Regent UniversityNon-Profit

(1) Summary of Auditors’ Results Financial Statements a. Type of report issued on whether the financial statements were prepared in accordance with generally accepted accounting principles: Unmodified b. Internal control deficiencies over financial reporting disclosed by the audit of the financial statements: • Material weaknesses: No • Significant deficiencies: No c. Noncompliance material to the financial statements: No Federal Awards d. Internal control deficiencies over major programs disclosed by the audit: • Material weaknesses: Yes • Significant deficiencies: No e. Type of report issued on compliance for major programs: Qualified f. Audit findings that are required to be reported in accordance with 2 CFR 200.516(a): Yes g. Major programs: • Student Financial Assistance Cluster – Various ALNs h. Dollar threshold used to distinguish between Type A and Type B programs: $750,000 i. Auditee qualified as a low-risk auditee: No (2) Findings Relating to the Financial Statements Reported in Accordance with Government Auditing Standards None (3) Findings and Questioned Costs Relating to Federal Awards Finding Number: 2025-01 Program: Student Financial Assistance Cluster ALN #: 84.063 and 84.268 Federal Award #’s: P063P235372, P268K225372 Federal Award Years: July 1, 2024 to June 30, 2025 Federal Agencies: U.S. Department of Education Pass-Through Entity: N/A – Direct Award Compliance Requirement: Enrollment Reporting Finding Type: Material Weakness and Material Noncompliance Criteria: Under the Pell grant and the Direct and Federal Family Education Loan programs, institutions are required to report enrollment information via the National Student Loan Data System (NSLDS) (OMB No. 845-0035). The administration of the Title IV programs depends heavily on the accuracy and timeliness of the enrollment information reported by institutions. Institutions must review, update and verify student enrollment statuses, program information and effective dates that appear on the Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS Financial Aid Professionals (NSLDSFAP) website. The data on the institution’s Enrollment Reporting Roster, or Enrollment Maintenance page, is what NSLDS has as the most recently certified enrollment information. There are two categories of enrollment information, “Campus Level” and “Program Level,” both of which need to be reported accurately and have separate record types. The NSLDS Enrollment Reporting Guide provides the requirements and guidance for reporting enrollment details using the NSLDS Enrollment Reporting Process. Institutions are responsible for timely reporting, whether they report directly or via a third-party servicer. Institutions must complete and return the Enrollment Reporting roster file placed in their Student Aid Internet Gateway (SAIG) (OMB No. 1845-0002) mailboxes sent by ED via NSLDS within 15 days. An institution determines how often it receives the Enrollment Reporting roster file with the default set at a minimum of every 60 days. Once received, the institution must update for changes in the data elements for the Campus Record and the Program Record identified above, and submit the changes electronically through the batch method, spreadsheet submittal or the NSLDS website. Additionally, per 2 CFR section 200.303, non-federal entities must establish and maintain effective internal control over federal awards that provide 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. Condition found: During our testwork over student enrollment reporting, we noted Regent did not report all students' status changes accurately or within the required 60 days. For a sample of 60 students who were recipients of Direct Loans or Pell Grants between July 1, 2024 and June 30, 2025 and that had been identified as having withdrawn, graduated, or modified their enrollment status as defined by Regent’s Satisfactory Academic Progress Policy through a change in course load, the following was noted: For 24 students out of the 60 selected for compliance testing, Regent did not transmit the students’ status change to NSLDS within 60 days. For 9 students out of the 60 selected for compliance testing, Regent did not transmit the students’ status change to NSLDS within 60 days and failed to report the correct effective date of the status change. For 2 students out of the 60 selected for compliance testing, Regent failed to report the correct effective date of the status change. For 2 students out of the 60 selected for compliance testing, Regent failed to report the proper status to NSLDS. Additionally, while Regent has controls in place to ensure that enrollment changes are reported timely to the National Student Clearinghouse (NSC), the control does not ensure that any required correspondence with NSC to resolve data matters is happening accurately and timely. Cause: For the students noted above, management communicated that there were delays in the data transmission from the NSC and the NSLDS. While the data was provided to the NSC in a timely manner, there were issues with the data that needed to be resolved between Regent and the NSC in order to proceed with the submission to NSLDS. For the reasons noted above, we determined the related control in place at Regent, which is designed to address the accuracy and timeliness of the transmission reports, is not designed at a sufficient level to verify the accuracy and timeliness of the data transmission to the NSC. Nor does Regent have a control to ensure that any subsequent issues are resolved timely and that the data is ultimately submitted to the NSLDS timely. Proper perspective: Regent’s policy is to submit enrollment data to the NSC on a predetermined schedule that allows Regent to comply with the enrollment reporting requirements. For our sample of 60 students with status changes, we identified 37 students where either the status change was not reported within 60 days, improper status was reported, or the effective date was not accurately reported which indicates a systemic issue. Possible asserted effect: Untimely submission of student enrollment information affects the determinations that lenders and servicers of students’ loans make related to in-school status, deferments, graces periods, and repayment schedules, as well as the federal government’s payment and interest schedules. Questioned costs: None noted. Statistical sampling: The sample was not intended to be, and was not, a statistically valid sample. Repeat finding: A similar finding was reported in the prior year. The prior year finding number was 2024-001 Recommendation: We recommend Regent evaluate its processes and procedures when submitting data to the NSC to mitigate the number of errors in data transmissions in order to expedite the accuracy and timeliness of the NSLDS enrollment reporting. Views of responsible officials: Regent agrees with this finding. Regent intends to strengthen its controls and quality assurance measures over the timeliness of enrollment information to NSLDS.

(1) Summary of Auditors’ Results Financial Statements a. Type of report issued on whether the financial statements were prepared in accordance with generally accepted accounting principles: Unmodified b. Internal control deficiencies over financial reporting disclosed by the audit of the financial statements: • Material weaknesses: No • Significant deficiencies: No c. Noncompliance material to the financial statements: No Federal Awards d. Internal control deficiencies over major programs disclosed by the audit: • Material weaknesses: Yes • Significant deficiencies: No e. Type of report issued on compliance for major programs: Qualified f. Audit findings that are required to be reported in accordance with 2 CFR 200.516(a): Yes g. Major programs: • Student Financial Assistance Cluster – Various ALNs h. Dollar threshold used to distinguish between Type A and Type B programs: $750,000 i. Auditee qualified as a low-risk auditee: Yes (2) Findings Relating to the Financial Statements Reported in Accordance with Government Auditing Standards None (3) Findings and Questioned Costs Relating to Federal Awards Finding Number: 2024-001 Program: Student Financial Assistance Cluster ALN #: 84.063 and 84.268 Federal Award #’s: P063P235372, P268K225372 Federal Award Years: July 1, 2023 to June 30, 2024 Federal Agencies: U.S. Department of Education Pass-Through Entity: N/A – Direct Award Compliance Requirement: Enrollment Reporting Finding Type: Material Weakness and Material Noncompliance Criteria: Under the Pell grant and the Direct and Federal Family Education Loan programs, institutions are required to report enrollment information via the National Student Loan Data System (NSLDS) (OMB No. 845-0035). The administration of the Title IV programs depends heavily on the accuracy and timeliness of the enrollment information reported by institutions. Institutions must review, update and verify student enrollment statuses, program information and effective dates that appear on the Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS Financial Aid Professionals (NSLDSFAP) website. The data on the institution’s Enrollment Reporting Roster, or Enrollment Maintenance page, is what NSLDS has as the most recently certified enrollment information. There are two categories of enrollment information, “Campus Level” and “Program Level,” both of which need to be reported accurately and have separate record types. The NSLDS Enrollment Reporting Guide provides the requirements and guidance for reporting enrollment details using the NSLDS Enrollment Reporting Process. Institutions are responsible for timely reporting, whether they report directly or via a third-party servicer. Institutions must complete and return the Enrollment Reporting roster file placed in their Student Aid Internet Gateway (SAIG) (OMB No. 1845-0002) mailboxes sent by ED via NSLDS within 15 days. An institution determines how often it receives the Enrollment Reporting roster file with the default set at a minimum of every 60 days. Once received, the institution must update for changes in the data elements for the Campus Record and the Program Record identified above, and submit the changes electronically through the batch method, spreadsheet submittal or the NSLDS website. Additionally, per 2 CFR section 200.303, non-federal entities must establish and maintain effective internal control over federal awards that provide 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. Condition found: During our testwork over student enrollment reporting, we noted Regent did not report all changes to students’ status within the required 60 days. For a sample of 40 students who were recipients of Direct Loans or Pell Grants between July 1, 2023 and June 30, 2024 and that had been identified as having withdrawn, graduated, or modified their enrollment status as defined by Regent’s Satisfactory Academic Progress Policy through a change in course load, the following was noted: For 33 students out of the 40 selected for compliance testing, Regent did not transmit the students’ status change to NSLDS within 60 days. Additionally, based on management’s further investigation, it was determined that there were multiple submissions during the year that were delayed and resulted in enrollment reporting being outside of the 60- day window. Additionally, while Regent has controls in place to ensure that enrollment changes are reported timely to the National Student Clearinghouse (NSC), the control does not ensure that any required correspondence with NSC to resolve data matters is happening timely. Cause: For the students noted above, management communicated that there were delays in the data transmission from the NSC and the NSLDS. While the data was provided to the NSC in a timely manner, there were issues with the data that needed to be resolved between Regent and the NSC in order to proceed with the submission to NSLDS. For the reasons noted above, we determined the related control in place at Regent, which is designed to address the timeliness of the transmission reports, is not designed at a level to verify the timeliness of the data transmission to the NSC nor ensure that any subsequent issues are resolved timely and that the data is ultimately submitted to the NSLDS timely. Proper perspective: Regent’s policy is to submit enrollment data to the NSC on a predetermined schedule that allows Regent to comply with the enrollment reporting requirements. For our sample of 40 students with status changes, we identified 33 students where the status change was not reported within 60 days. Upon further review by management, there were a total of 13 submissions for which the delay in the resolution of issues between Regent and the NSC resulted in the enrollment information being reported outside of the 60-day reporting requirement. As a result of these delays, there were a significant number of changes that were not reporting timely. Possible asserted effect: Untimely submission of student enrollment information affects the determinations that lenders and servicers of students’ loans make related to in-school status, deferments, graces periods, and repayment schedules, as well as the federal government’s payment and interest schedules. Questioned costs: None noted. Statistical sampling: The sample was not intended to be, and was not, a statistically valid sample. Repeat finding: A similar finding was not reported in the prior year. Recommendation: We recommend that Regent implement additional controls to ensure that the transmission reports are received by NSLDS timely. Additionally, we recommend Regent evaluate its processes and procedures when submitting data to the NSC to ensure that any data issues impacting the timeliness of the transmissions are resolved. Views of responsible officials: Regent agrees with this finding. Regent intends to strengthen its controls and quality assurance measures over the timeliness of enrollment information to NSLDS.

Criteria or Specific Requirement Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. ?Covered transactions? include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. All non-procurement transactions entered into by a passthrough entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. When a non-federal entity enters into a covered transaction with an entity at a lower tier, the nonfederal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended, or debarred or otherwise excluded from participating in the transaction. This verification may be accomplished by (1) checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration (GSA) (Note: The OMB guidance at 2 CFR Part 180 and agency implementing regulations still refer to the SAM Exclusions as the Excluded Parties List System (EPLS)), (2) collecting a certification from the entity, or (3) adding a clause or condition to the covered transaction with that entity (2 CFR section 180.300). Non-federal entities receiving contracts from the federal government are required to comply with the contract clause at FAR 52.209-6 before entering into a subcontract that will exceed $30,000, other than a subcontract for a commercially available off-the-shelf item. Per CFR 200.318 (b)(1), the non-Federal entity must maintain written standards of conduct covering conflicts of interest and governing the actions of its employees engaged in the selection, award, and administration of contracts. No employee, officer, or agent may participate in the selection, award, or administration of a contract supported by a federal award if he or she has a real or apparent conflict of interest. Condition Found and Context There was no policy in place to ensure that vendors who were used by Regent with the federal funds received were not suspended or debarred by the federal government. Possible Cause and Effect Management?s review control over its requirements for HEERF was not operating at a level of precision to ensure effective controls are in place for the program. There is an increased risk that Regent could use federal funds with a vendor who is suspended and disbarred by the federal government or selects a contract due to a conflict of interest. Questioned Costs None identified. Sampling Approach The sample was not intended to be, and was not, a statistically valid sample. Identification of Repeat Finding This finding is not a repeat of a finding in the prior year. Recommendation We recommend that Regent review the compliance supplement guidance annually and when funding for new programs is obtained to ensure that all controls required for each program meet the stated standards. Views of Responsible Officials The University concurs with the recommendation. The University has already taken the necessary steps to bring all relevant policies into alignment with 2 CFR 180.220 to ensure full compliance with the suspension and debarment requirements of the policy.

Findings and Questioned Costs Relating to Federal Awards Finding Number: 2021-001 Compliance requirement: Procurement, Suspension and Debarment Cluster name/program: Education Stabilization Fund Assistance Listing Number: 84.425F Federal agency: U.S. Department of Education Pass-through entity: N/A ? Direct Funding Award year: May 5, 2020, through May 19, 2022 Award number: P425F202071 Finding: Internal Control and Compliance over Procurement, Suspension and Department Prior Year Finding: No Type of Finding: Significant Deficiency Criteria or Specific Requirement Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. ?Covered transactions? include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. All non-procurement transactions entered into by a passthrough entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. When a non-federal entity enters into a covered transaction with an entity at a lower tier, the nonfederal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended, or debarred or otherwise excluded from participating in the transaction. This verification may be accomplished by (1) checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration (GSA) (Note: The OMB guidance at 2 CFR Part 180 and agency implementing regulations still refer to the SAM Exclusions as the Excluded Parties List System (EPLS)), (2) collecting a certification from the entity, or (3) adding a clause or condition to the covered transaction with that entity (2 CFR section 180.300). Non-federal entities receiving contracts from the federal government are required to comply with the contract clause at FAR 52.209-6 before entering into a subcontract that will exceed $30,000, other than a subcontract for a commercially available off-the-shelf item. .REGENT UNIVERSITY AND AFFILIATED ORGANIZATIONS Schedule of Findings and Questioned Costs Year ended June 30, 2021 9 Per CFR 200.318 (b)(1), the non-Federal entity must maintain written standards of conduct covering conflicts of interest and governing the actions of its employees engaged in the selection, award, and administration of contracts. No employee, officer, or agent may participate in the selection, award, or administration of a contract supported by a federal award if he or she has a real or apparent conflict of interest. Condition Found and Context There was no policy in place to ensure that vendors who were used by Regent with the federal funds received were not suspended or debarred by the federal government. Possible Cause and Effect Management?s review control over its requirements for HEERF was not operating at a level of precision to ensure effective controls are in place for the program. There is an increased risk that Regent could use federal funds with a vendor who is suspended and disbarred by the federal government or selects a contract due to a conflict of interest. Questioned Costs None identified. Sampling Approach The sample was not intended to be, and was not, a statistically valid sample. Identification of Repeat Finding This finding is not a repeat of a finding in the prior year. Recommendation We recommend that Regent review the compliance supplement guidance annually and when funding for new programs is obtained to ensure that all controls required for each program meet the stated standards. Views of Responsible Officials The University concurs with the recommendation. The University has already taken the necessary steps to bring all relevant policies into alignment with 2 CFR 180.220 to ensure full compliance with the suspension and debarment requirements of the policy.

Finding Number: 2021-002 Compliance requirement: Special Test: Enrollment Reporting Cluster name/program: Student Financial Assistance Programs Assistance Listing Number: 84.268, Federal agency: U.S. Department of Education Pass-through entity: N/A ? Direct Funding Award year: July 1, 2020, through June 30, 2021 Award number: Multiple Finding: Internal Control and Compliance Student Enrollment Status Prior Year Finding: No Type of Finding: Significant Deficiency Criteria or Specific Requirement In accordance with 34 CFR 682.610, institutions are required to accurately submit the changes in student status and report the date the enrollment status was effective within 60 days of the change to the National Student Loan Data System for Students (NSLDS). A student?s enrollment status determines eligibility for in-school status, deferment, and grace periods, as well as for the payment of interest subsidies to Federal Direct Loan Program loan holders by the U.S. Department of Education. Enrollment reporting in a timely and accurate manner is critical for effective management of the programs. The University uses the services of the National Student Clearinghouse (NSC) to report status changes to the NSLDS. Under this arrangement, the University reports all students enrolled and their status to the NSC. The NSC completes the roster file on behalf of the University and communicates status changes to the NSLDS. Although the University uses the services of NSC, it is still ultimately the University?s responsibility to submit timely, accurate and complete records to the NSLDS. Condition Found and Context For two (2) of the forty (40) students with enrollment changes that were tested, we identified changes in enrollment status and enrollment status effective dates that were not timely or accurately transmitted to NSLDS at the campus-level and program-level. Specifically, the enrollment status effective date in NSLDS for these students is listed as May 1, 2021 when the students graduated on May 8, 2021. The updates were transmitted 89 days and 152 days after the degree clearance process had been completed for these students, which is outside of the required 60 day limit. REGENT UNIVERSITY AND AFFILIATED ORGANIZATIONS Schedule of Findings and Questioned Costs Year ended June 30, 2021 11 Further, we noted Regent has designated controls to verify the data is properly sent to the NSC and NSLDS to ensure the records are complete and accurate, however, the controls did not identify these errors, and therefore, were not operating effectively. Possible Cause and Effect In discussing these conditions with Regent officials, they stated the error was a result of an oversight by staff involved which was not detected by established control procedures. Delayed submission of student enrollment status information affects the determination that lenders and servicers of student loans make related to in-school status, deferments, grace periods, and repayment schedules, as well as the federal government?s payment of interest subsidies. Questioned Costs None identified. Sampling Approach The sample was not intended to be, and was not, a statistically valid sample. Identification of Repeat Finding This finding is not a repeat of a finding in the prior year. Recommendation We recommend that Regent strengthen its processes and controls to ensure timely and accurate reporting of student enrollment status information to the NSLDS. Views of Responsible Officials Regent agrees with the findings that enrollment information was not submitted in a timely manner to NSLDS and/or the information submitted to NSLDS was not submitted accurately. Regent will improve its monitoring of the reports submitted related to student enrollment status.

(3) Findings and Questioned Costs Relating to Federal Awards: Finding 2020-001 ? Disbursement to or on Behalf of Students ? Significant Deficiency in Internal Control and Instance of Noncompliance Compliance requirement: Disbursement to or on Behalf of Students Cluster name/program: Student Financial Assistance CFDA number: 84.268 Federal Direct Student Loans 84.379 Teacher Education Assistance for College and Higher Education Grants (TEACH) Federal agency: U.S. Department of Education Pass-through entity: None Award year: July 1, 2019 through June 30, 2020 Criteria or Specific Requirement 34 CFR ? 668.165 Notices and authorizations. (a) Notices. (1) Before an institution disburses title IV, HEA program funds for any award year, the institution must notify a student of the amount of funds that the student or his or her parent can expect to receive under each title IV, HEA program, and how and when those funds will be disbursed. If those funds include Direct Loan program funds, the notice must indicate which funds are from subsidized loans, which are from unsubsidized loans, and which are from PLUS loans. (2) Except in the case of a post-withdrawal disbursement made in accordance with ? 668.22(a)(5), if an institution credits a student ledger account with Direct Loan, Federal Perkins Loan, or TEACH Grant program funds, the institution must notify the student or parent of - (i) The anticipated date and amount of the disbursement; (ii) The student's or parent's right to cancel all or a portion of that loan, loan disbursement, TEACH Grant, or TEACH Grant disbursement and have the loan proceeds or TEACH Grant proceeds returned to the Secretary; and (iii) The procedures and time by which the student or parent must notify the institution that he or she wishes to cancel the loan, loan disbursement, TEACH Grant, or TEACH Grant disbursement. (3) The institution must provide the notice described in paragraph (a)(2) of this section in writing - (i) No earlier than 30 days before, and no later than 30 days after, crediting the student's ledger account at the institution, if the institution obtains affirmative confirmation from the student under paragraph (a)(6)(i) of this section; or (ii) No earlier than 30 days before, and no later than seven days after, crediting the student's ledger account at the institution, if the institution does not obtain affirmative confirmation from the student under paragraph (a)(6)(i) of this section. 2 CFR ? 200.303 Internal controls. The non-Federal entity must: (a) 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). (b) Comply with the U.S. Constitution, Federal statutes, regulations, and the terms and conditions of the Federal awards. (c) Evaluate and monitor the non-Federal entity's compliance with statutes, regulations and the terms and conditions of Federal awards. (d) Take prompt action when instances of noncompliance are identified including noncompliance identified in audit findings. Condition Found and Context During our testwork over disbursement to or on behalf of students, we noted the following: ? For 39 of the 41 students selected for testing, the required Direct Loan disbursement notifications were sent outside the 30-day required timeframe. Of the 39 students, 5 students also received TEACH Grants and were not notified of their TEACH disbursements. ? For 1 of the 41 students selected for testing, the student did not receive notification of their Spring 2020 Direct Loan disbursement. The University?s control failed to detect that the University did not send the required disbursement notification to the students or parent in the required timeframe. Possible Cause and Effect The University?s control over the disbursement notification process was not performed timely. As a result, students or parents were not notified of their rights, loan date or loan amounts within the required timeframe. Questioned Costs None identified.

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