Mid-Atlantic Christian University

2025-001 Significant Deficiency: Untimely Return of Title IV Funds (U.S. Department of Education, William D. Ford Direct Loan Program, ALN #84.268; Federal Pell Grant Program, ALN #84.063; Federal Supplemental Opportunity Grant Program, ALN #84.007; and TEACH Grant Program, ALN #84.379) Criteria: In accordance with 34 CFR 668.22(j), an institution must complete calculation and return the amount of Title IV funds for which it is responsible as soon as possible, but no later than 45 days after the date of the institution's determination that the student withdrew. Statement of Condition: During the audit, it was noted that the University did not return the determined unearned Title IV funds for one student within the prescribed timeframe. Questioned Costs: There is no monetary error associated with this lapse. Perspective Information: The audit included a detailed testing of 2 student files, of which this significant deficiency applies to 1, indicating an error rate of 50.00%. No other possible students to which this issue could have affected exist beyond those tested during the audit, as all withdrawn students were examined. Cause and Effect: For the noted withdrawal, the return of unearned aid was not completed within the 45-day window due to lapses in communication and nonadherence to established procedures. This could result in compliance deficiencies and affect future aid eligibility for institutions that routinely miss this deadline. Recommendation: The University should ensure that return to Title IV funds calculations and returns of unearned funds, if applicable, are completed within a reasonable timeframe once a student has officially withdrawn or been determined to have unofficially withdrawn. This can be achieved through a thorough review of the current process and enhanced oversight to ensure timely returns. View of Responsible Officials: The finance department has been building back proper procedure and protocol after experiencing several transitions in key departments. The Financial Aid Coordinator left in Spring, paralleled by a medical absence of our VP of Finance, both of which contributed to this oversight. Systems are being implemented to ensure that there are layers of security in place to make sure that compliance deadlines are met. These additional layers consist of cross-training staff, encouraging clear concise communication, and implementing control factors within the software.

2025-001 Initial Fiscal Year End, 2024 Summary of Finding- During the audit, it was noted that the University did not return the determined unearned Title IV funds for one student within the prescribed timeframe which resulted in non-adherence to the 45-day window. Name and Title of Responsible Contact Person(s)- Jane Hodgkins, Vice President for Finance Corrective Action Plan Summary- The finance department has been building back proper procedures and protocol after experiencing several transitions in key departments. The university will institute a compliance checklist that will ensure adherence to the dates for Title IV funding to be returned. This checklist will have the oversight of the Finance department to ensure that action and calculations are done accurately and in a timely manner adhering to the Financial Aid handbook. Anticipated Completion Date- Feb 28, 2026

2025-002 Significant Deficiency: Unsupported Information Utilized in Return to Title IV Funds Calculation (U.S. Department of Education, William D. Ford Direct Loan Program, ALN #84.268; Federal Pell Grant Program, ALN #84.063; Federal Supplemental Opportunity Grant Program, ALN #84.007; and TEACH Grant Program, ALN #84.379) Criteria: In accordance with 34 CFR 668.22(b), an institution must document a student's withdrawal date determined and maintain the documentation as of the date of the institution's determination that the student withdrew. Statement of Condition: During the audit, it was noted that the University could not provide adequate support for the last day of attendance used in completing the return to Title IV funds calculation for one of the withdrawn students tested. Questioned Costs: There is no known monetary error related to this specific issue. Perspective Information: The audit included a detailed testing of 2 student files, of which this significant deficiency applies to 1, indicating an error rate of 50.0%. No other possible students to which this issue could have affected exist beyond those tested during the audit, as all withdrawn students were examined. Cause and Effect: Due to incomplete documentation and lapses in communication, the withdrawal date used in the aid calculation lacked sufficient supporting documentation and did not appear to align with other available records. Using an incorrect date could result in too little or too much Title IV being returned on the student’s behalf. Recommendation: The University should ensure that withdrawal dates are determined in accordance with the code of federal regulations and federal student aid handbook. Once the date is determined in accordance with applicable regulations, appropriate supporting documentation should be maintained to substantiate the date used. View of Responsible Officials: The finance department has begun analyzing existing data path communication within the department and across the University, identifying opportunities for improvement. In the future, the University intends to implement required student attendance reporting by professors. This step will assist in determining last day of attendance via confirmation processes by academic administrators and financial aid administrators and provide supporting documentation for reference. Adding this step is expected to override unreliable communication.

2025-002 Initial Fiscal Year End, 2025 Summary of Finding- During the audit, it was noted the University could not provide support for the last day of attendance to complete the return of Title IV funds for one of the students tested. This lapse in communication between departments led to a variance in the reported last day of attendance, which in turn did not provide a firm last day for calculating return of funding. Name and Title of Responsible Contact Person(s)- Jane Hodgkins, Vice President for Finance Corrective Action Plan Summary- The Finance Department will implement a compliance checklist to be used when a student begins the withdrawal process or when their absence becomes noticed. This checklist will comply with the Federal Student Aid handbook. This procedure will ensure compliance between Academic and Financial Aid Departments. This data path will begin with notification of respective departments and initiation by the Academic Department passing to Financial Aid with parallel communication with the Finance Department for compliance and accuracy of dates and ultimately the return of the accurate amount of Title IV funds. Anticipated Completion Date- Feb 28, 2026

2024-002 Significant Deficiency: Gramm-Leach-Bliley Act (GLBA) (U.S. Department of Education, William D. Ford Direct Loan Program, ALN #84.268) (Repeat Finding 2023-002) Criteria: In accordance with 16 CFR 314.4, a University shall develop, implement, and maintain a comprehensive information security program that is written in one or more readily accessible parts and contains administrative, technical, and physical safeguards that are appropriate to your size and complexity, the nature and scope of your activities, and the sensitivity of any customer information at issue and must contain all of the elements that are further described in 16 CFR 314.4. Statement of Condition: During the audit, it was noted that the University’s Gramm-Leach-Bliley Act Policy did not fully address all of the requirements as described by 16 CFR 314.4. In addition, the application of the comprehensive information security program was not effectively administered by the University during the 2024 year. An updated policy was put into place in February 2024, which addressed several of the deficiencies noted in the existing policy, but not all. The seven required elements for the GLBA policy are as follows, along with the status within each of the University’s policies in place during the year: 1. The policy designates a qualified individual responsible for overseeing and implementing the institution’s information security program and enforcing the information security program in compliance. This attribute was not addressed in the existing policy; the newly implemented policy does address this requirement, identifying a GLBA Compliance Program Coordinator responsible for the listed functions. 2. The policy provides for the information security program to be based on a risk assessment that identifies reasonably foreseeable internal and external risks to the security, confidentiality, and integrity of customer information (as the term customer information applies to the institution) that could result in the unauthorized disclosure, misuse, alteration, destruction, or other compromise of such information, and assesses the sufficiency of any safeguards in place to control these risks. This attribute was not addressed in the existing policy; the newly implemented policy does address this requirement. 3. The policy provides for the design and implementation of safeguards to control the risks the institution identifies through its risk assessment (16 CFR 314.4(c)). At a minimum, the institution’s written information security program must address the implementation of the minimum safeguards identified in 16 CFR 314.4(c)(1) through (8), which are detailed as follows: 3.1. Implement and periodically review access controls. This attribute was not addressed in the existing policy; the newly implemented policy does address this requirement, instituting a continuous monitoring process undertaken at periodic intervals. The timeframe of the periodic intervals is not defined. 3.2. Conduct a periodic inventory of data, noting where it is collected, stored or transmitted. This attribute was not addressed in the existing policy; the newly implemented policy does address this requirement. They will utilize data mapping to complete this process. However, the institution was unable to provide a date of the last inventory completed. 3.3. Encrypt customer information on the institution’s system and when it is in transit. Both the existing policy and the newly implemented policy are silent on this requirement. 3.4. Assess applications developed by the institution. Both the existing policy and the newly implemented policy are silent on this requirement. 3.5. Implement multi-factor authentication for anyone accessing customer information on the institution’s system. Both the existing policy and the newly implemented policy are silent on this requirement. 3.6. Dispose of customer information securely. This attribute was not addressed in the existing policy; the newly implemented policy does address this requirement. The new policy provides a link to the information regarding retention and destruction of documents. 3.7. Anticipate and evaluate changes to the information system or network. This attribute was not addressed in the existing policy; the newly implemented policy does address this requirement. 3.8. Maintain a log of authorized users’ activity and keep an eye out for unauthorized access. This attribute was not addressed in the existing policy; the newly implemented policy does address this requirement. The policy provides a link to the acceptable use policy. 4. The policy provides for the institution to regularly test or otherwise monitor the effectiveness of the safeguards it has implemented. This attribute was not addressed in the existing policy; the newly implemented policy does address this requirement, instituting a continuous monitoring process undertaken at periodic intervals. The timeframe of the periodic intervals is not defined. 5. The policy provides for the implementation of policies and procedures to ensure that personnel are able to enact the information security program. This attribute was not addressed in the existing policy; the newly implemented policy does address this requirement, identifying the IT department in collaboration with the VP of finance as the responsible parties for this process. 6. The policy addresses how the institution will oversee its information system service providers. This attribute was not addressed in the existing policy; the newly implemented policy does address this requirement. The program coordinator has been tasked with this activity in conjunction with the VP of Finance. 7. The policy provides for the evaluation and adjustment of its information security program in light of the results of the required testing and monitoring; any material changes to its operations or business arrangements; the results of the required risk assessments; or any other circumstances that it knows or has reason to know may have a material impact the institution’s information security program. This attribute was not addressed in the existing policy; the newly implemented policy does address this requirement. The policy will be reviewed annually at a minimum. Questioned Costs: Such information is not applicable for this finding since it is nonmonetary in nature. Perspective Information: The audit included testing of the University’s Gramm-Leach-Bliley Act Policy as outlined in Part 5 of the Compliance Supplement including the application of this program for the year. Cause and Effect: Due to lapses of oversight in multiple departments, the University failed to update their GLBA policy in a timely manner to include the required components in accordance with the Compliance Supplement. The University implemented an updated policy in February 2024. Both the previous policy and updated policy were subjected to audit procedures, and several requirements were missing from both policies. Therefore, the policy is considered incomplete and does not provide the appropriate disclosures to consumers. Recommendation: The University should update their Gramm-Leach-Bliley Act Policy to be in accordance with the requirements and put in place effective controls and practices to ensure the policy is monitored in a way to ensure it is administered effectively. View of Responsible Officials: The University recently reviewed the Gramm-Leach-Bliley Act Policy and has put in place controls and practices to effectively monitor and administer the policy. In April 2024, we hired an IT company to help with various campus needs, including data compliance procedures and security measures. The company has been reviewing our current policies and making recommendations to implement appropriate safeguards to keep the university up to date and compliant. We have already installed multi-factor authentication features for our software systems, and there are more updates to come. In July 2024, we received a notice of compliance from the Federal Student Aid regarding our corrective action procedures for the Gramm-Leach-Bliley Act.

2024-002 Initial Fiscal Year End, 2024 Summary of Finding- During the audit, it was noted that the University's Gramm-Leach-Bliley Act Policy did not fully address all of the requirements as described by 16 CFR 314.4. In addition, the application of the comprehensive information security program was not effectively administered by the University during the 2024 year. An updated policy was put into place in February 2024, which addressed several of the deficiencies noted in the existing policy, but not all. Name and Title of Responsible Contact Person(s)- Sara Shepherd, Vice President for Finance Corrective Action Plan Summary-The university recently reviewed the Gramm-Leach-Bliley Act Policy and has put in place controls and practices to effectively monitor antl administer the policy. In April 2024, we hired an IT company to help with various campus needs, including data compliance procedures and security measures. The company has been reviewing our current policies and making recommendations to implement appropriate safeguards to keep the university up to date and compliant. We have already installed multi-factor authentication features for our software systems, and there are more updates to come. In July 2024, we received a notice of compliance from the Federal Student Aid regarding our corrective action procedures for the Gramm-Leach-Bliley Act. Anticipated Completion Date- July 1, 2025

2023-002

2024-003 Significant Deficiency: Return to Title IV Funds (U.S. Department of Education, William D. Ford Direct Loan Program, ALN #84.268; Federal Pell Grant Program, ALN #84.063; Federal Supplemental Opportunity Grant Program, ALN #84.007; and TEACH Grant Program, ALN #84.379) (Repeat Finding 2022-003 and 2023-004) Criteria: In accordance with 34 CFR 668.22(f), in the calculation of the percentage of payment period and/or period of enrollment completed, the total number of calendar days in a payment and/or enrollment period includes all days within the period, except that institutionally scheduled breaks of at least 5 consecutive calendar days and days in which the student was on an approved leave of absence are excluded from the total number of calendar days in a payment period and/or period of enrollment. Statement of Condition: During the audit, it was noted that the University used the incorrect number of total days in the payment period or period of enrollment in calculating the percentage of payment period and/or period of enrollment completed. Questioned Costs: The known monetary error is $20 under-awarded. Extrapolation of the error was not necessary because all withdrawals were tested during the audit. Therefore, the monetary impact of this deficiency does not exceed the reporting threshold of $25,000. Perspective Information: The audit included a detailed testing of 2 student files, of which this significant deficiency applies to 1, indicating an error rate of 50.00%. No other possible students to which this issue could have affected exist beyond those tested during the audit, as all withdrawn students were examined. Cause and Effect: For noted withdrawal calculations, the total day count was not performed per the instructions described in the handbook. This results in a miscalculation of percentage of Title IV aid earned and could result in monetary error. Recommendation: The University should ensure that the total number of calendar days in the payment period or period of enrollment is counted correctly utilizing the guidance provided by the Compliance Supplement and the Student Financial Aid Handbook. View of Responsible Officials: The University improved the process for completing return to Title IV calculations by adding in additional training and workshops offered through the Department of Education. The financial aid office continued with the calendar process showing days of attendance from the first day of school to the last using the school’s master calendar as a reference. This will be used also as a double check of days when calculating returns. The dates used in the return calculations were off a day due to misreading the ending date of semester. The Financial Aid Administrator verified the beginning and last day of each semester with the Registrar’s office in writing.

2024-003 Initial Fiscal Year End, 2024 Summary of Finding- During the audit, it was noted that the University used the incorrect number of total days in the payment period or period of enrollment in calculating the percentage of payment period and/or period of enrollment completed. Name and'Title of Responsible Contact Person(s)- Sara Shepherd, Vice President for Finance and Nicole Umphlett, Financial Aid Administrator Corrective Action Plan Summary-The University improved the process for completing return to Title IV calculations by adding in additional training and workshops offered through the Department of Education. The financial aid office continued with the calendar process showing days of attendance from the first day of school to the last using the school's master calendar as a reference. This will be used also as a double check of days when calculating returns. The dates used in the return calculations were off a day due to misreading the ending date of semester. The Financial Aid Administrator verified the beginning and last day of each semester with the Registrar's office in writing. Anticipated Completion Date- July 1, 2025

2022-003, 2023-004

2024-004 Significant Deficiency: Return to Title IV Funds (U.S. Department of Education, William D. Ford Direct Loan Program, ALN #84.268; Federal Pell Grant Program, ALN #84.063; Federal Supplemental Opportunity Grant Program, ALN #84.007; and TEACH Grant Program, ALN #84.379) (Repeat Finding 2023-005) Criteria: In accordance with 34 CFR 668.22(e), the calculated percentage of Title IV assistance earned should be applied to the total amount of title IV grant or loan assistance that was disbursed or could have been disbursed to the student, or on the student's behalf, for the payment period or period of enrollment as of the student's withdrawal date. Statement of Condition: During the audit, it was noted that the University used the incorrect sum of aid disbursed or disbursable to the student when applying the percentage earned in calculating the return to Title IV Funds upon student withdrawal. Questioned Costs: The known monetary error is $1,984 under-awarded. Extrapolation of the error was not necessary because all withdrawals were tested during the audit. Therefore, the monetary impact of this deficiency does not exceed the reporting threshold of $25,000. Perspective Information: The audit included a detailed testing of 2 student files, of which this significant deficiency applies to 1, indicating an error rate of 50.00%. No other possible students to which this issue could have affected exist beyond those tested during the audit, as all withdrawn students were examined. Cause and Effect: For noted withdrawal calculations, the incorrect sum of disbursed or disbursable aid was used in calculating Return to Title IV Funds, according to guidance in the handbook. This results in a miscalculation of Title IV aid earned and could result in monetary error. Recommendation: In calculating a student’s Return to Title IV Funds upon withdrawal, the University should ensure that the calculated percentage of Title IV earned is applied to the total assistance disbursed or available to be disbursed to a student prior to withdrawal, according to the guidance provided by the Compliance Supplement and the Student Financial Aid Handbook. View of Responsible Officials: The University has enhanced the process of completing return to Title IV calculations by incorporating additional training and workshops provided by the Department of Education. The financial aid office has continued with the implementation of the calendar that displays the attendance days from the first day of school to the last day of school, referring to the school’s master calendar. The financial aid office added an extra verification step of written notification from the Registrar’s office of beginning and end days for each semester. The return calculations were one day off due to the misinterpretation of the semester’s ending date.

2024-004 Initial Fiscal Year End, 2024 Summary of Finding- During the audit, it was noted that the University used the incorrect sum of aid disbursed or disbursable to the student when applying the percentage earned in calculating the return to Title IV Funds upon student withdrawal. Name and Title of Responsible Contact Person(s)- Sara Shepherd, Vice President for Finance and Nicole Umphlett, Financial Aid Administrator Corrective Action Plan Summary-The University has enhanced the process of completing return to Title IV calculations by incorporating additional training and workshops provided by the Department of Education. The financial aid office has continued with the implementation of the calendar that displays the attendance days from the first day of school to the last day of school, referring to the school's master calendar. The financial aid office added an extra verification step of written notification from the Registrar's office of beginning and end days for each semester. The return calculations were one day off due to the misinterpretation of the semester's ending date. Anticipated Completion Date- July 1, 2025

2023-005

2024-005 Significant Deficiency: Return to Title IV Funds (U.S. Department of Education, William D. Ford Direct Loan Program, ALN #84.268; Federal Pell Grant Program, ALN #84.063; Federal Supplemental Opportunity Grant Program, ALN #84.007; and TEACH Grant Program, ALN #84.379) Criteria: In accordance with 34 CFR 668.22(i), unearned funds returned by the institution or the student, as appropriate, must be credited to outstanding balances on Title IV loans made to the student or on behalf of the student for the payment period or period of enrollment for which a return of funds is required. Those funds must be credited to outstanding balances for the payment period or period of enrollment for which a return of funds is required in the following order: (i) Unsubsidized Federal Direct Stafford loans, (ii) Subsidized Federal Direct Stafford loans, (iii) Federal Direct PLUS received on behalf of the student. If unearned funds remain to be returned after repayment of all outstanding loan amounts, the remaining excess must be credited to any amount awarded for the payment period or period of enrollment for which a return of funds is required in the following order: (i) Federal Pell Grants, (ii) Iraq and Afghanistan Service Grants, (iii) FSEOG Program aid, (iv) TEACH Grants. Statement of Condition: During the audit, it was noted that the University returned funds in an incorrect sequence during the Return to Title IV Funds process upon student withdrawal. Questioned Costs: There is no known monetary error as the mistake causes a misclassification in type of award, but net award amount is not affected. Perspective Information: The audit included a detailed testing of 2 student files, of which this significant deficiency applies to 2, indicating an error rate of 100%. No other possible students to which this issue could have affected exist beyond those tested during the audit, as all withdrawn students were examined. Cause and Effect: For noted withdrawal calculations, the institution applied the percentage of earned aid to each type of disbursed aid individually, returning the remaining portion of each type of aid. However, the guidance stipulates that funds should be returned in a set order, returning the full amount of each type before moving to the next. In the return to Title IV process for the first student, the institution calculated an earned percentage of 50.0% based upon completed days. The student had been disbursed both subsidized and unsubsidized loans for the term. The director applied the 50.0% to each subsidized and unsubsidized awards to determine the monetary amounts of earned aid, returning the remaining $495 of subsidized and $866 unsubsidized loan disbursements to G5. The appropriate treatment would have been to return the full unearned portion of aid from the unsubsidized award. In the return to Title IV process for the second student, the institution calculated an earned percentage of 42.2% based upon completed days. The student had been disbursed both Pell and FSEOG for the term. The director applied the 42.2% to each Pell and FSEOG awards to determine the monetary amounts of earned aid, returning the remaining $2,156 of Pell and $146 of FSEOG disbursements to G5. The appropriate treatment would have been to return the full unearned portion of aid from the Pell award. Recommendation: The University should ensure that funds are returned in the prescribed sequence in the determination of the return of aid as designated by the Compliance Supplement and the Student Financial Aid Handbook. View of Responsible Officials: The University’s Vice President of Finance and Financial Aid Administrator recently attended a week-long workshop and received training to complete the R2T4 calculation via COD. The training was received after the infringements and a plan has been adapted to utilize COD for future R2T4 calculations and sequence. The school calendar has been updated in COD for correct future calculations and sequence.

2024-005 Initial Fiscal Year End, 2024 Summary of Finding- During the audit, it was noted that the University returned funds in an incorrect sequence during the Return to Title IV Funds process upon student withdrawal. Name and Title of Responsible Contact Person(s)- Sara Shepherd, Vice President for Finance and Nicole Umphlett, Financial Aid Administrator Corrective Action Plan Summary-The University's Vice President of Finance and Financial Aid Administrator recently attended a week-long workshop and received training to complete the R2T4 calculation via COD. The training was received after the infringements and a plan has been adapted to utilize COD for future R2T 4 calculations and sequence. The school calendar has been updated in COD for correct future calculations and sequence. Anticipated Completion Date- July 1, 2025

2023-002 Material Weakness: Gramm-Leach-Bliley Act (GLBA) (U.S. Department of Education, William D. Ford Direct Loan Program, ALN #84.268) Criteria: In accordance with 16 CFR 314.4, a University shall develop, implement, and maintain a comprehensive information security program that is written in one or more readily accessible parts and contains administrative, technical, and physical safeguards that are appropriate to your size and complexity, the nature and scope of your activities, and the sensitivity of any customer information at issue and must contain all of the elements that are further described in 16 CFR 314.4. Statement of Condition: During the 2023 audit, it was noted that the University’s Gramm-Leach- Bliley Act Policy did not fully address all of the requirements as described by 16 CFR 314.4. In addition, the application of the comprehensive information security program was not effectively administered by the University for the 2023 year. Questioned Costs: Such information is not applicable for this finding since it is nonmonetary in nature. Perspective Information: The 2023 audit included testing of the University’s Gramm-Leach-Bliley Act Policy as outlined in Part 5 of the Compliance Supplement including the application of this program for the year. Cause and Effect: Due to lapses of oversight in multiple departments, the University failed to update their GLBA policy to include the required components in accordance with the Compliance Supplement. Therefore, the policy is considered incomplete and does not provide the appropriate disclosures to consumers. Recommendation: The University should update their Gramm-Leach-Bliley Act Policy to be in accordance with the requirements and put in place effective controls and practices to ensure the policy is monitored in a way to ensure it is administered effectively. View of Responsible Officials: The University has reviewed the Gramm-Leach-Bliley Act Policy and has put in place controls and practices to ensure the policy is monitored and administered effectively moving forward.

2023-002 Initial Fiscal Year End, 2023 Summary of Finding- During the 2023 audit, it was noted that the University's Gramm-Leach-Bliley Act Policy did not fully address all of the requirements as described by 16 CFR 314.4. In addition, the application of the comprehensive information security program was not effectively administered by the University for the 2023 year. Name and Title of Responsible Contact Person(s)- Sara Shepherd, Vice President for Finance and Nicole Umphlett, Financial Aid Administrator Corrective Action Plan Summary-The University has updated its Gramm-Leach-Bliley Act Policy to be in accordance with the requirements, and we have also put in place adequate controls and practices to ensure that the policy is monitored effectively. Anticipated Completion Date- February 1, 2024

2023-003 Significant Deficiency: National Student Loan Data System (NSLDS) Report (U.S. Department of Education, William D. Ford Direct Loan Program, ALN #84.268 and Federal Pell Grant Program, ALN #84.063) (Repeat Finding 2022-002) Criteria: In accordance with 34 CFR 685.309(b) and 34 CFR section 690.83(b)(2), for Direct Loans and Pell grants, respectively, once the Enrollment Reporting roster file is received from the NSLDS, the institution must update the Enrollment Reporting roster file for changes in student status, report the date the enrollment status was effective, enter the new anticipated completion date, and submit the changes to NSLDS. Statement of Condition: During the audit, it was noted that the University incorrectly reported student enrollment status at changes in enrollment. Questioned Costs: Such information is not applicable for this finding since it is nonmonetary in nature. Perspective Information: The audit included a detailed testing of 40 student files, of which this significant deficiency applies to 5, indicating an error rate of 12.50%. Cause and Effect: Due to lapses in communication between departments, in certain instances, the University failed to provide NSLDS with accurate updates to student enrollment statuses, resulting in misrepresentation within the NSLDS system. Recommendation: The University should ensure that the correct enrollment status is reported to NSLDS. View of Responsible Officials: The University is continuing to improve communication between the Registrar’s office, Financial Aid office, National Student Clearinghouse, and NSLDS with the goal of clear and correct reporting to NSLDS. Staff between the different departments have participated in training on enrollment reporting and how National Student Clearinghouse works directly with NSLDS. A monthly check list has also been created to make sure items are getting completed.

2023-003 Initial Fiscal Year End, 2023 Summary of Finding- During the audit, the University did not correctly report the student's enrollment status to National Student Loan Data System (NSLDS). The Department of Education had a waived window of errors from July 2022 to February 2023. Name and Title of Responsible Contact Person(s)- Sara Shepherd, Vice President for Finance and Nicole Umphlett, Financial Aid Administrator Corrective Action Plan Summary-The University is continuing to improve communication between the Registrar's office, Financial Aid office, National Student Clearinghouse, and NSLDS with the goal of clear and correct reporting to NSLDS. Staff between the different departments have participated in training on enrollment reporting and how National Student Clearinghouse works directly with NSLDS. A monthly check list has also been created to make sure items are getting completed. Anticipated Completion Date- July 1, 2024

2022-002

2023-004 Significant Deficiency: Return to Title IV Funds (U.S. Department of Education, William D. Ford Direct Loan Program, ALN #84.268; Federal Pell Grant Program, ALN #84.063; Federal Supplemental Opportunity Grant Program, ALN #84.007; and TEACH Grant Program, ALN #84.379) (Repeat Finding 2022-003) Criteria: In accordance with 34 CFR 668.22(f), in the calculation of the percentage of payment period and/or period of enrollment completed, the total number of calendar days in a payment and/or enrollment period includes all days within the period, except that institutionally scheduled breaks of at least 5 consecutive calendar days and days in which the student was on an approved leave of absence are excluded from the total number of calendar days in a payment period and/or period of enrollment. Statement of Condition: During the audit, it was noted that the University used the incorrect number of total days in the payment period or period of enrollment in calculating the percentage of payment period and/or period of enrollment completed. Questioned Costs: The known monetary error is $9 under-awarded. Extrapolation of the error was not necessary because all withdrawals were tested during the audit. Therefore, the monetary impact of this deficiency does not exceed the reporting threshold of $25,000. Perspective Information: The audit included a detailed testing of 6 student files, of which this significant deficiency applies to 5, indicating an error rate of 83.30%. Cause and Effect: For noted withdrawal calculations, the total day count was not performed per the instructions described in the handbook. This results in a miscalculation of percentage of Title IV aid earned and could result in monetary error. Recommendation: The University should ensure that the total number of calendar days in the payment period or period of enrollment is counted correctly utilizing the guidance provided by the Compliance Supplement and the Student Financial Aid Handbook. View of Responsible Officials: The University improved the process for completing return to Title IV calculations by adding in additional training and workshops offered through the Department of Education. The financial aid office created a calendar showing days of attendance from the first day of school to the last using the school’s master calendar as a reference. This will be used also as a double check of days when calculating returns. The dates used in the return calculations were off a day due to misreading the ending date of semester.

2023-004 Initial Fiscal Year End, 2023 Summary of Finding- During the audit, the University used the incorrect value for the total days in the students return to Title IV calculation. In completing the student's withdrawal, the institution used the incorrect amount of aid awarded/ disbursed for the applicable period. The university incorrectly calculated the institutional charges within the return to Title IV calculation. Name and Title of Responsible Contact Person(s)- Sara Shepherd, Vice President for Finance and Nicole Umphlett, Financial Aid Administrator Corrective Action Plan Summary-The University improved the process for completing return to Title IV calculations by adding in additional training and workshops offered through the Department of Education. The financial aid office created a calendar showing days of attendance from the first day of school to the last using the school's master calendar as a reference. This will be used also as a double check of days when calculating returns. The dates used in the return calculations were off a day due to misreading the ending date of semester. Anticipated Completion Date- July 1, 2024

2022-003

2023-005 Significant Deficiency: Return to Title IV Funds (U.S. Department of Education, William D. Ford Direct Loan Program, ALN #84.268; Federal Pell Grant Program, ALN #84.063; Federal Supplemental Opportunity Grant Program, ALN #84.007; and TEACH Grant Program, ALN #84.379) Criteria: In accordance with 34 CFR 668.22(e), the calculated percentage of Title IV assistance earned should be applied to the total amount of title IV grant or loan assistance that was disbursed or could have been disbursed to the student, or on the student's behalf, for the payment period or period of enrollment as of the student's withdrawal date. Statement of Condition: During the audit, it was noted that the University used the incorrect sum of aid disbursed or disbursable to the student when applying the percentage earned in calculating the return to Title IV Funds upon student withdrawal. Questioned Costs: The known monetary error is $12 under-awarded. Extrapolation of the error was not necessary because all withdrawals were tested during the audit. Therefore, the monetary impact of this deficiency does not exceed the reporting threshold of $25,000. Perspective Information: The audit included a detailed testing of 6 student files, of which this significant deficiency applies to 2, indicating an error rate of 33.30%. Cause and Effect: For noted withdrawal calculations, the incorrect sum of disbursed or disbursable aid was used in calculating Return to Title IV Funds, according to guidance in the handbook. This results in a miscalculation of Title IV aid earned and could result in monetary error. Recommendation: In calculating a student’s Return to Title IV Funds upon withdrawal, the University should ensure that the calculated percentage of Title IV earned is applied to the total assistance disbursed or available to be disbursed to a student prior to withdrawal, according to the guidance provided by the Compliance Supplement and the Student Financial Aid Handbook. View of Responsible Officials: The University improved the process for completing return to Title IV calculations by adding in additional training and workshops offered through the Department of Education. The financial aid office created a calendar showing days of attendance from the first day of school to the last using the school’s master calendar as a reference. This will be used also as a double check of days when calculating returns. The dates used in the return calculations were off a day due to misreading the ending date of semester.

2023-005 Initial Fiscal Year End, 2023 Summary of Finding- During the audit, it was noted that the University used the incorrect sum of aid disbursed or disbursable to the student when applying the percentage earned in calculating the return to Title IV Funds upon student withdrawal. Name and Title of Responsible Contact Person(s)- Sara Shepherd, Vice President for Finance and Nicole Umphlett, Financial Aid Administrator Corrective Action Plan Summary- The University has enhanced the process of completing return to Title IV calculations by incorporating additional training and workshops provided by the Department of Education. The financial aid office has designed a calendar that displays the attendance days from the first day of school to the last day of school, referring to the school's master calendar. This will be used as a cross-check of days when computing returns. The return calculations were one day off due to the misinterpretation of the semester's ending date. Anticipated Completion Date- July 1, 2024

2023-006 Significant Deficiency: Return to Title IV Funds (U.S. Department of Education, William D. Ford Direct Loan Program, ALN #84.268; Federal Pell Grant Program, ALN #84.063; Federal Supplemental Opportunity Grant Program, ALN #84.007; and TEACH Grant Program, ALN #84.379) Criteria: In accordance with 34 CFR 668.22(g), for the purpose of calculating the return of unearned aid upon withdrawal, “institutional charges” are tuition, fees, room and board (if the student contracts with the institution for the room and board) and other educationally related expenses assessed by the institution. Statement of Condition: During the audit, it was noted that the University incorrectly calculated institutional charges used in determining the amount of unearned aid to withdrawal. Questioned Costs: The known monetary error is $307 over-awarded. Extrapolation of the error was not necessary because all withdrawals were tested during the audit. Therefore, the monetary impact of this deficiency does not exceed the reporting threshold of $25,000. Perspective Information: The audit included a detailed testing of 6 student files, of which this significant deficiency applies to 2, indicating an error rate of 33.30%. Cause and Effect: For noted withdrawal calculations, the institutional charges were not calculated per the stipulations described in the handbook. This could result in a miscalculation of Title IV aid earned and could result in monetary error. Recommendation: The University should ensure that the calculation of institutional charges used in the determination of the return of aid for a payment period in which a student has withdrawn is formulated correctly utilizing the guidance provided by the Compliance Supplement and the Student Financial Aid Handbook. View of Responsible Officials: The University improved the process for completing return to Title IV calculations by adding in additional training and workshops offered through the Department of Education. The financial aid office created a calendar showing days of attendance from the first day of school to the last using the school’s master calendar as a reference. This will be used also as a double check of days when calculating returns. The dates used in the return calculations were off a day due to misreading the ending date of semester.

2023-006 Initial Fiscal Year End, 2023 Summary of Finding- During the audit, it was noted that the University incorrectly calculated institutional charges used in determining the amount of unearned aid to withdrawal. Name and Title of Responsible Contact Person(s)- Sara Shepherd, Vice President for Finance and Nicole Umphlett, Financial Aid Administrator Corrective Action Plan Summary- The University has recently made improvements to the process of completing the return to Title IV calculations. This was achieved by providing additional training and workshops offered through the Department of Education. Furthermore, we have also developed a spreadsheet to assist with calculating the returned aid due to withdraw. We will utilize this information to thoroughly double-check our calculations before issuing official documentation. Anticipated Completion Date- July 1, 2024

2022-002 Significant Deficiency: National Student Loan Data System (NSLDS) Report (U.S. Department of Education, William D. Ford Direct Loan Program, ALN #84.268 and Federal Pell Grant Program, ALN #84.063) Criteria: In accordance with 34 CFR 685.309(b) and 34 CFR section 690.83(b)(2), for Direct Loans and Pell grants, respectively, once the Enrollment Reporting roster file is received from the NSLDS, the institution must update the Enrollment Reporting roster file for changes in student status, report the date the enrollment status was effective, enter the new anticipated completion date, and submit the changes to NSLDS. Statement of Condition: During the audit, it was noted that the University incorrectly reported student enrollment status at changes in enrollment. Questioned Costs: Such information is not applicable for this finding since it is nonmonetary in nature. Perspective Information: The audit included a detailed testing of 40 student files, of which this significant deficiency applies to 4, indicating an error rate of 10.00%. Cause and Effect: Due to lapses in communication between departments, in certain instances, the University failed to provide NSLDS with accurate updates to student enrollment statuses, resulting in misrepresentation within the NSLDS system. Recommendation: The University should ensure that the correct enrollment status is reported to NSLDS. View of Responsible Officials: The University acknowledges this finding and is continuing to improve communication between departments. The University utilizes National Student Clearinghouse as its main source of updating student enrollment to the National Student Loan Data System. We recognize that there some time lapses from when the information was submitted to the Clearinghouse and then processed by NSLDS. This caused the incorrect enrollment status to appear and overlap the correct information.

2022-002 Significant Deficiency: National Student Loan Data System (NSLDS) Report (U.S. Department of Education, William D. Ford Direct Loan Program, ALN #84.268 and Federal Pell Grant Program, ALN #84.063) Summary of Finding During the audit, it was noted that the University incorrectly reported student enrollment status at changes in enrollment. Due to lapses in communication between departments, in certain instances, the University failed to provide NSLDS with accurate updates to student enrollment statuses, resulting in misrepresentation within the NSLDS system. Name and Title of the Responsible Contact Person(s) Emily R. Meneely, Financial Aid Administrator Corrective Action Plan Summary The University is continuing to improve communication between the Registrar?s office, Financial Aid office, National Student Clearinghouse, and NSLDS with the goal of clear and correct reporting to NSLDS. We will ensure that each of our staff have been trained in enrollment reporting and how National Student Clearinghouse works directly with NSLDS. Anticipated Completion Date July 1, 2023

2022-003 Significant Deficiency: Return to Title IV Funds (U.S. Department of Education, William D. Ford Direct Loan Program, ALN #84.268; Federal Pell Grant Program, ALN #84.063; Federal Supplemental Opportunity Grant Program, ALN #84.007; and TEACH Grant Program, ALN #84.379) Criteria: In accordance with 34 CFR 668.22(f), in the calculation of the percentage of payment period and/or period of enrollment completed, the total number of calendar days in a payment and/or enrollment period includes all days within the period, except that institutionally scheduled breaks of at least 5 consecutive calendar days and days in which the student was on an approved leave of absence are excluded from the total number of calendar days in a payment period and/or period of enrollment. Statement of Condition: During the audit, it was noted that the University used the incorrect number of total days in the payment period or period of enrollment in calculating the percentage of payment period and/or period of enrollment completed. Questioned Costs: The known monetary error is $74 over-awarded. Extrapolation of the error was not necessary because all withdrawals were tested during the audit. Therefore, the monetary impact of this deficiency does not exceed the reporting threshold of $25,000. Perspective Information: The audit included a detailed testing of 40 student files, of which this significant deficiency applies to 4, indicating an error rate of 10.00%. Cause and Effect: For all withdrawal calculations, the total day count was not performed per the instructions describe in the handbook. This results in a miscalculation of percentage of Title IV aid earned and could result in monetary error. Recommendation: The University should ensure that the total number of calendar days in the payment period or period of enrollment is counted correctly utilizing the guidance provided by the Compliance Supplement and the Student Financial Aid Handbook. View of Responsible Officials: The University acknowledges this finding and has created additional checks to make sure this does not happen in the future. The University identified the quantity of days completed based on the start and end date of the semester. One of the campus wide breaks was counted in the quantity of days when it did not meet the minimum amount to be counted as a break for Return to Title IV purposes. This caused a miscalculation in the percentage of Title IV earned aid.

2022-003 Significant Deficiency: Return to Title IV Funds (U.S. Department of Education, William D. Ford Direct Loan Program, ALN #84.268; Federal Pell Grant Program, ALN #84.063; Federal Supplemental Opportunity Grant Program, ALN #84.007; and TEACH Grant Program, ALN #84.379) Summary of Finding During the audit, it was noted that the University used the incorrect number of total days in the payment period or period of enrollment in calculating the percentage of payment period and/or period of enrollment completed. Name and Title of the Responsible Contact Person(s) Emily R. Meneely, Financial Aid Administrator Corrective Action Plan Summary The University has, and will continue, to improve its process for completing Return to Title IV calculations. We have set up additional checks within our newer student software system as well as making sure everyone who works with Return to Title IV is trained according to the Student Financial Aid Handbook. Anticipated Completion Date July 1, 2023

2021-002 Significant Deficiency: Federal Pell Grant Funds were Improperly Awarded (U.S Department of Education, Federal Pell Grant Program, ALN #84.063) Criteria: In accordance with 34 CFR 690.62, the amount of a student's Pell Grant for an academic year is based upon the payment and disbursement schedules published by the Secretary for each award year. Statement of Condition: During the audit, it was noted that the University awarded students the incorrect amount of Pell Grant funds with respect to their enrollment statuses. Questioned Costs: The known monetary error was $2,673, which resulted in an extrapolated error of $11,794. Perspective Information: The audit included a detailed testing of 40 student files, of which this deficiency applies to 5, indicating an error rate of 12.50%. Cause and Effect: This issue was caused by an oversight in the eligibility amounts of Pell that were awarded to the students. Recommendation: The University should ensure that students are awarded the appropriate amount of Pell in accordance with the Payment Schedules for Determining provided by the Department of Education. View of Responsible Officials: The University has improved our plans for accuracy in awarding the Pell Grant to eligible students. Within our new student system, the Pell Grant schedules are automatically uploaded, and updated, once they have been released from the Department of Education. Utilizing the updates in our new system and comparing it to the published schedules will provide a double check opportunity when awarding the Pell Grant.

Summary of Finding During the audit, it was noted that the University awarded students the incorrect amount of Pell Grant funds with respect to their enrollment statuses. The audit included a detailed testing of 40 student files, of which this deficiency applies to 5 students indicating an error rate of 12.5% Name and Title of the Responsible Contact Person(s) Emily R. Meneely, Financial Aid Administrator Corrective Action Plan Summary The University has improved our plans for accuracy in awarding the Pell Grant funds to eligible students. Within our new student system, the Pell Grant schedules are automatically nploaded, and updated as needed, once they have been released from the Department of Education. In utilizing the updates in our new system and comparing it to the published schedules, this will provide a double check opportunity when awarding Pell Grant funds. Anticipated Completion Date Ongoing

2019-001 Significant Deficiency: Federal Direct Loan Exit Counseling (CFDA 84.268) Criteria: In accordance with 34 CFR 685.304(b), an institution must ensure that exit counseling is conducted with each borrower either in person, by audiovisual presentation, of by interactive electronic means. The institution must ensure exit counseling is conducted shortly before the borrower ceases at least half-time enrollment at the institution. If a student withdraws from the institution without the institution's prior knowledge or fails to complete exit counseling, the institution must ensure that exit counseling is provided through either interactive electronic means or by mailing counseling materials to the borrower's last known address within 30 days after learning that the borrower has withdrawn from the institution or failed to complete exit counseling as required. Statement of Condition: During the audit, it was noted that the University was unable to provide documentation that exit counseling was provided to the Federal Direct Loan student borrowers who ceased at least half-time enrollment at the University. Questioned Costs: Such information is not applicable for this finding, due to the fact that it is nonmonetary in nature. Perspective Information: The audit included detailed testing of 40 student files, of which this significant deficiency applies to 6, indicating an error rate of 15%. Cause and Effect: It appears that this issue is due to the University?s internal controls surrounding the exit counseling process, which has resulted in this compliance issue related to lack of exit counseling documentation. Recommendation: We recommend that the University retain all documentation of exit counseling being provided to the student. Views of Responsible Officials: The University has improved its internal controls to provide exit counseling to non-returning students within 30 days of learning the students will not be returning to school. The Financial Aid office will coordinate with the registrar?s office to confirm non-returning students? status earlier to deliver exit counseling information prior to the 30-requirement. Changes were also made to the official withdrawal form to formalize the exit counseling process.

Initial Fiscal Year, 2019 2019-001 Significant Deficiency: Federal Direct Loan Exit Counseling(CFDA 84.268} Summary of Finding During the audit, it was noted that six students to which exit counseling was not provided within the thirty-day requirement, indicating an error rate of 15%. Name and Title of the Responsible Contact Person(s) Emily R. Meneely Financial Aid Administrator Corrective Action Plan Summary The University has improved its internal controls to provide exit counseling to non-returning students within 30 days of learning the students will not be returning to school. The Financial Aid office will coordinate with the registrar's office to confirm non-returning students' status earlier to deliver exit counseling information prior to the 30-requirement. Changes were also made to the official withdrawal form to formalize the exit counseling process. Anticipated Completion Date Ongoing

2019-002 Significant Deficiency: Federal Direct Loan Disbursement Notifications (CFDA 84.268) Criteria: In accordance with 34 CFR 668.165(a), if an institution credits a student ledger account with Direct Loan program funds, the institution must notify the student or parent of (1) the anticipated date and amount of the disbursement; (2) the student?s or parent?s right to cancel all or a portion of that loan or loan disbursement and have the loan proceeds returned to the Secretary; and (3) the procedures and time by which the student or parent must notify the institution that he or she wishes to cancel the loan or loan disbursement. The institution must provide the notice no earlier than 30 days before and no later than 30 days after crediting the student?s ledger account at the institution. Statement of Condition: During the audit, it was noted that the University was unable to provide documentation of Direct Loan disbursement notifications being provided to the student or parent. Questioned Costs: Such information is not applicable for this finding, due to the fact that it is nonmonetary in nature. Perspective Information: The audit included detailed testing of 40 student files, of which this significant deficiency applies to 4, indicating an error rate of 10%. Cause and Effect: It appears that this issue is due to the University?s internal controls surrounding the Direct Loan disbursement notification process, which has resulted in this compliance issue related to disbursement notifications not being provided to students or parents. Recommendation: We recommend that the University ensure the proper procedures and internal controls are in place to ensure Direct Loan disbursement notifications are provided to students or parents. Views of Responsible Officials: The University has improved its internal controls to ensure Direct Loan disbursement notifications to parents and students. The Financial Aid office has adjusted procedures to ensure all notifications will be produced.

Initial Fiscal Year, 2019 2019-002 Significant Deficiency: Federal Direct Loan Disbursement Notifications (CFDA 84.268} Summary of Finding During the audit, it was noted that the University was unable to provide documentation of Direct Loan disbursement notifications being provided to the student or parent. The audit included detailed testing of 40 student files, of which this significant deficiency applies to 4, indicating an error rate of 10%. Name and Title of the Responsible Contact Person(s) Emily R. Meneely Financial Aid Administrator Corrective Action Plan Summary The University has improved its internal controls to ensure Direct Loan disbursement notifications to parents and students. The Financial Aid office has adjusted procedures to ensure all notifications will be produced in a timely manner. Anticipated Completion Date Ongoing

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