LIMESTONE UNIVERSITY

Finding 2024-002 – Student Financial Aid Cluster, Assistance Listing # 84.063 and 84.268 Compliance Requirement: Special Test and Provisions – Enrollment Reporting Condition: The University did not send changes in attendance levels, graduated, withdrew, dropped out, or enrolled changes to the National Student Loan Data System (“NSLDS”) within 60 days of the change. Criteria: The University is required to send changes in attendance levels, graduated, withdrew, dropped out, or enrolled changes to the NSLDS within 60 days of the change. Cause: The University had not reported changes of statuses of students to the NSLDS as required under the Uniform Grant Guidance for the year ended June 30, 2024. The status information reported in the University’s system, Jenzabar, was incorrectly extracted for the submission to the National Student Clearinghouse and NSLDS, which created discrepancies between the statuses. The University did not have another monitoring mechanism in place that would have alerted them to this deficiency in the system reporting. Context: The University sent six changes related to graduated students to the NSLDS with incorrect statuses and updated the status after 60 days. Additionally, the University submitted the status change related to one withdrawn student after 60 days. Effect: The University did not report status changes to the NSLDS accurately or timely. Recommendation: The University should put in place a process to timely capture status changes so that they can be reported to the NSLDS. Management Response: The University concurs with this finding. Corrective Action Plan: See attached management’s corrective action plan.

Finding 2024-002 – Student Financial Aid Cluster, Assistance Listing # 84.063 and 84.268 Limestone University utilizes Jenzabar software to extract and report enrollment data to the National Student Clearinghouse (NSC). However, in some instances, the data reported was incorrect. Since the occurrence of this issue, the University hired a new Registrar in August 2024. After reviewing the findings, the Registrar implemented the use of the NSC Edit Student Data Records window, in addition to the NSC Edit Registration Transactions window. This change allows a special status on the NSC Edit Student Data Records window to override the status on the Registration Transactions window, providing more precise monitoring of withdrawal dates and ensuring the accuracy and timeliness of the data reported to NSC. To ensure ongoing accuracy, the Registrar now reports enrollment status changes to NSC on a monthly basis. Additionally, the University reviewed the students identified in the findings, along with other students who had the same status (withdrawn) and made adjustments as necessary to ensure that all student data was accurately reported.

2023-002

Finding 2024-002 – Student Financial Aid Cluster, Assistance Listing # 84.063 and 84.268 Compliance Requirement: Special Test and Provisions – Enrollment Reporting Condition: The University did not send changes in attendance levels, graduated, withdrew, dropped out, or enrolled changes to the National Student Loan Data System (“NSLDS”) within 60 days of the change. Criteria: The University is required to send changes in attendance levels, graduated, withdrew, dropped out, or enrolled changes to the NSLDS within 60 days of the change. Cause: The University had not reported changes of statuses of students to the NSLDS as required under the Uniform Grant Guidance for the year ended June 30, 2024. The status information reported in the University’s system, Jenzabar, was incorrectly extracted for the submission to the National Student Clearinghouse and NSLDS, which created discrepancies between the statuses. The University did not have another monitoring mechanism in place that would have alerted them to this deficiency in the system reporting. Context: The University sent six changes related to graduated students to the NSLDS with incorrect statuses and updated the status after 60 days. Additionally, the University submitted the status change related to one withdrawn student after 60 days. Effect: The University did not report status changes to the NSLDS accurately or timely. Recommendation: The University should put in place a process to timely capture status changes so that they can be reported to the NSLDS. Management Response: The University concurs with this finding. Corrective Action Plan: See attached management’s corrective action plan.

Finding 2024-002 – Student Financial Aid Cluster, Assistance Listing # 84.063 and 84.268 Limestone University utilizes Jenzabar software to extract and report enrollment data to the National Student Clearinghouse (NSC). However, in some instances, the data reported was incorrect. Since the occurrence of this issue, the University hired a new Registrar in August 2024. After reviewing the findings, the Registrar implemented the use of the NSC Edit Student Data Records window, in addition to the NSC Edit Registration Transactions window. This change allows a special status on the NSC Edit Student Data Records window to override the status on the Registration Transactions window, providing more precise monitoring of withdrawal dates and ensuring the accuracy and timeliness of the data reported to NSC. To ensure ongoing accuracy, the Registrar now reports enrollment status changes to NSC on a monthly basis. Additionally, the University reviewed the students identified in the findings, along with other students who had the same status (withdrawn) and made adjustments as necessary to ensure that all student data was accurately reported.

2023-002

Finding 2024-003 – U.S. Department of Agriculture – Community Facilities Loan and Grant, Assistance Listing # 10.766 Compliance Requirement: Other Information Condition: U.S. Department of Agriculture (“USDA”) covenants and requirements were not adhered to. Criteria: Borrowers are required to fund reserves, maintain insurance, deposit funds in Federally insured banks, meet financial covenants, maintain sufficient debt service ratios, and in some cases comply with additional requirements established as part of the loan approval process. These requirements indicate the continuing compliance requirements that borrowers must meet. Cause: The University had turnover in the business department and non-quantitative requirements were not closely monitored. Context: The University did not meet the all the requirements per the USDA loan agreement dated as of December 16, 2021. The following requirements were not met during the fiscal year ended June 30, 2024: - Internally produced financial statements within 45 days (Article V, 5.8 (b)) - Compliance certificate (Article V, 5.8 (c)) - Budget provided 30 days prior to the beginning of the new fiscal year (Article V, 5.8 (d)) - Student housing rent roll (Article V, 5.16) Effect: Lack of compliance with loan covenants and requirements. Recommendation: The University’s management should read and follow all USDA loan covenants and requirements. Management Response: The University concurs with this finding. Corrective Action Plan: See attached management’s corrective action plan.

Finding 2024-003 – U.S. Department of Agriculture – Community Facilities Loan and Grant, Assistance Listing # 10.766 Following the hiring of a permanent president, the new CFO has developed a quarterly reporting template to ensure compliance with the U.S. Department of Agriculture (USDA) reporting requirements. The CFO submits the completed reports to the USDA on a quarterly basis and maintains regular communication with USDA representatives to address any concerns or clarifications regarding compliance.

2023-003

Finding 2024-003 – U.S. Department of Agriculture – Community Facilities Loan and Grant, Assistance Listing # 10.766 Compliance Requirement: Other Information Condition: U.S. Department of Agriculture (“USDA”) covenants and requirements were not adhered to. Criteria: Borrowers are required to fund reserves, maintain insurance, deposit funds in Federally insured banks, meet financial covenants, maintain sufficient debt service ratios, and in some cases comply with additional requirements established as part of the loan approval process. These requirements indicate the continuing compliance requirements that borrowers must meet. Cause: The University had turnover in the business department and non-quantitative requirements were not closely monitored. Context: The University did not meet the all the requirements per the USDA loan agreement dated as of December 16, 2021. The following requirements were not met during the fiscal year ended June 30, 2024: - Internally produced financial statements within 45 days (Article V, 5.8 (b)) - Compliance certificate (Article V, 5.8 (c)) - Budget provided 30 days prior to the beginning of the new fiscal year (Article V, 5.8 (d)) - Student housing rent roll (Article V, 5.16) Effect: Lack of compliance with loan covenants and requirements. Recommendation: The University’s management should read and follow all USDA loan covenants and requirements. Management Response: The University concurs with this finding. Corrective Action Plan: See attached management’s corrective action plan.

Finding 2024-003 – U.S. Department of Agriculture – Community Facilities Loan and Grant, Assistance Listing # 10.766 Following the hiring of a permanent president, the new CFO has developed a quarterly reporting template to ensure compliance with the U.S. Department of Agriculture (USDA) reporting requirements. The CFO submits the completed reports to the USDA on a quarterly basis and maintains regular communication with USDA representatives to address any concerns or clarifications regarding compliance.

2023-003

Finding 2023-002 – Student Financial Aid Cluster, Assistance Listing # 84.063 and 84.268 Compliance Requirement: Special Test and Provisions – Enrollment Reporting Condition: The University is required to send changes in attendance levels, graduated, withdrew, dropped out, or enrolled changes to the NSLDS within 60 days of the change. Criteria: The University is required to send changes in attendance levels, graduated, withdrew, dropped out, or enrolled changes to the NSLDS within 60 days of the change. Cause: The University had not reported changes of withdrawn students to the NSLDS as required under the Uniform Grant Guidance for the year ended June 30, 2023. The status information reported in the University’s system, Jenzabar (withdrawal date and last date of academic activity), was incorrectly extracted for the submission to the National Student Clearinghouse and NSLDS, which created discrepancies between the statuses. The University was unaware of this technical issue and did not have another monitoring mechanism in place that would have alerted them to this deficiency in the system reporting. Context: The University did not send status changes related to seven withdrawn students, had four incorrect status effective dates, and sent two changes related to withdrawn students to the National Student Loan Data System (“NSLDS”) with incorrect effective dates and after 60 days. Nine of the thirteen findings occurred during the paused data reporting period of July 20, 2022 through February 28, 2023 as stated within the 2023 Compliance Supplement. Effect: The University did not report withdraw changes to the NSLDS timely. Recommendation: The University should put in place a process to timely capture withdrawn student changes so that they can be reported to the NSLDS. Management Response: The University concurs with this finding. Corrective Action Plan: See attached management’s corrective action plan.

Finding 2023-002- Student Financial Aid Cluster, Assistance Listing #84.063 and 84.268 Limestone University utilizes Jenzabar software to extract enrollment data to National Student Clearinghouse for reporting. Information was being reported to the National Clearinghouse, but in some instances, the data was incorrect. Since the review of the findings, the Registrar has implemented the use of the field NSC Edit Student Data Records window, in addition to the normal enrollment process status indicated on the NSC Edit Registration Transactions window. A special status on the NSC Edit Student Data Records window will override the status on the NSC Edit Registration Transactions window. This change allows for more detailed monitoring of withdrawal dates to ensure what is being reported to NSC is accurate and timely. The Registrar reports enrollment status changes monthly to NSC to ensure enrollment changes are reported accurately and timely. The University reviewed the students in the finding, as well as reviewed all other students with the same status (withdrawn) and adjusted, if necessary, to ensure accurate student data was reported. Responsible Parties: Jeremy Whitaker, Acting President/CFO jwhitaker@limestone.edu 864-488-4539 DaOsha Pack, Controller dlpack@limestone.edu 864-488-4528 Summer Nance, Director of Financial Aid snance@limestone.edu 864-488-8251

Finding 2023-003 – U.S. Department of Agriculture – Community Facilities Loan and Grant, CFDA# 10.766 Compliance Requirement: Other Information Condition: U.S. Department of Agriculture (“USDA”) covenants and requirements were not adhered to. Criteria: Borrowers are required to fund reserves, maintain insurance, deposit funds in Federally insured banks, meet financial covenants, maintain sufficient debt service ratios, and in some cases comply with additional requirements established as part of the loan approval process. These requirements indicate the continuing compliance requirements that borrowers must meet. Cause: The University had turnover in the business department and non-quantitative requirements were not closely monitored. Context: The University was not able to meet covenants during the year but obtained a covenant waiver through fiscal year 2024. Additionally, the University did not meet the all the requirements per the USDA loan agreement dated as of December 16, 2021. The following requirements were not met during the fiscal year ended June 30, 2023: 1. Internally produced financial statements within 45 days (Article V, 5.8 (b)) 2. Compliance certificate (Article V, 5.8 (c)) 3. Budget provided 30 days prior to the beginning of the new fiscal year (Article V, 5.8 (d)) 4. Student housing rent roll (Article V, 5.16) Effect: Lack of compliance with loan covenants and requirements. Recommendation: The University’s management should read and follow all USDA loan covenants and requirements. Management Response: The University concurs with this finding. Corrective Action Plan: See attached management’s corrective action plan.

Finding 2023-003 U.S. Department of Agriculture-Community Facilities Loan and Grant, CFDA #10.766 Acting President and CFO created a quarterly reporting template that he completes and submits to the USDA to meet their reporting compliance requirements. In addition, he regularly communicates with USDA representatives. Responsible Parties: Jeremy Whitaker, Acting President/CFO jwhitaker@limestone.edu 864-488-4539 DaOsha Pack, Controller dlpack@limestone.edu 864-488-4528 Summer Nance, Director of Financial Aid snance@limestone.edu 864-488-8251