University of Mount Olive, Inc.

Federal Program Information: Pell Grant Program (ALN 84.063) Criteria or Specific Requirement: E. Eligibility: Federal regulations (34 CFR 690.80 (b)(1) & (b)(2)(i)(ii)) require that if the student’s enrollment status changes from one academic term to another within the same award year, the institution shall recalculate the Federal Pell Grant award for the new payment period taking into account any changes in the cost of attendance. If the student’s projected enrollment status changes during a payment period after the student has begun attendance in all of his or her classes for that payment period, the institution may (but is not required to) establish a policy under which the student's award for the payment period is recalculated. Any such recalculations must take into account any changes in the cost of attendance. If such a policy is established, it must apply to all students. If a student's projected enrollment status changes during a payment period before the student begins attendance in all of his or her classes for that payment period, the institution shall recalculate the student's enrollment status to reflect only those classes for which the student actually began attendance. Condition: For two of the students selected for testing, the University did not properly reassess the student’s enrollment status and as a result, over awarded Federal Pell Grant funds. Cause: Administrative oversight and insufficient internal control. Effect or Potential Effect: The University was not in compliance with Pell eligibility requirements, resulting in an over award. Questioned Costs: Known questioned costs are $1,848 and projected questioned costs to the entire population are $91,787. Context: 2 out of 18 students selected for testing. Identification as a Repeat Finding: There were no similar findings identified in the prior year. Recommendation: We recommend the University enhance its procedures over Pell eligibility requirements to ensure students are not over awarded. Views of Responsible Officials: Financial Aid will use a daily credit change report generated automatically from academic records to make any manual credit updates in the PowerFAIDS financial system. Additionally, Financial Aid will use selection sets within PowerFAIDS to identify any credit hour mismatches between what is manually reported versus what is integrated from Power Campus, the academic records database.

Finding 2025-002 Name of Responsible Individuals: Mrs. Tiffany Grandy, Assistant Director of Financial Aid and Mr. Jared Peterson, Financial Aid Counselor Corrective Action: As a result of Audit Finding 2025-002, Financial Aid will use a daily credit change report generated automatically from academic records to make any manual credit updates in the PowerFAIDS financial system. Additionally, Financial Aid will use selection sets within PowerFAIDS to identify any credit hour mismatches between what is manually reported versus what is integrated from Power Campus, the academic records database. Anticipated Completion Date: March 19, 2026

Federal Program Information: Pell Grant Program (ALN 84.063), Direct Student Loans (ALN 84.268) Criteria or Specific Requirement: N. Special Tests and Provisions – Enrollment Reporting – Institutions are required to report enrollment information under the Pell grant and the Direct and Federal Family Education Loan (FFEL) loan programs via the National Student Loan Data System (NSLDS) (OMB No. 1845-0035). Although FFEL loans are no longer made or a part of the Student Financial Assistance Cluster, a student may have a FFEL loan from previous years that would require enrollment reporting for that student (Pell, 34 CFR 690.83(b)(2); FFEL, 34 CFR 682.610; Direct Loan, 34 CFR 685.309). 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 Professional Access (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,” each with separate record types requiring accurate reporting. At a minimum, institutions are required to certify enrollment every 60 days or every other month. The NSLDS Enrollment Reporting Guide provides the requirements and guidance for reporting enrollment details using the NSLDS Enrollment Reporting Process. Condition: Program Level: Significant data elements were inaccurately reported for certain students. Campus Level: Significant data elements were inaccurately reported for certain students and were not submitted within the required timeframe. Cause: Administrative oversight and insufficient internal control. Effect or Potential Effect: The University was not in compliance with the enrollment reporting requirements. Questioned Costs: None. Context: For 12 of 40 program level status changes tested, the University did not accurately report one or more significant data elements to NSLDS. For 2 of 40 campus level status changes tested, the University did not accurately report one or more significant data elements to NSLDS and enrollment was not certified within the required timeframe. Identification as a Repeat Finding: There was one similar finding identified in the prior year. See finding 2024-003. Recommendation: We recommend the University enhance its procedures and internal controls over enrollment reporting to ensure students’ enrollment statuses are accurately reported to NSLDS. Views of Responsible Officials: Financial Aid has generated a report specifically for the Registrar’s Office that indicates enrollment plans for students who stop attending or withdraw from all courses for a single semester. The Registrar’s Office will be using this report for reporting enrollment status changes for students via NSLDS.

Finding 2025-004 Name of Responsible Individuals: Mrs. Tiffany Grandy, Assistant Director of Financial Aid, Mr. Jared Peterson, Financial Aid Counselor, Mrs. Terri Grice, Associate Registrar, and Mrs. Vicky Warrick, Registrar Corrective Action: As a result of Audit Finding 2025-004, Financial Aid has generated a report specifically for the Registrar’s Office that indicates enrollment plans for students who stop attending or withdraw from all courses for a single semester. The Registrar’s Office will be using this report for reporting enrollment status changes for students via NSLDS. Anticipated Completion Date: March 19, 2026

2024-003

Federal Program Information: Pell Grant Program (ALN 84.063), Direct Student Loans (ALN 84.268) Criteria or Specific Requirement: N. Special Tests and Provisions – Enrollment Reporting – Institutions are required to report enrollment information under the Pell grant and the Direct and Federal Family Education Loan (FFEL) loan programs via the National Student Loan Data System (NSLDS) (OMB No. 1845-0035). Although FFEL loans are no longer made or a part of the Student Financial Assistance Cluster, a student may have a FFEL loan from previous years that would require enrollment reporting for that student (Pell, 34 CFR 690.83(b)(2); FFEL, 34 CFR 682.610; Direct Loan, 34 CFR 685.309). 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 Professional Access (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,” each with separate record types requiring accurate reporting. The NSLDS Enrollment Reporting Guide provides the requirements and guidance for reporting enrollment details using the NSLDS Enrollment Reporting Process. Condition: Program Level: Significant data elements were inaccurately reported for certain students. Campus Level: Significant data elements were inaccurately reported for certain students. Cause: Administrative oversight and insufficient internal control. Effect or Potential Effect: The University was not in compliance with the enrollment reporting requirements. Questioned Costs: None. Context: For 6 of 40 program level status changes tested, the University did not accurately report one or more significant data elements to NSLDS. For 1 of 40 campus level status changes tested, the University did not accurately report one or more significant data elements to NSLDS. Identification as a Repeat Finding: This is a repeat of Finding 2023-003. Recommendation: We recommend the University enhance its procedures and internal controls over enrollment reporting to ensure students’ enrollment statuses are accurately reported to NSLDS. Views of Responsible Officials: The University has implemented a plan to review the NSLDS website within 10 Business Days of any submission to ensure that the submitted data has been processed correctly by Clearinghouse and NSLDS.

Name of Responsible Individual: Ms. Terri Grice Corrective Action: The University has implemented a plan to review the NSLDS website within 10 Business Days of any submission to ensure that the submitted data has been processed correctly by Clearinghouse and NSLDS. Anticipated Completion Date: December 13, 2024

2023-003

Federal Program Information: Federal Direct Student Loans (ALN 84.268) Criteria or Specific Requirement: N. Special Test and Provisions – Disbursements To or On Behalf of Students - Loan Disbursement Notifications: Federal regulations (34 CFR section 668.165 (a)(6)(i)) require that the institution notify the student, or parent, in writing of (1) the date and amount of the disbursement; (2) the student’s right, or parent’s right, to cancel all or a portion of that loan or loan disbursement and have the loan proceeds returned to the holder of that loan or the TEACH Grant payments returned to the U.S. Department of Education; 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, TEACH Grant, or TEACH Grant 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 Direct Loan or TEACH Grants. 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, and (2) a notice when FSA loan funds or TEACH Grant funds are credited to a student’s account. Condition: Certain loan notifications were not sent timely. Cause: Administrative oversight and insufficient internal control. Effect or Potential Effect: The University was not in compliance with loan notification requirements. Questioned Costs: None. Context: For 11 of 25 loan disbursements tested, the University did not notify the borrower within the required timeframe. Identification as a Repeat Finding: There was no similar finding identified during the prior year. Recommendation: We recommend that the University enhance its procedures and internal controls over loan notifications to ensure timely and accurate notification to borrowers. Views of Responsible Officials: An automated batch email process has been updated to ensure that all loan disbursement notifications will be sent the same day as the loans are disbursed. In addition to the automation, calendar reminders have been set for all scheduled disbursement days. It will be the duty of the Director to ensure the process is successful and would only fall to the Assistant Director in times that the Director is unavailable.

Name of Responsible Individual: Brian K. Blackburn, Director of Financial Aid Corrective Action: An automated batch email process has been updated to ensure that all loan disbursement notifications will be sent the same day as the loans are disbursed. In addition to the automation, calendar reminders have been set for all scheduled disbursement days. It will be the duty of the Director to ensure the process is successful and would only fall to the Assistant Director in times that the Director is unavailable. Anticipated Completion Date: November 9, 2023

Federal Program Information: Federal Pell Grant Program (ALN 84.063), Federal Direct Student Loans (ALN 84.268) Criteria or Specific Requirement: N. Special Tests and Provisions – Enrollment Reporting – Institutions are required to report enrollment information under the Pell grant and the Direct and Federal Family Education Loan (FFEL) loan programs via the National Student Loan Data System (NSLDS) (OMB No. 1845-0035). Although FFEL loans are no longer made or a part of the Student Financial Assistance Cluster, a student may have a FFEL loan from previous years that would require enrollment reporting for that student (Pell, 34 CFR 690.83(b)(2); FFEL, 34 CFR 682.610; Direct Loan, 34 CFR 685.309). 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 Professional Access (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,” each with separate record types requiring accurate reporting. 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 within 15 days the Enrollment Reporting roster file placed in their Student Aid Internet Gateway (SAIG) (OMB No. 1845-0002) mailboxes sent by ED via NSLDS. After the institution submits the Enrollment Reporting roster to NSLDS, NSLDS evaluates the Enrollment Reporting roster and provides the institution an Error/Acknowledgement file. If errors are identified, institutions have 10 days to correct the errors and resubmit to NSLDS. Condition: Program Level: Significant data elements were inaccurately reported for certain students. Additionally, error records were not corrected within the required timeframe. Cause: Administrative oversight and insufficient internal control. Effect or Potential Effect: The University was not in compliance with the enrollment reporting requirements. Questioned Costs: None. Context: For 22 of 40 program level status changes tested, the University did not accurately report one or more significant data elements to NSLDS. Error records from 2 Error/Acknowledgement files received during the fiscal year were not corrected within the required timeframe. Identification as a Repeat Finding: This is a repeat of Finding 2022-003. Recommendation: We recommend the University enhance its procedures and internal controls over enrollment reporting to ensure students’ enrollment statuses are accurately reported to NSLDS. Views of Responsible Officials: The Registrar’s Office is continuously cross-training all team members so duties are cross-checked, shared by at least two team members, and completed in a timely manner. The reports used by this office will be reviewed on a frequent basis to ensure information is being reported as it was intended. The team will also meet with other departments on a frequent basis to ensure information is shared in a timely manner and continue to train on the regulations and policies between our institution, Clearinghouse, and NSLDS to ensure accurate reporting of information.

Name of Responsible Individual: Terri Grice, University Registrar Corrective Action: The Registrar’s Office is continuously cross-training all team members so duties are cross-checked, shared by at least two team members, and completed in a timely manner. The reports used by this office will be reviewed on a frequent basis to ensure information is being reported as it was intended. The team will also meet with other departments on a frequent basis to ensure information is shared in a timely manner and continue to train on the regulations and policies between our institution, Clearinghouse, and NSLDS to ensure accurate reporting of information. Anticipated Completion Date: February 23, 2024

2022-003

Federal Program Information: Student Financial Assistance Cluster (Various ALNs) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Using a Servicer or Financial Institution to Deliver Title IV Credit Balances to a Card or Other Access Device - In accordance with 34 CFR 668.164(e)(2 (viii), the University is required to provide to the Secretary of Education an up-to-date URL for its contract and contract data as described in 34 CFR 668.164(e)(2)(vii) for publication in a centralized database accessible to the public. Condition: The University did not report the URL of its cash management contract to the Department as required. Cause: Administrative oversight. Effect or Potential Effect: The University was not in compliance with certain Title IV cash management regulations. Questioned Costs: None. Context: The University has publicly disclosed its Tier One Arrangement via the University’s website; however, the URL of its contract was not reported to the Department as required. Identification as a Repeat Finding: There was no similar finding identified during the prior year. Recommendation: We recommend that the University implement procedures to ensure that links provided are accurate and to provide updates to the Department, as appropriate. Views of Responsible Officials: The link has been submitted to the Department of Education.

FINDING 2023-004 Name of Responsible Individual: Brian K. Blackburn, Director of Financial Aid Corrective Action: The link has been submitted to the Department of Education. Anticipated Completion Date: November 16, 2023

Federal Program Information: Student Financial Assistance Cluster (Various ALN?s) Criteria or Specific Requirement: N. Special Tests and Provisions ? Verification: For students selected for verification by the central processor, the University must obtain acceptable documentation to verify the information required, match information on the documentation to the student aid application, and, if necessary, submit data corrections to the central processor and recalculate awards (34 CFR Part 668 Subpart E). Condition: For certain students selected for verification, the information required to be verified either did not match the underlying supporting documentation (including certain tax information) or was not verified. Cause: Administrative oversight. Effect or Potential Effect: Inaccurate calculation of students? expected family contributions. Questioned Costs: None. Context: For 2 of 25 students tested, the University did not complete appropriate verification procedures. Identification as a Repeat Finding: There was no similar finding identified during the prior year. Recommendation: We recommend the University enhance its procedures over verification to ensure that FAFSA information is appropriately verified. Views of Responsible Officials: The University has in place documentation on completing the verification process and updating any necessary changes to a student?s FAFSA record. During a new employee?s training period, the identified errors were not properly updated by the new employee. If the updates had been made, there would not have been a change to the student?s Expected Family Contribution. The University has implemented a policy to have all verifications cross-checked by other Financial Aid Administrators to ensure the accuracy of the verifications.

Name of Responsible Individual: Brian K. Blackburn, Director of Financial Aid Corrective Action: The University has in place documentation on completing the verification process and updating any necessary changes to a student's FAFSA record. During a new employee's training period, the identified errors were not properly updated by the new employee. If the updates had been made, there would not have been a change to the student's Expected Family Contribution. The University has implemented a policy to have all verifications cross-checked by other Financial Aid Administrators to ensure the accuracy of the verifications. Anticipated Completion Date: March 2, 2023

Federal Program Information: Federal Pell Grant Program (ALN 84.063), Federal Direct Student Loans (ALN 84.268) Criteria or Specific Requirement: N. Special Tests and Provisions ? Enrollment Reporting ? Institutions are required to report enrollment information under the Pell grant and the Direct and Federal Family Education Loan (FFEL) loan programs via the National Student Loan Data System (NSLDS) (OMB No. 1845-0035), although FFEL loans are no longer made or a part of the Student Financial Assistance Cluster, a student may have a FFEL loan from previous years that would require enrollment reporting for that student (Pell, 34 CFR 690.83(b)(2); FFEL, 34 CFR 682.610; Direct Loan, 34 CFR 685.309). 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 Professional Access (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 within 15 days the Enrollment Reporting roster file placed in their Student Aid Internet Gateway (SAIG) (OMB No. 1845-0002) mailboxes sent by ED via NSLDS. After the institution submits the Enrollment Reporting roster to NSLDS, NSLDS evaluates the Enrollment Reporting roster and provides the institution an Error/Acknowledgement file. If errors are identified, institutions have 10 days to correct the errors and resubmit to NSLDS. Condition: Campus Level: Certain students? enrollment status changes were not reported to NSLDS. Program Level: Significant data elements were inaccurately reported for certain students. Additionally, error records were not corrected within the required timeframe. Cause: Administrative oversight. Effect or Potential Effect: The University was not in compliance with the enrollment reporting requirements. Questioned Costs: None. Context: For 2 of 40 campus level records tested, the University did not report the student?s graduated status to NSLDS. For 2 of 25 program level records tested, the University did not accurately report the student?s enrollment status to NSLDS. For 3 of 25 program level records tested, the University did not accurately report the student?s enrollment effective date to NSLDS. Errors identified in two Error/Acknowledgment files received during fiscal year 2022 were not corrected within 10 days. Identification as a Repeat Finding: There was no similar finding identified during the prior year. Recommendation: We recommend the University enhance its procedures over enrollment reporting to ensure students? enrollment statuses are accurately reported to NSLDS. Views of Responsible Officials: Although the Registrar?s Office has experienced turnover in leadership and staff roles in recent years, the remaining staff has adapted and taken on additional duties, as needed. This past summer, the office regained their sense of stability with the hiring of a staff member and a Registrar. The office is continuously cross-training all team members so duties are cross-checked, shared by at least two team members, and completed in a timely manner. The reports used by this office will be reviewed on a frequent basis to ensure information is being reported as it was intended. Team is also meeting with other departments to ensure information is shared consistently which will ensure accurate reporting to Clearinghouse and other agencies.

Name of Responsible Individual: Terri Grice, University Registrar Corrective Action: Although the Registrar?s Office has experienced turnover in leadership and staff roles in recent years, the remaining staff has adapted and taken on additional duties, as needed. This past summer, the office regained their sense of stability with the hiring of a staff member and a Registrar. The office is continuously cross-training all team members so duties are cross-checked, shared by at least two team members, and completed in a timely manner. The reports used by this office will be reviewed on a frequent basis to ensure information is being reported as it was intended. Team is also meeting with other departments to ensure information is shared consistently which will ensure accurate reporting to Clearinghouse and other agencies. Anticipated Completion Date: April 3, 2023 for five (5) audit findings/ Training will be continuous throughout the year.

Federal Program Information: Student Financial Assistance Cluster (Various ALN?s) Criteria or Specific Requirement: N. Special Tests and Provisions ?Disbursements To or On Behalf of Students - If a student received financial aid while attending one or more other institutions, schools are required to request financial aid history using the National Student Loan Data System (NSLDS) Student Transfer Monitoring Process. Under this process, a school informs NSLDS about its transfer students. NSLDS will ?monitor? those students on the school?s ?inform? list and ?alert? the school of any relevant financial aid history changes. A school must wait 7 days after it ?informs? NSLDS about a transfer student before disbursing Title IV aid to that student (34 CFR section 668.19). Condition: Certain students were not added to the Transfer Monitoring List, and the University did not wait to disburse in other instances. Cause: Administrative oversight and insufficient internal control. Effect or Potential Effect: The University did not adhere to the NSLDS Student Transfer Monitoring Process. Questioned Costs: None. Context: For 4 of 16 students tested, the University did not wait at least 7 days after adding the student to the NSLDS alert list before disbursing Title IV funds. For 9 of 16 students tested, the University was unable to provide documentation showing that the student was added to the Transfer Monitoring List. Identification as a Repeat Finding: There was no similar finding identified during the prior year. Recommendation: We recommend that the University enhance its procedures and internal controls to ensure that students are added to the Transfer Monitoring List and an appropriate time has passed before disbursing Title IV aid. Views of Responsible Officials: The University has assigned a Financial Aid Staff member to more closely monitor the NSLDS Transfer Monitoring List that comes in from NSLDS on a monthly basis and coordinate with the Registrar?s Office to ensure that all information is updated in a timely manner. Additionally, we have put in place a new policy that Title IV aid will not be paid until after the end of the Drop/Add period of any given semester.

Name of Responsible Individual: Brian Blackburn, Director of Financial Aid Corrective Action: The University has assigned a Financial Aid Staff member to more closely monitor the NSLDS Transfer Monitoring List that comes in from NSLDS on a monthly basis and coordinate with the Registrar's Office to ensure that all information is updated in a timely manner. Additionally, we have put in place a new policy that Title IV aid will not be paid until after the end of the Drop/ Add period of any given semester. Anticipated Completion Date: March 22, 2023

Federal Program Information: HEERF Supplemental Assistance for Institutions of Higher Education (SAIHE) Program (ALN 84.425S) Criteria or Specific Requirement: Institutions must receive affirmative written consent before providing an emergency financial aid grant to a student?s account. Condition: The University credited emergency financial aid grants to students? accounts without getting affirmative written consent. Cause: Administrative oversight. Effect or Potential Effect: The University was not in compliance with federal guidelines over making emergency financial aid grants to students. Questioned Costs: None. Context: The University was allocated $991,895 of HEERF SAIHE funds, under Absolute Priority 6, which limited the use of these funds to making financial aid grants to students. The University appropriately used the funds to award additional financial aid grants; however, students did not have discretion about how to receive these grants. Identification as a Repeat Finding: There was no similar finding identified during the prior year. Recommendation: We recommend the University enhance its procedures over awarding and disbursing financial aid to ensure adherence to all federal guidelines. Views of Responsible Officials: The University applied for and received the SAIHE grant to assist our students. There was no definitive guidance on handling of the funds for the students. As a result, we posted the grant proceeds to the students? accounts.

Name of Responsible Individual: Ken Buchanan, Senior Vice President for Business and Finance/CFO Corrective Action: The University applied for and received the SAIHE grant to assist our students. There was no definitive guidance on handling of the funds for the students. As a result, we posted the grant proceeds to the students' accounts. Anticipated Completion Date: March 24, 2023

Item 2020-001: Enrollment Reporting U.S. Department of Education Student Financial Assistance Cluster Criteria or specific requirement: The Code of Federal Regulations at 34 CFR Sections 685.309 and 690.83(b)(2) state that institutions must complete and return within 30 days of receipt the SSCR (Student Status Confirmation Report). Unless a roster will be submitted within the next 60 days, the University must notify the lender or guaranty agency within 30 days if it discovers that a student who has a loan either did not enroll or ceased to be in enrolled on at least a half-time basis. Further, under the Direct Loan program, institutions must complete and return within 15 days the enrollment reporting roster file to certify enrollment for all students. Condition: The University did not notify the National Student Loan Data System (NSLDS) within the required 60-day window of a student?s status change. The University did not notify the NSLDS within the required 15-day window a student's enrollment date. Cause: Administrative oversight in reporting status timely. Effect or potential effect: Change in student?s enrollment status was not reported timely and accurately. Questioned costs: None. The reporting date did not affect program costs. Context: Based on a sample of 40 students, one student or 2.5% of the students selected was not reported to the NSLDS within the required window as being withdrawn or enrolled less than half time. The same student had not been reported as enrolled to the NSLDS within the required timeframe. Repeat finding: Yes. Recommendation: We recommend that the University implement adequate procedures to ensure that all status changes are reported in a timely and accurate manner for students who receive federal loans. Views of responsible official: Refer to the University?s Corrective Action Plan.

Identifying Number: 2020-001 Finding: The Code of Federal Regulations at 34 CFR Sections 685.309 and 690.83(b)(2) state that institutions must complete and return within 30 days of receipt the SSCR (Student Status Confirmation Report). Unless a roster will be submitted within the next 60 days, the University must notify the lender or guaranty agency within 30 days if it discovers that a student who has a loan either did not enroll or ceased to be in enrolled on at least a half-time basis. Further, under the Direct Loan program, institutions must complete and return within 15 days the enrollment reporting roster file to certify enrollment for all students. The University did not notify the National Student Loan Data System (NSLDS) within the required 60-day window of a student?s status change. The University did not notify the NSLDS within the required 15-day window a student's enrollment date. Anticipated Completion Date: June 30, 2020 Contact Person: Katrina Lee, Director of Financial Aid Corrective Actions Taken or Planned: The student identified was reported originally reported as withdrawn to Clearinghouse on November 11. A Clearinghouse edit error alerted the university that the student had not been reported as an active student for the fall semester. After researching the issue, it was discovered that the student?s ?Address Type? was input in into Powercampus in incorrectly. Once the issue was resolved, the student was reported as withdrawn on December 24, which was beyond the 60- day window. While great efforts are made to ensure reporting is completed timely, we have added an additional layer to our reporting: The Office of Technology Services and Support has developed a report to identify ?Address Type? errors in the Powercampus system. This report will run on a monthly basis prior to the 30- day reporting period. This process will allow the University to take corrective action and ensure the timely reporting of students who have an incorrect address type.

2019-001

Item 2020-002: Higher Education Emergency Relief Funds U.S. Department of Education COVID-19 Education Stabilization Fund Criteria or specific requirement: In accordance with the CARES Act, institutions are required to have a documented plan in place to distribute emergency financial aid grants to students. Institutions are also required to follow that policy Condition: The University did not award the correct amount of Higher Education Emergency Relief fund program to one identified student. The student was under-awarded by $1,000. Cause: Administrative oversight in calculating the award amount in accordance with the documented policy. Effect or potential effect: Students award was not properly calculated. Questioned costs: None. Context: The University did not follow its internally developed methodology in calculating the Higher Education Emergency Relief Fund awarded. Repeat finding: No. Recommendation: We recommend that the University implement adequate procedures to ensure that all award amount are properly calculated and reviewed. Views of responsible official: Refer to the University?s Corrective Action Plan.

Identifying Number: 2020-002 Finding: In accordance with the CARES Act, institutions are required to have a documented plan in place to distribute emergency financial aid grants to students. Institutions are also required to follow that policy. The University did not award the correct amount of Higher Education Emergency Relief funding to one identified student. The student was under-awarded by $1,000. Anticipated Completion Date: June 30, 2020 Contact Person: Katrina Lee, Director of Financial Aid Corrective Actions Taken or Planned: The HEERF funds were awarded to students based on a matrix, which included the enrollment status and Expected Family Contribution (EFC). The final piece of the matrix was an extra amount for students who resided on campus to offset the additional cost for a studentto abruptly vacate the campus. The student in question did reside on campus, but the university did not award the extra amount. The university has since awarded and disbursed the additional amount to which the student was entitled.

Item 2020-003: Gramm Leach Bliley Act documentation U.S. Department of Education Student Financial Assistance Cluster 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. 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 CFR313.3(k)(2)(vi). Under an institution?s Program Participation Agreement with the Department of Education and the Gramm-Leach-Bliley Act, schools must protect student financial aid information, with particular attention to information provided to institutions by the Department or otherwise obtained in support of the administration of the federal student financial aid programs. Condition: The University does not have a policy in place documenting specific risks identified in relation to the Gramm-Leach-Bliley Act, or safeguards to address identified risk. Cause: Lack of understanding of formal documentation required for (i) risks identified and (ii) safeguards to such risks. Effect or potential effect: The University is not in compliance with the requirement to follow the Gramm-Leach-Bliley Act. Questioned costs: None Context: The University does not have sufficient documentation to evidence compliance with these requirements. Repeat finding: No. Recommendation: The University should implement a policy to ensure it follows the Gramm-Leach-Bliley Act requirements. Views of responsible official: Refer to the University?s Corrective Action Plan.

Identifying Number: 2020-003 Finding: 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. 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 CFR313.3(k)(2)(vi). Under an institution?s Program Participation Agreement with the Department of Education and the Gramm-Leach-Bliley Act, schools must protect student financial aid information, with particular attention to information provided to institutions by the Department or otherwise obtained in support of the administration of the federal student financial aid programs. The University does not have a policy in place documenting specific risks identified in relation to the Gramm-Leach-Bliley Act, or safeguards to address identified risks. Anticipated Completion Date: June 30, 2020 Contact Person: Katrina Lee, Director of Financial Aid Corrective Actions Taken or Planned: The university has several policies addressing the requirements of the Gramm-Leach-Bliley Act. However, work on an additional policy that addresses the risk assessment specific to employee training and management is ongoing. An existing committee will take over the review and updates of the new policy once it is completed. In addition, the same group will monitor and update as necessary the initial and ongoing training provided to staff in regards to information security.

Item 2019-001: Enrollment Reporting Criteria or specific requirement: The Code of Federal Regulations at 34 CFR Sections 685.309 and 690.83(b)(2) state that schools must complete and return within 30 days of receipt the SSCR (Student Status Confirmation Report). Unless a roster will be submitted within the next 60 days, the University must notify the lender or guaranty agency within 30 days if it discovers that a student who has a loan either did not enroll or ceased to be in enrolled on at least a half-time basis. Condition: The University did not notify the National Student Loan Data System (NSLDS) within the required 60-day window of a student?s status change. Cause: Administrative oversight in reporting status timely. Effect or potential effect: Change in student?s enrollment status was not reported timely and accurately. Questioned costs: None. The reporting date did not affect program costs. Context: Based on a sample of 65 students, one student or 1.5% of the students selected was not reported to the NSLDS within the required window as being withdrawn or enrolled less than half time. Repeat finding: Yes. Recommendation: We recommend that the University implement adequate procedures to ensure that all status changes are reported in a timely and accurate manner for students who receive federal loans. Views of responsible official: Refer to the University?s Corrective Action Plan.

Identifying Number: 2019-001 Finding: The Code of Federal Regulations at 34 CFR Sections 685.309 and 690.83(b)(2) state that schools must complete and return within 30 days of receipt the SSCR (Student Status Confirmation Report). Unless a roster will be submitted within the next 60 days, the University must notify the lender or guaranty agency within 30 days if it discovers that a student who has a loan either did not enroll or ceased to be in enrolled on at least a half-time basis. The University did not notify the National Student Loan Data System (NSLDS) within the required 60-day window of a student?s status change. Based on a sample of 65 students, 1 student or 1.5% of the students selected was not reported to the NSLDS within the required window as being withdrawn or enrolled less than half time. There were no questioned costs relating to this finding. Anticipated Completion Date: October 9, 2019 Contact Person: Katrina Lee, Director of Financial Aid Corrective Actions Taken or Planned: When a student withdraws or stops attending the information is added to the financial aid management system. Each week financial aid creates and provides a report to the registrar?s office to ensure timely reporting of each student. For the student in the finding, the date of the R2T4 and the last day of attendance were reversed which caused the student not to appear in order on the report. The financial aid office has adjusted the report to allow for easy identification in the event of future reversed entries.

2018-001

Item 2019-002: Refunding Unearned Federal Student Financial Aid Criteria or specific requirement: Returns of Title IV funds are required to be deposited or transferred into the SFA account or electronic fund transfers initiated to ED or the appropriate FFEL lender as soon as possible, but no later than 45 days after the date the institution determines that the student withdrew. Returns by check are late if the check is issued more than 45 days after the institution determined the student withdrew or the date on the canceled check shows the check was endorsed more than 60 days after the date the institution determined that the student withdrew (34 CFR 668.173(b)). Condition: The University did not return Title IV funds for one student within the 45 day requirement. Cause: Administrative oversight in refunding Title IV funds timely. Effect or potential effect: Return of a student?s Title IV funds was not completed timely. Questioned costs: None. Timing of refund did not affect program costs. Context: Based on a sample of 40 students who withdrew during the award year, a refund for one student or 2.5% of the students selected, was not returned within the 45 day requirement. Repeat finding: No. Recommendation: We recommend that the University implement adequate procedures to ensure that all refunds of Title IV funds are returned within a timely manner. Views of responsible official: Refer to the University?s Corrective Action Plan.

Identifying Number: 2019-002 Finding: Returns of Title IV funds are required to be deposited or transferred into the SFA account or electronic fund transfers initiated to ED or the appropriate FFEL lender as soon as possible, but no later than 45 days after the date the institution determines that the student withdrew. Returns by check are late if the check is issued more than 45 days after the institution determined the student withdrew or the date on the canceled check shows the check was endorsed more than 60 days after the date the institution determined that the student withdrew (34 CFR 668.173(b)). The University did not return Title IV funds for one student within the 45 day requirement. Based on a sample of 40 students who withdrew during the award year, a refund for one student or 2.5% of the students selected, was not returned within the 45 day requirement. There were no questioned costs for this finding. Anticipated Completion Date: October 9, 2019 Contact Person: Katrina Lee, Director of Financial Aid Corrective Actions Taken or Planned: The university has a robust process in place for checking R2T4s. Each week after R2T4s are completed, a staff member other than the one who completed the R2T4s reviews each one. Yet another staff member randomly selects 25% of the R2T4s and conducts a review. Finally, another staff member randomly selects 10% and conducts a final review. The error for the student identified in this finding was not identified in the R2T4 reviews, but in our random monthly reviews of files. The staff who complete and review R2T4s have been retrained on the entire process. Currently, the Director of Financial Aid is also conducting 100% reviews to make sure the additional training has been sufficient.

Item 2019-003: Refunding Unearned Federal Student Financial Aid Criteria or specific requirement: Federal regulations require that if a student withdraws from classes prior to the completion of 60% of a semester, the balance of unearned student financial aid should be refunded within 45 days of the student?s withdrawal date. 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. The total number of calendar days in a payment or enrollment period includes all days within the period, except for institutionally scheduled breaks of at least five consecutive calendar days (34 CFR 668.22(f)). Condition: The University did not correctly calculate the refund calculations for a certain term. An institutionally schedule break of five consecutive day was not excluded from the total number of calendar days in the enrollment period. Cause: Administrative oversight in reviewing the accuracy of the refund calculations. Effect or potential effect: Refund calculations were not calculated correctly and initial amounts returned were not for the correct amount.Questioned costs: Known questioned costs for the initial sample population are $87. Known questioned costs for the entire population are $160. Context: Out of an initial sample of 40 refunds selected for test work, we noted one refund that was not calculated correctly. We determined the cause was isolated to an incorrect calculation in the spring period for the Traditional program, and therefore all refunds in this spring Traditional program population were examined. Subsequently, we examined all 11 refunds for this spring Traditional program population, five of which had errors related to an incorrect calculation of the break in the enrollment period. Repeat finding: No. Recommendation: We recommend the University develop a process to separately review refund calculations prepared within the financial aid software. Inputs used within the refund calculation should be separately verified and the amounts returned relating to these withdrawals can be calculated correctly prior to returning amounts to the federal government. Views of responsible official: Refer to the University?s Corrective Action Plan. Additional information requested by the U.S. Department of Education for this finding is as follows:[See Schedule of Findings and Questioned Costs for chart]

Identifying Number: 2019-003 Finding: Federal regulations require that if a student withdraws from classes prior to the completion of 60% of a semester, the balance of unearned student financial aid should be refunded within 45 days of the student's withdrawal date. During 2019, there were instances where refunds were not calculated correctly. A break in the spring enrollment period for the Traditional program was not calculated correctly resulting in errors in the refund calculations. Out of an initial sample of 40 refunds selected for test work, we noted one refund that was not calculated correctly. We determined the cause was isolated to an incorrect calculation in the spring period for the Traditional program, and therefore all refunds in this spring Traditional program population were examined. We examined 11 refunds in total for this spring Traditional program population, all of which had errors isolated to an incorrect calculation in the spring break period. Known questioned costs for the initial sample population are $87. Known questioned costs for the entire population are $160. Anticipated Completion Date: October 9, 2019 Contact Person: Katrina Lee, Director of Financial Aid Corrective Actions Taken or Planned: The University uses the Return of Title IV Funds on the Web worksheet available in PowerFaids. In setting up the calendar for fall of 2018-19, the break in question excluded the weekend prior to the first day with no classes scheduled. We have added a step in our set up that includes verifying the number of days in a break as well as the number of days in the semester. In addition to returning the funds that were due to the Department of Education, students affected by this omission were given institutional grants to make up for the amount of the loans returned after the end of their enrollment for the academic year.

Item 2019-004: Award Packaging and Financial Need Calculation Criteria or specific requirement: Federal regulations stipulate that awards must be coordinated among the various programs and with other Federal and non-Federal aid (need and non-need based aid) to ensure that total aid is not awarded in excess of the student?s financial need (Direct Loan, 34 CFR 685.301). The determination of student financial aid award amounts is based on financial need. Financial need is generally defined as the student?s cost of attendance minus financial resources reasonably available. The Direct Loan Program, 34 CFR 685.200, requires that a direct subsidized loan borrower demonstrate financial need. In determining loan amounts for direct subsidized loans, the financial aid administrator subtracts from the cost of attendance, the effective family contribution and the estimated financial assistance for the period of enrollment that the student (or parent on behalf of the student) will receive from Federal, State, institutional or other sources. Condition: The University incorrectly calculated the financial need and related award packaging for one student. Out of a sample of 40 students selected for testing, we noted one student was awarded a direct subsidized loan in excess of their financial need. Cause: The University did not take into consideration all financial assistance the student received during period and excluded certain financial assistance provided by the student?s employer. Effect or potential effect: Direct subsidized loan applicant was over awarded by $1,159. Questioned costs: The direct subsidized loan overpayment for the one student noted in our sample was $1,159. Based on the federal awards of $483,370 in our sample, the extrapolated error was $69,334. Context: We selected 40 students for eligibility testing, which included a review to ensure that total aid was not awarded in excess of the student?s financial need. We noted that the University incorrectly calculated the financial need and related award packaging for one student which resulted in an over award of a direct subsidized loan. Repeat finding: No. Recommendation: We recommend the University review the existing process for award packaging and calculating a student?s financial need to ensure that students are awarded aid in accordance with federal regulations and that all financial assistance, including assistance from all Federal, State, institutional and other sources, is included in the determination of the student?s financial need and total aid to be awarded. Views of responsible officials: Refer to the University?s Corrective Action Plan. Additional information requested by the U.S. Department of Education for this finding is as follows:[See Schedule of Findings and Questioned Costs for chart/table]

Identifying Number: 2019-004 Finding: Federal regulations stipulate that awards must be coordinated among the various programs and with other Federal and non-Federal aid (need and non-need based aid) to ensure that total aid is not awarded in excess of the student's financial need (Direct Loan, 34 CFR 685.301). The determination of student financial aid award amounts is based on financial need. Financial need is generally defined as the student?s cost of attendance minus financial resources reasonably available. The Direct Loan Program, 34 CFR 685.200, requires that a direct subsidized loan borrower demonstrate financial need. In determining loan amounts for direct subsidized loans, the financial aid administrator subtracts from the cost of attendance, the effective family contribution and the estimated financial assistance for the period of enrollment that the student (or parent on behalf of the student) will receive from Federal, State, institutional or other sources. The University incorrectly calculated the financial need and related award packaging for one student, resulting in a direct subsidized loan overpayment of $1,159. Anticipated Completion Date: October 29, 2019 Contact Person: Katrina Lee, Director of Financial Aid Corrective Actions Taken or Planned: The student in question had a late increase in the amount awarded for the NC Need Based Scholarship, which per the state legislation can be awarded up to the cost of attendance. When the award was increased, the staff member failed to decrease the amount of the direct subsidized loan. A review of the system was completed to insure proper set up of funds and packaging formulas and additional training will be completed with the entire financial aid staff.

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2015-002

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2015-004