OUR LADY OF THE LAKE UNIVERSITY OF SAN ANTONIO

Special Tests and Provisions – Enrollment Reporting Student Financial Assistance Cluster, Assistance Listing Number 84.268 Federal Direct Student Loans, Assistance Listing Number 84.063 Federal Pell Grant Program U.S. Department of Education Program Year 2023–2024 Type of Finding: Other Instance of Noncompliance and Deficiency Criteria: Management is responsible for compliance with Special Tests and Provisions – Enrollment Reporting procedures in accordance with the Uniform Guidance. (34 CFR 690.93(b)(2); 34 CFR 682.610; 34 CFR 685.309) Condition: Federal regulations provide that the University is responsible for notifying the National Student Loan Data System (NSLDS) of enrollment change. NSLDS was not notified timely, and the University’s internal control system did not prevent or detect that the NSLDS was not notified timely of the change. Questioned Costs: None Context: Out of a population of 388 students with enrollment changes, a sample of 25 students were selected for testing. 5 out of the 25 enrollment changes did not get reported timely to NSLDS. Our sampling method was not, and was not intended to be, statistically valid. Effect: The failure to timely report enrollment changes to NSLDS may result in inaccurate or delayed updates to student loan records. Cause: The University’s processes did not ensure that enrollment status changes were completed accurately and timely to NSLDS. Report Finding: No Recommendation: We recommend the University evaluate controls around monitoring enrollment reporting, ensuring NSLDS receives notification of enrollment changes. Views of Responsible Officials and Planned Corrective Actions: Management concurs with the finding and recommendation. See further information on the corrective action plan provided by management.

Finding: Special Tests and Provisions – Enrollment Reporting Student Financial Assistance Cluster, Assistance Listing Number 84.268 Federal Direct Student Loans, Assistance Listing Number 84.063 Federal Pell Grant Program U.S. Department of Education Program Year 2023–2024 Type of Finding: Other Instance of Noncompliance and Deficiency Corrective Action: The failure to report certain enrollment status changes to the NSLDS on a timely basis during the fiscal year ending May 31, 2024, was an isolated instance due to turnover in the Registrar’s Office. The University has updated the process for reporting enrollment status changes to the NSLDS and has ensured there is adequate cross-training in the Registrar’s Office to prevent future instances of non-compliance with reporting deadlines. Status: Completed Person Responsible for Implementing: Melissa Delgado, Registrar Implementation Date: 01/01/2025

Special Tests and Provisions – Key Personnel Research and Development Cluster, Assistance Listing Number: 84.031S Federal Granting Agency: U.S. Department of Education Program Year 2023–2024 Award No. PP031S220202-23 Type of Finding: Other Instance of Noncompliance and Deficiency Criteria: Special Test - Key Personnel-Applications/proposals or awards may include staffing proposals that specify individuals who will work on the project and the extent of the planned involvement of personnel. The nonfederal entity may change the staffing mix and level of involvement within limits specified by agency policy or in the award, but may be required to obtain federal awarding agency approval of changes in key personnel (as identified in the award, which may differ from the nonfederal entity’s designation in the application/proposal) and changes in the project director’s time commitment/level of participation in the project (OMB Circular A-110 §§_.25(c)(2) and (3)/2 CFR Sections 200.308(b)(2) and (3)). Condition: Federal regulations provide that the University is responsible for ensuring the staffing mix and level of involvement is within limits specified by agency policy or in the award, and to obtain federal awarding agency approval of changes in key personnel. The University’s internal control system did not prevent or detect that key personnel did not complete personal activity reports to support their involvement in the project as required. Questioned Costs: None Context: Out of a population of 13 key personnel assigned to the grants, a sample of four key personnel were selected for testing. One out of the four key personnel did not have formal documentation related to charging their time to the project. Our sampling method was not, and was not intended to be, statistically valid. Effect: Management failed to perform effective control activities to appropriately reduce the risk of noncompliance related to the key personnel special test during the fiscal year. The lack of an adequate control environment over this special test requirement could result in personnel being involved in projects utilizing federal funds that have not been properly approved by the granting agency. Cause: The University’s processes did not ensure that key personnel were properly involved in projects under the Research and Development Cluster. Report Finding: No Recommendation: We recommend the University strengthen its processes and controls to help ensure that all key personnel involved in projects under the Research and Development Cluster are properly approved and involved in grant project objectives. Views of Responsible Officials and Planned Corrective Actions: Management concurs with the finding and recommendation. See further information on the corrective action plan provided by management.

Finding: Special Tests and Provisions – Key Personnel Research and Development Cluster, Assistance Listing Number: 84.031S Federal Granting Agency: U.S. Department of Education Program Year 2023–2024 Type of Finding: Other Instance of Noncompliance and Deficiency Corrective Action: The University has a process in place for personnel charged to grants to complete personal activity reports to monitor their level of effort on the grants. We were not requiring key personnel that are providing in-kind services on grants to complete the personal activity reports, although the project directors are monitoring the involvement of all personnel working on grants to ensure we are providing an appropriate level of effort in the grant activities. The individual identified in this finding was providing in-kind services and was not paid from federal funds. The University will update its processes to ensure that that project activity reports are documented and reviewed for all key personnel assigned to grants, including in-kind personnel. Status: In-progress Person Responsible for Implementing: Edith Cogdell, Chief Financial Officer Implementation Date: 05/31/2025

Federal Program – Student Financial Assistance Cluster Assistance Listing No. 84.268 U.S. Department of Education Program Year 2022–2023 Criteria or Specific Requirement – Direct Loan Reconciliation CFR 685.300 Condition – The University’s failed to complete required direct loan reconciliations during the 2022–2023 aid year. The University is responsible for reconcilng University disbursement data to the Department of Education’s Common Origination and Disbursement System on a monthly basis and for establishing internal controls to ensure that such reconciliations are completed within federal requirements. Questioned Costs – N/A Context – Out of a population of 12 months, two months were selected for testing. No support for the monthly reconcilations for these months was able to be provided, and it was noted that reconcilations did not take place for any months during the year ended May 31, 2023. Our sample was not, and was not intended to be, statistically valid. Effect – The University failed to complete monthly reconcilations as required and could have had errors in direct loans that were not identified. Cause – The University experienced turnover and decreased staffing levels during the year. Identification as a Repeat Finding, if Applicable – N/A Recommendation – The University should put controls in place to ensure that reconcilations are being completed on a monthly basis as required. Corrective Action Plan – OLLU has already begun coordinating processes between its Accounting and Financial Aid departments to download the monthly SAS into the University’s system electronically, where Accounting will then reconcile the statement monthly as part of its month-end close procedures. The Financial Aid Director will be responsible for ensuring that the statement is downloaded monthly as a part of the regular electronic data file transfer between OLLU and the Department of Education. The Senior Accountant in the Accounting Department will generate the report in Colleague via the DRSS process and reconcile the SAS statement to cash records. The Director of Accounting and Reporting will review the reconciliation monthly. Anticipated Completion Date – February 15, 2024

Our Lady of the Lake University of San Antonio FY 2023 Single Financial Audit Finding Response Corrective Action Plan – Reconciliation of COD Monthly School Account Statement Compliance Finding: The Department of Education’s (DoE) School Account Statement (SAS), downloaded electronically from the Common Origination Destination (COD) website, was not being reconciling monthly as required by the Student Financial Aid/ Direct Loan Program. Criteria or Specific Requirement: Per the Student Financial Aid/ Direct Loan Program requirements with the DoE, every school is required to reconcile their SAS to their accounting system records at least monthly. This statement is issued to each participating school through the SAIG mailbox monthly. The auditors noted 34 CFR 685.102(b), 385.300(b), 685.301, and 303 as the compliance regulation. Cause of Noncompliance: It appears that the SAS was reconciled monthly per the compliance requirement in recent years, but with high turnover and periods of under-staffing in the Accounting department this procedure was changed to one that did not meet the above requirement. Although OLLU did regularly reconcile the accounting system records with reports from COD, it was not the official monthly SAS statement. OLLU’s modified procedures did not completely meet the compliance requirement but did offer some mitigating procedures. Institution Response: OLLU has already begun coordinating processes between its Accounting and Financial Aid departments to download the monthly SAS into the university’s system electronically, where Accounting will then reconcile the statement monthly as a part of its month-end close procedures. The Financial Aid Director will be responsible for ensuring that the statement is downloaded monthly as a part of the regular electronic data file transfer between OLLU and the Department of Education. The Senior Accountant in the Accounting department will generate the report in Colleague via the DRSS process and reconcile the SAS statement to cash records. The Director of Accounting and Reporting will review the reconciliation monthly.

Federal Pell Grant Program, CFDA 84.063 Federal Work Study Program, CFDA 84.033 Federal Supplemental Educational Opportunities Grants, CFDA 84.007 Teacher Education Assistance for College and Higher Education (TEACH) Grants, CFDA 84.379 Federal Direct Student Loans, CFDA 84.268 Federal Perkins Loan Program, CFDA 84.038 U.S. Department of Education Award Year 2019-2020 Criteria or specific requirement - Special Tests and Provisions - Return of Title IV Funds - Returns of Title IV funds are required to be deposited or transferred into the SFA account or electronic funds transfers initiated to ED no later than 45 days after the date the institution determines that the student withdrew. Condition - The University did not return funds within the 45 day time period for students who were enrolled in both Fast Track A and Fast Track B, completed Fast Track A, and dropped Fast Track B. Questioned costs - None Context - Out of 76 students who received Title IV funds and who withdrew during fiscal year 2019-2020, a sample of 12 students were selected for testing. Five students return of funds were remitted within the 45 days after the date the University determined that they had withdrawn. The sample was not, and was not intended to be, statistically valid. Effect - Funds were returned late. Identification as a repeat finding - No Cause - Due to limitations of the withdrawal report used to determine and perform R2T4 calculations, students who were enrolled in both Fast Track A and Fast Track B and who dropped during the break period between the two Fast Tracks were not captured. This limitation resulted in instances where the 45-day window to return funds had passed. Recommendation - Controls and procedures should be reviewed to ensure timely remittance of Title IV funds.

Views of responsible officials and planned corrective actions - Responsible Individual: Esme Flores, Director of Financial Aid Finding 2020-001 Federal Agency Name: U.S. Department of Education Program Name: Student Financial Assistance Cluster CFDA #84.268, 84.063, 84.007, 84.033, 84.038, 84.379 Finding Summary Returns of Title IV funds are required to be deposited or transferred into the SFA account or electronic funds transfers initiated to ED no later than 45 days after the date the institution determines that the student withdrew. Five students return of funds were remitted subsequent to the 45 days after the date the university determined that they had withdrawn. Corrective Action Plan (CAP) The University will send two employees from the Financial Aid department to a comprehensive training on the R2T4 process. The financial aid department will work with the Office of Institutional Research to generate a report run after the end of each session, which will be used to reconcile against the weekly withdrawal reports. Discrepancies and other exceptions between these two reports in relation to regulations involving the R2T4 will be investigated and resolved by Financial Aid. Anticipated Completion Date May 31, 2021