained to ensure that the university is in compliance with the requirements under this section. Views of Responsible Officials and Planned Corrective Actions – See Corrective Action Plan

SIGNIFICANT DEFICIENCY (SD) 2023-001- Special Tests and Provisions- Return to Title IV Based on a population of 7 Return to Title IV students Condition: It appears that the University is not performing the R2T4 calculations accurately and timely. We found 2 instances where the withdrawal date for the students was not determined within the required time, 2 instances where the R2T4 calculation was performed incorrectly, 2 instances where funds were not returned timely and students were over-awarded, and 1 instance where a student was under-awarded. Criteria When a recipient of Title IV grant or loan assistance withdraws from an institution during a payment period or period of enrollment in which the recipient began attendance, the institution must determine the amount of Title IV aid earned by the student as of the student’s withdrawal date. If the total amount of Title IV assistance earned by the student is less than the amount that was disbursed to the student or on his or her behalf as of the date of the institution’s determination that the student withdrew, the difference must be returned to the Title IV programs as outlined in this section and no additional disbursements may be made to the student for the payment period or period of enrollment. If the amount the student earned is greater than the amount disbursed, the difference between the amounts must be treated as a post-withdrawal disbursement (34 CFR 668.22(a)(1) through (a)(5)) . The unearned amount of Title IV assistance to be returned is calculated by subtracting the amount of Title IV assistance earned by the student from the amount of Title IV aid that was disbursed to the student as of the date of the institution’s determination that the student withdrew (34 CFR 668.22(e)). Returns of Title IV funds are required to be deposited or transferred into the SFA account or electronic fund transfers initiated to ED as soon as possible, but no later than 45 days after the date the institution determines that the student withdrew. An institution that is not required to take attendance must determine the withdrawal date for a student who withdraws without providing notification to the institution no later than 30 days after the end of the earlier of the (1) payment period or period of enrollment, (2) academic year in which the student withdrew, or (3) educational program from which the student withdrew (34 CFR 668.22(j)). The institution must also notify the recipient of Title IV loans returned (34 CFR 685.306(a)(2)). Cause: There have been several departmental transitions during the evaluated period which has led to the noncompliance of RT24 requirements, including over-award findings. This transition includes the onboarding of a new Director of Financial aid. Effect: Noncompliance of R2T4 requirements, including over-awards for two students in the amounts of $1,687 and $1,724 in Pell Grant, $300 and $4,202 in Direct Loan and $8 in SEOG. One student was under-awarded earned Pell grant in the amount of $1,225. Recommendation: We recommend for the University to put in place a plan of action to ensure that the registrar’s office and the financial aid office perform timely processes to capture unofficial withdrawals and that proper communication between departments is effective to ensure that R2T4 calculations are performed timely. We recommend that individuals involved in performing the R2T4 procedures be properly trained to ensure that the university is in compliance with the requirements under this section. Views of Responsible Officials and Planned Corrective Actions – See Corrective Action Plan

SIGNIFICANT DEFICIENCY (SD) 2023-001- Special Tests and Provisions- Return to Title IV Based on a population of 7 Return to Title IV students Condition: It appears that the University is not performing the R2T4 calculations accurately and timely. We found 2 instances where the withdrawal date for the students was not determined within the required time, 2 instances where the R2T4 calculation was performed incorrectly, 2 instances where funds were not returned timely and students were over-awarded, and 1 instance where a student was under-awarded. Criteria When a recipient of Title IV grant or loan assistance withdraws from an institution during a payment period or period of enrollment in which the recipient began attendance, the institution must determine the amount of Title IV aid earned by the student as of the student’s withdrawal date. If the total amount of Title IV assistance earned by the student is less than the amount that was disbursed to the student or on his or her behalf as of the date of the institution’s determination that the student withdrew, the difference must be returned to the Title IV programs as outlined in this section and no additional disbursements may be made to the student for the payment period or period of enrollment. If the amount the student earned is greater than the amount disbursed, the difference between the amounts must be treated as a post-withdrawal disbursement (34 CFR 668.22(a)(1) through (a)(5)) . The unearned amount of Title IV assistance to be returned is calculated by subtracting the amount of Title IV assistance earned by the student from the amount of Title IV aid that was disbursed to the student as of the date of the institution’s determination that the student withdrew (34 CFR 668.22(e)). Returns of Title IV funds are required to be deposited or transferred into the SFA account or electronic fund transfers initiated to ED as soon as possible, but no later than 45 days after the date the institution determines that the student withdrew. An institution that is not required to take attendance must determine the withdrawal date for a student who withdraws without providing notification to the institution no later than 30 days after the end of the earlier of the (1) payment period or period of enrollment, (2) academic year in which the student withdrew, or (3) educational program from which the student withdrew (34 CFR 668.22(j)). The institution must also notify the recipient of Title IV loans returned (34 CFR 685.306(a)(2)). Cause: There have been several departmental transitions during the evaluated period which has led to the noncompliance of RT24 requirements, including over-award findings. This transition includes the onboarding of a new Director of Financial aid. Effect: Noncompliance of R2T4 requirements, including over-awards for two students in the amounts of $1,687 and $1,724 in Pell Grant, $300 and $4,202 in Direct Loan and $8 in SEOG. One student was under-awarded earned Pell grant in the amount of $1,225. Recommendation: We recommend for the University to put in place a plan of action to ensure that the registrar’s office and the financial aid office perform timely processes to capture unofficial withdrawals and that proper communication between departments is effective to ensure that R2T4 calculations are performed timely. We recommend that individuals involved in performing the R2T4 procedures be properly trained to ensure that the university is in compliance with the requirements under this section. Views of Responsible Officials and Planned Corrective Actions – See Corrective Action Plan

COMPLIANCE FINDING 2023-002- Special Tests and Provisions – Disbursements to or on behalf of Students. Based on a sample of 2 students Condition: We found one student with a credit balance of $12,584, entirely attributable to awarded Title IV (TIV), where the University did not make additional attempts to disburse the TIV funds to the student and did not return to funds to the Department of Education in a timely manner. Criteria 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. 34 CFR § 668.164 (i)(2). 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. 34 CFR § 668.164 (l)(3). Cause: The university had experienced transition in key unit areas that resulted in this noncompliance finding. The proper checks and balances have since been implemented. Effect: As outlined under 34 CFR 668.164(l), an institution must have a process that ensures SFA funds never escheat to a state or revert to the institution or any other third party. A failure to have such a process in place would call into question an institution’s administrative capability, its fiscal responsibility, and its system of internal controls required under the FSA regulations. Recommendation: We recommend that the University put in place a plan of action to monitor funds due back to the Department of Education throughout the academic term to ensure that they are returned timely. Views of Responsible Officials and Planned Corrective Actions – See Corrective Action Plan

COMPLIANCE FINDING 2023-002- Special Tests and Provisions – Disbursements to or on behalf of Students. Based on a sample of 2 students Condition: We found one student with a credit balance of $12,584, entirely attributable to awarded Title IV (TIV), where the University did not make additional attempts to disburse the TIV funds to the student and did not return to funds to the Department of Education in a timely manner. Criteria 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. 34 CFR § 668.164 (i)(2). 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. 34 CFR § 668.164 (l)(3). Cause: The university had experienced transition in key unit areas that resulted in this noncompliance finding. The proper checks and balances have since been implemented. Effect: As outlined under 34 CFR 668.164(l), an institution must have a process that ensures SFA funds never escheat to a state or revert to the institution or any other third party. A failure to have such a process in place would call into question an institution’s administrative capability, its fiscal responsibility, and its system of internal controls required under the FSA regulations. Recommendation: We recommend that the University put in place a plan of action to monitor funds due back to the Department of Education throughout the academic term to ensure that they are returned timely. Views of Responsible Officials and Planned Corrective Actions – See Corrective Action Plan

COMPLIANCE FINDING 2023-002- Special Tests and Provisions – Disbursements to or on behalf of Students. Based on a sample of 2 students Condition: We found one student with a credit balance of $12,584, entirely attributable to awarded Title IV (TIV), where the University did not make additional attempts to disburse the TIV funds to the student and did not return to funds to the Department of Education in a timely manner. Criteria 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. 34 CFR § 668.164 (i)(2). 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. 34 CFR § 668.164 (l)(3). Cause: The university had experienced transition in key unit areas that resulted in this noncompliance finding. The proper checks and balances have since been implemented. Effect: As outlined under 34 CFR 668.164(l), an institution must have a process that ensures SFA funds never escheat to a state or revert to the institution or any other third party. A failure to have such a process in place would call into question an institution’s administrative capability, its fiscal responsibility, and its system of internal controls required under the FSA regulations. Recommendation: We recommend that the University put in place a plan of action to monitor funds due back to the Department of Education throughout the academic term to ensure that they are returned timely. Views of Responsible Officials and Planned Corrective Actions – See Corrective Action Plan

SIGNIFICANT DEFICIENCY (SD) 2023-001- Special Tests and Provisions- Return to Title IV Based on a population of 7 Return to Title IV students Condition: It appears that the University is not performing the R2T4 calculations accurately and timely. We found 2 instances where the withdrawal date for the students was not determined within the required time, 2 instances where the R2T4 calculation was performed incorrectly, 2 instances where funds were not returned timely and students were over-awarded, and 1 instance where a student was under-awarded. Criteria When a recipient of Title IV grant or loan assistance withdraws from an institution during a payment period or period of enrollment in which the recipient began attendance, the institution must determine the amount of Title IV aid earned by the student as of the student’s withdrawal date. If the total amount of Title IV assistance earned by the student is less than the amount that was disbursed to the student or on his or her behalf as of the date of the institution’s determination that the student withdrew, the difference must be returned to the Title IV programs as outlined in this section and no additional disbursements may be made to the student for the payment period or period of enrollment. If the amount the student earned is greater than the amount disbursed, the difference between the amounts must be treated as a post-withdrawal disbursement (34 CFR 668.22(a)(1) through (a)(5)) . The unearned amount of Title IV assistance to be returned is calculated by subtracting the amount of Title IV assistance earned by the student from the amount of Title IV aid that was disbursed to the student as of the date of the institution’s determination that the student withdrew (34 CFR 668.22(e)). Returns of Title IV funds are required to be deposited or transferred into the SFA account or electronic fund transfers initiated to ED as soon as possible, but no later than 45 days after the date the institution determines that the student withdrew. An institution that is not required to take attendance must determine the withdrawal date for a student who withdraws without providing notification to the institution no later than 30 days after the end of the earlier of the (1) payment period or period of enrollment, (2) academic year in which the student withdrew, or (3) educational program from which the student withdrew (34 CFR 668.22(j)). The institution must also notify the recipient of Title IV loans returned (34 CFR 685.306(a)(2)). Cause: There have been several departmental transitions during the evaluated period which has led to the noncompliance of RT24 requirements, including over-award findings. This transition includes the onboarding of a new Director of Financial aid. Effect: Noncompliance of R2T4 requirements, including over-awards for two students in the amounts of $1,687 and $1,724 in Pell Grant, $300 and $4,202 in Direct Loan and $8 in SEOG. One student was under-awarded earned Pell grant in the amount of $1,225. Recommendation: We recommend for the University to put in place a plan of action to ensure that the registrar’s office and the financial aid office perform timely processes to capture unofficial withdrawals and that proper communication between departments is effective to ensure that R2T4 calculations are performed timely. We recommend that individuals involved in performing the R2T4 procedures be properly trained to ensure that the university is in compliance with the requirements under this section. Views of Responsible Officials and Planned Corrective Actions – See Corrective Action Plan

SIGNIFICANT DEFICIENCY (SD) 2023-001- Special Tests and Provisions- Return to Title IV Based on a population of 7 Return to Title IV students Condition: It appears that the University is not performing the R2T4 calculations accurately and timely. We found 2 instances where the withdrawal date for the students was not determined within the required time, 2 instances where the R2T4 calculation was performed incorrectly, 2 instances where funds were not returned timely and students were over-awarded, and 1 instance where a student was under-awarded. Criteria When a recipient of Title IV grant or loan assistance withdraws from an institution during a payment period or period of enrollment in which the recipient began attendance, the institution must determine the amount of Title IV aid earned by the student as of the student’s withdrawal date. If the total amount of Title IV assistance earned by the student is less than the amount that was disbursed to the student or on his or her behalf as of the date of the institution’s determination that the student withdrew, the difference must be returned to the Title IV programs as outlined in this section and no additional disbursements may be made to the student for the payment period or period of enrollment. If the amount the student earned is greater than the amount disbursed, the difference between the amounts must be treated as a post-withdrawal disbursement (34 CFR 668.22(a)(1) through (a)(5)) . The unearned amount of Title IV assistance to be returned is calculated by subtracting the amount of Title IV assistance earned by the student from the amount of Title IV aid that was disbursed to the student as of the date of the institution’s determination that the student withdrew (34 CFR 668.22(e)). Returns of Title IV funds are required to be deposited or transferred into the SFA account or electronic fund transfers initiated to ED as soon as possible, but no later than 45 days after the date the institution determines that the student withdrew. An institution that is not required to take attendance must determine the withdrawal date for a student who withdraws without providing notification to the institution no later than 30 days after the end of the earlier of the (1) payment period or period of enrollment, (2) academic year in which the student withdrew, or (3) educational program from which the student withdrew (34 CFR 668.22(j)). The institution must also notify the recipient of Title IV loans returned (34 CFR 685.306(a)(2)). Cause: There have been several departmental transitions during the evaluated period which has led to the noncompliance of RT24 requirements, including over-award findings. This transition includes the onboarding of a new Director of Financial aid. Effect: Noncompliance of R2T4 requirements, including over-awards for two students in the amounts of $1,687 and $1,724 in Pell Grant, $300 and $4,202 in Direct Loan and $8 in SEOG. One student was under-awarded earned Pell grant in the amount of $1,225. Recommendation: We recommend for the University to put in place a plan of action to ensure that the registrar’s office and the financial aid office perform timely processes to capture unofficial withdrawals and that proper communication between departments is effective to ensure that R2T4 calculations are performed timely. We recommend that individuals involved in performing the R2T4 procedures be properly trained to ensure that the university is in compliance with the requirements under this section. Views of Responsible Officials and Planned Corrective Actions – See Corrective Action Plan

SIGNIFICANT DEFICIENCY (SD) 2023-001- Special Tests and Provisions- Return to Title IV Based on a population of 7 Return to Title IV students Condition: It appears that the University is not performing the R2T4 calculations accurately and timely. We found 2 instances where the withdrawal date for the students was not determined within the required time, 2 instances where the R2T4 calculation was performed incorrectly, 2 instances where funds were not returned timely and students were over-awarded, and 1 instance where a student was under-awarded. Criteria When a recipient of Title IV grant or loan assistance withdraws from an institution during a payment period or period of enrollment in which the recipient began attendance, the institution must determine the amount of Title IV aid earned by the student as of the student’s withdrawal date. If the total amount of Title IV assistance earned by the student is less than the amount that was disbursed to the student or on his or her behalf as of the date of the institution’s determination that the student withdrew, the difference must be returned to the Title IV programs as outlined in this section and no additional disbursements may be made to the student for the payment period or period of enrollment. If the amount the student earned is greater than the amount disbursed, the difference between the amounts must be treated as a post-withdrawal disbursement (34 CFR 668.22(a)(1) through (a)(5)) . The unearned amount of Title IV assistance to be returned is calculated by subtracting the amount of Title IV assistance earned by the student from the amount of Title IV aid that was disbursed to the student as of the date of the institution’s determination that the student withdrew (34 CFR 668.22(e)). Returns of Title IV funds are required to be deposited or transferred into the SFA account or electronic fund transfers initiated to ED as soon as possible, but no later than 45 days after the date the institution determines that the student withdrew. An institution that is not required to take attendance must determine the withdrawal date for a student who withdraws without providing notification to the institution no later than 30 days after the end of the earlier of the (1) payment period or period of enrollment, (2) academic year in which the student withdrew, or (3) educational program from which the student withdrew (34 CFR 668.22(j)). The institution must also notify the recipient of Title IV loans returned (34 CFR 685.306(a)(2)). Cause: There have been several departmental transitions during the evaluated period which has led to the noncompliance of RT24 requirements, including over-award findings. This transition includes the onboarding of a new Director of Financial aid. Effect: Noncompliance of R2T4 requirements, including over-awards for two students in the amounts of $1,687 and $1,724 in Pell Grant, $300 and $4,202 in Direct Loan and $8 in SEOG. One student was under-awarded earned Pell grant in the amount of $1,225. Recommendation: We recommend for the University to put in place a plan of action to ensure that the registrar’s office and the financial aid office perform timely processes to capture unofficial withdrawals and that proper communication between departments is effective to ensure that R2T4 calculations are performed timely. We recommend that individuals involved in performing the R2T4 procedures be properly trained to ensure that the university is in compliance with the requirements under this section. Views of Responsible Officials and Planned Corrective Actions – See Corrective Action Plan

COMPLIANCE FINDING 2023-002- Special Tests and Provisions – Disbursements to or on behalf of Students. Based on a sample of 2 students Condition: We found one student with a credit balance of $12,584, entirely attributable to awarded Title IV (TIV), where the University did not make additional attempts to disburse the TIV funds to the student and did not return to funds to the Department of Education in a timely manner. Criteria 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. 34 CFR § 668.164 (i)(2). 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. 34 CFR § 668.164 (l)(3). Cause: The university had experienced transition in key unit areas that resulted in this noncompliance finding. The proper checks and balances have since been implemented. Effect: As outlined under 34 CFR 668.164(l), an institution must have a process that ensures SFA funds never escheat to a state or revert to the institution or any other third party. A failure to have such a process in place would call into question an institution’s administrative capability, its fiscal responsibility, and its system of internal controls required under the FSA regulations. Recommendation: We recommend that the University put in place a plan of action to monitor funds due back to the Department of Education throughout the academic term to ensure that they are returned timely. Views of Responsible Officials and Planned Corrective Actions – See Corrective Action Plan

COMPLIANCE FINDING 2023-002- Special Tests and Provisions – Disbursements to or on behalf of Students. Based on a sample of 2 students Condition: We found one student with a credit balance of $12,584, entirely attributable to awarded Title IV (TIV), where the University did not make additional attempts to disburse the TIV funds to the student and did not return to funds to the Department of Education in a timely manner. Criteria 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. 34 CFR § 668.164 (i)(2). 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. 34 CFR § 668.164 (l)(3). Cause: The university had experienced transition in key unit areas that resulted in this noncompliance finding. The proper checks and balances have since been implemented. Effect: As outlined under 34 CFR 668.164(l), an institution must have a process that ensures SFA funds never escheat to a state or revert to the institution or any other third party. A failure to have such a process in place would call into question an institution’s administrative capability, its fiscal responsibility, and its system of internal controls required under the FSA regulations. Recommendation: We recommend that the University put in place a plan of action to monitor funds due back to the Department of Education throughout the academic term to ensure that they are returned timely. Views of Responsible Officials and Planned Corrective Actions – See Corrective Action Plan

COMPLIANCE FINDING 2023-002- Special Tests and Provisions – Disbursements to or on behalf of Students. Based on a sample of 2 students Condition: We found one student with a credit balance of $12,584, entirely attributable to awarded Title IV (TIV), where the University did not make additional attempts to disburse the TIV funds to the student and did not return to funds to the Department of Education in a timely manner. Criteria 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. 34 CFR § 668.164 (i)(2). 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. 34 CFR § 668.164 (l)(3). Cause: The university had experienced transition in key unit areas that resulted in this noncompliance finding. The proper checks and balances have since been implemented. Effect: As outlined under 34 CFR 668.164(l), an institution must have a process that ensures SFA funds never escheat to a state or revert to the institution or any other third party. A failure to have such a process in place would call into question an institution’s administrative capability, its fiscal responsibility, and its system of internal controls required under the FSA regulations. Recommendation: We recommend that the University put in place a plan of action to monitor funds due back to the Department of Education throughout the academic term to ensure that they are returned timely. Views of Responsible Officials and Planned Corrective Actions – See Corrective Action Plan

SIGNIFICANT DEFICIENCY (SD) 2023-001- Special Tests and Provisions- Return to Title IV Based on a population of 7 Return to Title IV students Condition: It appears that the University is not performing the R2T4 calculations accurately and timely. We found 2 instances where the withdrawal date for the students was not determined within the required time, 2 instances where the R2T4 calculation was performed incorrectly, 2 instances where funds were not returned timely and students were over-awarded, and 1 instance where a student was under-awarded. Criteria When a recipient of Title IV grant or loan assistance withdraws from an institution during a payment period or period of enrollment in which the recipient began attendance, the institution must determine the amount of Title IV aid earned by the student as of the student’s withdrawal date. If the total amount of Title IV assistance earned by the student is less than the amount that was disbursed to the student or on his or her behalf as of the date of the institution’s determination that the student withdrew, the difference must be returned to the Title IV programs as outlined in this section and no additional disbursements may be made to the student for the payment period or period of enrollment. If the amount the student earned is greater than the amount disbursed, the difference between the amounts must be treated as a post-withdrawal disbursement (34 CFR 668.22(a)(1) through (a)(5)) . The unearned amount of Title IV assistance to be returned is calculated by subtracting the amount of Title IV assistance earned by the student from the amount of Title IV aid that was disbursed to the student as of the date of the institution’s determination that the student withdrew (34 CFR 668.22(e)). Returns of Title IV funds are required to be deposited or transferred into the SFA account or electronic fund transfers initiated to ED as soon as possible, but no later than 45 days after the date the institution determines that the student withdrew. An institution that is not required to take attendance must determine the withdrawal date for a student who withdraws without providing notification to the institution no later than 30 days after the end of the earlier of the (1) payment period or period of enrollment, (2) academic year in which the student withdrew, or (3) educational program from which the student withdrew (34 CFR 668.22(j)). The institution must also notify the recipient of Title IV loans returned (34 CFR 685.306(a)(2)). Cause: There have been several departmental transitions during the evaluated period which has led to the noncompliance of RT24 requirements, including over-award findings. This transition includes the onboarding of a new Director of Financial aid. Effect: Noncompliance of R2T4 requirements, including over-awards for two students in the amounts of $1,687 and $1,724 in Pell Grant, $300 and $4,202 in Direct Loan and $8 in SEOG. One student was under-awarded earned Pell grant in the amount of $1,225. Recommendation: We recommend for the University to put in place a plan of action to ensure that the registrar’s office and the financial aid office perform timely processes to capture unofficial withdrawals and that proper communication between departments is effective to ensure that R2T4 calculations are performed timely. We recommend that individuals involved in performing the R2T4 procedures be properly trained to ensure that the university is in compliance with the requirements under this section. Views of Responsible Officials and Planned Corrective Actions – See Corrective Action Plan

SIGNIFICANT DEFICIENCY (SD) 2023-001- Special Tests and Provisions- Return to Title IV Based on a population of 7 Return to Title IV students Condition: It appears that the University is not performing the R2T4 calculations accurately and timely. We found 2 instances where the withdrawal date for the students was not determined within the required time, 2 instances where the R2T4 calculation was performed incorrectly, 2 instances where funds were not returned timely and students were over-awarded, and 1 instance where a student was under-awarded. Criteria When a recipient of Title IV grant or loan assistance withdraws from an institution during a payment period or period of enrollment in which the recipient began attendance, the institution must determine the amount of Title IV aid earned by the student as of the student’s withdrawal date. If the total amount of Title IV assistance earned by the student is less than the amount that was disbursed to the student or on his or her behalf as of the date of the institution’s determination that the student withdrew, the difference must be returned to the Title IV programs as outlined in this section and no additional disbursements may be made to the student for the payment period or period of enrollment. If the amount the student earned is greater than the amount disbursed, the difference between the amounts must be treated as a post-withdrawal disbursement (34 CFR 668.22(a)(1) through (a)(5)) . The unearned amount of Title IV assistance to be returned is calculated by subtracting the amount of Title IV assistance earned by the student from the amount of Title IV aid that was disbursed to the student as of the date of the institution’s determination that the student withdrew (34 CFR 668.22(e)). Returns of Title IV funds are required to be deposited or transferred into the SFA account or electronic fund transfers initiated to ED as soon as possible, but no later than 45 days after the date the institution determines that the student withdrew. An institution that is not required to take attendance must determine the withdrawal date for a student who withdraws without providing notification to the institution no later than 30 days after the end of the earlier of the (1) payment period or period of enrollment, (2) academic year in which the student withdrew, or (3) educational program from which the student withdrew (34 CFR 668.22(j)). The institution must also notify the recipient of Title IV loans returned (34 CFR 685.306(a)(2)). Cause: There have been several departmental transitions during the evaluated period which has led to the noncompliance of RT24 requirements, including over-award findings. This transition includes the onboarding of a new Director of Financial aid. Effect: Noncompliance of R2T4 requirements, including over-awards for two students in the amounts of $1,687 and $1,724 in Pell Grant, $300 and $4,202 in Direct Loan and $8 in SEOG. One student was under-awarded earned Pell grant in the amount of $1,225. Recommendation: We recommend for the University to put in place a plan of action to ensure that the registrar’s office and the financial aid office perform timely processes to capture unofficial withdrawals and that proper communication between departments is effective to ensure that R2T4 calculations are performed timely. We recommend that individuals involved in performing the R2T4 procedures be properly trained to ensure that the university is in compliance with the requirements under this section. Views of Responsible Officials and Planned Corrective Actions – See Corrective Action Plan

SIGNIFICANT DEFICIENCY (SD) 2023-001- Special Tests and Provisions- Return to Title IV Based on a population of 7 Return to Title IV students Condition: It appears that the University is not performing the R2T4 calculations accurately and timely. We found 2 instances where the withdrawal date for the students was not determined within the required time, 2 instances where the R2T4 calculation was performed incorrectly, 2 instances where funds were not returned timely and students were over-awarded, and 1 instance where a student was under-awarded. Criteria When a recipient of Title IV grant or loan assistance withdraws from an institution during a payment period or period of enrollment in which the recipient began attendance, the institution must determine the amount of Title IV aid earned by the student as of the student’s withdrawal date. If the total amount of Title IV assistance earned by the student is less than the amount that was disbursed to the student or on his or her behalf as of the date of the institution’s determination that the student withdrew, the difference must be returned to the Title IV programs as outlined in this section and no additional disbursements may be made to the student for the payment period or period of enrollment. If the amount the student earned is greater than the amount disbursed, the difference between the amounts must be treated as a post-withdrawal disbursement (34 CFR 668.22(a)(1) through (a)(5)) . The unearned amount of Title IV assistance to be returned is calculated by subtracting the amount of Title IV assistance earned by the student from the amount of Title IV aid that was disbursed to the student as of the date of the institution’s determination that the student withdrew (34 CFR 668.22(e)). Returns of Title IV funds are required to be deposited or transferred into the SFA account or electronic fund transfers initiated to ED as soon as possible, but no later than 45 days after the date the institution determines that the student withdrew. An institution that is not required to take attendance must determine the withdrawal date for a student who withdraws without providing notification to the institution no later than 30 days after the end of the earlier of the (1) payment period or period of enrollment, (2) academic year in which the student withdrew, or (3) educational program from which the student withdrew (34 CFR 668.22(j)). The institution must also notify the recipient of Title IV loans returned (34 CFR 685.306(a)(2)). Cause: There have been several departmental transitions during the evaluated period which has led to the noncompliance of RT24 requirements, including over-award findings. This transition includes the onboarding of a new Director of Financial aid. Effect: Noncompliance of R2T4 requirements, including over-awards for two students in the amounts of $1,687 and $1,724 in Pell Grant, $300 and $4,202 in Direct Loan and $8 in SEOG. One student was under-awarded earned Pell grant in the amount of $1,225. Recommendation: We recommend for the University to put in place a plan of action to ensure that the registrar’s office and the financial aid office perform timely processes to capture unofficial withdrawals and that proper communication between departments is effective to ensure that R2T4 calculations are performed timely. We recommend that individuals involved in performing the R2T4 procedures be properly trained to ensure that the university is in compliance with the requirements under this section. Views of Responsible Officials and Planned Corrective Actions – See Corrective Action Plan

COMPLIANCE FINDING 2023-002- Special Tests and Provisions – Disbursements to or on behalf of Students. Based on a sample of 2 students Condition: We found one student with a credit balance of $12,584, entirely attributable to awarded Title IV (TIV), where the University did not make additional attempts to disburse the TIV funds to the student and did not return to funds to the Department of Education in a timely manner. Criteria 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. 34 CFR § 668.164 (i)(2). 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. 34 CFR § 668.164 (l)(3). Cause: The university had experienced transition in key unit areas that resulted in this noncompliance finding. The proper checks and balances have since been implemented. Effect: As outlined under 34 CFR 668.164(l), an institution must have a process that ensures SFA funds never escheat to a state or revert to the institution or any other third party. A failure to have such a process in place would call into question an institution’s administrative capability, its fiscal responsibility, and its system of internal controls required under the FSA regulations. Recommendation: We recommend that the University put in place a plan of action to monitor funds due back to the Department of Education throughout the academic term to ensure that they are returned timely. Views of Responsible Officials and Planned Corrective Actions – See Corrective Action Plan

COMPLIANCE FINDING 2023-002- Special Tests and Provisions – Disbursements to or on behalf of Students. Based on a sample of 2 students Condition: We found one student with a credit balance of $12,584, entirely attributable to awarded Title IV (TIV), where the University did not make additional attempts to disburse the TIV funds to the student and did not return to funds to the Department of Education in a timely manner. Criteria 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. 34 CFR § 668.164 (i)(2). 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. 34 CFR § 668.164 (l)(3). Cause: The university had experienced transition in key unit areas that resulted in this noncompliance finding. The proper checks and balances have since been implemented. Effect: As outlined under 34 CFR 668.164(l), an institution must have a process that ensures SFA funds never escheat to a state or revert to the institution or any other third party. A failure to have such a process in place would call into question an institution’s administrative capability, its fiscal responsibility, and its system of internal controls required under the FSA regulations. Recommendation: We recommend that the University put in place a plan of action to monitor funds due back to the Department of Education throughout the academic term to ensure that they are returned timely. Views of Responsible Officials and Planned Corrective Actions – See Corrective Action Plan

COMPLIANCE FINDING 2023-002- Special Tests and Provisions – Disbursements to or on behalf of Students. Based on a sample of 2 students Condition: We found one student with a credit balance of $12,584, entirely attributable to awarded Title IV (TIV), where the University did not make additional attempts to disburse the TIV funds to the student and did not return to funds to the Department of Education in a timely manner. Criteria 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. 34 CFR § 668.164 (i)(2). 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. 34 CFR § 668.164 (l)(3). Cause: The university had experienced transition in key unit areas that resulted in this noncompliance finding. The proper checks and balances have since been implemented. Effect: As outlined under 34 CFR 668.164(l), an institution must have a process that ensures SFA funds never escheat to a state or revert to the institution or any other third party. A failure to have such a process in place would call into question an institution’s administrative capability, its fiscal responsibility, and its system of internal controls required under the FSA regulations. Recommendation: We recommend that the University put in place a plan of action to monitor funds due back to the Department of Education throughout the academic term to ensure that they are returned timely. Views of Responsible Officials and Planned Corrective Actions – See Corrective Action Plan

DEPARTMENT OF EDUCATION- Student Financial Aid Cluster COMPLIANCE FINDING 2022-001- Special Test and Provisions Based on a sample size of 40 students Condition: It appears that the University reported inaccurate enrollment statuses to The National Student Loan Data System (NSLDS) for two students. The students graduated from the University in the fall 2021 term but were reported as withdrawn to NSLDS. Criteria A participating school shall establish and maintain proper administrative and fiscal procedures and all necessary records as set forth in this part and in 34 C.F.R. part 668; and submit all reports required by this part and 34 C.F.R. part 668 to the Secretary. 34 C.F.R. ? 685.309(a). Regulations require that upon receipt of an enrollment report from the Secretary or a similar report from any guaranty agency, an institution must complete and return that report within 30 days of receipt and, unless it expects to submit its next enrollment report to the Secretary within the next 60 days, notify the Secretary within 30 if it discovers that a Direct Subsidized, Direct Unsubsidized, or Direct PLUS Loan has been made to or on behalf of a student who enrolled at the school but has ceased to be enrolled on at least a half-time, has been accepted for enrollment at the school but failed to enroll on at least a half-time basis for the period for which the loan was intended, or has changed his or her permanent address. 34 C.F.R. ?685.309 (b)(2)(i)(ii) Cause: The University experienced a cyber-attack during the fall 2021 semester, and as a result, portions of the National Student Clearing House reporting was affected. Resulting in inaccurate data being reported to NSLDS. Effect: Enrollment reporting is critical for the effective administration of Federal loans and the accuracy of student loan records depends heavily on the information reported by the institution. An institution is ultimately responsible for timely and accurate reporting. An institution?s failure to report student enrollment status data timely and accurately to NSLDS may delay or prevent the student?s eligibility for deferments, grace periods, repayments, and the payment of interest subsidies. Recommendation: We recommend for the University to put in place a plan of action to mitigate the risk of incorrect enrollment reporting to NSLDS. Views of Responsible Officials and Planned Corrective Actions ? See Corrective Action Plan

COMPLIANCE FINDING 2022-002- Special Test and Provisions Based on a sample of 6 students Condition: It appears that the University did not send exit counseling communication to two students within 30 days of determining that the student borrower was graduating in the fall 2021 term. Criteria 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. 34 C.F.R. ? 685.304 (b)(1). 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. 34 C.F.R. ? 685.304 (b)(3). Cause: Due to the ransomware attack to the University?s system management was not able to access the system and student records in order to email exit counseling notifications to students within the required time frame, approximate to their graduation dates. Effect: An institution?s failure to provide loan counseling to students in accordance with the Federal regulations may result in increased student loan defaults and cause increased expense for the Department. Recommendation: We recommend that the University put in place a plan of action to ensure exit counseling notifications are sent to students in a timely manner. Views of Responsible Officials and Planned Corrective Actions ? See Corrective Action Plan

DEPARTMENT OF EDUCATION- COVID-19 Higher Education Emergency Relief Fund (HEERF COMPLIANCE and INTERNAL CONTROL FINDING 2022-003 Condition: The University was not able to provide all supporting documentation for the HEERF annual report that was submitted to the Department of Education for calendar year 2021. Criteria The CARES Act 18004(e) and the CRRSAA 314(e) requires an institution receiving funds under HEERF I and HEERF II to submit a report to the secretary, at such time in such a manner as the secretary may require. While ARP does not explicitly identify procedures by which institutions must report on their uses of HEERF grant funds, ED exercises this reporting authority under 2 CFR section 200.328 and 2 CFR section 200.329. Cause: The University experienced turn-over in personnel responsible for performing the periodic and annual reporting for the HEERF funding requirements and the responsibilities were not properly communicated during the transition. Effect: The University did not have the appropriate support and source documentation to substantiate the information contained in the annual report. Recommendation: We recommend that the University maintain a file for all periodic and annual reporting to contain and preserve all supporting information and documentation to back up the number and disclosures in each report. Views of Responsible Officials and Planned Corrective Actions ? See Corrective Action Plan

Condition: The University provided multiple updated versions of the SEFA to correct the amount of expenditures for some federal programs. Journal entries that are considered material both individually and in aggregate were made by the client. It appears that the Financial Aid office and Accounting/Finance are not working together to ensure that the SEFA is accurate and complete and reconciled in a timely manner. Criteria: 2 CFR 200.510(b) ? the auditee must prepare a schedule of expenditures of federal awards for the period covered by the auditee?s financial statement which must include the total federal awards expended for each individual federal program as determine with. Cause: There appears to be inadequate monitoring and review over the accuracy and completeness of the SEFA. Effect: Multiple updates were made to the amounts on the SEFA which caused difficulty and delays in the auditing process. Recommendation: We recommend that the University designate a separate individual to review and approve the accuracy and completeness of the SEFA.

SD 2019-01 Return to Title IV Federal Agency: Department of Education Federal Program Title: Student Financial Assistance Cluster Awarding Period: July 1, 2018 to June 30, 2019 Criteria: 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. 34 CFR 690.83(b)(2) Upon receipt of an enrollment report from the Secretary, a school must update all information included in the report and return the report to the Secretary within the timeframe prescribed by the Secretary. 34 CFR 685.309(b)(1)(ii). At a minimum, schools are required to certify enrollment every 60 days. Condition: Based on a sample of 31 Title IV Students In our sample of 31 students who received Title IV aid, we found 5 instances where the University did not report the appropriate change in enrollment status to the National Student Loan Data System (NSLDS) within the required 60 days. Cause: The University sends monthly reports to the National Student Clearinghouse (NSC) on the enrollment status of students. The five students completed their academic requirements after the Spring end of term report was submitted to NSC, therefore, the University failed to report their enrollment status within 60 days. When WAU sent in their first term report for the following new semester (Fall), the students were omitted because they were not currently enrolled even though they were actively finishing outstanding requirements. The Office of Registrar failed to monitor the students requiring enrollment status updates. Effect: Title IV requirements were not followed for students who graduated from the institution during the fiscal year. Recommendation: We recommend for the University to have an ongoing monitoring process to ensure that enrollment reporting requirements are met. Management Response: See attached

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