MANNA UNIVERSITYHigher Education

Monthly Reconciliations of Pell Grant and Federal Direct Loans Significant Deficiency DEPARTMENT OF EDUCATION ALN #: 84.268, 84.063 Federal Award Identification #: 2021-22 Financial Aid Year Condition: Under Federal Financial Responsibility regulations and Federal Direct Loan regulations, the College is required to reconcile the Pell grants and Direct Loans disbursed between Common Origination and Disbursement (COD), the student information system, and student accounts on a monthly basis. This reconciliation should be on a student-by-student basis to identify any discrepancies between systems. Additionally, any discrepancies that arise during the reconciliation process should be resolved at that time. Criteria: 34 CFR 685.300(b)(5) and 34 CFR 668 Subpart L Questioned Costs:$0 Context: During the fiscal year-end, the University did not complete any monthly reconciliations on a student-by-student basis. Cause: This was an oversight by the University. Effect: There could be discrepancies between systems that could impact student eligibility and institutional eligibility for Federal Student Aid. Identification as repeat finding, if applicable: Not applicable. Recommendation: We recommend that the University implement monthly reconciliations and resolve any discrepancies as outlined in the regulations. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.

Incorrect Return of Title IV Funds Calculations DEPARTMENT OF EDUCATION ALN #: 84.268, 84.063 Federal Award Identification #: 2021-22 Financial Aid Year Condition: Return to Title IV calculations were not always accurate based on the actual amounts disbursed to students. Criteria: 34 CFR 668.22 Questioned Costs: $689 Context: Out of 3 R2T4 calculations tested, 1 student?s return calculation did not use the actual amount of Pell grant disbursed to the student. Cause: This was an oversight by the University. Effect: The error resulted in an additional $689 of Pell grant to be returned to Title IV. This was corrected during the audit. Identification as repeat finding, if applicable: 2021-007 Recommendation: We recommend that the University work with their third-party administrator to regularly review R2T4 calculations for accuracy. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.

Incorrect Pell Calculations DEPARTMENT OF EDUCATION ALN #: 84.063 Federal Award Identification #: 2021-22 Financial Aid Year Condition: One student out of 30 were not properly awarded Pell based on enrollment status. Criteria: 34 CFR 690.63(b) Questioned Costs: $0 Context: There was one student who was not disbursed their maximum Pell eligibility based on their enrollment status. Cause: Oversight by management when packaging the student. Effect: Pell was not awarded correctly based on enrollment status. Identification as repeat finding, if applicable: 2021-009 Recommendation: We recommend that the University periodically review enrollment status and Pell grant disbursements to ensure students are being disbursed the proper Pell Grant amount as determined by the annual Pell grant tables. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.

FINDING 2021-001 ? Financial Close and Reporting Condition Found: During our audit, we noted that the Organization recognized a deposit related to a vendor contract during fiscal year 2021 as an expense in fiscal year 2021, but the underlying services were received in fiscal year 2022. Prepaid expense reconciliations are not included as part of the financial close and reporting process. As part of our testing of journal entries, we noted no evidence of documented review nor approval. Further, one of the journal entries tested had no support due to it not being a legitimately recordable financial transaction. Criteria: The design and implementation of policies and procedures should be in place sufficient for the reconciliation of significant financial accounts and transaction classes to prevent and detect material misstatements in the financial statements. Cause: The deposit was invoiced at the end of the fiscal year ended June 30, 2021, and the Organization rarely has to consider expense cutoff in terms of prepaid expense, given its historical immateriality. Thus, it tends to be an unusual and infrequent situation. Independent review of nonstandard journal entries is not included as part of the financial close and reporting process. Possible Asserted Effect: In fiscal year 2021, we proposed an adjustment to reduce expense and increase prepaid expense by $8,340. The journal entry that was not a recordable financial transaction amounted to $1,000, affecting both revenue and expense. If individual journal entries are not reviewed and approved, misstatements are highly likely to occur in the financial statements without anyone?s knowledge, making it difficult to prevent and detect them, whether due to fraud or error. Repeat Finding: A Single Audit was not required for the year ended June 30, 2020. Recommendation: We recommend that the Organization put in place necessary controls and procedures to ensure that all transactions are properly classified, including prepaid expenses and whether each journal entry represents a valid, accurate transaction. As part of this evaluation, the Organization should consider the preparation and separate, independent document review and approval of these transactions, also. While there appears to be review of budget vs actual and other financial statement review by the management and the Board at an overall level, journal entries should also be reviewed at a granular, individual level. Some journal entries are naturally a part of the monthly reconciliation processes that already have existing document review and approval, which would be standard journal entries. Either all journal entries should be numbered, or all nonstandard journal entries should be numbered separately from the standard entries. The independent reviewer should track the last entry number reviewed when obtaining the next set of entries to review, and the reviewer should have available all supporting documentation in order to make an appropriate conclusion as to the entries? legitimacy. Further, matters relating to changes in the budget are not financial transactions and should not be recorded. Management Response: We will establish new policies and procedures concerning journal entries with a separate document and an independent review of all nonstandard journal entries on this document. Each nonstandard journal entry will be numbered and documented with supporting documentation to be reviewed by the CFO. Each of these entries must be approved by the CFO through this process. When examining these journal entries, the reviewer will check the previous journal entries to ensure that all journal entries are accounted for and the entries have a proper sequence. This process will be implemented over the next few months with the goal of having the system fully functional by May 1, 2022.

Condition Found: Paycheck Protection Program (?PPP?) loan funds, which were treated as refundable advances at June 30, 2020, were not properly and timely recorded as contribution revenue in accordance with ASC 958-605 during fiscal year 2021. Deferred revenue amounts related to summer semester Term A was not considered for revenue recognition purposes, considering that the term spanned May to July, with the fiscal year-end of June 30th being in the middle of that timeframe. Unspent HEERF I funds from June 30, 2020, were not properly recognized as federal grant revenue in fiscal year 2021. HEERF I and HEERF II funds included student aid money, which should have been treated as pass-through revenue, instead of federal grant revenue. While all available FIPSE funds were drawn down, a significant portion of these funds were not matched to eligible expenditures prior to drawing them down. Criteria: Revenue should be recognized consistent with Financial Accounting Standards Board (?FASB?) Accounting Standards Codification (?ASC?) Topics 606 and 958-605. Cause: The PPP transaction was an unusual transaction, and the Organization was not aware of the AICPA Technical Q&A 3200.18 pertaining to options on how to record the PPP funds. Additionally, despite having spent the funds on eligible expenditures and receiving forgiveness from the SBA, the refundable advance account was not reconciled or relieved and revenue subsequently recognized. The Organization does not have a process for evaluating revenue recognition in accordance with ASC Topic 606, nor does it have a process for reconciling deferred revenue pro-rata based on timing of its semesters. The HEERF and FIPSE federal grant funds were new grants for both the federal government and the Organization. The Organization has not had federal grant funds in the past and thus mechanisms to track expenditures in accordance with grant agreements were not in place. Additionally, the Organization typically does not receive pass-through funds such as the student assistance received through HEERF, let alone the fact that those funds were imbedded and included with other institutional relief funding. Possible Asserted Effect: With respect to the PPP loan funds, we proposed an entry to recognize $85,300 in contribution revenue during fiscal year 2021. We proposed an entry to de-recognize $4,600 in tuition revenue, affecting deferred revenue by $14,000 and beginning of year net assets without donor restrictions by $9,400. The net effects of the HEERF and FIPSE proposed adjustments were to increase refundable advances by $360,412 representing the unspent portion of FIPSE at June 30, 2021, to decrease government grant revenue by $376,285, to decrease July 1, 2020 beginning net assets with donor restrictions by $19,926, and to reduce grant-related expenses by $35,799. Repeat Finding: A Single Audit was not required for the year ended June 30, 2020. Recommendation: We recommend that the Organization familiarize itself with the nuances of AICPA Technical Q&A 3200.18 pertaining to PPP loan funds, Accounting Standards Update (?ASU 2018-08?) pertaining to updated guidance for contributions including government grants, and ASC Topic 606 pertaining to exchange transactions including specific application nuances for tuition and scholarships. The Organization should then establish processes and controls to account for contributions, government grants, and tuition revenue consistent with that guidance. Finally, we recommend that the Organization ensure that all statement of financial position accounts be reconciled completely as of June 30, 2022 prior to them being submitted for audit. Management Response: We will review and notate areas for needed updates in our processes and budget after reviewing AICPA Technical Q & A 3200.18 of the Accounting Standards Update (ASU 2018-8) and ASC Topic 606 concerning the updated guidance concerning exchange transactions with attention to specific application nuances for tuition and scholarships. Based upon the findings, as the result of this documented review we will update and establish processes and controls for contributions, government grants and tuition revenue. Then we will ensure through our finance department that all budgets reflect these updates. ? Stage 1 of the review of the official guidance will be completed by January 31, 2022. ? Stage 2 of the written document of the review with updated processes and controls will be completed by March 1, 2022. ? Stage 3 of implementing the new processes and controls will be completed by April 10, 2022. ? Stage 4 of Updating all budgets and reports to reflect these new procedures will be completed by May 5, 2022.

FINDING 2021-003 ? Annual Security and Fire Safety Report Federal Agency: U.S. Department of Education; Office of Federal Student Aid Pass through Entity: Not applicable Program Name: Federal Direct Student Loan Program Federal Pell Grant Program CFDA# and Program Expenditures: 84.268 ($466,916) 84.063 ($338,841) Award Number: P268K217643 P063P207643 Federal Award Year: July 1, 2020 to June 30, 2021 Questioned Costs: None Condition Found: The Annual Security and Fire Safety Report did not contain all of the required documentation and information. The Annual Security Report must include: 1. The crime statistics submitted to the Department of Education. 2. A statement of current campus policies regarding procedures for students and others to report criminal actions or other emergencies on campus. The statement must include the institution's policies concerning its response to these reports including ? o Policies for making timely warning reports to members of the campus community regarding the occurrence of crimes. o Policies for preparing the annual disclosure of crime statistics; and o A list of the titles of each person or organization to whom students and employees should report the criminal offenses described below for the purpose of making timely warning reports and the annual statistical disclosure. o This statement must also disclose whether the institution has any policies or procedures that allow victims or witnesses to report crimes on a voluntary, confidential basis for inclusion in the annual disclosure of crime statistics, and, if so, a description of those policies and procedures. 3. A statement of current policies concerning security of and access to campus facilities, including campus residences, and security considerations used in the maintenance of campus facilities. 4. A statement of current policies concerning campus law enforcement that - o Addresses the enforcement authority of security personnel, including their relationship with state and local police agencies and whether those security personnel have the authority to arrest individuals; o Encourages accurate and prompt reporting of all crimes to the campus police and the appropriate police agencies; and o Describes procedures, if any, that encourages pastoral counselors and professional counselors, if and when they deem it appropriate, to inform the persons they are counseling of any procedures to report crimes on a voluntary, confidential basis for inclusion in the annual disclosure of crime statistics. 5. A description of the type and frequency of programs designed to inform students and employees about campus security procedures and practices and to encourage students and employees to be responsible for their own security and the security of others. 6. A description of programs designed to inform students and employees about the prevention of crimes. 7. A statement of policy concerning the monitoring and recording through local police agencies of criminal activity in which students engaged at off-campus locations of student organizations officially recognized by the institution, including student organizations with off-campus housing facilities. 8. A statement of policy regarding the possession, use, and sale of alcoholic beverages and enforcement of State underage drinking laws. 9. A statement of policy regarding the possession, use, and sale of illegal drugs and enforcement of federal and state drug laws. 10. A description of any drug or alcohol-abuse education programs. 11. A statement of policy regarding the institution?s campus sexual assault programs to prevent sex offenses, and the procedures to follow when a sex offense occurs. The statement must include: o A description of educational programs to promote the awareness of rape, acquaintance rape, and other forcible and non-forcible sex offenses; o Procedures students should follow if a sex offense occurs, including procedures concerning who should be contacted, the importance of preserving evidence for the proof of a criminal offense, and to whom the alleged offense should be reported; o Information on a student?s option to notify appropriate law enforcement authorities, including on?campus and local police, and a statement that institutional personnel will assist the student in notifying these authorities, if the student requests the assistance of these personnel; o Notification to students of existing on- and off-campus counseling, mental health, or other student services for victims of sex offenses; o Notification to students that the institution will change a victim's academic and living situations after an alleged sex offense and of the options for those changes, if those changes are requested by the victim and are reasonably available; o Procedures for campus disciplinary action in cases of an alleged sexual offense, including a clear statement that- ? The accuser and the accused are entitled to the same opportunities to have others present during a disciplinary proceeding; and ? Both the accuser and the accused must be informed of the outcome of any institutional disciplinary proceeding brought alleging a sex offense. Compliance with this paragraph does not constitute a violation of the Family Educational Rights and Privacy Act. For the purpose of this paragraph, the outcome of a disciplinary proceeding means only the institution's final determination with respect to the alleged sex offense and any sanction that is imposed against the accused; and ? Sanctions the institution may impose following a final determination of an institutional disciplinary proceeding regarding rape, acquaintance rape, or other forcible or non-forcible sex offenses. 12. A statement advising the campus community where law enforcement agency information provided by a state under 42 USC 1407(j)) concerning registered sex offenders may be obtained, such as a local law enforcement office of the institution, a local law enforcement agency with jurisdiction for the campus, or a computer network address. 13. A description of the school's emergency response and evacuation procedures. 14. A statement of the school's policy regarding missing student notification procedures. The Annual Fire Safety Report must include: 1. The fire statistics submitted to the Department of Education. 2. A description of each on-campus student housing facility fire safety system. 3. The number of fire drills held during the previous calendar year. 4. The institution's policies or rules on portable electrical appliances, smoking, and open flames in a student housing facility. 5. The institution's procedures for student housing evacuation in the case of a fire. 6. The policies regarding fire safety education and training programs provided to the students and employees. In these policies, the institution must describe the procedures that students and employees should follow in the case of a fire. 7. For purposes of including a fire in the statistics in the annual fire safety report, a list of the titles of each person or organization to which students and employees should report that a fire occurred. 8. Plans for future improvements in fire safety, if determined necessary by the institution. If the institution publishes two reports instead of a combined report, both reports must reference the other report. Cause: The Organization complied and released the crime statics to the students and staff; however, the Organization?s administration was unaware of the remaining requirements surrounding the Annual Security and Fire Safety Report. Possible Asserted Effect: The students and staff were not aware of certain policies and procedures. Repeat Finding: A Single Audit was not required for the year ended June 30, 2020. Recommendation: The Organization should review and revise its institutional policies. The Organization should improve procedures to ensure the Annual Security and Fire Safety Report contains all required documentation. Management Response: The Executive Council of Manna University reviewed the requirements of the Annual Security and Fire Safety Report. Some members of the Executive Council and the Director of Security wrote and implemented the necessary policies and procedures. The required data was gathered for the 2020 and 2021 Annual Security and Fire Safety Reports. In December 2021, Manna issued the 2020 and 2021 Annual Security and Fire Safety Reports. The students and staff of the Organization were notified of the availability of both reports and a copy of the reports was placed on the Organization?s website.

FINDING 2021-004 ? COD Disbursement Dates Federal Agency: U.S. Department of Education; Office of Federal Student Aid Pass through Entity: Not applicable Program Name: Federal Direct Student Loan Program Federal Pell Grant Program CFDA# and Program Expenditures: 84.268 ($466,916) 84.063 ($338,841) Award Number: P268K217643 P063P207643 Federal Award Year: July 1, 2020 to June 30, 2021 Questioned Costs: $-0- Condition Found: The Common Origination and Disbursement System (?COD?) disbursement date did not agree with the disbursement date on accounts for thirteen of the thirteen students receiving Federal Direct Loans and twenty of the twenty-one students receiving Federal Pell Grant funds in our sample. Criteria: The disbursement date to be reported to the COD is the date that the institution credits funds to a student?s account or pays funds to a student or parent directly. Cause: The Organization began working with a new third-party servicer. The Vice President for Administration was not aware that the third-party servicer was reporting disbursements to COD that differed from the date the Organization posted the funds to the students? accounts. Possible Asserted Effect: The disbursement date in COD is the date interest begins accruing on the Federal Direct Loans. In order for the interest calculation to be accurate, the disbursement date in COD should be the date the students received the loan funds. Repeat Finding: A Single Audit was not required for the year ended June 30, 2020. Statistical Sampling: The sample was not intended to be, and was not, a statistically valid sample. Recommendation: The Vice President for Administration should correct the disbursement dates on the student accounts so that the dates agree with the COD disbursement dates. In addition, the Vice President for Administration should verify the COD and student account disbursement dates agree for all 2020-2021 FDL and Pell recipients. Management Response: The Vice President for Administration corrected the disbursements for the students in question in November 2021. In addition, she has reviewed and corrected, as necessary, the disbursement dates for all 2020-2021 FDL and Pell recipients. Going forward, the Vice President for Administration will verify the disbursement dates agree when the payments are made.

FINDING 2021-005? NSLDS Reporting Federal Agency: U.S. Department of Education; Office of Federal Student Aid Pass through Entity: Not applicable Program Name: Federal Direct Student Loan Program CFDA# and Program Expenditures: 84.268 ($466,916) Award Number: P268K217643 Federal Award Year: July 1, 2020 to June 30, 2021 Questioned Costs: $-0- Condition Found: The incorrect enrollment status was reported to the National Student Loan Database System (?NSLDS?) for seven of the twenty-five students selected for testing. Criteria: NSLDS informs loan servicers of changes in a student?s enrollment status that indicate when the repayments or interest accrual begins and ends. The date a student enrolls, withdraws, graduates, or drops below half-time status should be reported accurately. Cause: The Organization began working with a new third-party servicer. There was confusion related to the responsibility for reporting the changes to NSLDS and the timeframe for reporting the changes. Possible Asserted Effect: The loan servicers were not aware of the correct deferral, repayment, and interest calculation dates. Repeat Finding: A Single Audit was not required for the year ended June 30, 2020. Statistical Sampling: The sample was not intended to be, and was not, a statistically valid sample. Recommendation: The Vice President for Administration should work with the third-party servicer to update the enrollment status of the seven affected students in NSLDS. We also recommend scheduling a meeting with the third-party servicer to determine the specific functions that the third-party servicer is actually performing and what functions Manna is performing. Management Response: The Vice President for Administration corrected the enrollment status and withdrawal date for the students in question in November 2021. Procedures are being improved to ensure the information is communicated timely to the third-party servicer and that third-party servicer reports the changes to NSLDS timely.

FINDING 2021-006? Exit Interview Federal Agency: U.S. Department of Education; Office of Federal Student Aid Pass through Entity: Not applicable Program Name: Federal Direct Student Loan Program CFDA# and Program Expenditures: 84.268 ($466,916) Award Number: P268K217643 Federal Award Year: July 1, 2020 to June 30, 2021 Questioned Costs: $-0- Condition Found: Eleven of the twenty-five federal student financial aid recipients in our sample did not complete or were not sent an exit interview instructions to complete. Criteria: An exit interview should be completed or mailed to a student to complete within thirty days from when a student withdraws, graduates from school, or is enrolled less than half-time for Federal Direct Loans. Cause: The Organization thought exit interviews were being completed by the third-party servicer. Possible Asserted Effect: The students were unaware of the loan repayment responsibilities at the time the student withdrew from the Organization. Repeat Finding: A Single Audit was not required for the year ended June 30, 2021. Statistical Sampling: The sample was not intended to be, and was not, a statistically valid sample. Recommendation: Exit interview instructions were sent to the students in question in October 2021. Procedures should be improved to ensure that an exit interview is completed when a student withdraws from the Organization. We also recommend reviewing the student listing to determine if any other student should have been completed an exit interview for the 2020-2021 award year. Management Response: An exit interview was sent to the students in question in October 2021. Procedures should be improved to ensure that an exit interview is completed when a student withdraws from the Organization.

FINDING 2021-007 ? R2T4 Calculation Federal Agency: U.S. Department of Education; Office of Federal Student Aid Pass through Entity: Not applicable Program Name: Federal Direct Student Loan Program Federal Pell Grant Program CFDA# and Program Expenditures: 84.268 ($466,916) 84.063 ($338,841) Award Number: P268K217643 P063P207643 Federal Award Year: July 1, 2020 to June 30, 2021 Questioned Costs: $-0- Condition Found: The return of Title IV funds was not returned timely for three of the twenty-five students in the compliance testing sample. In addition, the R2T4 was not calculated correctly for two of the four students. The incorrect number of days in the semester was used for one student and Federal Pell Grant funds were not adjusted for a module the student did not begin attendance in before calculating the R2T4 for the second student. Criteria: Per Student Financial Aid Handbook Volume 5, Chapter 2, ?a school must return unearned funds for which it is responsible as soon as possible but no later than 45 days after the date of determination of a student?s withdrawal.? For a student enrolled in modules, Federal Pell Grant fund eligibility must be recalculated to exclude courses in which a student does not begin attendance. The number of days in the semester is calculated by counting the number of days in the semester less any breaks of four or more days. Cause: The third-party servicer did not process the R2T4 calculation or return the funds timely. The Organization did not inform the third-party servicer that the student failed to begin attendance in one module. This reduced the student?s Pell eligibility from full-time to ? time. The weekend days surrounding a week long break were not included in the number of break days total. Possible Asserted Effect: The R2T4 calculation was not completed accurately and Title IV funds were not returned timely. Repeat Finding: A Single Audit was not required for the year ended June 30, 2021. Recommendation: Procedures and communication should be improved with the third-party servicer to ensure that the third-party servicer is given all of the information needed to complete the calculation and that the R2T4 calculation is completed and the funds are returned to the Department of Education timely. The two R2T4s that were not calculated correctly should be recalculated and any funds due should be returned to the Department of Education. Management Response: The Vice President for Administration contacted the third-party servicer to see that the two R2T4 calculations in question were recalculated. Funds that were due to the Department of Education were returned in December 2021. Procedures will be improved to ensure that R2T4s are completed and funds are returned timely.

FINDING 2021-008 ? Overaward Federal Agency: U.S. Department of Education; Office of Federal Student Aid Pass through Entity: Not applicable Program Name: Federal Direct Student Loan Program Federal Pell Grant Program CFDA# and Program Expenditures: 84.268 ($466,916) 84.063 ($338,841) Award Number: P268K217643 P063P207643 Federal Award Year: July 1, 2020 to June 30, 2021 Questioned Costs: $3,562 Condition Found: There was a $3,562 overaward given to one of the twenty-five students selected for testing. The student?s cost of attendance was $10,086 and the student received $13,648 in federal student financial aid funds. Criteria: The total amount of aid a student receives cannot be greater than his or her cost of attendance. Cause: The student asked for the maximum amount of loans. The third-party servicer awarded the maximum amount of loans based on the student?s grade level instead of limiting the amount of loans to the student?s cost of attendance. Possible Asserted Effect: The student received $3,562 of unsubsidized loans that he or she was not eligible to receive. Repeat Finding: A Single Audit was not required for the year ended June 30, 2020. Statistical Sampling: The sample was not intended to be, and was not, a statistically valid sample. Recommendation: Since the overaward occurred because of an unsubsidized Federal Direct loan and was discovered after the funds had been disbursed, the Organization is not required to return the funds unless notified, otherwise, by the Department of Education. Going forward, the Organization should limit subsidized and unsubsidized, plus, and private loan borrowing to a student?s cost of attendance. Management Response: The Organization worked with the third-party servicer to correct the error. The Organization returned the $3,562 overaward of unsubsidized loan funds to the Department of Education.

FINDING 2021-009 ?Pell Award Calculation Federal Agency: U.S. Department of Education; Office of Federal Student Aid Pass through Entity: Not applicable Program Name: Federal Pell Grant Program CFDA# and Program Expenditures: 84.063 ($338,841) Award Number: P063P207643 Federal Award Year: July 1, 2020 to June 30, 2021 Questioned Costs: $-0- Condition Found: The amount of Pell grant awarded was calculated incorrectly for one out of the twenty-one students who received Pell in our sample. The student was awarded Pell grant funds as if the student was enrolled ? time when the student was enrolled full-time. Cause: The financial aid office was not informed that the student enrolled in an additional ?B term? course. This increased the enrollment status from ? time to full-time. Possible Asserted Effect: The student is eligible to receive an additional $792 of Pell grant funds. Repeat Finding: A Single Audit was not required for the year ended June 30, 2020. Statistical Sampling: The sample was not intended to be, and was not, a statistically valid sample. Recommendation: The Organization should award an additional $792 to the student in question. Communication between the offices should be improved so that financial aid is made aware of enrollment status changes timely. Management Response: The Organization awarded $792 to the student in question on December 2, 2021. Communication between the offices will be improved to ensure that the financial aid office is made aware of enrollment status changes timely.

FINDING 2021-010 ? Drug Free Workplace Policy, Drug and Alcohol Abuse Prevention Program, and Biennial Review of the Policy Federal Agency: U.S. Department of Education; Office of Federal Student Aid Pass through Entity: Not applicable Program Name: Federal Direct Student Loan Program Federal Pell Grant Program CFDA# and Program Expenditures: 84.268 ($466,916) 84.063 ($338,841) Award Number: P268K217643 P063P207643 Federal Award Year: July 1, 2020 to June 30, 2021 Questioned Costs: $-0- Condition Found: The Drug Free Workplace Policy and other drug free prevention material does not include all of the required documentation. The Organization administration could not accurately complete the biennial review of their Drug Free Workplace Policy and drug free prevention process because the policies did not include the information the Organization is required to review. Criteria: The Organization?s published policy must include the following: o Information on preventing drug and alcohol abuse; o Standards of conduct that clearly prohibit, at a minimum, the unlawful possession, use, or distribution of drugs and alcohol by students and employees on the school's property or as part of the school's activities; o A description of the sanctions under local, state, and federal law for unlawful possession, use, or distribution of illicit drugs and alcohol; o A description of any drug and alcohol counseling, treatment, or rehabilitation programs available to students and employees; o A description of the health risks associated with the use of illicit drugs and alcohol; and o A clear statement that the school will impose sanctions on students and employees for violations of the standards of conduct (consistent with local, state, and federal law) and a description of these sanctions, up to and including expulsion, termination of employment, and referral for prosecution. In addition, the biennial review should include the following: o The number of drug and alcohol-related violations and fatalities that occur on a Organization?s campus or as a part of any of the Organization?s activities that are reported to campus officials; and o The number and type of sanctions that are imposed by the school as a result of drug and alcohol-related violations and fatalities on the Organization?s campus or as part of any of the Organization?s activities. Cause: The Organization?s administration has not revised the policy to comply with the SFA regulations. Possible Asserted Effect: The policy did not contain all of the required documentation listed above. Staff and students were unaware of the Organization?s full policy and drug prevention efforts. Because of the lack of information in the policy, the biennial review was unable to include the required information. Repeat Finding: A Single Audit was not required for the year ended June 30, 2020. Recommendation: The Organization?s administration should rewrite the Drug Free Workplace Policy and drug prevention information to include the information listed above. The biennial review should be completed when adequate data is available. Management Response: The Organization updated its drug related policies in December 2021. The Organization is tracking the information necessary to complete the biennial review accurately.