Harding University, Inc.

UNTIMELY UPDATES TO STUDENT STATUSES IN NSLDS

As of August 2025, management has implemented controls to monitor student enrollment statuses and ensure the timeliness and accuracy of NSLDS reporting.

UNTIMELY RETURN OF TITLE IV FUNDS FOR UNOFFICIAL WITHDRAWAL

Management has implemented controls to ensure that all students receiving only failing grades ("all F") at the end of the semester are evaluated for potential R2T4 calculations.

UNTIMELY UPDATES TO STUDENT STATUSES IN NSLDS

As of August 2025, management has implemented controls to monitor student enrollment statuses and ensure the timeliness and accuracy of NSLDS reporting.

UNTIMELY RETURN OF TITLE IV FUNDS FOR UNOFFICIAL WITHDRAWAL

Management has implemented controls to ensure that all students receiving only failing grades ("all F") at the end of the semester are evaluated for potential R2T4 calculations.

UNTIMELY RETURN OF TITLE IV FUNDS FOR UNOFFICIAL WITHDRAWAL

Management has implemented controls to ensure that all students receiving only failing grades ("all F") at the end of the semester are evaluated for potential R2T4 calculations.

SECTION III ? FEDERAL AWARDS FINDINGS AND QUESTIONED COSTS Finding 2021-1 ? Special Tests and Provisions: Enrollment Reporting Federal Program ?Federal Perkins Loans, Federal Pell Grant, Federal Direct Student Loans CFDA Number ? 84.038, 84.063, 84.268 Federal Agency ? U.S. Department of Education Federal Award Year ? June 30, 2021 Criteria Enrollment reporting is required by Title 34 CFR Section 685.309 for all schools that participate in Title IV aid. These regulations require that schools report information requested by the Department in a timeframe specified by the Department. Enrollment information must be reported within 30 days whenever attendance changes for students, unless the University is expected to submit its next updated enrollment roster report within the next 60 days. Condition Out of a sample of 40 students with enrollment status changes during the audit period, 1 student had a status change that was not reported to the National Student Loan Data System (NSLDS) within the required timeframe. Questioned Costs None Cause This instance of noncompliance was due to a flaw in the process of reporting graduations for a certain small subset of students. Controls in the review process of the of the enrollment status information submitted to NSLDS via the National Student Loan Clearinghouse (NSLC) need improvement. Effect Timely and accurate enrollment reporting is critical for effective management of the Federal Direct Loan program. The collection of enrollment data allows the Department to ensure that loan interest subsidies are based on accurate enrollment information, loan repayment dates are accurate, as well as determining eligibility for a school status, deferment, and grace periods. Recommendation The University Registrar corrected the graduation date in NSLDS subsequent to audit field work. Controls for reporting should be enhanced to ensure student status changes are reported accurately and transmitted within the appropriate timeframe. Subsequent verification and review with NSLDS records should be implemented for all enrollment status changes. Management?s Response The University concurs with our comments and has implemented procedures to ensure that all student enrollment status changes are reported timely and accurately. See attached corrective action plan. ECTION III ? FEDERAL AWARDS FINDINGS AND QUESTIONED COSTS

1. Auditors' findings alerted us to the fact that a student (---name removed---) who graduated from the Harding School of Theology on the Memphis Campus had not been reported to the National Student Clearinghouse as "graduated". He had continued to be reported to NSC as an enrolled student when in fact he was not. 2. The Registrar's Office discovered that the Memphis campus did not award the student's degree at the same time the Searcy campus was doing so. The Searcy campus conferred degrees, and then the NSC graduation repo1i for Spring 2021 was submitted. Because (name removed)' s degree was conferred after the NSC graduation report was submitted, his graduation status was not captured in that data. 3. Upon being made aware of the error, the Registrar on the Main Campus (Searcy) submitted a manual adjustment in Clearinghouse to reflect (name removed)'s actual graduation date. 4. The Registrar's Office in Searcy and the Memphis campus for the School of Theology have agreed to coordinate their degree conferral dates, and will be awarding degrees on the same day going forward. The Institutional Research Office on the Main Campus is also aware of this, and has agreed to submit the graduation report only after receiving clearance from both the Main Campus and Memphis campus that all degrees for that term have been awarded.

GSA_MIGRATION

GSA_MIGRATION