Oklahoma Christian University and SubsidiariesHigher Education

Student Financial Assistance Cluster Assistance Listing Number 84.268 Federal Direct Student Loans, and 84.063 Federal Pell Grant Program U.S. Department of Education Program Year 2024-2025 Criteria or Specific Requirement – Disbursements to or on behalf of students, 34 CFR Section 668.164(h)(2) Condition – Students did not receive refunds within the required timeframe Questioned Costs – N/A Context – 7 out of 25 students tested received their credit balance refund more than 14 days after the credit balance was generated. All but 1 of these students received their refund within 16 days of the generation of the credit balance. Our sample was not, and was not intended to be, statistically valid. Effect – Noncompliance with federal regulations requiring timely disbursement of credit balance refunds Cause – Due to the high volume of credit balance refunds being processed, the University encountered operational constraints that prevented all refunds from being generated within the designated 14-day timeframe. Indication as a Repeat Finding – N/A Recommendation – To ensure timely refund of student credit balances, implement a control that flags any refund not processed before the end of the 14-day timeframe for immediate review and escalation. Additionally, establish a monitoring report to track refund timeliness weekly and reinforce accountability for processing within the required timeframe. Views of Responsible Officials and Planned Corrective Actions – Amy Schlup, Director of Student Financial Services, and Carrie Hamilton, Assistant Director of Financial Aid, will oversee the corrective action plan. As part of this process, they will review the daily Student Refund Report to identify and assist the personal financial counselor in expediting student refunds. The Student Financial Services team will also review and retrain on the proper procedures for processing refunds within the required timeframe. The corrective action plan is already in progress and will be fully implemented by October 1, 2025. Office of Financial Services PO Box 11000 Oklahoma City, OK 73136 405.425.5190 financialservices@oc.edu

Student Financial Assistance Cluster Assistance Listing Number 84.268 Federal Direct Student Loans, and 84.063 Federal Pell Grant Program U.S. Department of Education Program Year 2024-2025 Criteria or Specific Requirement – Special Tests and Provisions – Enrollment Reporting – 34 CFR Sections 690.83(b)(2) and 685.309 Condition – Student enrollment and program information was not communicated to the National Student Loan Data System (NSLDS) timely or accurately Questioned Costs – N/A Context – A total of 7 out of 40 students tested were noted to have at least 1 error in enrollment or program information reported to NSLDS within the required 60 days. Our sample was not, and was not intended to be, statistically valid. Effect – NSLDS was not notified of student status changes or program information in accordance with compliance requirements. Cause – The University did not have effective internal control processes in place to ensure the accurate collection, review, and reporting of student status changes occurred timely or accurately. The recent turnover in personnel resulted in a lack of oversight as well. Indication as a Repeat Finding – Yes Recommendation – The University should review its internal controls surrounding the enrollment reporting process and ensure internal controls provide for the timely and accurate reporting of student status changes. Views of Responsible Officials and Planned Corrective Actions – Tina Petersen, Registrar, will oversee the two-fold corrective action plan. First, we are immediately reviewing our degree posting policy and dates to create a more effective and standardized process. This policy review will enable us to properly assess any delayed completers and ensure that students are "completed" in our systems and reported to NSLDS in a more timely and accurate manner. Additionally, we are updating our formal, step-by-step written procedure manual for all enrollment reporting processes, with a specific focus on degree conferral and the subsequent reporting to NSLDS. This updated manual will serve as a crucial resource to ensure procedural consistency, especially during personnel changes. Second, we are enhancing our training protocols and internal controls. All staff members involved in the NSLDS reporting process will be required to attend mandatory, recurring training to ensure they are up-to-date on all compliance requirements. We will also implement a more robust system of checks and balances to verify the accuracy of the data before it is submitted to NSLDS. By taking these steps, the University is dedicated to improving its internal controls and fully remediating this finding. The corrective action plan will be implemented by November 1, 2025. Office of Financial Services PO Box 11000 Oklahoma City, OK 73136 405.425.5190 financialservices@oc.edu

2024-002

Criteria or Specific Requirement - Eligibility, 34 CFR Section 685.200(a)(2)(i) Condition - One student received need-based aid exceeding that student's financial need Questioned Costs - $2,069 Context - Out of the population of 1,301 students who received federal student financial assistance during the year, a sample of 25 students was selected for testing. One student was awarded need-based aid who did not have financial need. Our sample was not, and was not intended to be, statistically valid. Effect - One student received aid for which they were not eligible Cause - The student's estimated family contribution (EFC) was not updated to reflect a change in the student's attendance plan, and the student was awarded aid for the year using the student's four-month EFC rather than the twelve-month EFC. Indication as a Repeat Finding - N/A Recommendation - The University should review its procedures for ensuring appropriate EFC figures are used when awarding financial aid to ensure any changes in student information is accurately reflected in the information used to award student aid. Views of Responsible Officials and Planned Corrective Actions - Amy Schlup, Director of Student Financial Services, and Carrie Hamilton, Assistant Director of Financial Aid, will oversee the corrective action plan. University IT personnel are creating a Change Report to identify students whose SAi (Student Aid Index, formerly EFC) months do not match the attendance pattern. This will alert Financial Services to adjust the budget to the appropriate timeframe that will prevent overawarding. The Student Financial Services team will review and retrain on the proper procedure to assign SAi months. The corrective action has begun and will be completed as of November 1, 2024. Contact information for responsible officials: Office of Financial Services Box 11000 Oklahoma City, OK 73136 405.425.5190 financialservices@oc.edu

Criteria or Specific Requirement - Special Tests and Provisions - Enrollment Reporting - 34 CFR Section 690.83(b)(2) and 685.309 Condition - Eight student status changes were not communicated to the NSLDS timely Questioned Costs - N/A Context - Out of the population of 312 students with enrollment status changes requiring reporting to NSLDS, a sample of 25 students was selected for testing. Of those 25 students, 8 student status changes were not reported to NSLDS within the required 60 days. Our sample was not, and was not intended to be, statistically valid. Effect - NSLDS was not notified of student status changes in accordance with compliance requirements Cause - The University did not have effective internal control processes in place to ensure the accurate collection, review and reporting of student status changes occurred timely. Recent turnover in personnel resulted in a lack of oversight as well. Indication as a Repeat Finding - N/A Recommendation - The University should review its internal controls surrounding the enrollment reporting process and ensure internal controls provide for the timely and accurate reporting of student status changes. Views of Responsible Officials and Planned Corrective Actions - Amy Schlup, Director of Student Financial Services, and Rachel Hart, Registrar, will oversee the corrective action plan. New personnel in the Registrar's office have received training for student enrollment reporting and will submit reporting to NSLDS every 30 days in order to stay within the required 60 days. This reporting will take place around the 25th of every month and be completed by the Registrar only. The Associate Registrar and Director of Administrative Computing will retain alternate access in case of emergency. Error reports will be reviewed and resolved within one week ensuring that accurate information is provided to NSLDS well within the required time frame. The corrective action plan has already been completed as of October 9, 2024. Contact information for responsible officials: Office of Financial Services Box 11000 Oklahoma City, OK 73136 405.425.5190 financialservices@oc.edu

Condition: An error in the date calculation for the count of spring break days in the Spring 2020 semester impacted the overall count of semester days, adjusting the Return to Title IV calculations by one day. Eight (8) students withdrawn prior to the 60 percent date of the semester were affected. Cause: When calculating the number of days for spring break, the start date for spring break was set as 03/15/2020 rather than 03/14/2020 in the FAM System. The number of days in the break should have been eight (8) but were calculated as seven (7). The number of days in the semester were 103 but should have been 102. Corrective Action Plan: Financial Services will review the students who were withdrawn prior to the 60 percent date of the Spring 2020 semester and determine if their earned financial aid is correctly calculated when reduced by one (1) day. These will be hand calculations of Return to Title IV on these eight (8) students. The University will also review break dates more carefully to assure we are adding the correct number of break days greater than four in a term. We will review the number with the Registrar based on the expected semester dates on the academic calendar. Responsible official(s) and Implementation Date: The responsible official for this corrective action plan is Judy Cuellar, Director of Student Financial Services with the assistance of Carrie Hamilton, Assistant Director of Financial Aid. They will begin the hand calculations as soon as possible to be certain to complete any necessary aid adjustments prior to the close date of the 219-2020 Federal Aid Year on June 30, 2021.