BEULAH HEIGHTS UNIVERSITYHigher Education

Information on the federal program: Federal Direct Student Loans, FAL No. 84.268, June 30, 2025; Federal Pell Grant Program, FAL No. 84. 063, June 30, 2025; Federal Supplemental Educational Opportunity Grant, FAL No. 84.007, June 30, 2025; Federal Work-Study Program, FAL No. 84.033, June 30, 2025. Finding 2025-001 - U.S. Department of Education (ED), Title IV Student Financial Aid Programs- Pell Grant Disbursement Reported in Incorrect Award Year (significant deficiency): Criteria – Per 34 CFR § 690.61, institutions must ensure that Pell Grant disbursements are made and reported for the correct award year and in accordance with program requirements. Institutions are required to report Pell Grant disbursements in the correct award year and submit all disbursement records by the published COD closeout deadline for the applicable award year Disbursements not reported by the closeout deadline may not be shifted to a subsequent award year to compensate for missed reporting. Condition - For the 2024–2025 award year, testing revealed that one (1) out of ten (10) students selected for testing became eligible for a Federal Pell Grant disbursement of $204 during the 2023–2024 award year. The institution failed to process and report the disbursement in COD prior to the 2023–2024 COD closeout deadline. To compensate, the institution incorrectly posted the $204 disbursement to the student’s account and reported the payment to COD under the subsequent 2024–2025 award year. Cause – The infraction appears to have resulted from failure to monitor and comply with COD Pell Grant closeout deadlines and inadequate controls to ensure disbursements are reported in the correct award year. Effect – Pell Grant disbursement activity was reported inaccurately to the Department of Education. Reporting the disbursement in the incorrect award year compromises the accuracy and integrity of federal Pell reporting. Misreported Pell activity increases the risk of required data corrections and program review findings. Questioned Costs - $204 Perspective – Accurate and timely reporting of Pell Grant disbursements by award year is a key Title IV compliance control, as Pell Grant funding is awarded, monitored, and closed out on an annual basis. In this instance, one (1) out of ten (10) students tested (10%) had a Pell Grant disbursement that was reported in an incorrect award year due to failure to meet the applicable COD closeout deadline. Although the dollar amount involved was limited, the error demonstrates that controls designed to ensure award-year accuracy and timely COD reporting did not operate effectively. Repeat Finding – No Auditor’s Recommendation – We recommend that the institution strengthen closeout monitoring procedures, ensure award-year accuracy, and perform periodic internal reviews. Management’s Response – For the 2024–2025 award year, one (1) out of ten (10) students selected for testing became eligible for a Federal Pell Grant disbursement of $204 in the 2023-2024 award year. The institution failed to process the disbursement in COD prior to the 2023-2024 closeout deadline. To compensate, the institution incorrectly posted the $204 disbursement to the student’s account and reported the payment to COD under the subsequent 2024-2025 award year. Per 34 C.F.R. § 690.61 and the U.S. Department of Education’s Common Origination and Disbursement (COD) system requirements, institutions must report Pell Grant disbursements in the correct award year and by the published COD closeout deadline. A. Agree B. Conditions That Caused the Infraction a. Upon further review of the student’s account ledger, the institution identified that a $204 Pell Grant disbursement was incorrectly reflected for the Fall 2024 term. The student did not attend or enroll in Fall 2024; therefore, no Title IV funds should have been associated with that payment period. b. The Pell award was disbursed but was not properly aligned with the student’s actual enrollment timeline. Although the student attended Summer 2024 and Spring 2025, the institution did not submit a Student Bill Letter (SBL) for Spring 2025 because the student was enrolled in only one course. At the time, institutional practice did not require SBL submission for students enrolled less than half time or in a single course. As a result:  The Pell disbursement was not aligned with the correct payment period.  The $204 Pell award was incorrectly reflected as a Fall 2024 disbursement instead of being applied to the appropriate term.  This created a compliance issue related to Title IV disbursement timing and documentation.  Subsequent guidance from FA Solutions clarified that SBLs must be submitted for all enrolled students, regardless of enrollment intensity, to ensure proper alignment of Title IV funds with the correct payment period. C. The School’s Planned Corrective Action Plan (CAP)- The institution will implement the following corrective actions to address and prevent recurrence of this finding: a. Ledger Correction  The Student Accounts Office will revise the student’s ledger to accurately reflect the $204 Pell Grant disbursement as a Summer 2024 credit/refund, the term in which the student had eligible enrollment.  Any misapplied term references will be removed to ensure alignment with Title IV regulations. b. Policy and Procedure Update  Institutional procedures will be updated to require submission of Student Bill Letters (SBLs) for all enrolled students, including those enrolled in a single course or less than half time, when Title IV funds are involved.  This requirement will be documented in both Financial Aid and Student Accounts procedural manuals. c. Staff Training  Financial Aid and Student Accounts staff will receive training on updated SBL submission requirements and Title IV disbursement alignment.  Training will include review of payment period eligibility, enrollment intensity, and documentation standards. d. Cross Departmental Review Process  Financial Aid and Student Accounts will implement a secondary review process prior to Pell disbursement to confirm:  Enrollment for the applicable term  Presence of a submitted SBL  Correct payment period assignment D. Responsible Officials a. Dr. Gina Garlington, Financial Aid Administrator Responsible for Title IV compliance, staff training, SBL submission, and oversight of Pell disbursement procedures. b. CLA, Third Party Servicer and School’s Student Accounts Office Responsible for ledger corrections, and reconciliation of student accounts. E. Expected Timeline for Implementation a. All timelines have been complete F. Monitoring of Corrective Action Plan a. The CAP will be monitored through the following mechanisms:  Monthly reconciliation reviews between Financial Aid and Student Accounts  Random sampling of Pell disbursements to confirm correct payment period alignment.  Annual internal compliance review of SBL submissions and Title IV disbursements.  Documentation of corrective actions retained for audit and program review purposes.  Any discrepancies identified during monitoring will be addressed immediately and documented. G. Status of CAP Prior to This Finding a. This is the first occurrence of this finding for the institution. b. No prior corrective action plan existed addressing this specific issue. View of Responsible Officials- Officials agree with findings

Finding 2025-002 - U.S. Department of Education (ED), Title IV Student Financial Aid Programs - Federal Work-Study Community Service Requirement Not Met and Failure to Report FWS Earnings (significant deficiency): Criteria – Per 34 CFR § 675.18(g), each institution participating in the Federal Work-Study (FWS) Program must use at least 7 percent of its total FWS allocation to compensate students employed in community service activities unless the institution has received an approved waiver from the Department of Education. Per 34 CFR § 675.19(b), institution must maintain fiscal control and accountability over FWS funds and comply with all reporting requirements established by the Secretary. This includes accurately reporting FWS student earnings through required federal systems and maintaining documentation to support reported activity. Condition - Based on documentation provided for the 2024–2025 award year, the institution was authorized a total of $26,649 in Federal Work-Study funds. Of this amount, only $1,057 was identified as wages paid to students employed in community service activities. No documentation was provided to demonstrate that additional community service wages were paid or that a waiver from the U.S. Department of Education of not meeting the required 7 percent community service expenditure threshold. Additionally, during review of the institution’s 2024–2025 Federal Work-Study (FWS) activity, it was noted that FWS student earnings were not reported to the Common Origination and Disbursement (COD) System. The institution’s financial aid records and payroll registers indicate that students earned a total of $23,131 in FWS wages during the award year; however, no corresponding COD submissions or COD acknowledgment files were provided for review to demonstrate that these earnings were reported as required. Cause – The infraction appears to have resulted from failure to monitor compliance with the 7 percent FWS community service requirement and inadequate internal controls to ensure timely and accurate reporting of FWS earnings. Effect – The institution did not comply with the statutory community service spending requirement and FWS earnings were not reported through required federal reporting channels, limiting transparency and federal oversight. Questioned Costs - $0 Perspective – The Federal Work-Study Program includes explicit statutory spending and reporting requirements that are considered key compliance controls. In this instance, the institution expended approximately 4 percent of its authorized FWS allocation ($1,057 of $26,649) on community service wages, compared to the required 7 percent, resulting in a 43 percent shortfall from the required threshold. In addition, 100 percent of FWS earnings identified during testing ($23,131) were not reported to the COD System, as no submission or acknowledgment records were available. Repeat Finding – No Auditor’s Recommendation – We recommend that the institution strengthen monitoring of community service requirements and establish formal FWS reporting controls and perform periodic internal audits of FWS expenditures and reporting to identify and correct issues prior to year-end and federal reporting deadlines. Management’s Response – Per 34 CFR § 675.18(g), each institution participating in the Federal Work-Study (FWS) Program must use at least 7 percent of its total FWS allocation to compensate students employed in community service activities. Based on documentation provided for the 2024-2025 award year, the institution was authorized a total of $26,649 in Federal Work-Study funds. Of this amount, $1,057 was identified as community service wages. No documentation was provided to demonstrate that additional community service wages were paid or that a waiver from ED was requested or approved

We observed the following condition in connection with our testing of the various U.S. Department of Education, Title IV, Student Financial Assistance Programs: • Per 34 CFR 668.34, one (1) student out of 15 tested for satisfactory academic progress requirements (SAP) received Title IV, HEA program funds in the amount of $6,342 and was not meeting the requirements specified by the University. The University subsequently returned the funds. The University should implement corrective actions to ensure that the above findings are resolved and do not recur in future periods. Corrective Action – The University agrees with the finding. To address, the University’s registrar’s office will flag students in the student information system and place a registration hold on their account if they are not currently meeting Satisfactory Academic Progress (SAP) requirements. The financial aid office will check for all holds, any former SAP corrective actions and ensure that all students, including those re-entering the University following an absence, are meeting SAP requirements.

Finding 2023-001 – U.S. Department of Education (USDE), Title IV Student Financial Aid Programs We observed the following conditions in connection with our testing of the various U.S. Department of Education, Title IV, Student Financial Assistance Programs: 1. Two (2) out of 16 students tested did not have timely or accurate enrollment reporting to the National Student Loan Data System (NSLDS). 2. One (1) out of 16 students tested did not have a post withdrawal disbursement within the allotted days of the school’s withdrawal date determination. 3. One (1) out of 16 students tested did not have Title IV funds returned within the allotted days of the school’s withdrawal date determination. 4. One (1) out of 16 students received Title IV funding and was not charged for courses taken. The questioned cost is $124. The funds were subsequently returned to the USDE. 5. One (1) out of 16 students received a Pell grant greater than the amount for which the student was eligible. The questioned cost is $862. The funds were subsequently returned to the USDE. 6. Five (5) out of 16 students were selected for refund canceled check testing. There was no documentation provided to test signatures for two (2) of the students selected. All requested documents were subsequently provided. 7. One (1) out of 16 students tested was eligible for a Federal Direct Subsidized loan and was not awarded. 8. One (1) out of 16 students tested had an award letter that stated subsequent Title IV disbursements were available to the student and the subsequent disbursements were not awarded." The University should implement corrective actions to ensure that the above findings are resolved and do not recur in future periods. Corrective Actions – 1. NSLDS reporting is actively reconciled monthly with our third-party financial aid servicer and, as of November 16, 2023, the University confirmed 97.34% reported. The University will continue to actively monitor this reporting to ensure accuracy and timeliness. 2. Student Information System integration with third-party financial aid servicer’s system will allow the University to improve timing of drop notifications to ensure the third-party financial aid servicer is notified timely. The University will continue to monitor and review the process of withdrawal disbursement more thoroughly with the third-party financial aid processor to ensure that they are processed timely. 3. The University will monitor and review the process of returning Title IV funds to ensure that returns are processed timely. 4. The University has implemented a process that cross-checks enrollment with financial aid funding to identify and address situations in which students are inappropriately awarded Title IV funding. 5. The University is working with its third-party financial aid servicer to ensure Pell grants are awarded appropriately and within the amounts eligible. The University will ensure timely enrollment changes are sent to third-party financial aid servicer for any adjustments to aid eligibility. 6. The University has robust controls related to student refunds, and will continue to enforce these controls and retain the necessary documentation. 7. The University is working with its third-party financial aid servicer to ensure Federal Direct Subsidized Loans are awarded in all cases where appropriate. This is a unique situation where the FA software failed to recognize NSLDS information. The third-party financial aid servicer will monitor students closer until the system issue is resolved. 8. The Universiy is working with its third-party financial aid servicer to ensure Title IV disbursements, as outlined in award letters, are ultimately awarded.

2022-002

Finding 2022-002 - U.S. Department of Education (USDEJ. Title IV Student Financial Aid Programs (deficiency}: We observed the following conditions in connection with our testing of the various U.S. Department of Education, Title IV, Student Financial Assistance Programs: 1. One (1) out of 10 students tested did not have timely or accurate enrollment reporting to the National Student Loan Data System (NSLDS). 2. One (1) out of 60 students tested was overpaid Pell funds. The over awarded funds were subsequently returned. 3. One (1) out of 60 students tested was not eligible for but was awarded Federal Supplemental Educational Opportunity Grant (FSEOG). The University subsequently returned the ineligible grant amount. 4. One (1) out of 60 students tested showed a discrepancy during verification testing where we observed tax documents submitted with an incorrect social security number. The questioned cost is $5,195. 5. Two (2) out of Five (S) students tested did not show the returned amount on the student's statement of account during R2T4 testing. Both statements of account were subsequently updated with the returned amounts. Corrective Actions - 1. NSLDS reporting is actively reconciled monthly with our financial aid servicer and, as of August 18, 2022, the University confirmed 97.18% reported. The University will continue to actively monitor this reporting to ensure accuracy and timeliness. 2. The University will monitor and review the process of enrollment more thoroughly with the third-party financial aid processor to ensure all non-enrolled students are not included in payment batches. The University has moved to a new third-party financial aid processor in a further effort to ensure compliance with Title IV regulations. 3. The University will monitor and review the process of enrollment more thoroughly with the third-party financial aid processor to ensure all non-enrolled students are not included in payment batches. The University has moved to a new third-party financial aid processor in a further effort to ensure compliance with Title IV regulations. 4. The University will monitor and review the process of verification more thoroughly with the third-party financial aid processor to ensure all applicable steps are taken and that all information is accurate. The University has moved to a new third-party financial aid processor in a further effort to ensure compliance with Title IV regulations. 5. The University has implemented a new student information system, as well as processes to ensure that Title IV transactions are applied timely to student ledgers. The University also notes that, in the case of this finding, the Title IV funds were returned timely and accurately.

2021-002

Auditor's Recommendation - The University should implement corrective actions to ensure that the above findings are resolved and does not recur in future periods. Moreover, internal controls over compliance with federal program regulations should be revisited to ensure adequate supervisory controls, quality assurance reviews of compliance steps, technical training of staff, and adequate procedures are being followed for compliance purposes. Viewso f ResponsibleO fficials- The University agrees with the finding. There was considerable confusion surrounding the HEERF guidance for many colleges and universities, and this confusion extended to the drawdown and disbursement requirements. While the University drew funds and did not disburse within the allotted timeframe, it did use all funds for allowable expenses in the current fiscal year. Further, funds drawn were kept in a separate, non-operating bank account held by the University until fully disbursed.

The University should implement corrective actions to ensure that the above findings are resolved and do not recur in future periods. Corrective Actions ? a) The students received a presidential scholarship which resulted in a credit on their account. The business office will conduct weekly credit balance reconciliations to ensure credit balances do not remain on student accounts longer than 14 days and are disbursed to students or returned to the Department of Education. b) We will monitor and review the process of enrollment more thoroughly with the third-party processors to ensure all non-enrolled students are not included in the payment batches. c) We will monitor and review our process by implementing a more thorough review with our third-party processors by uploading documents for review to report in a timely manner. d) The students identified in the audit were notified and asked to complete the entire Form I-9 and provide another form of identification. The Human Resource department was able to receive some, but not all of the requested information. Beulah Heights University?s policy states ?Students must complete the Employment Eligibility Verification Form (or Form I-9) with the Beulah Heights University?s Human Resource department prior to the start of work or training.(This is a requirement of the U.S. Citizenship and Immigration Services and not of Beulah Heights University). Form I-9 is the form required by all U.S. employers to verify the identity and employment authorization of newly hired individuals. Students must bring original, unexpired document(s) to establish identity and employment authorization. Please refer to the attached list of acceptable documents as defined by the U.S. Citizenship and Immigration Services?.

2020-001

We observed the following conditions in connection with our testing of the various U. S. Department of Education, Title IV, Student Financial Assistance Programs: 1. Five (5) out of 10 students tested did not have timely or accurate enrollment reporting to the National Students Loan Data System. 2. One (1) out of 60 students was overpaid Pell Grant funds. The funds were subsequently returned. 3. Eight (8) out of 60 students tested had a credit balance on their accounts beyond the required 14 days. 4. One (1) out of 60 students tested shows total assistance exceeded need. The over award totals $8,361. 5. One (1) of 60 students tested was paid all Unsubsidized Direct Student Loans but the student qualified for Subsidized Direct Student Loans for the program attended. 6. One (1) out of 60 files tested did not have the Institutional student Information Record (ISIR) comment code resolved. The questioned cost is $16,469. 7. The FISAP report for fiscal year 2019-2020 was submitted to USDE with incorrect data based on our testing of the grid income levels. 8. Verification Process: a. One (1) student tested showed differences in the household and the number in college between the Institutional Student Information Record (ISIR) and the verification worksheet. The institution subsequently addressed the variances. b. Two (2) students tested had incomplete verification worksheets. c. Two (2) students tested show discrepancies during verification within the tax and child support information. The variances resulted in a change to the estimated family contribution and a return of $90 to the USDE for one (1) student. The funds associated with this finding were subsequently returned. 9. One (1) out of 5 students tested show an error within the R2T4 calculation where the Federal Student Equal Opportunity Grant (FSEOG) amount was incorrectly recorded. The error did not create an under or overpayment to the USDE. Corrective Actions ? 1. NSLDS reporting is actively reconciled monthly with our servicer and as of 5.18.21, the University confirmed 98.67% reported. 2. The institution will perform regular monthly reconciliations of all federal funds including assessing the student cost of attendance, which will alleviate the overpayment of Pell funds. 3. The business office will conduct weekly credit balance reconciliation to ensure credit balances do not remain on student accounts longer than 14 days and are disbursed to students or returned to the Department of Education. 4. The institution will perform regular monthly reconciliations of all federal funds including assessing the student cost of attendance, which will alleviate exceeding student need. In addition, the institution will review and increase the COA attendance budget if applicable to the student. 5. The ineffective loan qualifications process practices have been addressed and the institution has created a secondary review step to ensure all loan awarding is accurate. 6. A quarterly review process has been implemented by the institution to review ISIRs with our third-party servicer to ensure each student?s comment code is resolved. 7. The institution has implemented a monthly reconciliation process between the Financial Aid and Business Office that will ensure that the data on the FISAP report is accurate. 8. Verification Process: (a ? c) The ineffective verification process practices have been addressed and the institution and servicer have created a secondary review step to ensure all dates are accurate. 9. We will monitor and review the process of the template to report timely updates. The institution will implement a more structured internal audit function to resolve issues with R2T4 calculation.

2019-001

FINDING 2019-001 ?Inaccurate Enrollment Reporting to NSLDS (Repeat Finding) CONDITION: The Institution did not accurately report the enrollment status to NSLDS for various students. CRITERIA: 34 CFR 685.309 CONTEXT: Out of eighty-five (85) files tested, twenty (20) had inaccurate enrollment status reported to NSLDS. CAUSE: The Institution is using a new third party servicer and the reporting portal instructions for NSLDS information created issues that caused the dates reported to be inaccurate. This issue has been discussed with the third party servicer and has been resolved. The Institution is updating the NSLDS records to reflect the correct dates. EFFECT: Inaccurate and untimely student enrollment status reporting negatively affects the Department of Education?s ability to properly manage its student loan portfolio and may increase its costs. RECOMMENDATION: No recommendation considered necessary. The issue has been resolved and reporting going forward should be timely and accurate. MANAGEMENT RESPONSE: The Institution agrees with the auditor?s finding. The Institution had identified the problem and already implemented new procedures to correct this issue.

2018-001

FINDING 2019-002 ? Cyber Security Deficiency CONDITION: The Institution has not yet implemented an information security program. It is in the process of performing the risk assessments and documenting the safeguards for each identified risk. CRITERIA: 16 CFR 314.4(b) CAUSE: The Institution was not aware of the requirement. EFFECT: Student financial records, which includes sensitive personal identifiable information pertaining to the administration of Title IV funds are possibly at risk to an unauthorized access. RECOMMENDATION: 2019-002-a - The Institution should complete the implementation of its information security program as soon as possible. 2019-002-b ? The Institution should consider attending additional training courses to better understand DE rules and regulations. MANAGEMENT RESPONSE: The Institution agrees with the auditor?s finding. The Institution has started the process to have a risk assessment completed and documenting its identified risks.

FINDING 2019-003 ? Late Return of Credit Balance CONDITION: The credit balance on the student?s ledger card was not returned to Department of Education in a timely manner after the student dropped from the Institution. CRITERIA: 34 CFR 668.164 (h) CONTEXT: Out of eighty-five (85) student files selected for testing, two (2) had late returns of credit balances. CAUSE: The Institution did not have internal controls in place to ensure the credit balances were returned to the Department of Education in a timely manner. EFFECT: The Institution had access to Title IV funds to which it was not entitled. RECOMMENDATION: The Institution should consider implementing a more rigorous and structured internal audit function for the review of activity and documentation in the student files. MANAGEMENT RESPONSE: The Institution agrees with the auditor?s finding and will implement his recomendations

GSA_MIGRATION

2017-002

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2016-002

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