William Peace UniversityHigher Education

Federal Agency: U.S. Department of Education Federal Program Name: Student Financial Aid Cluster Assistance Listing Numbers: 84.063, 84.268, 84.007, 84.033 Federal Award Identification Numbers: P007A243144, P063P241946, P033A243144, P268K251946 Award Period: July 1, 2024 – June 30, 2025 Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or Specific Requirement: In accordance with 34 CFR 668.22(a)(1), 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 grant or loan assistance that the student earned as of the student’s withdrawal date. Condition: During our testing, it was noted that an R2T4 calculation was not completed. Questioned Costs: N/A Context: One out of seven students selected for testing should have had a R2T4 calculation completed upon withdrawing from the University. Cause: The University’s controls over performing R2T4 calculations were not functioning as designed. Effect: The University is not following guidelines to calculate and return funds depending upon the date of the student’s withdrawal. Repeat Finding: Yes, 2024-005 Recommendation: We recommend the University review the R2T4 requirements and ensure their process incorporates a review of students to ensure no calculations are missed that should be performed. Views of Responsible Officials: There is no disagreement with the audit finding and the University is in the process of implementing corrective procedures.

Federal Agency: U.S. Department of Education Federal Program Name: Student Financial Aid Cluster Assistance Listing Number: 84.063, 84.268 Federal Award Identification Number: P063P241946, P268K251946 Award Period: July 1, 2024 – June 30, 2025 Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or Specific Requirement: Per U.S. Department of Education (ED) regulations, all school participating (or approved to participate) in the Federal Student Aid programs must have an arrangement to report student enrollment data to the NSLDS through a roster file. The school is required to report enrollment status at both the school and program level. The school is required to report changes in the student’s enrollment status, the effective date of the status and an anticipated completion date. An academic program is defined as the combination of the school’s Office of Postsecondary Education Identification (OPEID) number and the program’s Classification of Instructional Program (CIP) code, credential level, and published program length. ED requires the University to report changes in enrollment status and indicate the date that the changes occurred (34 CFR 685.309). Condition: Certain students’ enrollment information was not accurately or timely reported to the NSLDS. Questioned Costs: N/A Context: During our testing of enrollment information at both the program and campus-level detail, we noted the following: • One out of forty students were reported to the NSLDS with the incorrect effective date on the campus -level records. • One out of forty students enrollment status was not reported timely. • Seven out of forty students program begin date was not reported accurately to NSLDS. Cause: The enrollment information that was sent did not adhere to the NSLDS reporting guidelines. Effect: Inaccurate reporting to the NSLDS can result in incorrect determination of a student’s grace period. Repeat Finding: Yes, 2024-006 Recommendation: We recommend the University evaluate its procedures and review regulations to ensure the University understands the definitions for enrollment information required to be reported to the NSLDS. Views of Responsible Officials: There is no disagreement with the audit finding and the University is in the process of implementing corrective procedures.

Federal Agency: U.S. Department of Education Federal Program Name: Student Financial Aid Cluster Assistance Listing Number: 84.268 Federal Award Identification Number: P268K251946 Award Period: July 1, 2024 – June 30, 2025 Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or Specific Requirement: In accordance with CFR 685.200(2)(i), a Direct Subsidized Loan borrower must demonstrate financial need in accordance with title IV, part F of the Act. Condition: A student received a Direct Subsidized Loan that did not demonstrate financial need. Questioned Costs: N/A Context: This condition occurred for one out of forty students. Cause: The University’s controls over the awarding of the appropriate aid based off need were not functioning as designed. Effect: A student received Title IV funding for which they were not eligible. Repeat Finding: Yes, 2024-007 Recommendation: We recommend the University establish additional policies to ensure all students meet the financial need criteria before awarding Title IV funds. Views of Responsible Officials: There is no disagreement with the audit finding and the University is in the process of implementing corrective procedures.

Federal Agency: U.S. Department of Education Federal Program Name: Student Financial Aid Cluster Assistance Listing Number: 84.063, 84.268 Federal Award Identification Number: P063P241946, P268K251946 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 Department of Education requires the University to accurately report disbursement dates and disbursement amounts to the Common Origination and Disbursement (COD) system within 15 days of making Pell Grant and Direct Loan disbursements to students, in accordance with federal regulations (34 CFR 690.83(b)(2) and 34 CFR 685.309). Condition: Certain student loan disbursements were not reported to COD in compliance with federal requirements. Questioned Costs: N/A Context: During our testing of forty disbursements, we noted: • Three out of forty disbursement date errors. • Two out of forty disbursements reported outside of fifteen days. • One out of forty disbursement amount errors. Cause: The University’s controls around reporting to COD were not functioning as designed to ensure timely and accurate reporting. Effect: The University is not in compliance with the Department of Education guidelines. Repeat Finding: Yes, 2024-012 Recommendation: We recommend the University evaluate its procedures and policies around reporting to the COD to ensure that student information is reported timely and accurately. Views of Responsible Officials: There is no disagreement with the audit finding and the University is in the process of implementing corrective procedures.

2025-008: Direct Loan Reconciliations Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Assistance Cluster Federal Assistance Listing Number: 84.268 Federal Award Identification Number: P268K251946 Award Period: 7/1/2024 – 6/30/2025 Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 685.300(b)(5) requires an institution to reconcile their records with the Direct Loan funds received from the Secretary and the Direct Loan disbursement records submitted to and accepted by the Secretary monthly. Condition: Direct loan reconciliations between the COD, G5, and student accounts were not being performed monthly. Questioned Costs: N/A Context: While testing direct loan reconciliations, it was noted that the University did not perform monthly reconciliations for the three months selected for testing. Cause: The University’s process to reconcile direct loans on a monthly basis was not followed during the year. Effect: The University is not complying with internal policy and federal requirements to ensure funds are properly reconciled. Repeat Finding: Yes, 2024-013 Recommendation: The University should ensure all necessary employees receive proper training, support, and time to follow the University’s policies and federal requirements related to monthly reconciliations. There should be a process to maintain all reconciliations as support of performance monthly. Views of Responsible Officials: There is no disagreement with the audit finding and the University is in the process of implementing corrective procedures.

Federal Agency: U.S. Department of Education Federal Program Name: Student Financial Aid Cluster Assistance Listing Number: 84.063, 84.268, 84.007, 84.033 Federal Award Identification Number: P007A243144, P063P241946, P033A243144, P268K251946 Award Period: July 1, 2024 – June 30, 2025 Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or Specific Requirement: Federal regulations require that when a Title IV credit balance occurs, the institution must disburse the credit balance to the student or parent within 14 calendar days of the date the credit balance is created, in accordance with 34 CFR 668.164(h)(2). Condition: The University did not refund the student's Title IV credit balance within 14 days period. Questioned Costs: N/A Context: During our testing we noted two out of forty students were not refunded within the fourteen days per federal requirements. Cause: The University’s controls around credit balances were not functioning as designed to ensure timely refunds to students. Effect: The University is not in compliance with the Department of Education guidelines. Repeat Finding: No Recommendation: We recommend the University evaluate its procedures and policies around credit balances to ensure that students are refunded within the fourteen day requirement. Views of Responsible Officials: There is no disagreement with the audit finding and the University is in the process of implementing corrective procedures.

Federal Agency: U.S. Department of Education Federal Program Name: Student Financial Aid Cluster Assistance Listing Number: 84.063, 84.268, 84.007, 84.033 Criteria or Specific Requirement: Per 2 CFR section 200.303(a), a nonfederal entity must: Establish and maintain effective internal control over the federal award that provides reasonable assurance that the nonfederal 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: During the audit, it was observed that the University did not have adequate segregation of duties in its financial aid office and did not maintain supporting documentation. The Director of Financial Aid prepares is responsible for authorizing, processing, and reviewing transactions related to Title IV funds. Questioned Costs: N/A Context: Effective internal controls are crucial to ensure funds are properly managed and disbursed. There are instances where the Director of Financial Aid is reviewing and approving financial aid packages, reconciliations and other required reports. We also noted instances were supporting documentation could not be provided. Cause: The University’s financial aid processes have overlapping responsibilities which has resulted in inadequate segregation of duties. Effect: The absence of proper segregation of duties increases risk for errors, noncompliance, and inaccuracies in awarding and reporting of Title IV funds. Repeat Finding: No Recommendation: We recommend the University implement additional internal controls to ensure proper segregation of duties. This includes hiring additional staff or redistributing responsibilities to separate the functions of authorizing, processing, and reviewing transactions. Additionally, ongoing training should be provided to financial aid staff on the importance of internal controls and compliance with Title IV regulations. Views of Responsible Officials: There is no disagreement with the audit finding and the University is in the process of implementing corrective procedures. Federal Award Identification Number: P007A243144, P063P241946, P033A243144, P268K251946 Award Period: July 1, 2024 – June 30, 2025 Type of Finding: Material Weakness in Internal Control over Compliance

Federal Agency: U.S. Department of Education Federal Program Name: Student Financial Aid Cluster Assistance Listing Numbers: 84.063, 84.268, 84.007, 84.033 Federal Award Identification Numbers: P007A233144, P063P231946, P033A233144, P268K241946 Award Period: July 1, 2023 – June 30, 2024 Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or Specific Requirement: In accordance with 34 CFR 668.22(a)(1), 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 grant or loan assistance that the student earned as of the student’s withdrawal date. Condition: During our testing, it was noted that an R2T4 calculation was not completed. Questioned Costs: N/A Context: One out of ten students selected for testing should have had a R2T4 calculation completed upon withdrawing from the University. Cause: The University’s controls over performing R2T4 calculations were not functioning as designed. Effect: The University is not following guidelines to calculate and return funds depending upon the date of the student’s withdrawal. Repeat Finding: No Recommendation: We recommend the University review the R2T4 requirements and ensure their process incorporates a review of students to ensure no calculations are missed that should be performed. 2024 – 005: Return of Title IV (R2T4) Funds (Continued) Views of Responsible Officials: There is no disagreement with the audit finding and the University is in the process of implementing corrective procedures.

Federal Agency: U.S. Department of Education Federal Program Name: Student Financial Aid Cluster Assistance Listing Number: 84.063, 84.268 Federal Award Identification Number: P063P231946, P268K241946 Award Period: July 1, 2023 – June 30, 2024 Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or Specific Requirement: Per U.S. Department of Education (ED) regulations, all school participating (or approved to participate) in the Federal Student Aid programs must have an arrangement to report student enrollment data to the NSLDS through a roster file. The school is required to report enrollment status at both the school and program level. The school is required to report changes in the student’s enrollment status, the effective date of the status and an anticipated completion date. An academic program is defined as the combination of the school’s Office of Postsecondary Education Identification (OPEID) number and the program’s Classification of Instructional Program (CIP) code, credential level, and published program length. ED requires the University to report changes in enrollment status and indicate the date that the changes occurred (34 CFR 685.309). Condition: Certain students’ enrollment information was not accurately or timely reported to the NSLDS. Questioned Costs: N/A Context: During our testing of enrollment information at both the program and campus-level detail, we noted the following: • One out of forty students was reported to the NSLDS with an incorrect date of withdrawal on the campus-level records. • Two out of forty students were reported to the NSLDS with the incorrect effective date on the campus -level records. • One out of forty students had a program length incorrectly reported on the program-level records of the NSLDS. Cause: The enrollment information that was sent did not adhere to the NSLDS reporting guidelines. Effect: Inaccurate reporting to the NSLDS can result in incorrect determination of a student’s grace period. Repeat Finding: No Recommendation: We recommend the University evaluate its procedures and review regulations to ensure the University understands the definitions for enrollment information required to be reported to the NSLDS. Views of Responsible Officials: There is no disagreement with the audit finding and the University is in the process of implementing corrective procedures.

Federal Agency: U.S. Department of Education Federal Program Name: Student Financial Aid Cluster Assistance Listing Number: 84.268 Federal Award Identification Number: P268K241946 Award Period: July 1, 2023 – June 30, 2024 Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or Specific Requirement: In accordance with CFR 685.200(2)(i), a Direct Subsidized Loan borrower must demonstrate financial need in accordance with title IV, part F of the Act. Condition: A student received a Direct Subsidized Loan that did not demonstrate financial need. Questioned Costs: $5,500 Context: This condition occurred for one out of forty students. Cause: The University’s controls over the awarding of the appropriate aid based off need were not functioning as designed. Effect: A student received Title IV funding for which they were not eligible. Repeat Finding: No Recommendation: We recommend the University establish additional policies to ensure all students meet the financial need criteria before awarding Title IV funds. Views of Responsible Officials: There is no disagreement with the audit finding and the University is in the process of implementing corrective procedures.

Federal Agency: U.S. Department of Education Federal Program Name: Student Financial Aid Cluster Assistance Listing Number: 84.063, 84.268, 84.007, 84.033 Federal Award Identification Number: P007A233144, P063P231946, P033A233144, P268K241946 Award Period: July 1, 2023 – June 30, 2024 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 nine 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. Condition: Certain elements of the University’s information security program were not maintained in written form. Questioned Costs: N/A Context: As of June 2024, the University’s written information security program did not address the following requirements: • Encrypting customer information on the institution’s system and during transit. • Anticipating and evaluating changes to the information system or network. • Regularly testing or monitoring the effectiveness of implemented safeguards (16 CFR 314.4(d)). • Evaluating and adjusting the information security program based on testing and monitoring results, material changes to operations or business arrangements, risk assessment results, or any other circumstances that may materially impact the program (16 CFR 314.4(g)). Cause: The University’s written policy did not explicitly address the required elements, and there was no process in place to ensure the written information security program aligned with the requirements. Effect: Information security management may not be optimized and responses delayed without the written plan. Repeat Finding: No Recommendation: We recommend the University 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 and the University is in the process of implementing corrective procedures.

Federal Agency: U.S. Department of Education Federal Program Name: Federal Pell Grant Program Assistance Listing Number: 84.063 Federal Award Identification Number: P063P231946 Award Period: July 1, 2023 – June 30, 2024 Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 690.62 states the Pell grant for an academic year is based upon the payment and disbursement schedules published by the Secretary for each award year. The payment schedules take into account the cost of attendance, the student’s Estimated Family Contribution (EFC) and the enrollment status of the student. Condition: During our testing, it was noted one student was under-awarded Pell due to the University using incorrect information. Questioned Costs: N/A Context: One out of a sample of forty students tested was under-awarded Pell grant funds. Cause: The University’s process did not ensure the most accurate information was used when awarding aid. Effect: The student was under-awarded Pell grant funds. Repeat Finding: Yes, 2023-002. Recommendation: We recommend the University implement a review process to ensure calculations of Pell awards are using the correct information. Views of Responsible Officials: There is no disagreement with the audit finding and the University is in the process of implementing corrective procedures.

Federal Agency: U.S. Department of Education Federal Program Name: Student Financial Aid Cluster Assistance Listing Number: 84.268 Federal Award Identification Number: P268K241946 Award Period: July 1, 2023 – June 30, 2024 Type of Finding: Material Weakness in Internal Control over Compliance, Other Matters Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 685.304 requires entrance counseling be performed before disbursing loan funds to the student for Direct Subsidized Loan, Direct Unsubsidized Loan, and Direct PLUS Loans to a graduate or professional student. The regulations also require exit counseling for all students who cease at least half-time study at the school. Condition: During our testing, it was noted that individuals did not receive exit counseling. Questioned Costs: N/A Context: All thirteen students in our sample who either ceased at least half-time study or left the University, did not receive exit counseling. Cause: The University did not follow procedures to ensure students who left the University received exit counseling. Effect: Students may not fully understand their repayment obligations, leading to higher default rates on student loans. This can negatively impact the University’s cohort default rate, potentially resulting in sanctions or loss of eligibility for federal financial aid programs. Repeat Finding: No Recommendation: We recommend the University review its process around sending exit counseling information to students to ensure this information is received and the University is performing required procedures. Views of Responsible Officials: There is no disagreement with the audit finding and the University is in the process of implementing corrective procedures.

Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Assistance Cluster Federal Assistance Listing Number: 84.063, 84.007, 84.268, 84.033 Federal Award Identification Number: P007A233144, P063P231946, P033A233144, P268K241946 Award Period: July 1, 2023 – June 30, 2024 Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 668.56 requires institutions to obtain supporting documentation and perform verification procedures for students selected by the Central Processing System (CPS). Supporting documents must be retained to support the results of students selected for verification. 34 CFR 668.57 lists the acceptable documentation to be obtained for the verification procedures. Condition: During our testing, students did not have the required support for household verification in their files. Questioned Costs: N/A Context: The condition occurred for one of nine students tested. Cause: The University’s internal controls regarding verification procedures were not functioning as designed. Effect: Failing to verify household size could lead to an incorrect household size which impacts the calculation of a student’s Expected Family Contribution which is used for calculating federal aid. Repeat Finding: No Recommendation: The University should review the procedures surrounding the verification process to ensure all necessary support and documentation is obtained as well as maintained in student files. Views of Responsible Officials: There is no disagreement with the audit finding and the University is in the process of implementing corrective procedures.

Federal Agency: U.S. Department of Education Federal Program Name: Student Financial Aid Cluster Assistance Listing Number: 84.063, 84.268 Federal Award Identification Number: P063P231946, P268K241946 Award Period: July 1, 2023 – June 30, 2024 Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or Specific Requirement: The Department of Education requires the University to report the disbursement dates and amounts to the COD system within 15 days of disbursing Pell and Direct Loan funds to a student. (34 CFR 690.83(b)(2) and CFR 685.309) Condition: Disbursements were not reported to COD within the required 15-day timeframe. Questioned Costs: N/A Context: During our testing of forty disbursements, we noted one disbursement was not reported to COD in a timely manner. Cause: The University’s controls around reporting to COD were not functioning as designed to ensure timely reporting. Effect: The University is not in compliance with the Department of Education guidelines. Repeat Finding: No Recommendation: We recommend the University evaluate its procedures and policies around reporting to the COD to ensure that student information is reported timely. Views of Responsible Officials: There is no disagreement with the audit finding and the University is in the process of implementing corrective procedures.

Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Assistance Cluster Federal Assistance Listing Number: 84.268 Federal Award Identification Number: P268K241946 Award Period: 7/1/2023 – 6/30/2024 Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 685.300(b)(5) requires an institution to reconcile their records with the Direct Loan funds received from the Secretary and the Direct Loan disbursement records submitted to and accepted by the Secretary monthly. Condition: Direct loan reconciliations between the COD, G5, and student accounts were not being performed monthly. Questioned Costs: N/A Context: While testing direct loan reconciliations, it was noted that the University did not perform monthly reconciliations for the three months selected for testing. Cause: The University’s process to reconcile direct loans on a monthly basis was not followed during the year. Effect: The University is not complying with internal policy and federal requirements to ensure funds are properly reconciled. Repeat Finding: N/A Recommendation: The University should ensure all necessary employees receive proper training, support, and time to follow the University’s policies and federal requirements related to monthly reconciliations. There should be a process to maintain all reconciliations as support of performance monthly. Views of Responsible Officials: There is no disagreement with the audit finding and the University is in the process of implementing corrective procedures.

Federal Agency: U.S. Department of Education Federal Program Name: Student Financial Aid Cluster Assistance Listing Number: 84.063, 84.268, 84.007, 84.033 Federal Award Identification Number: P007A233144, P063P231946, P033A233144, P268K241946 Award Period: July 1, 2023 – June 30, 2024 Type of Finding: Material Weakness in Internal Control over Compliance Criteria or Specific Requirement: Per 2 CFR section 200.303(a), a nonfederal entity must: Establish and maintain effective internal control over the federal award that provides reasonable assurance that the nonfederal 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: During the audit, it was observed that the University did not have adequate segregation of duties in its financial aid office and did not maintain supporting documentation. The Director of Financial Aid prepares is responsible for authorizing, processing, and reviewing transactions related to Title IV funds. Questioned Costs: N/A Context: Effective internal controls are crucial to ensure funds are properly managed and disbursed. There are instances where the Director of Financial Aid is reviewing and approving financial aid packages, reconciliations and other required reports. We also noted instances were supporting documentation could not be provided. Cause: The University’s financial aid processes have overlapping responsibilities which has resulted in inadequate segregation of duties. Effect: The absence of proper segregation of duties increases risk for errors, noncompliance, and inaccuracies in awarding and reporting of Title IV funds. Repeat Finding: No Recommendation: We recommend the University implement additional internal controls to ensure proper segregation of duties. This includes hiring additional staff or redistributing responsibilities to separate the functions of authorizing, processing, and reviewing transactions. Additionally, ongoing training should be provided to financial aid staff on the importance of internal controls and compliance with Title IV regulations. Views of Responsible Officials: There is no disagreement with the audit finding and the University is in the process of implementing corrective procedures.

Federal Program Information: Student Financial Assistance Cluster (Various Federal Assistance Listing Numbers) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): Special Tests and Provisions – Loan Disbursement Notification - Federal regulations (34 CFR section 668.165) require that the institution notify the student, or parent, in writing of (1) the anticipated date and amount of the disbursement; (2) the student’s right, or parent’s right, to cancel all or a portion of that loan or loan disbursement and have the loan proceeds returned; and (3) the procedure and time by which the student or parent must notify the institution that he or she wishes to cancel the loan or loan disbursement. Institutions that implement an affirmative confirmation process (as described in 34 CFR section 668.165 (a)(6)(i)) must make this notification to the student or parent no earlier than 30 days before, and no later than 30 days after, crediting the student’s account at the institution with the loans. The Federal Student Aid Handbook further clarifies that in general, there are two types of notifications a school must provide: (1) a general notification to parent Direct PLUS borrowers and all students receiving Federal Student Aid (“FSA”) funds (often referred to as award letters), and (2) a notice when FSA loan funds are credited to a student’s account. Condition: The University did not provide award letters to parent Direct PLUS borrowers and all students receiving any FSA funds. Loan disbursement notifications were not sent to all borrowers. Cause: Lack of administrative oversight with respect to award letters and loan disbursement notifications. Effect: Recipients of FSA funds and/or borrowers were not properly notified of their awards or their loan disbursements and their right to cancel or decline loan awards. Questioned Costs: None. Context: For 22 of the 25 students selected for testing, award letters were not sent. For 25 of 25 students, loan disbursement notifications were not sent. Repeat Finding: This is not a repeat finding from the prior year. Recommendation: We recommend the University enhance its policies and procedures over award notifications to ensure that notifications are sent to borrowers and award recipients within the required timeframe. Views of responsible officials and planned corrective actions: Management concurs with the finding. The University plans to review its process of notifying individuals.

Federal Program Information: Student Financial Assistance Cluster (ALN #84.063) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): In accordance with Eligibility – Federal Pell Grants criteria, the amount of a student’s Pell Grant for an academic year is based upon the payment and disbursement schedules published by the Department of Education. (34.CFR Section 690.62(a)) Condition: For one student selected, the University did not award the appropriate Federal Pell amount for the payment period. As a result, the student did not receive the full Pell Grant amount for which they were eligible. Cause: The University did not accurately calculate and disburse the Federal Pell Grant for one student. Effect: One student was awarded the incorrect amount of Federal Pell award for the payment period. Questioned Costs: None. Context: 1 of 25 students selected for testing. Repeat Finding: This is not a repeat finding from the prior year. Recommendation: We recommend that the University accurately calculate Pell Grants for students. Views of responsible officials and planned corrective actions: Management concurs with the finding. The University plans to review its process for calculating Federal Pell Grant awards.

Federal Program Information: Student Financial Assistance Cluster (Various Federal Assistance Listing Numbers) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): In accordance with Eligibility requirements, the University is required to calculate the cost of attendance for students based on the cost of attendance budget. Condition: The cost of attendance for one student did not agree to the budget based on the student’s enrollment. Cause: The University did not appropriately calculate one student’s cost of attendance. Effect: The University did not comply with the requirement to appropriately calculate the cost of attendance for a student. Questioned Costs: None. Context: 1 of 25 students selected for testing. Repeat Finding: This is not a repeat finding from the prior year. Recommendation: We recommend that the University accurately calculate the cost of attendance. Views of responsible officials and planned corrective actions: Management concurs with the finding. The University plans to review its process for the cost of attendance calculation.

Federal Program Information: Student Financial Assistance Cluster (Various Federal Assistance Listing Numbers) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): In accordance with the Special Tests and Provisions ? General Title IV Disbursement Criteria compliance requirements, the University is required to return funds to students within 14 days of the disbursement of Title IV funds creating a credit balance within the student?s account. (34 CFR ? 668.164(i)) Condition: For 3 students selected for testing, the University refunded the students outside of the permissible 14-day period after the credit balance was created. Cause: The University was processing amounts for refund, which took longer than the allowable 14-day period. Effect: The University did not comply with the requirement to refund the students within 14 days. Questioned Costs: None. Context: 3 of the 25 students selected for testing. Repeat Finding: This is not a repeat finding from the prior year. Recommendation: We recommend that the University refund students within 14 days of a credit balance being created. Views of responsible officials and planned corrective actions: Management concurs with the finding. The University plans to expedite its review process in order to return funds timely to students once a credit balance is created.

Federal Program Information: Federal Pell Grant Program (CFDA 84.063) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): In accordance with the Reporting compliance requirements, the University must report all Pell disbursements and submit required records to the Direct Loan Servicing System via the Common Origin and Disbursement (?COD?) system within 15 days of disbursement. (34 CFR ? 690.83) Condition: For 2 students selected for testing, the University did not submit the appropriate records within the 15-day required time period. Cause: The University was unaware that their initial attempt to submit the required information was rejected. Effect: The University did not comply with the requirement to submit records to COD within 15 days of disbursement. Questioned Costs: None. Context: 2 of the 25 students selected for testing. Repeat Finding: This is a repeat finding from the prior year. Recommendation: We recommend that the University submit the appropriate records timely to the COD. Views of responsible officials and planned corrective actions: Management concurs with the finding. The University has implemented a new process on a scheduled basis in order to verify that records are being appropriately submitted on a timely basis.

Federal Program Information: Student Financial Assistance Cluster (various CFDA numbers) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): In accordance with the Return of Title IV Funds compliance requirements within the Special Tests and Provisions compliance requirements, for students who withdraw from the University, the University is required to calculate the return of Title IV funds and return these funds to the Department of Education with 45 days of becoming aware of the withdrawal. (34 CFR ? 668.58) Condition: For 2 students selected for testing, the University did not return the appropriate amount of funds within the 45 day time period. Cause: The University miscalculated the refund or returned the funds outside of the 45 day allowable period. Effect: The University did not comply with the requirement to return funds within 45 days. Questioned Costs: Below reportable threshold. Context: 2 of the 7 students selected for testing. Repeat Finding: This is not a repeat finding from the prior year. Recommendation: We recommend that the University appropriately calculate the return of Title IV funds and return amounts within 45 days of becoming aware of the withdrawal. Views of responsible officials and planned corrective actions: Management concurs with the finding. The University has implemented a new process to verify that the office of financial aid and the registrar work closely to identify withdrawals timely and appropriately calculate the Return of Title IV Funds.

Federal Program Information: Higher Education Emergency Relief Fund (various CFDA numbers) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): In accordance with the Reporting compliance requirements, the University is required to publicly post completed Quarterly Reporting Forms within 10 days of each quarter end. Condition: For 1 quarter, the University did not post the Quarterly Reporting Form and required information within the appropriate time period. Cause: Due to the evolving rules, the University was unaware of the related requirement. Effect: The University did not comply with the requirement to post the Quarterly Reporting Form within 10 days of the quarter end. Questioned Costs: None. Context: 1 of the 4 quarters in the current year. Repeat Finding: This is not a repeat finding from the prior year. Recommendation: We recommend that the University post the required Quarterly Reporting Form each quarter within the appropriate time period. Views of responsible officials and planned corrective actions: Management concurs with the finding. The University has filed all required reports to date and participated in training in order to remain current on compliance requirements.

Federal Program Information: Student Financial Assistance Cluster Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): In accordance with the Special Tests and Provisions compliance requirements, for any checks sent to students that are not returned to the University but are not cashed, the University must return the funds no later than 240 days after the date the University issued the check. (34 CFR ? 668.164) Condition: For 1 student selected for testing that received a refund in the current year, the student did not cash the check and the University did not return the funds within 240 days of the check being issued. Cause: The University did not note that the student had not cashed the check until after the appropriate return window had passed. Effect: The University did not return funds within 240 days after the date of the original check being issued. Questioned Costs: $0 Context: 1 of the 25 students selected for testing. Repeat Finding: This is not a repeat finding from the prior year. Recommendation: We recommend that the University track outstanding checks to monitor the time period outstanding. Views of responsible officials and planned corrective actions: The University agrees with the finding. See Management?s Corrective Action Plan for additional information.

Federal Program Information: Student Financial Assistance Cluster Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): In accordance with the Special Tests and Provisions compliance requirements, for transfer students, the University must request certain information through the National Student Loan Data System (?NSLDS?) and wait seven days after notification to disburse financial aid to the student. (34 CFR ? 668.19) Condition: For 2 students selected for testing that transferred to the University and received financial aid in the current year, the University did not notify NSLDS of the transfer. Cause: The University did not access the NSLDS for these students and thus did not request the related information required. Effect: The University disbursed funds to the students without requesting the appropriate information from NSLDS. Questioned Costs: $0 Context: 2 of the 10 students selected for testing. Repeat Finding: This is not a repeat finding from the prior year. Recommendation: We recommend that the University verify that any transfer students are appropriately monitored within NSLDS prior to receiving financial aid. Views of responsible officials and planned corrective actions: The University agrees with the finding. See Management?s Corrective Action Plan for additional information.

Federal Program Information: Student Financial Assistance Cluster Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): In accordance with the Special Tests and Provisions compliance requirements, for students selected for verification, the University is required to verify certain information from the student?s FAFSA application. (34 CFR ? 668.58) Condition: For 3 students selected for testing the University did not appropriately verify certain pieces of information as required. Cause: The University did not appropriately verify one piece of information for each of the students. Effect: The University did not comply with the request to verify all required information for these students. Questioned Costs: $0 Context: 3 of the 25 students selected for testing. Repeat Finding: This is not a repeat finding from the prior year. Recommendation: We recommend that the University verify that any transfer students are appropriately monitored within NSLDS prior to receiving financial aid. Views of responsible officials and planned corrective actions: The University agrees with the finding. See Management?s Corrective Action Plan for additional information.

Federal Program Information: Federal Pell Grant Program (CFDA 84.063) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): In accordance with the Reporting and Special Tests and Provisions compliance requirements, the University must report all Pell disbursements and submit required records to the Direct Loan Servicing System via the Common Origin and Disbursement (COD) system within 15 days of disbursement. Condition: For 4 students selected for testing the University either did not submit the appropriate records within the 15-day required time period or submitted inaccurate information. Cause: The University did not submit the appropriate records to COD due to overlooking these students. Effect: The University did not comply with the requirement to submit appropriate records to COD within 15 days of disbursement. Questioned Costs: $0 Context: 4 of the 25 students selected for testing. Repeat Finding: This is not a repeat finding from the prior year. Recommendation: We recommend that the University submit the appropriate records timely to the COD. Views of responsible officials and planned corrective actions: The University agrees with the finding. See Management?s Corrective Action Plan for additional information.

Federal Program Information: Federal Direct Student Loans Program (CFDA 84.268) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): In accordance with the Special Tests and Provisions compliance requirements, the University must report all loan disbursements and submit required records to the Direct Loan Servicing System via the Common Origin and Disbursement system within 15 days of disbursement. Condition: For 1 student selected for testing that received direct loans, the University did not notify the Direct Loan Servicing System within the required time frame. Cause: The University did not note the oversight until the subsequent month?s reconciliation process. Effect: The University did not submit the required information in the appropriate timeframe. Questioned Costs: $0 Context: 1 of the 25 students selected for testing. Repeat Finding: This is not a repeat finding from the prior year. Recommendation: We recommend that the University report all loan disbursements and submit required records within the appropriate time period. Views of responsible officials and planned corrective actions: The University agrees with the finding. See Management?s Corrective Action Plan for additional information.

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