University of Holy CrossNon-Profit

Criteria: In accordance with the U.S. Department of Education’s regulations, awards must be coordinated among the various Title IV programs and with other federal and nonfederal aid (need and non-need based aid) to ensure that total aid awarded is not in excess of the student’s financial need or cost of attendance (“COA”) (34 CFR 668.42, FWS, and FSEOG, 34 CFR 673.5 and 673.6; Direct Loan, 34 CFR 685.301). The determination of need-based student financial aid award amounts is based on financial need. Financial need is defined as the student’s COA minus the student’s student aid index (“SAI”) and other financial assistance. An overaward exists when a student’s financial aid exceeds the student’s need. Universe / Population: The universe / population for Eligibility is 567 student financial aid award recipients for the year ended June 30, 2025. We selected 60 student financial aid award recipients for testing of eligibility compliance requirements applicable to the program. Condition: In our sample of 60 student financial aid award recipients, we identified 1 incidence in which the student received a direct subsidized loan in excess of their financial need as determined by the institution’s COA calculation and the student’s SAI. The student’s total aid package exceeded the allowable financial need by $4,948. Cause: After the University’s initial financial need calculation was completed, the student received a scholarship that reduced their financial need. The University failed to properly update the student’s COA and/or other estimated financial assistance before disbursing the direct subsidized loan funds. Effect: Awarding aid in excess of a student's financial need results in noncompliance with federal regulations governing Title IV programs. The institution may be required to return the overawarded portion of direct subsidized loan funds to the U.S. Department of Education. Continued noncompliance may increase the risk of federal sanctions or additional oversight. Questioned Costs: $4,948 Repeat Finding: No Recommendation: We recommend that management strengthen controls over the financial aid awarding process, including implementing a more robust review of COA, SAI, and other estimated financial assistance prior to finalizing loan disbursements in order to not overaward financial assistance to students.

2022-001 Special Reporting U.S. Department of Education 84.425E, 84.425F, 84.425M COVID-19 - Higher Education Emergency Relief Fund (HEERF 2021-2022 Award Year Questioned Costs: None Criteria: The U.S. Department of Education sets the criteria for HEERF Annual Performance Reports (APRs). This report is due annually from HEERF grantees. Annual Reports must be submitted and reviewed within a certain timeframe set by the U.S. Department of Education. Universe / Population: The universe / population is one Annual Report submitted during the fiscal year ended June 30, 2022. P&N selected the one Annual Report for testing of reporting compliance requirements applicable to the program. Condition: The University did not submit the January 1, 2021 through December 31, 2021 Annual Report by the grantee submission deadline. The annual report had a submission deadline of May 6, 2022 and was submitted on May 11, 2022. Cause: The University lacks an established control monitoring timely submission of Annual Reports. Effect: Failure to comply with the reporting requirements may result in sanctions, including: losing access to HEERF grant funds as a result of the grantee?s noncompliance with its reporting requirements as specified by their HEERF Certification and Agreement or Supplemental Agreement. Recommendation: The University should establish a formalized control to monitor timely submission of Annual Reports. Repeat finding: No.

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