RANDALL UNIVERSITY

EIN: 730074245

UEI: LLLHD5T56F25

Data as of August 25, 2026

RANDALL UNIVERSITY2 audit years15 findings3 repeat
2
Audit Years
15
Total Findings
3
Repeat Findings

FY 2025-06-30

Management decision deadline — for entities that funded this organization

The FAC accepted this audit on February 9, 2026. Under 2 CFR 200.521(d), a pass-through entity that provided federal funds to this organization for this audit period must issue a management decision on these findings by August 9, 2026 (16 days ago).

What is a management decision? →
2025-001
Other
MATERIAL WEAKNESSREPEAT

Condition Found: During our audit, we noted the following: • Adjustments were necessary for accounts receivable, bad debt, scholarships, deferred revenue and depreciation, and for assets held for sale. Criteria: The design and implementation of policies and procedures in place should be sufficient enough for the reconciliation of significant financial accounts and transaction classes to prevent and detect material misstatements in the financial statements. Cause: The University currently does not have a strong process for making sure the ending balances are correct before providing the trial balance for audit. Possible Asserted Effect: In fiscal year 2025, we proposed adjustments to accounts such as accounts receivable, assets held for sale, and various income and expense items. Repeat Finding: See Finding 2024-001 for a similar finding in the prior year. Recommendation: We recommend that the University put in place necessary controls and procedures to ensure that all transactions are properly classified. Management Response: Randall University will put processes in place to adjust accounts to the actual balance before the audit begins.

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Full finding narrative

Condition Found: During our audit, we noted the following: • Adjustments were necessary for accounts receivable, bad debt, scholarships, deferred revenue and depreciation, and for assets held for sale. Criteria: The design and implementation of policies and procedures in place should be sufficient enough for the reconciliation of significant financial accounts and transaction classes to prevent and detect material misstatements in the financial statements. Cause: The University currently does not have a strong process for making sure the ending balances are correct before providing the trial balance for audit. Possible Asserted Effect: In fiscal year 2025, we proposed adjustments to accounts such as accounts receivable, assets held for sale, and various income and expense items. Repeat Finding: See Finding 2024-001 for a similar finding in the prior year. Recommendation: We recommend that the University put in place necessary controls and procedures to ensure that all transactions are properly classified. Management Response: Randall University will put processes in place to adjust accounts to the actual balance before the audit begins.

Corrective Action Plan

FINDING 2025-001 – Financial Close and Reporting Condition Found: During our audit, we noted the following: • Adjustments were necessary for accounts receivable, bad debt, scholarships, deferred revenue and depreciation, and for assets held for sale. Corrective Action Plan: The University will put processes in place to adjust accounts to the actual balance before the audit begins. Anticipated Completion Date: The corrective action will be completed by June 30, 2026. Contact Person: Tim Van Horn, Chief Financial Officer 405-200-5311

Prior Finding References

2024-001

About Other →
2025-002
Special Tests & Provisions / Other

Federal Agency: U.S. Department of Education; Office of Federal Student Aid Pass through Entity: Not applicable Program Name: Federal Direct Loan Program ALN and Program Expenditures: 84.268 ($866,312) Award Number: P268K253315 Federal Award Year: July 1, 2024 to June 30, 2025 Questioned Costs: N/A Condition Found: Six of the seventeen federal student financial aid recipients in our sample did not complete or were not sent exit interview instructions to complete within thirty days of the student ceasing to be enrolled in the University at least half-time. Criteria: An exit interview should be completed or mailed to a student to complete within thirty days from when a student withdraws, graduates from school, or is enrolled less than half-time for Federal Direct Loans or TEACH Grant. Cause: This requirement was overlooked by the interim Financial Aid Director. Possible Asserted Effect: The students were unaware of the loan repayment responsibilities at the time the students withdrew from the University. Repeat Finding: There was not a similar finding in the prior year. Statistical Sampling: The sample was not intended to be, and was not, a statistically valid sample. Recommendation: An exit interview and instructions should be mailed to the home address of the student in question. Management Response: A new Financial Aid Director was hired in July 2025. The Financial Aid Director will review the students in question to determine if exit instructions were sent after the thirty-day time period. If an exit interview has not already been sent, the Financial Aid will mail exit interview instructions to the students’ home address. In addition, the Director of Financial Aid will work with the third-party administrator to determine which entity is responsible for sending exit interview information to students.

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Full finding narrative

Federal Agency: U.S. Department of Education; Office of Federal Student Aid Pass through Entity: Not applicable Program Name: Federal Direct Loan Program ALN and Program Expenditures: 84.268 ($866,312) Award Number: P268K253315 Federal Award Year: July 1, 2024 to June 30, 2025 Questioned Costs: N/A Condition Found: Six of the seventeen federal student financial aid recipients in our sample did not complete or were not sent exit interview instructions to complete within thirty days of the student ceasing to be enrolled in the University at least half-time. Criteria: An exit interview should be completed or mailed to a student to complete within thirty days from when a student withdraws, graduates from school, or is enrolled less than half-time for Federal Direct Loans or TEACH Grant. Cause: This requirement was overlooked by the interim Financial Aid Director. Possible Asserted Effect: The students were unaware of the loan repayment responsibilities at the time the students withdrew from the University. Repeat Finding: There was not a similar finding in the prior year. Statistical Sampling: The sample was not intended to be, and was not, a statistically valid sample. Recommendation: An exit interview and instructions should be mailed to the home address of the student in question. Management Response: A new Financial Aid Director was hired in July 2025. The Financial Aid Director will review the students in question to determine if exit instructions were sent after the thirty-day time period. If an exit interview has not already been sent, the Financial Aid will mail exit interview instructions to the students’ home address. In addition, the Director of Financial Aid will work with the third-party administrator to determine which entity is responsible for sending exit interview information to students.

Corrective Action Plan

FINDING 2025-002 – Exit Interview Program Name: Federal Direct Loan Program ALN and Program Expenditures: 84.268 ($866,312) Award Number: P268K253315 Federal Award Year: July 1, 2024 to June 30, 2025 Questioned Costs: N/A Condition Found: Six of the seventeen federal student financial aid recipients in our sample did not complete or were not sent exit interview instructions to complete within thirty days of the student ceasing to be enrolled in the University at least half-time. Corrective Action Plan: A new Financial Aid Director was hired in July 2025. The Financial Aid Director will review the students in question to determine if exit instructions were sent after the thirty-day time period. If an exit interview has not already been sent, the Financial Aid will mail exit interview instructions to the students’ home address. In addition, the Director of Financial Aid will work with the third-party administrator to determine which entity is responsible for sending exit interview information to students. Anticipated Completion Date: The University anticipates the corrective action being completed by March 31, 2026. Contact Person: Brad Burnett, Director of Financial Aid 405-912-9000

About Special Tests and Provisions, Other →
2025-003
Cash Management / Other

Federal Agency: U.S. Department of Education; Office of Federal Student Aid Pass through Entity: Not applicable Program Name: Federal Direct Student Loan Program Federal Pell Grant Program ALN and Program Expenditures: 84.268 ($866,312) 84.063 ($509,088) Award Number: P268K253315 P063P243315 Federal Award Year: July 1, 2024 to June 30, 2025 Questioned Costs: N/A Condition Found: The University was placed on the Heightened Cash Monitoring Method 2 (“HCM2”) for disbursing aid in May 2023. In the current fiscal year, a Title IV Credit Balance was held for more than 14 days for one of the seventeen students in our sample. Criteria: One of the requirements of HCM2 is that an institution cannot hold credit balances even with the student’s authorization. An institution must disburse aid and return all credit balances created by Title IV funds before requesting reimbursement from the U.S. Department of Education. Cause: This credit balance was overlooked by the business office and Bursar when issuing Title IV credit balance refunds. Possible Asserted Effect: The Title IV Credit Balance was not returned timely as required by Institution being placed on the HCM2 method of disbursing aid. Repeat Finding: There was not a similar finding for the year ended June 30, 2024. Statistical Sampling: The sample was not intended to be, and was not, a statistically valid sample. Recommendation: There is no longer a credit balance on the account of the student in question. The business office should review student accounts to determine if any additional credit balances should be refunded. Procedures should be improved to ensure the University is following the HCM2 regulations. Management Response: There is no longer a credit balance on the account of the student in question. If time allows, the business office will review student accounts to determine if any additional credit balances should be refunded. Procedures should be improved to ensure the University is following the HCM2 regulations.

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Full finding narrative

Federal Agency: U.S. Department of Education; Office of Federal Student Aid Pass through Entity: Not applicable Program Name: Federal Direct Student Loan Program Federal Pell Grant Program ALN and Program Expenditures: 84.268 ($866,312) 84.063 ($509,088) Award Number: P268K253315 P063P243315 Federal Award Year: July 1, 2024 to June 30, 2025 Questioned Costs: N/A Condition Found: The University was placed on the Heightened Cash Monitoring Method 2 (“HCM2”) for disbursing aid in May 2023. In the current fiscal year, a Title IV Credit Balance was held for more than 14 days for one of the seventeen students in our sample. Criteria: One of the requirements of HCM2 is that an institution cannot hold credit balances even with the student’s authorization. An institution must disburse aid and return all credit balances created by Title IV funds before requesting reimbursement from the U.S. Department of Education. Cause: This credit balance was overlooked by the business office and Bursar when issuing Title IV credit balance refunds. Possible Asserted Effect: The Title IV Credit Balance was not returned timely as required by Institution being placed on the HCM2 method of disbursing aid. Repeat Finding: There was not a similar finding for the year ended June 30, 2024. Statistical Sampling: The sample was not intended to be, and was not, a statistically valid sample. Recommendation: There is no longer a credit balance on the account of the student in question. The business office should review student accounts to determine if any additional credit balances should be refunded. Procedures should be improved to ensure the University is following the HCM2 regulations. Management Response: There is no longer a credit balance on the account of the student in question. If time allows, the business office will review student accounts to determine if any additional credit balances should be refunded. Procedures should be improved to ensure the University is following the HCM2 regulations.

Corrective Action Plan

84.063 ($509,088) Award Number: P268K253315 P063P243315 Federal Award Year: July 1, 2024 to June 30, 2025 Questioned Costs: N/A Condition Found: The University was placed on the Heightened Cash Monitoring Method 2 (“HCM2”) for disbursing aid in May 2023. In the current fiscal year, a Title IV Credit Balance was held for more than 14 days for one of the seventeen students in our sample. Corrective Action Plan: There is no longer a credit balance on the account of the student in question. If time allows, the business office will review student accounts to determine if any additional credit balances should be refunded. Procedures should be improved to ensure the University is following the HCM2 regulations. Anticipated Completion Date: The University anticipates the corrective action being completed by March 31, 2026. Contact Person: Brad Burnett, Director of Financial Aid 405-912-9000

About Cash Management, Other →
2025-004
Other
MATERIAL WEAKNESS

Federal Agency: U.S. Department of Education; Office of Federal Student Aid Pass through Entity: Not applicable Program Name: Federal Direct Student Loan Program Federal Pell Grant Program Federal Supplemental Educational Opportunity Grant ALN and Program Expenditures: 84.268 ($866,312) 84.063 ($509,088) 84.007 ($ 5,400) Award Number: P268K253315 P063P243115 P007A243421 Federal Award Year: July 1, 2024 to June 30, 2025 Questioned Costs: Undetermined Condition Found: The University lacked policies and procedures to reconcile the SEFA data to the financial statements or other supporting documentation. The University was on the HCM2 method of payment and could not provide of the listing by student of the aid requested. During the audit, we were unable to reconcile the Amount Due from the Government on the Financial Statement to the amount due per the financial aid records. In addition, aid was posted to student accounts and never requested from the government for five of the seventeen students in our sample. Criteria: The design and implementation of policies and procedures in place should be sufficient enough for the reconciliation of significant financial accounts and transaction classes to prevent and detect material misstatements in the statement of expenditures of federal awards. There also should be policies and procedures in place to ensure that the amounts posted to individual student accounts and student account balances are accurate. Cause: There was turnover in the financial aid office and at the bursar position. In addition, the University did not have adequate policies and procedures in place. Possible Asserted Effect: The amounts on the SEFA were not able to be reconciled to the financial statements or other supporting documentation. In addition, the University could not provide various forms of documentation requested to attempt to reconcile the amounts. Finally, the following five students had errors on their accounts: For the first student, $28,215 of Federal Plus Loans were posted to the student account. These funds have not been requested from the Department of Education as of November 2025. The loans are not showing in COD or NSLDS. The University is still investigating this account. For the second student, $3,772 of TEACH Grant funds were posted to the student’s account and never requested from the Department of Education. The University could not determine if the student was eligible for TEACH Grant Funds. In December 2025, the funds were replaced with an institutional scholarship. For the third student, the fall Pell award was posted to the student’s account twice. $3,698 of Federal Pell Grant funds were returned in December 2025. For the fourth student, $3,698 of Federal Pell Grant funds were posted to the student’s account for a semester when the student was not enrolled. The funds were removed from the student’s account in December 2025. Since the University was on the HCM2 disbursement method, the funds had not been received from the Department of Education. For the fifth student, $4,587 of Federal Plus Loans were posted to the student’s account. These funds have not been requested from the Department of Education as of November 2025. The loans are also not showing in NSLDS or COD. The University is still investigating this account. Repeat Finding: There was not a similar finding in the prior year.Statistical Sampling: The sample was not intended to be, and was not, a statistically valid sample. Recommendation: We recommend the University reconcile the aid posted to students’ accounts to the aid that has been requested from the Department of Education to determine if funds have been posted to student accounts incorrectly or if additional aid should be requested. Procedures should be improved to reconcile the SEFA amounts to the financial statements. Supporting documentation for Title IV funds requested should be kept. Management Response: The bursar, business office staff, and financial aid staff will work together to review and reconcile Title IV posted to the student accounts to the amounts requested from the Department of Education. When discrepancies are found, the University staff will investigate and determine if the student was eligible for aid and request additional funds as necessary. See the possible effect section for the resolution of the students in this finding.

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Full finding narrative

Federal Agency: U.S. Department of Education; Office of Federal Student Aid Pass through Entity: Not applicable Program Name: Federal Direct Student Loan Program Federal Pell Grant Program Federal Supplemental Educational Opportunity Grant ALN and Program Expenditures: 84.268 ($866,312) 84.063 ($509,088) 84.007 ($ 5,400) Award Number: P268K253315 P063P243115 P007A243421 Federal Award Year: July 1, 2024 to June 30, 2025 Questioned Costs: Undetermined Condition Found: The University lacked policies and procedures to reconcile the SEFA data to the financial statements or other supporting documentation. The University was on the HCM2 method of payment and could not provide of the listing by student of the aid requested. During the audit, we were unable to reconcile the Amount Due from the Government on the Financial Statement to the amount due per the financial aid records. In addition, aid was posted to student accounts and never requested from the government for five of the seventeen students in our sample. Criteria: The design and implementation of policies and procedures in place should be sufficient enough for the reconciliation of significant financial accounts and transaction classes to prevent and detect material misstatements in the statement of expenditures of federal awards. There also should be policies and procedures in place to ensure that the amounts posted to individual student accounts and student account balances are accurate. Cause: There was turnover in the financial aid office and at the bursar position. In addition, the University did not have adequate policies and procedures in place. Possible Asserted Effect: The amounts on the SEFA were not able to be reconciled to the financial statements or other supporting documentation. In addition, the University could not provide various forms of documentation requested to attempt to reconcile the amounts. Finally, the following five students had errors on their accounts: For the first student, $28,215 of Federal Plus Loans were posted to the student account. These funds have not been requested from the Department of Education as of November 2025. The loans are not showing in COD or NSLDS. The University is still investigating this account. For the second student, $3,772 of TEACH Grant funds were posted to the student’s account and never requested from the Department of Education. The University could not determine if the student was eligible for TEACH Grant Funds. In December 2025, the funds were replaced with an institutional scholarship. For the third student, the fall Pell award was posted to the student’s account twice. $3,698 of Federal Pell Grant funds were returned in December 2025. For the fourth student, $3,698 of Federal Pell Grant funds were posted to the student’s account for a semester when the student was not enrolled. The funds were removed from the student’s account in December 2025. Since the University was on the HCM2 disbursement method, the funds had not been received from the Department of Education. For the fifth student, $4,587 of Federal Plus Loans were posted to the student’s account. These funds have not been requested from the Department of Education as of November 2025. The loans are also not showing in NSLDS or COD. The University is still investigating this account. Repeat Finding: There was not a similar finding in the prior year.Statistical Sampling: The sample was not intended to be, and was not, a statistically valid sample. Recommendation: We recommend the University reconcile the aid posted to students’ accounts to the aid that has been requested from the Department of Education to determine if funds have been posted to student accounts incorrectly or if additional aid should be requested. Procedures should be improved to reconcile the SEFA amounts to the financial statements. Supporting documentation for Title IV funds requested should be kept. Management Response: The bursar, business office staff, and financial aid staff will work together to review and reconcile Title IV posted to the student accounts to the amounts requested from the Department of Education. When discrepancies are found, the University staff will investigate and determine if the student was eligible for aid and request additional funds as necessary. See the possible effect section for the resolution of the students in this finding.

Corrective Action Plan

FINDING 2025-004– Reporting/Internal Control Over the SEFA Program Name: Federal Direct Student Loan Program Federal Pell Grant Program Federal Supplemental Educational Opportunity Grant ALN and Program Expenditures: 84.268 ($866,312) 84.063 ($509,088) 84.007 ($ 5,400) Award Number: P268K253315 P063P243115 P007A243421 Federal Award Year: July 1, 2024 to June 30, 2025 Questioned Costs: Undetermined Condition Found: The University lacked policies and procedures to reconcile the SEFA data to the financial statements or other supporting documentation. The University was on the HCM2 method of payment and could not provide of the listing by student of the aid requested. During the audit, we were unable to reconcile the Amount Due from the Government on the Financial Statement to the amount due per the financial aid records. In addition, aid was posted to student accounts and never requested from the government for five of the seventeen students in our sample. Corrective Action Plan: The bursar, business office staff, and financial aid staff will work together to review and reconcile Title IV posted to the student accounts to the amounts requested from the Department of Education. When discrepancies are found, the University staff will investigate and determine if the student was eligible for aid and request additional funds as necessary. See the possible effect section for the resolution of the students in this finding. Anticipated Completion Date: The University anticipates the corrective action being completed by June 30, 2026. Contact Person: Brad Burnett, Director of Financial Aid 405-912-9000

About Other →
2025-005
Reporting

Federal Agency: U.S. Department of Education; Office of Federal Student Aid Pass through Entity: Not applicable Program Name: Federal Direct Student Loan Program ALN and Program Expenditures: 84.268 ($866,312) Award Number: P268K253315 Federal Award Year: July 1, 2024 to June 30, 2025 Questioned Costs: N/A Condition Found: During our compliance testing, student enrollment status changes were reported to the National Student Loan Database System (“NSLDS”) timely for nine of the seventeen students selected for testing. Criteria: Student enrollment status changes must be reported to NSLDS within sixty days of the enrollment status change. Cause: There was an interim financial aid director during the fiscal year. There was confusion about whose responsibility it was to update enrollment status in NSLDS. Possible Asserted Effect: Loan servicers were not informed of the students’ enrollment status changes timely. Thus, the servicers did not know when repayment should begin. Repeat Finding: There was not a similar finding in the prior year. Statistical Sampling: The sample was not intended to be, and was not, a statistically valid sample. Recommendation: The Student Financial Aid Director and Registrar should work together to make sure NSLDS is updated timely and accurately. Management Response: A new Student Financial Aid Director was hired in July 2025. The Student Financial Aid Director and Registrar will work together to determine and report student enrollment status changes within the required timeframe to NSLDS.

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Full finding narrative

Federal Agency: U.S. Department of Education; Office of Federal Student Aid Pass through Entity: Not applicable Program Name: Federal Direct Student Loan Program ALN and Program Expenditures: 84.268 ($866,312) Award Number: P268K253315 Federal Award Year: July 1, 2024 to June 30, 2025 Questioned Costs: N/A Condition Found: During our compliance testing, student enrollment status changes were reported to the National Student Loan Database System (“NSLDS”) timely for nine of the seventeen students selected for testing. Criteria: Student enrollment status changes must be reported to NSLDS within sixty days of the enrollment status change. Cause: There was an interim financial aid director during the fiscal year. There was confusion about whose responsibility it was to update enrollment status in NSLDS. Possible Asserted Effect: Loan servicers were not informed of the students’ enrollment status changes timely. Thus, the servicers did not know when repayment should begin. Repeat Finding: There was not a similar finding in the prior year. Statistical Sampling: The sample was not intended to be, and was not, a statistically valid sample. Recommendation: The Student Financial Aid Director and Registrar should work together to make sure NSLDS is updated timely and accurately. Management Response: A new Student Financial Aid Director was hired in July 2025. The Student Financial Aid Director and Registrar will work together to determine and report student enrollment status changes within the required timeframe to NSLDS.

Corrective Action Plan

FINDING 2025-005– NSLDS Reporting Program Name: Federal Direct Student Loan Program ALN and Program Expenditures: 84.268 ($866,312) Award Number: P268K253315 Federal Award Year: July 1, 2024 to June 30, 2025 Questioned Costs: N/A Condition Found: During our compliance testing, student enrollment status changes were reported to the National Student Loan Database System (“NSLDS”) timely for nine of the seventeen students selected for testing. Corrective Action Plan: A new Student Financial Aid Director was hired in July 2025. The Student Financial Aid Director and Registrar will work together to determine and report student enrollment status changes within the required timeframe to NSLDS. Anticipated Completion Date: The University anticipates the corrective action being completed by March 31, 2026. Contact Person: Brad Burnett, Director of Financial Aid 405-912-9000

About Reporting →
2025-006
Eligibility
REPEATQUESTIONED COSTS

Federal Agency: U.S. Department of Education; Office of Federal Student Aid Pass through Entity: Not applicable Program Name: Federal Direct Student Loan Program ALN and Program Expenditures: 84.268 ($866,312) Award Number: P268K253315 Federal Award Year: July 1, 2024 to June 30, 2025 Questioned Costs: $484, net Condition Found: The amount of subsidized Federal Direct Loans awarded was incorrect for four of the ten students in our sample that received Federal Direct Loans. In addition, the two of the students was eligible for additional Federal Direct Loan funds. Criteria: The annual subsidized Federal Direct Loan limit is $3,500 for freshmen, $4,500 for sophomores, and $5,500 for juniors and seniors. For students who are considered independent for financial aid purposes the amount of unsubsidized Federal Direct loans are $6,000 for freshman and sophomores, and $7,000 for junior and seniors. In addition, if a student is only enrolled in an associate’s degree program, the maximum subsidized loan amount the student can receive is $4,500. Cause: Two of the students had several transfer credits that were not considered when determining the grade-level of the student for Federal Direct Loan awarding purposes. One student was enrolled in an associate’s degree program and the degree program was not reviewed before awarding aid. The fourth student’s needs analysis was not reviewed before determining the amount subsidized funds the student was eligible to receive. Possible Asserted Effect: The first student was correctly awarded $5,500 in subsidized funds by the financial office. The third-party administrator changed this amount to $4,500 because the transfer credits were not considered when determining loan eligibility. The second student was correctly awarded $5,500 of subsidized loan per the student award letter. The COD also shows that $5,500 of subsidized loan funds were disbursed to the student. However, only $4,500 of subsidized loan funds were posted to the student’s account. The third student was awarded subsidized loans at the junior level while the student was only eligible for sophomore level subsidized loans. The student received $484 of subsidized loan funds that the student was ineligible to receive. The fourth student was awarded $1,732 in subsidized loans when the student was only eligible for unsubsidized loans. Repeat Finding: See Finding 2024-003 for a similar finding in the prior year. Statistical Sampling: The sample was not intended to be, and was not, a statistically valid sample. Recommendation: For the first student, the Financial Aid Director should determine the correct amount of loans the student was eligible to receive. If the student was eligible for $5,500 in subsidized loans, an additional $1,000 should be requested from the Department of Education For the second student, the Financial Aid Director should work with business office to reconcile student accounts. $1,000 of aid that was disbursed per COD has not been posted to the student’s account. If the student was only eligible for $4,500 in subsidized loans, $1,000 of institutional funds should be returned to the Department of Education on the student’s behalf. For the third student, $484 of Federal Direct Loan funds were returned in December 2025. For the fourth student, $1,732 of subsidized loans should be reclassified as unsubsidized loans.Management Response: For the first student, the student was eligible to receive $5,500 of subsidized funds, but only $4,500 was requested. The University gave the student an additional $1,000 of institutional funds to cover the difference in the amount the student was eligible to receive and the amount requested from the Department of Education in December 2025. For the second student, the COD correctly shows the that $5,500 of subsidized aid was disbursed to the student. However, only $4,500 of subsidized loan funds were posted to the student’s account. An institutional scholarship of $1,000 was posted to the student account in December 2025. For the third student, $484 of subsidized loan funds were returned to the Department of Education in December 2025. For the fourth student, the Director of Financial Aid will work with third party administrator to reclassify the subsidized loan funds as unsubsidized loan funds.

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Full finding narrative

Federal Agency: U.S. Department of Education; Office of Federal Student Aid Pass through Entity: Not applicable Program Name: Federal Direct Student Loan Program ALN and Program Expenditures: 84.268 ($866,312) Award Number: P268K253315 Federal Award Year: July 1, 2024 to June 30, 2025 Questioned Costs: $484, net Condition Found: The amount of subsidized Federal Direct Loans awarded was incorrect for four of the ten students in our sample that received Federal Direct Loans. In addition, the two of the students was eligible for additional Federal Direct Loan funds. Criteria: The annual subsidized Federal Direct Loan limit is $3,500 for freshmen, $4,500 for sophomores, and $5,500 for juniors and seniors. For students who are considered independent for financial aid purposes the amount of unsubsidized Federal Direct loans are $6,000 for freshman and sophomores, and $7,000 for junior and seniors. In addition, if a student is only enrolled in an associate’s degree program, the maximum subsidized loan amount the student can receive is $4,500. Cause: Two of the students had several transfer credits that were not considered when determining the grade-level of the student for Federal Direct Loan awarding purposes. One student was enrolled in an associate’s degree program and the degree program was not reviewed before awarding aid. The fourth student’s needs analysis was not reviewed before determining the amount subsidized funds the student was eligible to receive. Possible Asserted Effect: The first student was correctly awarded $5,500 in subsidized funds by the financial office. The third-party administrator changed this amount to $4,500 because the transfer credits were not considered when determining loan eligibility. The second student was correctly awarded $5,500 of subsidized loan per the student award letter. The COD also shows that $5,500 of subsidized loan funds were disbursed to the student. However, only $4,500 of subsidized loan funds were posted to the student’s account. The third student was awarded subsidized loans at the junior level while the student was only eligible for sophomore level subsidized loans. The student received $484 of subsidized loan funds that the student was ineligible to receive. The fourth student was awarded $1,732 in subsidized loans when the student was only eligible for unsubsidized loans. Repeat Finding: See Finding 2024-003 for a similar finding in the prior year. Statistical Sampling: The sample was not intended to be, and was not, a statistically valid sample. Recommendation: For the first student, the Financial Aid Director should determine the correct amount of loans the student was eligible to receive. If the student was eligible for $5,500 in subsidized loans, an additional $1,000 should be requested from the Department of Education For the second student, the Financial Aid Director should work with business office to reconcile student accounts. $1,000 of aid that was disbursed per COD has not been posted to the student’s account. If the student was only eligible for $4,500 in subsidized loans, $1,000 of institutional funds should be returned to the Department of Education on the student’s behalf. For the third student, $484 of Federal Direct Loan funds were returned in December 2025. For the fourth student, $1,732 of subsidized loans should be reclassified as unsubsidized loans.Management Response: For the first student, the student was eligible to receive $5,500 of subsidized funds, but only $4,500 was requested. The University gave the student an additional $1,000 of institutional funds to cover the difference in the amount the student was eligible to receive and the amount requested from the Department of Education in December 2025. For the second student, the COD correctly shows the that $5,500 of subsidized aid was disbursed to the student. However, only $4,500 of subsidized loan funds were posted to the student’s account. An institutional scholarship of $1,000 was posted to the student account in December 2025. For the third student, $484 of subsidized loan funds were returned to the Department of Education in December 2025. For the fourth student, the Director of Financial Aid will work with third party administrator to reclassify the subsidized loan funds as unsubsidized loan funds.

Corrective Action Plan

FINDING 2025-006 – Federal Direct Loan Eligibility Program Name: Federal Direct Student Loan Program ALN and Program Expenditures: 84.268 ($866,312) Award Number: P268K253315 Federal Award Year: July 1, 2024 to June 30, 2025 Questioned Costs: $484, net Condition Found: The amount of subsidized Federal Direct Loans awarded was incorrect for four of the ten students in our sample that received Federal Direct Loans. In addition, the two of the students was eligible for additional Federal Direct Loan funds. Corrective Action Plan: For the first student, the student was eligible to receive $5,500 of subsidized funds, but only $4,500 was requested. The University gave the student an additional $1,000 of institutional funds to cover the difference in the amount the student was eligible to receive and the amount requested from the Department of Education in December 2025. For the second student, the COD correctly shows the that $5,500 of subsidized aid was disbursed to the student. However, only $4,500 of subsidized loan funds were posted to the student’s account. An institutional scholarship of $1,000 was posted to the student account in December 2025. For the third student, $484 of subsidized loan funds were returned to the Department of Education in December 2025. For the fourth student, the Director of Financial Aid will work with third party administrator to reclassify the subsidized loan funds as unsubsidized loan funds. Anticipated Completion Date: The University anticipates the corrective action being completed by March 31, 2026. Contact Person: Brad Burnett, Director of Financial Aid 405-912-9000

Prior Finding References

2024-003

About Eligibility →
2025-007
Reporting

Federal Agency: U.S. Department of Education; Office of Federal Student Aid Pass through Entity: Not applicable Program Name: Federal Pell Grant Program ALN and Program Expenditures: 84.063 ($509,088) Award Number: P063P243315 Federal Award Year: July 1, 2024 to June 30, 2025 Questioned Costs: N/A Condition Found: The Common Origination and Disbursement System (“COD”) disbursement date did not agree with the disbursement date on the students’ accounts for one of the seventeen students in our compliance testing sample. Criteria: The disbursement date to be reported to the COD is the date that the institution credits funds to a student’s account or pays funds to a student or parent directly. Cause: This was an oversight of the business and financial aid offices. The disbursement date from COD was August 30, 2024 and the disbursement date per the student account was January 27, 2025. Possible Asserted Effect: The University did not comply with the requirement that the disbursements in COD and the disbursement dates on the student account agree with each other. Repeat Finding: There was not a similar finding for the year ended June 30, 2024. Statistical Sampling: The sample was not intended to be, and was not, a statistically valid sample. Recommendation: The Student Financial Aid Director should either correct the disbursement date on the student account or in COD so that the two disbursement dates agree. Management Response: The Student Financial Aid Director corrected the date the aid was posted to the student account in December 2025. Procedures will be improved to ensure that the disbursements date per COD and the student account agree.

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Full finding narrative

Federal Agency: U.S. Department of Education; Office of Federal Student Aid Pass through Entity: Not applicable Program Name: Federal Pell Grant Program ALN and Program Expenditures: 84.063 ($509,088) Award Number: P063P243315 Federal Award Year: July 1, 2024 to June 30, 2025 Questioned Costs: N/A Condition Found: The Common Origination and Disbursement System (“COD”) disbursement date did not agree with the disbursement date on the students’ accounts for one of the seventeen students in our compliance testing sample. Criteria: The disbursement date to be reported to the COD is the date that the institution credits funds to a student’s account or pays funds to a student or parent directly. Cause: This was an oversight of the business and financial aid offices. The disbursement date from COD was August 30, 2024 and the disbursement date per the student account was January 27, 2025. Possible Asserted Effect: The University did not comply with the requirement that the disbursements in COD and the disbursement dates on the student account agree with each other. Repeat Finding: There was not a similar finding for the year ended June 30, 2024. Statistical Sampling: The sample was not intended to be, and was not, a statistically valid sample. Recommendation: The Student Financial Aid Director should either correct the disbursement date on the student account or in COD so that the two disbursement dates agree. Management Response: The Student Financial Aid Director corrected the date the aid was posted to the student account in December 2025. Procedures will be improved to ensure that the disbursements date per COD and the student account agree.

Corrective Action Plan

FINDING 2025-007 – COD Disbursement Dates Program Name: Federal Pell Grant Program ALN and Program Expenditures: 84.063 ($509,088) Award Number: P063P243315 Federal Award Year: July 1, 2024 to June 30, 2025 Questioned Costs: N/A Condition Found: The Common Origination and Disbursement System (“COD”) disbursement date did not agree with the disbursement date on the students’ accounts for one of the seventeen students in our compliance testing sample. Corrective Action Plan: The Student Financial Aid Director correct the date the aid was posted to the student account in December 2025. Procedures will be improved to ensure that the disbursements date per COD and the student account agree. Anticipated Completion Date: The corrective action was completed in December 2025. Contact Person: Brad Burnett, Director of Financial Aid 405-912-9000

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2025-008
Eligibility
QUESTIONED COSTS

Federal Agency: U.S. Department of Education; Office of Federal Student Aid Pass through Entity: Not applicable Program Name: Federal Pell Grant Program ALN and Program Expenditures: 84.063 ($509,088) Award Number: P063P243315 Federal Award Year: July 1, 2024 to June 30, 2025 Questioned Costs: $1,849 Condition Found: The amount of Pell grant awarded was calculated incorrectly for one of the eleven students who received Pell grant funds in our sample. The student received $1,849 of Federal Pell Grant funds that the student was ineligible to receive. Criteria: Federal Pell Grant eligibility is determined by the student’s aid index (“SAI”) and enrollment status. Cause: The student’s expected enrollment status was not the same as the actual enrollment status. The student was awarded aid based on a full-time enrollment status while the student was only enrolled half-time. Possible Asserted Effect: The student received $1,849 of Federal Pell Grant funds that the student was ineligible to receive. Repeat Finding: There was not a similar finding for the year ended June 30, 2024. Statistical Sampling: The sample was not intended to be, and was not, a statistically valid sample. Recommendation: The Student Financial Aid Director should return the $1,849 of Federal Pell Grant funds to the Department of Education. Procedures should be improved to ensure the student’s enrollment status is verified before disbursing aid. Management Response: The Student Financial Aid Director is working with the third-party administrator to the return $1,849 to the Department of Education. The Student Financial Aid Director and third-party administrator will work together to verify a student’s enrollment status before disbursing aid.

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Full finding narrative

Federal Agency: U.S. Department of Education; Office of Federal Student Aid Pass through Entity: Not applicable Program Name: Federal Pell Grant Program ALN and Program Expenditures: 84.063 ($509,088) Award Number: P063P243315 Federal Award Year: July 1, 2024 to June 30, 2025 Questioned Costs: $1,849 Condition Found: The amount of Pell grant awarded was calculated incorrectly for one of the eleven students who received Pell grant funds in our sample. The student received $1,849 of Federal Pell Grant funds that the student was ineligible to receive. Criteria: Federal Pell Grant eligibility is determined by the student’s aid index (“SAI”) and enrollment status. Cause: The student’s expected enrollment status was not the same as the actual enrollment status. The student was awarded aid based on a full-time enrollment status while the student was only enrolled half-time. Possible Asserted Effect: The student received $1,849 of Federal Pell Grant funds that the student was ineligible to receive. Repeat Finding: There was not a similar finding for the year ended June 30, 2024. Statistical Sampling: The sample was not intended to be, and was not, a statistically valid sample. Recommendation: The Student Financial Aid Director should return the $1,849 of Federal Pell Grant funds to the Department of Education. Procedures should be improved to ensure the student’s enrollment status is verified before disbursing aid. Management Response: The Student Financial Aid Director is working with the third-party administrator to the return $1,849 to the Department of Education. The Student Financial Aid Director and third-party administrator will work together to verify a student’s enrollment status before disbursing aid.

Corrective Action Plan

FINDING 2025-008 – Pell Grant Calculation Program Name: Federal Pell Grant Program ALN and Program Expenditures: 84.063 ($509,088) Award Number: P063P243315 Federal Award Year: July 1, 2024 to June 30, 2025 Questioned Costs: $1,849 Condition Found: The amount of Pell grant awarded was calculated incorrectly for one of the eleven students who received Pell grant funds in our sample. The student received $1,849 of Federal Pell Grant funds that the student was ineligible to receive. Corrective Action Plan: The Student Financial Aid Director is working with the third-party administrator to the return $1,849 to the Department of Education. The Student Financial Aid Director and third-party administrator will work together to verify a student’s enrollment status before disbursing aid. Anticipated Completion Date: The University anticipates the corrective action being completed by March 31, 2026. Contact Person: Brad Burnett, Director of Financial Aid 405-912-9000

About Eligibility →
2025-009
Eligibility / Special Tests & Provisions
REPEATQUESTIONED COSTS

Federal Agency: U.S. Department of Education; Office of Federal Student Aid Pass through Entity: Not applicable Program Name: Federal Direct Loan Program Federal Pell Grant Program ALN and Program Expenditures: 84.268 ($866,312) 84.063 ($487,504) Award Number: P268K253315 P063P243315 Federal Award Year: July 1, 2024 to June 30, 2025 Questioned Costs: $1,652 (84.268) $1,616 (84.063) Condition Found: R2T4s were not calculated during for the award year ending June 30, 2025. During the compliance testing, it was determined that an R2T4 should have been calculated for two of the seventeen students selected for testing. Criteria: Per the Student Financial Aid Handbook Volume 5, Chapter 1, an R2T4 is required “in the case of a program that is measured in credit hours, the student does not complete all of the days in the payment period or period of enrollment that the student was schedule to complete.” Cause: The Interim Financial Aid Director did not realize R2T4s were still required when the institution was on the HCM2 method of disbursement. Possible Asserted Effect: The first student was awarded $3,697 in Federal Pell Grant funds. The student withdrew during the semester. After the R2T4 was completed, the student was only eligible to receive $2,081 in Federal Pell Grant funds. $1,616 of Federal Pell Grant funds should be returned to the Department of Education. The second student received $2,721 in Subsidized Federal Direct Loan funds. The student withdrew during the semester. After the R2T4 was completed, the student was only eligible to receive $1,069 in Subsidized Federal Direct Loan funds. $1,652 of Subsidized Federal Direct loan funds should be returned to the Department of Education. Repeat Finding: See Finding 2024-002 for a similar finding the prior year. Recommendation: $1,616 of Federal Pell Grant funds and $1,652 of Subsidized Federal Direct Loan funds should be returned to the Department of Education. Procedures should be improved to ensure that R2T4s are completed timely and accurately. Management Response: Management agrees that the R2T4s were not completed. For the first student, the Student Financial Director determined that while the Federal Pell Grant funds were posted to the student’s account, the funds were never requested from the Department of Education. $1,616 was of aid was removed from the student’s account and only $2,081 will be requested from the Department of Education. For the second student, $1,652 of Subsidized Federal Direct Loan funds were returned to the Department of Education in December 2025.

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Full finding narrative

Federal Agency: U.S. Department of Education; Office of Federal Student Aid Pass through Entity: Not applicable Program Name: Federal Direct Loan Program Federal Pell Grant Program ALN and Program Expenditures: 84.268 ($866,312) 84.063 ($487,504) Award Number: P268K253315 P063P243315 Federal Award Year: July 1, 2024 to June 30, 2025 Questioned Costs: $1,652 (84.268) $1,616 (84.063) Condition Found: R2T4s were not calculated during for the award year ending June 30, 2025. During the compliance testing, it was determined that an R2T4 should have been calculated for two of the seventeen students selected for testing. Criteria: Per the Student Financial Aid Handbook Volume 5, Chapter 1, an R2T4 is required “in the case of a program that is measured in credit hours, the student does not complete all of the days in the payment period or period of enrollment that the student was schedule to complete.” Cause: The Interim Financial Aid Director did not realize R2T4s were still required when the institution was on the HCM2 method of disbursement. Possible Asserted Effect: The first student was awarded $3,697 in Federal Pell Grant funds. The student withdrew during the semester. After the R2T4 was completed, the student was only eligible to receive $2,081 in Federal Pell Grant funds. $1,616 of Federal Pell Grant funds should be returned to the Department of Education. The second student received $2,721 in Subsidized Federal Direct Loan funds. The student withdrew during the semester. After the R2T4 was completed, the student was only eligible to receive $1,069 in Subsidized Federal Direct Loan funds. $1,652 of Subsidized Federal Direct loan funds should be returned to the Department of Education. Repeat Finding: See Finding 2024-002 for a similar finding the prior year. Recommendation: $1,616 of Federal Pell Grant funds and $1,652 of Subsidized Federal Direct Loan funds should be returned to the Department of Education. Procedures should be improved to ensure that R2T4s are completed timely and accurately. Management Response: Management agrees that the R2T4s were not completed. For the first student, the Student Financial Director determined that while the Federal Pell Grant funds were posted to the student’s account, the funds were never requested from the Department of Education. $1,616 was of aid was removed from the student’s account and only $2,081 will be requested from the Department of Education. For the second student, $1,652 of Subsidized Federal Direct Loan funds were returned to the Department of Education in December 2025.

Corrective Action Plan

FINDING 2025-009– R2T4 Calculation Program Name: Federal Direct Loan Program Federal Pell Grant Program ALN and Program Expenditures: 84.268 ($866,312) 84.063 ($487,504) Award Number: P268K253315 P063P243315 Federal Award Year: July 1, 2024 to June 30, 2025 Condition Found: R2T4s were not calculated during for the award year ending June 30, 2025. During the compliance testing, it was determined that an R2T4 should have been calculated for two of the seventeen students selected for testing. Corrective Action Plan: Management agrees that the R2T4s were not completed. For the first student, the Student Financial Director determined that while the Federal Pell Grant funds were posted to the student’s account, the funds were never requested from the Department of Education. $1,616 was of aid was removed from the student’s account and only $2,081 will be requested from the Department of Education. For the second student, $1,652 of Subsidized Federal Direct Loan funds were returned to the Department of Education in December 2025. Anticipated Completion Date: The University anticipates the corrective action being completed by March 31, 2026. Contact Person: Brad Burnett, Director of Financial Aid 405-912-9000

Prior Finding References

2024-002

About Eligibility, Special Tests and Provisions →
2025-010
Reporting

Federal Agency: U.S. Department of Education; Office of Federal Student Aid Pass through Entity: Not applicable Program Name: Federal Work Study ALN and Program Expenditures: 84.033 ($-0-) Award Number: P033A243421 Federal Award Year: July 1, 2024 to June 30, 2025 Questioned Costs: N/A Condition Found: The University did not award Federal Work Study funds during the 24-25 academic year. However, the FISAP reports that students participating in the Federal Work Study Program earned $26,232. An administrative allowance of $1,312 was also claimed. Total Federal Work Study funds per the FISAP totaled $27,544. Criteria: The amounts claimed as federal expenditures on the FISAP should agree with the institutions records. Cause: The person responsible for completing the FISAP was unaware that the University did not participate in the Federal Work Study Program for the 24-25 award. Possible Asserted Effect: The FISAP reporting was incorrect. In addition, the University claimed an administrative allowance, that the institution was not eligible to receive. As of June 30, 2025, the funds had not been requested from G5. This was a FISAP reporting error. Repeat Finding: There was not a similar finding in the prior year. Recommendation: All sections of the FISAP should be completed accurately. The University should have supporting documentation for the numbers and amounts reported on the FISAP. Management Response: Management will work with the third-party servicer to ensure the figures and amounts reported on the FISAP are accurate. An independent review of the FISAP will be completed by the CFO before the FISAP is filed.

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Full finding narrative

Federal Agency: U.S. Department of Education; Office of Federal Student Aid Pass through Entity: Not applicable Program Name: Federal Work Study ALN and Program Expenditures: 84.033 ($-0-) Award Number: P033A243421 Federal Award Year: July 1, 2024 to June 30, 2025 Questioned Costs: N/A Condition Found: The University did not award Federal Work Study funds during the 24-25 academic year. However, the FISAP reports that students participating in the Federal Work Study Program earned $26,232. An administrative allowance of $1,312 was also claimed. Total Federal Work Study funds per the FISAP totaled $27,544. Criteria: The amounts claimed as federal expenditures on the FISAP should agree with the institutions records. Cause: The person responsible for completing the FISAP was unaware that the University did not participate in the Federal Work Study Program for the 24-25 award. Possible Asserted Effect: The FISAP reporting was incorrect. In addition, the University claimed an administrative allowance, that the institution was not eligible to receive. As of June 30, 2025, the funds had not been requested from G5. This was a FISAP reporting error. Repeat Finding: There was not a similar finding in the prior year. Recommendation: All sections of the FISAP should be completed accurately. The University should have supporting documentation for the numbers and amounts reported on the FISAP. Management Response: Management will work with the third-party servicer to ensure the figures and amounts reported on the FISAP are accurate. An independent review of the FISAP will be completed by the CFO before the FISAP is filed.

Corrective Action Plan

FINDING 2025-010– FISAP Accuracy Program Name: Federal Work Study ALN and Program Expenditures: 84.033 ($-0-) Award Number: P033A243421 Federal Award Year: July 1, 2024 to June 30, 2025 Questioned Costs: N/A Condition Found: The University did not award Federal Work Study funds during the 24-25 academic year. However, the FISAP reports that students participating in the Federal Work Study Program earned $26,232. An administrative allowance of $1,312 was also claimed. Total Federal Work Study funds per the FISAP totaled $27,544. Corrective Action Plan: Management will work with the third-party servicer to ensure the figures and amounts reported on the FISAP are accurate. An independent review of the FISAP will be completed by the CFO before the FISAP is filed. Anticipated Completion Date: The University anticipates the corrective action being completed by October 1, 2026. Contact Person: Brad Burnett, Director of Financial Aid 405-912-9000

About Reporting →

FY 2024-06-30

FAC accepted this audit on March 24, 2025 — management decision was due September 24, 2025.

2024-001
Other
MATERIAL WEAKNESS

Condition Found: During our audit, we noted the following: • Adjustments were necessary for accounts receivable, scholarships, deferred revenue and a prior period adjustment for net assets and assets held for sale. Criteria: The design and implementation of policies and procedures in place should be sufficient enough for the reconciliation of significant financial accounts and transaction classes to prevent and detect material misstatements in the financial statements. Cause: The University currently does not have a strong process for making sure the ending balances are correct before providing the trial balance for audit. Possible Asserted Effect: In fiscal year 2024, we proposed adjustments to accounts such as accounts receivable, assets held for sale, net assets and various income and expense items. Recommendation: We recommend that the University put in place necessary controls and procedures to ensure that all transactions are properly classified. Management Response: Randall University will put processes in place to adjust accounts to the actual balance before the audit begins.

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Full finding narrative

Condition Found: During our audit, we noted the following: • Adjustments were necessary for accounts receivable, scholarships, deferred revenue and a prior period adjustment for net assets and assets held for sale. Criteria: The design and implementation of policies and procedures in place should be sufficient enough for the reconciliation of significant financial accounts and transaction classes to prevent and detect material misstatements in the financial statements. Cause: The University currently does not have a strong process for making sure the ending balances are correct before providing the trial balance for audit. Possible Asserted Effect: In fiscal year 2024, we proposed adjustments to accounts such as accounts receivable, assets held for sale, net assets and various income and expense items. Recommendation: We recommend that the University put in place necessary controls and procedures to ensure that all transactions are properly classified. Management Response: Randall University will put processes in place to adjust accounts to the actual balance before the audit begins.

Corrective Action Plan

FINDING 2024-001 – Financial Close and Reporting Condition Found: During our audit, we noted the following: • Adjustments were necessary for accounts receivable, scholarships, deferred revenue and a prior period adjustment for net assets and assets held for sale. Corrective Action Plan: Randall University will put processes in place to adjust accounts to the actual balance before the audit begins. Anticipated Completion Date: The corrective action will be completed by June 30, 2025. Contact Person: Todd Jenson, Chief Financial Officer 405-912-9475

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2024-002
Special Tests & Provisions / Other
QUESTIONED COSTS

FINDING 2024-002– R2T4 Calculation Federal Agency: U.S. Department of Education; Office of Federal Student Aid Pass through Entity: Not applicable Program Name: Federal Pell Grant Program ALN and Program Expenditures: 84.063 ($487,504) Award Number: P063P233315 Federal Award Year: July 1, 2023 to June 30, 2024 Questioned Costs: $1,574 Condition Found: The R2T4 was calculated correctly, but the Title IV funds were not returned timely for one of the twenty students in the compliance testing sample. Criteria: Per the Student Financial Aid Handbook Volume 5, Chapter 2, “a school must return unearned funds for which it is responsible as soon as possible but no later than 45 days after the date of determination of a student’s withdrawal.” Cause: The financial aid director did not realize the funds had not been returned. Possible Asserted Effect: $1,547 of Pell Grant funds have not been returned to the Department of Education. Repeat Finding: See Finding 2023-002 for a similar finding the prior year. Recommendation: $1,547 of Federal Pell Grant funds should be returned to the Department of Education. Procedures should be improved to ensure that funds are returned to the Department of Education timely after an R2T4 is completed. Management Response: Management agrees that the funds were not returned after the R2T4 was completed. The Interim Director of Financial Aid has submitted a request to the University’s third party servicer to return the funds.

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Full finding narrative

FINDING 2024-002– R2T4 Calculation Federal Agency: U.S. Department of Education; Office of Federal Student Aid Pass through Entity: Not applicable Program Name: Federal Pell Grant Program ALN and Program Expenditures: 84.063 ($487,504) Award Number: P063P233315 Federal Award Year: July 1, 2023 to June 30, 2024 Questioned Costs: $1,574 Condition Found: The R2T4 was calculated correctly, but the Title IV funds were not returned timely for one of the twenty students in the compliance testing sample. Criteria: Per the Student Financial Aid Handbook Volume 5, Chapter 2, “a school must return unearned funds for which it is responsible as soon as possible but no later than 45 days after the date of determination of a student’s withdrawal.” Cause: The financial aid director did not realize the funds had not been returned. Possible Asserted Effect: $1,547 of Pell Grant funds have not been returned to the Department of Education. Repeat Finding: See Finding 2023-002 for a similar finding the prior year. Recommendation: $1,547 of Federal Pell Grant funds should be returned to the Department of Education. Procedures should be improved to ensure that funds are returned to the Department of Education timely after an R2T4 is completed. Management Response: Management agrees that the funds were not returned after the R2T4 was completed. The Interim Director of Financial Aid has submitted a request to the University’s third party servicer to return the funds.

Corrective Action Plan

FINDING 2024-002 – R2T4 Calculation Program Name: Federal Pell Grant Program ALN and Program Expenditures: 84.063 ($487,504) Award Number: P063P233315 Federal Award Year: July 1, 2023 to June 30, 2024 Questioned Costs: $1,574 Condition Found: The R2T4 was calculated correctly, but the Title IV funds were not returned timely for one of the twenty students in the compliance testing sample. Corrective Action Plan: Management agrees that the funds were not returned after the R2T4 was completed. The Interim Director of Financial Aid has submitted a request to the University’s third-party servicer to return the funds. Anticipated Completion Date: The University anticipates the corrective action being completed by April 30, 2025. Contact Person: L. Evan Aldridge, Interim Financial Aid Administrator 405-912-9007

About Special Tests and Provisions, Other →
2024-003
Eligibility

FINDING 2024-003 – Federal Direct Loan Eligibility Federal Agency: U.S. Department of Education; Office of Federal Student Aid Pass through Entity: Not applicable Program Name: Federal Direct Student Loan Program ALN and Program Expenditures: 84.268 ($709,913) Award Number: P268K243315 Federal Award Year: July 1, 2023 to June 30, 2024 Questioned Costs: N/A Condition Found: The amount of subsidized Federal Direct Loans awarded was incorrect for one of the twelve students in our sample that received Federal Direct Loans. In addition, the student was eligible for additional unsubsidized funds. Criteria: The annual subsidized Federal Direct Loan limit is $3,500 for freshmen, $4,500 for sophomores, and $5,500 for juniors and seniors. For students who are considered independent for financial aid purposes the amount of unsubsidized Federal Direct loans are $6,000 for freshman and sophomores, and $7,000 for junior and seniors Cause: The student had several transfer credits that were not considered when determining the grade-level of the student for Federal Direct Loan awarding purposes. Possible Asserted Effect: The student in question was eligible to receive a $5,500 subsidized Federal Direct Loan but was only offered $4,500. In addition, the student in question was eligible to receive $7,000 in unsubsidized Federal Direct Loan but was only offered $6,000. Repeat Finding: There was not a similar finding for the year ended June 30, 2023. Statistical Sampling: The sample was not intended to be, and was not, a statistically valid sample. Recommendation: An additional $1,000 of subsidized and unsubsidized Federal Direct Loan funds could be offered to the student. If the student declines the additional funds, $1,000 of the unsubsidized loan should be reclassified as a subsidized loan. Procedures should be improved to ensure that all eligible credit hours are included when determining subsidized loan eligibility. Management Response: The Interim Student Financial Aid Director has requested a repackage of aid by the third-party financial aid administrator. Procedures will be improved to ensure that credit hours are reviewed before awarding aid.

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Full finding narrative

FINDING 2024-003 – Federal Direct Loan Eligibility Federal Agency: U.S. Department of Education; Office of Federal Student Aid Pass through Entity: Not applicable Program Name: Federal Direct Student Loan Program ALN and Program Expenditures: 84.268 ($709,913) Award Number: P268K243315 Federal Award Year: July 1, 2023 to June 30, 2024 Questioned Costs: N/A Condition Found: The amount of subsidized Federal Direct Loans awarded was incorrect for one of the twelve students in our sample that received Federal Direct Loans. In addition, the student was eligible for additional unsubsidized funds. Criteria: The annual subsidized Federal Direct Loan limit is $3,500 for freshmen, $4,500 for sophomores, and $5,500 for juniors and seniors. For students who are considered independent for financial aid purposes the amount of unsubsidized Federal Direct loans are $6,000 for freshman and sophomores, and $7,000 for junior and seniors Cause: The student had several transfer credits that were not considered when determining the grade-level of the student for Federal Direct Loan awarding purposes. Possible Asserted Effect: The student in question was eligible to receive a $5,500 subsidized Federal Direct Loan but was only offered $4,500. In addition, the student in question was eligible to receive $7,000 in unsubsidized Federal Direct Loan but was only offered $6,000. Repeat Finding: There was not a similar finding for the year ended June 30, 2023. Statistical Sampling: The sample was not intended to be, and was not, a statistically valid sample. Recommendation: An additional $1,000 of subsidized and unsubsidized Federal Direct Loan funds could be offered to the student. If the student declines the additional funds, $1,000 of the unsubsidized loan should be reclassified as a subsidized loan. Procedures should be improved to ensure that all eligible credit hours are included when determining subsidized loan eligibility. Management Response: The Interim Student Financial Aid Director has requested a repackage of aid by the third-party financial aid administrator. Procedures will be improved to ensure that credit hours are reviewed before awarding aid.

Corrective Action Plan

FINDING 2024-003 – Federal Direct Loan Eligibility Program Name: Federal Direct Student Loan Program ALN and Program Expenditures: 84.268 ($709,713) Award Number: P268K243315 Federal Award Year: July 1, 2023 to June 30, 2024 Questioned Costs: N/A Condition Found: The amount of subsidized Federal Direct Loans awarded was incorrect for one of the twelve students in our sample that received Federal Direct Loans. In addition, the student was eligible for additional unsubsidized funds. Corrective Action Plan: The Interim Student Financial Aid Director has requested a repackage of aid by the third-party financial aid administrator. Procedures will be improved to ensure that credit hours are reviewed before awarding aid. Anticipated Completion Date: The University anticipates the corrective action being completed by April 30, 2025. Contact Person: L. Evan Aldridge, Interim Financial Aid Administrator 405-912-9007

About Eligibility →
2024-004
Special Tests & Provisions / Other
QUESTIONED COSTS

FINDING 2024-004 – Title IV Aid Not Returned Federal Agency: U.S. Department of Education; Office of Federal Student Aid Pass through Entity: Not applicable Program Name: Federal Direct Student Loan Program ALN and Program Expenditures: 84.268 ($709,913) Award Number: P268K243315 Federal Award Year: July 1, 2023 to June 30, 2024 Questioned Costs: $3,711 Condition Found: A student requested that the University return $3,711 of unsubsidized Federal Direct Loan funds to the lender in December 2023. The University has yet to return the funds. Criteria: The University is required to notify students of the process to return or deny a loan disbursement at the time the disbursement is made. The student in question followed the procedures within the required timeframe. Cause: All of the steps were not completed in the return process. While COD no longer shows the loan disbursement as outstanding, NSLDS still lists the disbursement as outstanding with a December 2023 disbursement date, and the funds were never removed from the student’s account. Possible Asserted Effect: $3,711 of unsubsidized Federal Direct Loan funds should be returned. Repeat Finding: There was not a similar finding in the prior year. Statistical Sampling: The sample was not intended to be, and was not, a statistically valid sample. Recommendation: We recommend the University work with the third-party administrator to return the $3,711 as soon as possible. Procedures should be improved to ensure that funds are being returned timely. Management Response: The Interim Financial Aid Director will work with the third-party administrator to return the $3,711. The student’s account and NSLDS will be updated. Procedures will be improved to ensure that funds are returned timely.

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Full finding narrative

FINDING 2024-004 – Title IV Aid Not Returned Federal Agency: U.S. Department of Education; Office of Federal Student Aid Pass through Entity: Not applicable Program Name: Federal Direct Student Loan Program ALN and Program Expenditures: 84.268 ($709,913) Award Number: P268K243315 Federal Award Year: July 1, 2023 to June 30, 2024 Questioned Costs: $3,711 Condition Found: A student requested that the University return $3,711 of unsubsidized Federal Direct Loan funds to the lender in December 2023. The University has yet to return the funds. Criteria: The University is required to notify students of the process to return or deny a loan disbursement at the time the disbursement is made. The student in question followed the procedures within the required timeframe. Cause: All of the steps were not completed in the return process. While COD no longer shows the loan disbursement as outstanding, NSLDS still lists the disbursement as outstanding with a December 2023 disbursement date, and the funds were never removed from the student’s account. Possible Asserted Effect: $3,711 of unsubsidized Federal Direct Loan funds should be returned. Repeat Finding: There was not a similar finding in the prior year. Statistical Sampling: The sample was not intended to be, and was not, a statistically valid sample. Recommendation: We recommend the University work with the third-party administrator to return the $3,711 as soon as possible. Procedures should be improved to ensure that funds are being returned timely. Management Response: The Interim Financial Aid Director will work with the third-party administrator to return the $3,711. The student’s account and NSLDS will be updated. Procedures will be improved to ensure that funds are returned timely.

Corrective Action Plan

FINDING 2024-004– Title IV Aid Not Returned Program Name: Federal Direct Student Loan Program ALN and Program Expenditures: 84.268 ($709,913) Award Number: P268K243315 Federal Award Year: July 1, 2023 to June 30, 2024 Questioned Costs: $3,711 Condition Found: A student requested that the University return $3,711 of unsubsidized Federal Direct Loan funds to the lender in December 2023. The University has yet to return the funds. Corrective Action Plan: The Interim Financial Aid Director will work with the third-party administrator to return the $3,711. The student’s account and NSLDS will be updated. Procedures will be improved to ensure that funds are returned timely. Anticipated Completion Date: The University anticipates the corrective action being completed by April 30, 2025. Contact Person: L. Evan Aldridge, Interim Financial Aid Administrator 405-912-9007

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2024-005
Eligibility
QUESTIONED COSTS

FINDING 2024-005– Aid Not Disbursed Federal Agency: U.S. Department of Education; Office of Federal Student Aid Pass through Entity: Not applicable Program Name: Federal Direct Student Loan Program Federal Pell Grant Program ALN and Program Expenditures: 84.268 ($709,913) 84.063 ($487,504) Award Number: P268K243315 P063P233315 Federal Award Year: July 1, 2023 to June 30, 2024 Questioned Costs: $2,722(84.268) $1,023(84.063) Condition Found: The second financial aid disbursement was not made to one of the twenty students in our sample. The student in question was eligible to receive $1,023 of Federal Pell Grant funds, $1,732 of subsidized Federal Direct Loan funds, and $990 of unsubsidized Federal Direct Loan Funds. Criteria: Title IV aid should be made in two disbursements. Typically, there is one disbursement per academic period or semester as in the case of Randall University. Cause: The disbursements for the student in question were overlooked. Possible Asserted Effect: The student did not receive $1,023 of Federal Pell Grant funds, $1,732 of subsidized Federal Direct Loan funds, and $990 of unsubsidized Federal Direct Loan Funds that the student was eligible to receive. Repeat Finding: There was not a similar finding in the prior year. Recommendation: The University should disburse the aid to the student in question. Checks and balances should be created to ensure that aid is awarded and requested for all eligible students. Management Response: The University is on the HCM2 method for disbursing aid. The funds in question will be posted to the student’s account. The University will request the funds from the Department of Education when the next aid batch is submitted.

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Full finding narrative

FINDING 2024-005– Aid Not Disbursed Federal Agency: U.S. Department of Education; Office of Federal Student Aid Pass through Entity: Not applicable Program Name: Federal Direct Student Loan Program Federal Pell Grant Program ALN and Program Expenditures: 84.268 ($709,913) 84.063 ($487,504) Award Number: P268K243315 P063P233315 Federal Award Year: July 1, 2023 to June 30, 2024 Questioned Costs: $2,722(84.268) $1,023(84.063) Condition Found: The second financial aid disbursement was not made to one of the twenty students in our sample. The student in question was eligible to receive $1,023 of Federal Pell Grant funds, $1,732 of subsidized Federal Direct Loan funds, and $990 of unsubsidized Federal Direct Loan Funds. Criteria: Title IV aid should be made in two disbursements. Typically, there is one disbursement per academic period or semester as in the case of Randall University. Cause: The disbursements for the student in question were overlooked. Possible Asserted Effect: The student did not receive $1,023 of Federal Pell Grant funds, $1,732 of subsidized Federal Direct Loan funds, and $990 of unsubsidized Federal Direct Loan Funds that the student was eligible to receive. Repeat Finding: There was not a similar finding in the prior year. Recommendation: The University should disburse the aid to the student in question. Checks and balances should be created to ensure that aid is awarded and requested for all eligible students. Management Response: The University is on the HCM2 method for disbursing aid. The funds in question will be posted to the student’s account. The University will request the funds from the Department of Education when the next aid batch is submitted.

Corrective Action Plan

FINDING 2024-005– Aid Not Disbursed Program Name: Federal Direct Student Loan Program Federal Pell Grant Program ALN and Program Expenditures: 84.268 ($709,913) 84.063 ($487,504) Award Number: P268K243315 P063P233315 Federal Award Year: July 1, 2023 to June 30, 2024 Questioned Costs: $2,722(84.268) $1,023(84.063) Condition Found: The second financial aid disbursement was not made to one of the twenty students in our sample. The student in question was eligible to receive $1,023 of Federal Pell Grant funds, $1,732 of subsidized Federal Direct Loan funds, and $990 of unsubsidized Federal Direct Loan Funds. Corrective Action Plan: The University is on the HCM2 method for disbursing aid. The funds in question will be posted to the student’s account. The University will request the funds from the Department of Education when the next aid batch is submitted. Anticipated Completion Date: The University anticipates the corrective action being completed by April 30, 2025. Contact Person: L. Evan Aldridge, Interim Financial Aid Administrator 405-912-9007

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