THOMAS UNIVERSITY, INC.

Information on Federal Program: United States Department of Education. Student Financial Assistance Cluster. Federal Assistance Listing Number 84.063 – Federal Pell Grant Program; 84.268 – Federal Direct Loan Program Compliance Requirements: Return of Title IV Funds Criteria: (34 CFR 668.22(a)(1)) When a recipient of title IV grant or loan assistance withdraws from an institution during a payment period or period of enrollment in which the recipient began attendance, the institution must determine the amount of title IV grant or loan assistance that the student earned as of the student's withdrawal date in accordance with paragraph (e) of this section.Condition: For the year ended May 31, 2025, we reviewed return of title IV funds requirements for students who received title IV program funds and withdrew from the institution during the audit period and noted three (3) instances where the institution used the incorrect calculation resulting in funds due to the Department, one (1) instance where the institution used the incorrect calculation resulting in too much funds returned to the department, and one (1) instance where the student received financial aid but never began attendance. Cause: No cause could be determined. Effect: Students retained the incorrect amount of title IV funds after a withdraw. Questioned Costs: $7,368 in 24-25 Unsubsidized Federal Direct Loan program funds under refunded to the department, $15 in 24-25 Federal Pell Grant Program Funds under refunded to the department, and $217 in 24-25 Unsubsidized Federal Direct Loan program funds over refunded to the department. Context: We tested six (6) randomly selected student files totaling $7,566 Title IV funds returned to the department from a population of $106,750 Title IV funds returned to the department and found three (3) instances where the institution used the incorrect calculation resulting in funds due to the Department, and one (1) instance where the institution used the incorrect calculation resulting in too many funds returned to the department, and one (1) instance where the student received financial aid but never began attendance. Student #E2 – The student received $6,762 24-25 Unsubsidized Federal Direct Loan program funds and did not begin attendance. The institution returned $0 24-25 Unsubsidized Federal Direct Loan program funds. The institution should have returned $6,762 in 24-25 Unsubsidized Federal Direct Loan program funds. Student #E32 – The student withdrew during the Spring 2025 term and the institution returned $0 24-25 Unsubsidized Federal Direct Loan program funds. The institution should have returned $1,428 in 24-25 Unsubsidized Federal Direct Loan program funds. The institution used a start date of January 6, 2025, in the return of title IV calculation and should have used the start date of March 10, 2025, resulting in additional funds to be returned to the department in the amount of $1,428 24-25 Unsubsidized Federal Direct Loan program funds. Student #E33 - The student withdrew during the Fall 2024 term and the institution returned $1,013 24-25 Federal Pell Grant Program funds. The institution should have returned $796 in 24- 25 Federal Pell Grant Program funds. The institution’s calculation had $932 in Federal Pell Grant Program funds that could have been disbursed. The Pell funds should have been included as funds disbursed for $1,013. The institution’s calculation also used 108 total days and should have used 103 total days resulting in too many funds returned to the department in the amount of $217 24-25 Federal Pell Grant Program funds. Student #E34 - The student withdrew during the Fall 2024 term and the institution returned $0 24-25 Unsubsidized Federal Direct Loan program funds. The institution should have returned $3,179 in 24-25 Unsubsidized Federal Direct Loan program funds. The institution excluded all student financial aid disbursements from the calculation, used a start date of August 18, 2024, in the return of title IV calculation and should have used the start date of August 19, 2024, used an end date of December 12, 2024, in the return to title IV calculation and should have used the end date of December 13, 2024, resulting in additional funds to be returned to the department in the amount of $3,179 24-25 Unsubsidized Federal Direct Loan program funds. Student #E37 – The student withdrew during the Fall 2024 term and the institution returned $3,361 24-25 Federal Pell Grant Program funds. The institution should have returned $3,376 in 24-25 Federal Pell Grant Program funds. The institution used 10 days completed out of 110 days total in their return of title IV calculation and should have used 9 days completed out of 103 days total resulting in additional funds to be returned to the department in the amount of $15 24-25 Federal Pell Grant Program funds. Repeat Finding: Is a repeat finding. Recommendation: We recommend management return the funds in question and review and revise controls over student withdrawals to ensure the information used in the calculation is correct. Responsible Official’s Response and Corrective Action Planned: We agree with the finding and recommendations.  All monies owed, will be paid back to the department.  Thomas University is actively searching for a qualified individual to fill the role of Director of Financial Aid, and interview is being held with a high potential candidate on Friday June 25, 2026.  Thomas University will revise and document Return of Title IV Funds procedure to ensure calculations are completed in accordance with 34 CFR 668.22 requirements.  Establish standardized processes for determining withdrawal dates, enrollment status, and earned versus unearned Title IV aid.  A secondary review process requiring a qualified financial aid administrator to review and approve all calculations before funds are returned or adjustments are processed.  Increase coordination between Financial Aid office, Registrar Office, and Business office to endure timely communication of attendance and withdrawal information.  Staff will be required to participate in periodic federal compliance training and regulatory update sessions. Planned Implementation Date of Corrective Action: December 31, 2026. Person Responsible for Corrective Action: Kurt Stringfellow, President

Finding 2024-002: Information on Federal Program: United States Department of Education. Student Financial Assistance Cluster. Federal Assistance Listing Number 84.063 – Federal Pell Grant Program. Compliance Requirements: Eligibility Criteria: (34 CFR 690.62(a)) 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. Condition: For the year ended May 31, 2024, we reviewed general eligibility requirements for students who received Title IV program funds and noted two (2) instances where a student received Federal Pell Grant Program funds during the audit period in excess of the amount published by the Secretary. Cause: No cause could be determined. Effect: Students received more Federal Pell Grant program funds than allowed. Questioned Costs: $1,809 in 23-24 Federal Pell Grant program funds. Context: We tested forty (40) randomly selected student files totaling $75,687 Federal Pell Grant Program funds from a population of $2,323,602 Federal Pell Grant Program funds and found two (2) instances of noncompliance in the amount of $1,809. Student #E1 – The student received $2,658 in 23-24 Federal Pell Grant program funds. The student was eligible for $1,773 in 23-24 Federal Pell Grant program funds, resulting in an $885 overaward in 23-24 Federal Pell Grant program funds. For the Sprint 2024 semester the student was awarded based on a full-time status while only enrolled half-time. Student #E30 - The student received $7,395 in 23-24 Federal Pell Grant program funds. The student was eligible for $6,471 in 23-24 Federal Pell Grant program funds, resulting in a $924 overaward in 23-24 Federal Pell Grant program funds. For the Sprint 2024 semester the student was awarded based on a full-time status while only attending enough classes to be considered enrolled three-quarter time. Repeat Finding: Not a repeat finding. Recommendation: We recommend management review and revise controls over student eligibility to determine students had begun attendance in enough classes to maintain the enrollment status their Federal Pell Grant program funds were awarded on. Responsible Official’s Response and Corrective Action Planned: We agree with the finding and recommendations. Thomas University has upgraded its student information system from CAMS to Jenzabar. The Financial Aid module Jenzabar Financial Aid has been configured by the Director of Financial Aid with a group process to identify enrollment level changes. This process is programmed to adjust the student scheduled Pell to reflect the updated Pell amount based on the Pell table. This process will reduce the Pell amount if the hours adjust down even when the Pell has already disbursed. This process will also increase the Pell when the hours increase. This process is on a scheduler that runs daily. Planned Implementation Date of Corrective Action: This process was created and implemented 10/01/2024. Person Responsible for Corrective Action: Derek Haskins, Director of Financial Aid

Information on Federal Program: United States Department of Education. Student Financial Assistance Cluster. Federal Assistance Listing Number 84.063 – Federal Pell Grant Program; 84.268 – Federal Direct Loan Program Compliance Requirements: Return of Title IV Funds Criteria: (34 CFR 668.22(a)(1)) When a recipient of title IV grant or loan assistance withdraws from an institution during a payment period or period of enrollment in which the recipient began attendance, the institution must determine the amount of title IV grant or loan assistance that the student earned as of the student's withdrawal date in accordance with paragraph (e) of this section. Condition: For the year ended May 31, 2024, we reviewed return of title IV funds requirements for students who received title IV program funds and withdrew from the institution during the audit period and noted one (1) instance where the institution used the incorrect calculation resulting in funds due to the Department and two (2) instances where the institution used the incorrect calculation resulting in too much funds returned to the department. Cause: No cause could be determined. Effect: Students retained the incorrect amount of title IV funds after a withdraw. Questioned Costs: $2,733 in 23-24 Unsubsidized Federal Direct Loan program funds under refunded to the department and $50 in 23-24 Federal Pell Grant Program Funds over refunded to the department. Context: We tested six (6) randomly selected student files totaling $3,556 Title IV funds returned to the department from a population of $70,058 Title IV funds returned to the department and found one (1) instance where the institution used the incorrect calculation resulting in funds due to the Department and two (2) instances where the institution used the incorrect calculation resulting in too many funds returned to the department. Student #E35 – The student withdrew during the Spring 2024 term and the institution returned $0 23-24 Unsubsidized Federal Direct Loan program funds. The institution should have returned $2,733 in 23-24 Unsubsidized Federal Direct Loan program funds. The institution used a withdrawal date of April 3, 2024, in the return of title IV calculation and should have used the withdrawal date of March 10, 2024, resulting in additional funds to be returned to the department in the amount of $2,733 23-24 Unsubsidized Federal Direct Loan program funds. Student #E39 - The student withdrew during the Fall 2023 term and the institution returned $1,499 23-24 Federal Pell Grant Program funds. The institution should have returned $1,449 in 23-24 Federal Pell Grant Program funds. The institution’s calculation used 112 total days in their return of title IV funds calculation and should have used 103 total days resulting in too many funds returned to the department in the amount of $50 23-24 Federal Pell Grant Program funds. Student #E40 - The student withdrew during the Fall 2023 term and the institution returned $3,252 23-24 Federal Pell Grant Program funds. The institution should have returned $3,083 23- 24 Unsubsidized Federal Direct Loan program funds. The institution used 108 days in their return of title IV funds calculation and should have used 103 break days resulting in too many funds returned to the department in the amount of $169 23-24 Federal Pell Grant Program funds. Repeat Finding: Not a repeat finding. Recommendation: We recommend management return the funds in question and review and revise controls over student withdrawals to ensure the information used in the calculation is correct. Responsible Official’s Response and Corrective Action Planned: We agree with the finding and recommendations. Thomas University has upgraded its student information system from CAMS to Jenzabar. Thomas University Financial Aid office has an add and drop Report process that runs every day to identify changes in enrollment. Jenzabar has intergraded process that updates the R2T4 withdraw date based on the date input by the Registrar as the Last Date of Attendance according to the Withdraw Record. All Withdraw Records are shared with Financial Aid and the dates are reviewed for accuracy prior to completing calculation. Students are identified as Online or On-Campus students determined by Site. Based on the students’ Site, the number of break days are entered. Jenzabar automatically adjusts any award determined by the calculation process built in Jenzabar. Planned Implementation Date of Corrective Action: This process was created and implemented February 5, 2025. Person Responsible for Corrective Action: Derek Haskins, Director of Financial Aid

Finding 2023-001: Information on Federal Program: United States Department of Education. Student Financial Assistance Cluster. Federal Assistance Listing Number 84.268 – Federal Direct Loan Program. Compliance Requirements: Eligibility Criteria: (34 CFR 668.32(g)(2)) A student is eligible to receive Title IV, HEA program assistance if the student has not obtained loan amounts that exceed annual or aggregate loan limits made under any Title IV, HEA loan program. Condition: For the year ended May 31, 2023, we reviewed general eligibility requirements for students who received Title IV program funds and noted one (1) instance where a student received Title IV program funds during the audit period after the student exceeded their aggregate loan limit. Cause: No cause could be determined. Effect: Students received more loan funds than allowed. Questioned Costs: $1,732 in 22-23 Subsidized Federal Direct Loan program funds and $2,969 in 22-23 Unsubsidized Federal Direct Loan program funds. Context: We tested forty (40) randomly selected student files totaling $491,875 from a population of $17,533,359 and found one (1) instance of noncompliance in the amount of $4,701. Student #E25 – The student received $1,732 in 22-23 Subsidized Federal Direct Loan program funds and $2,969 in 22-23 Unsubsidized Federal Direct Loan program funds. The student was eligible for $0 in 22-23 Subsidized Federal Direct Loan program funds and $0 22-23 Unsubsidized Federal Direct Loan program funds, resulting in a $1,732 overaward in 22-23 Subsidized Federal Direct Loan program funds and a $2,969 overaward in 22-23 Unsubsidized Federal Direct Loan program funds. At the time of the audit, the student had received $77,645 in aggregate loans. An independent undergraduate student is only allowed to receive up to $57,500 in aggregate loans. Subsequent to the audit, the University refunded $1,732 in 22-23 Subsidized Federal Direct Loan program funds and $2,969 in 22-23 Unsubsidized Federal Direct Loan program funds. Repeat Finding: Not a repeat finding. Recommendation: Subsequent to the audit, the University refunded the awards in question. Therefore, we recommend management review and revise controls over student eligibility, at the time of packaging, to determine students have not or will not exceed their annual or aggregate loan limits. Responsible Official’s Response and Corrective Action Planned: Management agrees with the finding and recommendations. The organization will undergo a software upgrade aimed at augmenting the efficiency and precision of the financial aid department. We anticipate that this upgrade will be fully operational by the end of the first quarter of the next calendar year. Planned Implementation Date of Corrective Action: 03/29/2024 Person Responsible for Corrective Action: Clifton Mitchell, Director of Student Financial Services.

Finding 2021-001: Information on the Federal Program: United States Department of Education. Student Financial Assistance Cluster. CFDA 84.268 ? Federal Direct Loan Program. Compliance Requirements: Eligibility Criteria: (34 CFR 668.32(g)(2)) A student is eligible to receive Title IV, HEA program assistance if the student has not obtained loan amounts that exceed annual or aggregate loan limits made under any title IV, HEA loan program. Condition: For the year ended May 31, 2021, we reviewed general eligibility requirements for students who received title IV program funds and noted one (1) instance where a student received title IV program funds during the audit period after the student exceeded their aggregate loan limit and one (1) instance where a student received title IV program funds during the audit period in excess of their aggregate loan limit. Cause: No cause could be determined. Effect: Students received more loan funds than allowed. Questioned Costs: $8,246 in 20-21 Unsubsidized Federal Direct Loan program funds. Context: We tested forty (40) randomly selected student files totaling $468,602 from a population of $13,962,181 and found two (2) instances of noncompliance in the amount of $8,246. Student #E18 ? The student received $5,442 in 20-21 Subsidized Federal Direct Loan program funds and $1,980 in 20-21 Unsubsidized Federal Direct Loan program funds. The student was eligible for $5,442 in 20-21 Subsidized Federal Direct Loan program funds and $495 20-21 Unsubsidized Federal Direct Loan program funds, resulting in a $1,485 overaward in 20-21 Unsubsidized Federal Direct Loan program funds. At the time of the audit, the student had received $32,500 in aggregate loans. A dependent student is only allowed to receive up to $31,000 in aggregate loans. Student #E37 ? The student received $6,761 in 20-21 Unsubsidized Federal Direct Loan program funds. The student was not eligible to receive 20-21 Unsubsidized Federal Direct Loan program funds, resulting in a $6,761 of overaward 20-21 Unsubsidized Federal Direct Loan program funds. At the time of the student?s award, the student had an aggregate undergraduate loan balance of $57,673. The aggregate undergraduate loan limit for a student is $57,500. Because the student had obtained loan amounts that exceed the undergraduate student loan limit prior to the start of the loan period, they were not allowed to receive additional title IV program funds without first repayment of the excess loan amount or providing the school with a copy of the reaffirmation agreement (repayment arrangement). Repeat Finding: Not a repeat finding. Recommendation: We recommend management review and revise controls over student eligibility, at the time of packaging, to determine students have not or will not exceed their annual or aggregate loan limits. Responsible Official's Response and Corrective Action Planned: The University accepts the finding and recommendations. The University has purchase a propriety software called CampusLogic which was installed subsequent to the audit. CampusLogic simplifies the financial aid processes verification, professional judgments, and SAP appeals. A key component of the cloud based Campus Logic student financial success platform, Student Forms provides a digital portal for financial aid professionals to manage tasks, review files, and automate student communications and reminders via text and email. Additional we will review annually, key eligibility criteria. Planned Implementation Date of Corrective Action: Fall 2021. Person Responsible for Corrective Action: Clifton Mitchell, Director of Student Financial Services

Finding 2021-002: Information on the Federal Program: United States Department of Education. Student Financial Assistance Cluster. Compliance Requirements: Special Tests and Provisions - Verification Criteria: (34 CFR 685.57) If an applicant is selected for verification, an institution must obtain specific documentation. Condition: For the year ended May 31, 2021, we reviewed verification documents for students who received title IV program funds and were selected for verification. We noted specific documentation was not obtained. Cause: Students completed a verification worksheet/form that verified information for time periods different from the time periods referred to in the FASFA. In addition, verification documentation was not reviewed for accuracy or completeness. Effect: Students may not have received the correct amount of funding. Questioned Costs: Questioned costs could not be determined. Context: We tested nineteen (19) randomly selected student files totaling $222,836, from a population of $1,586,957, and found nineteen (19) instances of noncompliance. The noncompliance was due to one or more the following: - Verification worksheet was not completed. - Verification worksheet did not verify the household size from the 2020-2021 FASFA/ISIR. - Verification worksheet did not verify the 2018 income tax year information from the 2020-2021 FASFA/ISIR. - Student ISIR was not updated for the household size verified by the student or parent. - Student ISIR was not updated for the income tax information verified by the student or parent. - Tax return provided did not meet the criteria for acceptable documentation. Repeat Finding: Not a repeat finding. Recommendation: We recommend management review and revise controls over verification to ensure the correct information is verified and provided. Responsible Official's Response and Corrective Action Planned: The University agrees with the finding and recommendations. The University has purchase a propriety software called CampusLogic which was installed subsequent to the audit. CampusLogic simplifies the financial aid processes?verification, professional judgments, and SAP appeals. A key component of the cloud-based Campus Logic student financial success platform, Student Forms provides a digital portal for financial aid professionals to manage tasks, review files, and automate student communications and reminders via text and email. Additional we will review annually, key verification criteria. Planned Implementation Date of Corrective Action: Fall 2021. Person Responsible for Corrective Action: Clifton Mitchell, Director of Student Financial Services.