Northeastern Oklahoma A & M CollegeHigher Education

Federal Agency: US Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Number: 84.063, 84.007, 84.033, 84.268 Federal Award Identification Number and Year: P063P242037 - 2025, P007A243429 - 2025, P033A243429 - 2025, P268K252037 - 2025 Award Period: July 1, 2024 to June 30, 2025 Type of Finding: • Compliance, Other Matter • Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: 34 CFR 682.604, states that a school must ensure that exit counseling is conducted with each Stafford Loan borrower and graduate or professional student PLUS Loan borrower either in person, by audiovisual presentation, or by interactive electronic means. In each case, the school must ensure that this counseling is conducted shortly before the student borrower ceases at least half-time study at the school. Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Condition: The College did not properly have documentation of exit counseling notification. Questioned costs: None. Context: During our testing of 40 students, we identified 7 students that did not have documentation of exit counseling notification. Cause: The College did not have proper procedures in place to ensure that notification of required exit counseling was sent to applicable students. Effect: Exit counseling helps federal student loan borrowers understand how to repay their loans and reviews deferment and repayment plans options. If students are not notified of exit counseling, they could be at risk of not understanding their rights and responsibilities regarding loan repayment. Repeat Finding: No Recommendation: We recommend the College review reporting processes to ensure all students that require exit counseling receive it in a timely manner. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.

Federal Agency: US Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Number: 84.063, 84.007, 84.033, 84.268 Federal Award Identification Number and Year: P063P242037 - 2025, P007A243429 - 2025, P033A243429 - 2025, P268K252037 - 2025 Award Period: July 1, 2024 to June 30, 2025 Type of Finding: • Compliance, Other Matter • Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: Per 34 CFR 668.22(f)(2)(i), the total number of calendar days in a payment period or period of enrollment includes all days within the period that the student was scheduled to complete, except that scheduled breaks of at least five consecutive days are excluded from the total number of calendar days in a payment period or period of enrollment and the number of calendar days completed in that period. The Code of Federal Regulations, 34 CFR 668.22(j)(1), states that an institution must return the amount of title IV funds for which it is responsible as soon as possible but no later than 45 days after the date of the institution's determination that the student withdrew. Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Condition: The College incorrectly calculated Return to Title IV (R2T4) calculations and did not return Title IV funds within 45-days. Questioned costs: None. Context: During our testing of 40 R2T4 calculations, we identified that 15 had mechanically incorrect calculations by using the incorrect number of scheduled break days in the Spring term. Additionally, we identified 1 student with Title IV refund that was not returned within the 45-day requirement. Cause: The College was using the incorrect number of scheduled break days for Spring Term. Effect: The College could return incorrect amounts based off of their calculations, which could effect student repayment amounts based off of amount earned. Repeat Finding: Yes, 2024-003 Recommendation: We recommend that the College review policies and procedures related to R2T4 calculations to ensure calculations are performed correctly and timely. We also recommend the College implement formal review procedures to document the Return of Title IV calculations are being performed to minimize the likelihood that errors may go undetected and not be corrected in a timely manner. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.

Federal Agency: US Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Number: 84.063, 84.007, 84.033, 84.268 Federal Award Identification Number and Year: P063P242037 - 2025, P007A243429 - 2025, P033A243429 - 2025, P268K252037 - 2025 Award Period: July 1, 2024 to June 30, 2025 Type of Finding: • Compliance, Other Matter • Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless of if they receive aid from the institution or not. Changes to said status are required to be reported within 30 days of becoming aware of the status change, or with the next scheduled transmission of statuses if the scheduled transmission is within 60 days. Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Condition: The College did not properly report student enrollment changes for students who received federal student aid to the National Student Loan Data System (NSLDS). Questioned costs: None. Context: During our testing of 40 students, we identified 7 students with an effective date reported to NSLDS that did not align with institutional records and 6 students that were reported after the 60 day requirement. Cause: The College did not have proper procedures in place to verify students' status in NSLDS matched the institutions records accurately and reported timely. Effect: The College was not in compliance with the requirements to properly report student enrollment data correctly. Incorrect dates submitted to NSLDS may be used to determine the grace period for the repayment and interest of outstanding Title IV student loans. Repeat Finding: Yes, 2024-002 Recommendation: We recommend the College review current processes for reporting to NSLDS and implement procedures to ensure submissions are reported accurately and timely. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.

Federal Agency U.S. Department of Education Federal Program Name Student Financial Assistance Cluster Assistance Listing Number 84.063, 84.007, 84.033, 84.268 Federal Award Identification Number and Year P063P232037 - 2024, P007A233429 - 2024, P033A233429 - 2024, P268K242037 - 2024 Pass-Through Agency (if applicable) N/A Pass-Through Number(s) (if applicable) N/A Award Period 7/1/23 - 6/30/24 Compliance Requirement Affected Special Test and Provision Type of Finding Internal Control Significant Deficiency Document judgment for your assessment The College did not properly report student enrollment changes for students who received federal student aid to the National Student Loan Data System (NSLDS). Compliance Not Material Document judgment for your assessment Not greater than 5% and not a systemic failure Criteria or specific requirement "The Code of Federal Regulations, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless of if they receive aid from the institution or not. Changes to said status are required to be reported within 30 days of becoming aware of the status change, or with the next scheduled transmission of statuses if the scheduled transmission is within 60 days. In addition per the Uniform Guidance 2 CRF 200.303, non-federal entities receiving federal awards are required to establish and maintain internal controls designed to reasonable ensure compliance with federal laws, regulations, and program compliance requirements." Condition The College did not properly report student enrollment changes for students who received federal student aid to the National Student Loan Data System (NSLDS). Questioned costs: N/A Known Likely Context During our testing of 40 students, we identified ten instances for which the student’s enrollment status was not correctly reported to NSLDS in a timely manner and five instance where the enrollment effective date was not reported correctly to NSLDS. Cause The College did not have proper procedures in place to verify students status in NSLDS matched the institutions records in a timely manner. Effect Failure to properly report enrollment status changes on NSLDS could affect the timing of the grace period for repayment of Title IV loans. Additionally, the College was not in compliance with the requirements to properly report student enrollment data correctly or timely to NSLDS. Repeat Finding No Recommendation We recommend that the College implement procedures to ensure that enrollment data, changes in status and effective dates within NSLDS match the records of the institution and are reported timely. And we recommend that the College implement formal review procedures to document the review process. Views of Responsible Officials Management agrees with this finding.

Federal Agency U.S. Department of Education Federal Program Name Student Financial Assistance Cluster Assistance Listing Number 84.063, 84.007, 84.033, 84.268 Federal Award Identification Number and Year P063P232037 - 2024, P007A233429 - 2024, P033A233429 - 2024, P268K242037 - 2024 Pass-Through Agency (if applicable) N/A Pass-Through Number(s) (if applicable) N/A Award Period 7/1/23 - 6/30/24 Compliance Requirement Affected Special Tests and Provisions Type of Finding Internal Control Significant Deficiency Document judgment for your assessment The College used the incorrect withdraw date and incorrectly performed the Return of Title IV funds calculation Compliance Not Material Document judgment for your assessment Not greater than 5% and not a systemic failure. Criteria or specific requirement "34 CFR 668.21(a) states that the institution must return all title IV, HEA program funds that were credited to the student's account at the institution or disbursed directly to the student for the payment period. The institution must return those funds no later than 30 days after the date that the institution becomes aware that the student will not or has not begun attendance. Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements." Condition "The College incorrectly calculated Return to Title IV (R2T4) calculations. " Questioned costs: N/A Known Not over $25k Likely See Question Cost Tab Context During our testing of 40 R2T4 calculations, we identified that 5 had mechanically incorrect calculations by using the incorrect withdraw date. Cause The College was using the incorrect withdraw date Effect The College could return incorrect amounts based off of their calculations, which could effect student repayment amounts based off of amount earned. Repeat Finding No Recommendation We recommend that the College review policies and procedures related to R2T4 calculations to ensure calculations are performed correctly and timely. Views of Responsible Officials Management agrees with this finding.

Federal Agency U.S. Department of Education Federal Program Name Higher Educational Institutional Aid Assistance Listing Number 84.031X Federal Award Identification Number and Year " P031X220005 - 2024, P031X200005 - 2024, P031X230006 - 2024" Pass-Through Agency (if applicable) N/A Pass-Through Number(s) (if applicable) N/A Award Period 7/1/23 - 6/30/24 Compliance Requirement Affected Allowable Costs and Special Tests and Provisions Type of Finding Internal Control Significant Deficiency Document judgment for your assessment Control finding did not result in material questioned costs-therefore we will document as a SD. Additionally qualitatively failure did not have material impact on compliance. Compliance Not Material Document judgment for your assessment Not greater than 5% and not a systemic failure. Criteria or specific requirement "Per 2 CFR 200.430(g)(1)(vi), Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records should support the distribution of the employee's salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements." Condition The College did not have proper documentation of Time and Effort reporting. Questioned costs: N/A Known Likely Context During our testing of 40 Payroll transactions, we identified 8 time and effort reports that were not documented properly to track hours worked on federal grant and 12 reports that did not have a documentation of review. Additionally during our testing of 5 key personnel with Level of Effort provisions in the grant award notification, we identified 1 key personnel did not have documentation to track hours for level of effort required by the Federal agency. Cause The College did not have proper procedures in place to track time and effort for personnel on federal grants. Effect The College could potentially expense incorrect amount to federal grants. Repeat Finding No Recommendation "We recommend the College review policies and procedures to ensure all personnel on federal grants documented time and effort reports as stated in federal regulations. " Views of Responsible Officials Management agrees with this finding.

Federal Agency U.S. Department of Education Federal Program Name Higher Educational Institutional Aid Assistance Listing Number 84.031X Federal Award Identification Number and Year " P031X220005 - 2024, P031X230006 - 2024" Pass-Through Agency (if applicable) N/A Pass-Through Number(s) (if applicable) N/A Award Period 7/1/23 - 6/30/24 Compliance Requirement Affected Procurement Type of Finding Internal Control Significant Deficiency Document judgment for your assessment Control finding did not result in material questioned costs-therefore we will document as a SD. Additionally qualitatively failure did not have material impact on compliance. Compliance Not Material Document judgment for your assessment Not greater than 5% and not a systemic failure. Criteria or specific requirement "The Federal Government requires that all procurement transactions for the acquisition of property or services required under a Federal award must be conducted in a manner providing full and open competition consistent with the standards of 2 CFR section 200.320. In addition, per the Uniform Guidance CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements." Condition The College did not have documentation that sole source justification was provided during the procurement process. Questioned costs: N/A Known Likely Context During our testing of 5 procurement transactions, we identified 3 vendors that had sole source justifications however they were not dated to verify that the documentation was provided prior to entering the contract. Cause The College did not have proper documentation to support the procurement process was completed prior to purchase. Effect The College could not be in compliance with federal procurement regulations. Repeat Finding No Recommendation We recommend the College evaluate its procedures to ensure documentation is properly supported within their procurement files. Views of Responsible Officials Management agrees with this finding.

Criteria or Specific Requirement: The Gramm-Leach Bliley Act (GLBA) requires financial institutions to explain their information-sharing practices to their customers and to safeguard sensitive data (16 CFR 314). The regulation states that the college must designate a qualified individual responsible for overseeing and implementing your information security program and enforcing your information security program. (16 CFR 314.4(a)). The entity shall have a Written Information Security Program (WISP) that outlines the design and implementation of the risk assessment procedures. (16 CFR 314.4(b)). At a minimum, the institution’s written information security program must address the implementation of the minimum safeguards identified in 16 CFR 314.4(c)(1) through (8) including: Assess apps developed by the institution. In addition, the written security program provides for the institution to regularly test or otherwise monitor the effectiveness of the safeguards it has implemented (16 CFR 314.4(d)). Condition: The college was missing all the requirements from the Gramm-Leach-Bliley Act except for having a Written Information Security Program, approval by appropriate individual, implement and periodically review access controls, and proper disposal of customer information securely. These GLBA requirements were applicable beginning on June 9, 2023, and there were multiple elements missing from their Written Information Security Program. Context: The institution has been in compliance with previous iterations of GLBA compliance. The Written Information Security Program (WISP) which was required as of June 9, 2023 had missing elements. Some controls were in place whereas others were not. They did, however, have a WISP as of the deadline but it was missing some required information. Questioned Costs: N/A Cause: There was not a formal process in place to review against all the new GLBA requirements to ensure compliance.Effect: Student personal information could be vulnerable. Repeat Finding: No Recommendation: We recommend that the College review the updated GLBA requirements and ensure their Written Information Security Program (WISP) includes all required elements. Views of Responsible Officials: Management agrees with the finding and has developed a plan to correct the finding.

Criteria or Specific Requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations and program compliance requirements. Condition: The college did not have a formal review process, as the student financial aid director was both preparing and reviewing the calculation. Context: Out of the forty sampled calculations, all forty lacked evidence of a formal review. Questioned Costs: N/A Cause: Lack of formal review of last date of attendance for online students including Canvas activity logs. Effect: No formal review could allow errors in the calculation and errors in the timing of payments. Repeat Finding: No Recommendation: We recommend someone other than the preparer of Return of Title IV calculations review said calculations. Views of Responsible Officials: Management agrees with the finding and has developed a plan to correct the finding.

2022 ? 002 Federal Agency: U.S. Department of Education Federal Program Title: COVID-19 Education Stabilization Fund Assistance Listing Number: 84.425F ? HEERF Institutional Portion Award Period: July 1, 2021 to June 30, 2022 Type of Finding: ? Compliance, Other Matter ? Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Condition and context: During the testing of the Northeastern Oklahoma A&M annual HEERF report CLA observed there was no formal review process of quarterly or annual reports which resulted in the annual report Institutional Expenditures in sections 8a and 9b of the Annual report to be overstated by $2,017,325. Questioned costs: None Cause: Northeastern Oklahoma A&M did not have a formal review process in place to review the accuracy of HEERF reports for the year ended June 30, 2022. Effect: Overstatement of institutional expenditures in the Annual Report for the year ended June 30, 2022. Repeat finding: No Recommendation: We recommend the Northeastern Oklahoma A&M implement a formal review process over the HEERF reports. Views of responsible officials: There is no disagreement with the audit finding.

2022 ? 003 Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Aid Cluster Assistance Listing Number: 84.007, 84.038, 84.063, 84.268, 84.379, 84.033 Award Period: July 1, 2021 to June 30, 2022 Type of Finding: ? Compliance, Other Matter ? Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 685.309(b), states the school is required to report changes in the student?s enrollment status, the effective date of the status, and an anticipated completion date. Condition and context: Two exceptions were observed during return of Title IV fund (R2T4) testing for students who did not have documentation for their participation in online courses. One of these students had an incorrect last date of attendance as a result. Questioned costs: None Cause: Lack of formal review of last date of attendance for online students including Canvas activity logs. Effect: Incorrect last date of attendance used in Return of Title IV funds calculation which would result in incorrect refund amounts and incorrect withdrawal date reported to NSLDS. Repeat finding: No Recommendation: CLA recommends the institution review student activity logs in Canvas when determining an online student?s last date of attendance. View of responsible official: The University agrees with the finding.

2022 ? 004 Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Aid Cluster Assistance Listing Number: 84.007, 84.038, 84.063, 84.268, 84.379, 84.033 Award Period: July 1, 2021 to June 30, 2022 Type of Finding: ? Compliance, Other Matter ? Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 685.309(b), states the school is required to report changes in the student?s enrollment status, the effective date of the status, and an anticipated completion date. Condition and context: Twenty exceptions were observed during Enrollment Reporting testing. Among the twenty students, six students had the incorrect enrollment status reported to the NSLDS, two students did not have any records in NSLDS, eleven students? status enrollment changes were reported beyond the sixty-day allowable timeframe, and nine students has status dates that did not agree to the "Enrollment Effective Date" in NSLDS. Questioned costs: None Cause: At the campus, there is a process that is run by the registrar for unofficial withdrawals at the end of every semester that overrides the correct institutional last date of attendance with the last date of the semester. This incorrect date is then reported to the Clearinghouse and ultimately NSLDS. This also impacts transfer students who may have their enrollment status incorrectly reported by the automated process. Effect: NEO was not in compliance with the requirements to properly report student enrollment data correctly. Incorrect dates submitted to NSLDS may be used to determine the grace period for the repayment and interest of outstanding Title IV student loans. Repeat finding: Yes, see 2021-001 for the prior year finding. Recommendation: We recommend that the SFA department work with the campus registrar?s office to develop an alternative process that will enable the student financial aid office to review and correct the last dates of attendance and enrollment status prior to being reported to the Clearinghouse. View of responsible official: The University agrees with the finding.