UNIVERSITY OF PROVIDENCE

Reporting U.S. Department of Education Student Financial Aid Cluster: ALN: 84.063 Pell Grant ALN: 84.007 Supplemental Educational Opportunity Grant ALN 84.033 Federal Work Study ALN 84.038 Federal Perkins Loan Program ALN 84.268 Federal Direct Student Loans Criteria: The Fiscal Operations Report and Application to Participate (FISAP) is due by October 1st of each year. Part II Section E requires tuition and fee revenue be reported. Part II Section F requires the number of eligible aid applicants enrolled at the University for the reporting period who applied for financial aid be reported. Condition: The amounts reported for tuition and fee revenue in Part II Section E was understated by $335,611, representing fees collected during the reporting period. The amounts reported for Section F did not report accurate information as it was not available. Context: The University mistakenly omitted the fee revenue from the FISAP report. The University converted software systems during the year, resulting in reporting problems for Part II Section F. Effect: The information reported in the FISAP for Part II Sections E and F is not accurate. Questioned Costs: None. Cause: The University made an error in reporting the tuition and fee income. Part II Section F information supplied in the new software, Jenzabar, did not work because all of the information was not available in the module used to generate the information for this part of the FISAP. The Part F information was obtained from the Jenzabar Financial Aid module. Auditor Recommendation: We recommend the University enhance procedures for reporting to ensure accuracy of reported information. University Response: The University went through a software conversion at the beginning of the fiscal year and due to the timing of the reporting and familiarity of the new software this was unintentionally omitted from the report. The creation of a procedure documenting where information is gathered from and a review process will ensure accuracy of reported information.

Reporting U.S. Department of Education Student Financial Aid Cluster: ALN: 84.063 Pell Grant ALN: 84.007 Supplemental Educational Opportunity Grant ALN 84.033 Federal Work Study ALN 84.038 Federal Perkins Loan Program ALN 84.268 Federal Direct Student Loans Criteria: The Fiscal Operations Report and Application to Participate (FISAP) is due by October 1st of each year. Part II Section E requires tuition and fee revenue be reported. Part II Section F requires the number of eligible aid applicants enrolled at the University for the reporting period who applied for financial aid be reported. Condition: The amounts reported for tuition and fee revenue in Part II Section E was understated by $335,611, representing fees collected during the reporting period. The amounts reported for Section F did not report accurate information as it was not available. Context: The University mistakenly omitted the fee revenue from the FISAP report. The University converted software systems during the year, resulting in reporting problems for Part II Section F. Effect: The information reported in the FISAP for Part II Sections E and F is not accurate. Questioned Costs: None. Cause: The University made an error in reporting the tuition and fee income. Part II Section F information supplied in the new software, Jenzabar, did not work because all of the information was not available in the module used to generate the information for this part of the FISAP. The Part F information was obtained from the Jenzabar Financial Aid module. Auditor Recommendation: We recommend the University enhance procedures for reporting to ensure accuracy of reported information. University Response: The University went through a software conversion at the beginning of the fiscal year and due to the timing of the reporting and familiarity of the new software this was unintentionally omitted from the report. The creation of a procedure documenting where information is gathered from and a review process will ensure accuracy of reported information.

Eligibility U.S. Department of Education Student Financial Aid Cluster: ALN: 84.063 Pell Grant ALN: 84.007 Supplemental Educational Opportunity Grant ALN 84.033 Federal Work Study ALN 84.038 Federal Perkins Loan Program ALN 84.268 Federal Direct Student Loans Criteria: The 2024-2025 Federal Student Aid Handbook, Vol 2, Chapter 3, states that the Financial Aid Administrator must be supported by an adequate number of professional and clerical personnel. The number of staff that is adequate depends on the number of students aided, the number and types of programs in which the school participates, the number of applicants evaluated and processed, the number of funds administered, and the type of financial data delivery system the school uses. Internal controls that pertain to Eligibility include the accuracy and completeness of data used to determine eligibility requirements, which are reviewed and agreed to support as necessary by staff and reviewed by a knowledgeable supervisor. Manual checklists or automated processes used when making eligibility determinations are reviewed and approved by a knowledgeable supervisor. Calculations of amounts to be received for or on behalf of participants are reperformed by a knowledgeable supervisor. Segregation of duties exists between those determining a participant’s eligibility and those reviewing/approving eligibility. Condition: During the audit period, an additional staff member was hired to assist the Financial Aid Director. However, the awarding of financial aid award packages completed by the Financial Aid Director were not reviewed. Context: The University did hire a financial aid staff member to assist with packaging; however, the Financial Aid Director continued to handle the majority of the workload. The staff member subsequently left the University following the June 20, 2025 year-end. Effect: With only one staff member performing the packaging process, this does not provide adequate internal controls over the Eligibility requirement. Questioned Costs: None. Cause: The University has made efforts to hire and train support staff for the Financial Aid Director. However, no alternative control procedures were implemented to address the issue of having only one person involved with the awarding process. Auditor Recommendation: We recommend the University enhance the system of internal control for Eligibility and award packaging determinations. University Response: The University understands the need to have adequate staffing in financial aid that allows for a separate review of financial aid packaging. The University is looking at the options of both hiring staff and working with a firm that provides financial aid assistance in order to enhance the system of internal controls for determination of financial aid eligibility and to review financial aid packaging prepared by staff.

Eligibility U.S. Department of Education Student Financial Aid Cluster: ALN: 84.063 Pell Grant ALN: 84.007 Supplemental Educational Opportunity Grant ALN 84.033 Federal Work Study ALN 84.038 Federal Perkins Loan Program ALN 84.268 Federal Direct Student Loans Criteria: The 2024-2025 Federal Student Aid Handbook, Vol 2, Chapter 3, states that the Financial Aid Administrator must be supported by an adequate number of professional and clerical personnel. The number of staff that is adequate depends on the number of students aided, the number and types of programs in which the school participates, the number of applicants evaluated and processed, the number of funds administered, and the type of financial data delivery system the school uses. Internal controls that pertain to Eligibility include the accuracy and completeness of data used to determine eligibility requirements, which are reviewed and agreed to support as necessary by staff and reviewed by a knowledgeable supervisor. Manual checklists or automated processes used when making eligibility determinations are reviewed and approved by a knowledgeable supervisor. Calculations of amounts to be received for or on behalf of participants are reperformed by a knowledgeable supervisor. Segregation of duties exists between those determining a participant’s eligibility and those reviewing/approving eligibility. Condition: During the audit period, an additional staff member was hired to assist the Financial Aid Director. However, the awarding of financial aid award packages completed by the Financial Aid Director were not reviewed. Context: The University did hire a financial aid staff member to assist with packaging; however, the Financial Aid Director continued to handle the majority of the workload. The staff member subsequently left the University following the June 20, 2025 year-end. Effect: With only one staff member performing the packaging process, this does not provide adequate internal controls over the Eligibility requirement. Questioned Costs: None. Cause: The University has made efforts to hire and train support staff for the Financial Aid Director. However, no alternative control procedures were implemented to address the issue of having only one person involved with the awarding process. Auditor Recommendation: We recommend the University enhance the system of internal control for Eligibility and award packaging determinations. University Response: The University understands the need to have adequate staffing in financial aid that allows for a separate review of financial aid packaging. The University is looking at the options of both hiring staff and working with a firm that provides financial aid assistance in order to enhance the system of internal controls for determination of financial aid eligibility and to review financial aid packaging prepared by staff.

Cash Management U.S. Department of Education Student Financial Aid Cluster: ALN: 84.063 Pell Grant ALN: 84.007 Supplemental Educational Opportunity Grant ALN 84.033 Federal Work Study ALN 84.038 Federal Perkins Loan Program ALN 84.268 Federal Direct Student Loans Criteria: The Department of Education provides funds to an institution under the advance, reimbursement, or heightened cash monitoring payment methods. With the advance payment method, it permits the institution to draw down Title IV funds prior to disbursing funds to eligible students and parents. The institution’s request must not exceed the amount immediately needed to disburse funds to students or parents. A disbursement of funds occurs on the date an institution credits a student’s account or pays a student or parent directly with either SFA funds or institutional funds. The institution must make the disbursement as soon as administratively feasible, but no later than 3 business days following the receipt of funds. The Department of Education considers excess cash to be any amount of Title IV funds that an institution does not disburse to students or parents by the end of the third business day. The Department of Education allows an institution to retain, for up to seven days, excess cash that does not exceed one percent of the total amount of funds drawn by the institution in the prior award year. The institution must return to the Department of Education any excess cash over the tolerable amount (one percent) and any amount remaining after the tolerance period (seven days). Questioned costs would be those in excess of the one percent threshold. Condition: The University drew $1,334,720 for Direct Loans on September 12, 2024, but drew down too much. They were notified by the Department of Education of the overdrawn portion, and a refund was issued on October 25, 2024, for $75,428. The University held excess cash for longer than the allowed time frame. Context: Funds are drawn from the Department of Education periodically throughout the year. This was the only instance of drawing in advance and not returning the funds timely to Department of Education. Effect: The University did not follow cash management requirements as noted in the criteria. Questioned Costs: Questioned costs are those that were reported by Department of Education of $75,428. Cause: The University converted from Banner to Jenzabar around the time this draw occurred. At this time the Student Financial Aid activity was in Jenzabar, but the other departments were still using Banner modules. The amount drawn came from totals in Banner and not Jenzabar or what had been reported as disbursed in COD (Common Origination and Disbursement system). Auditor Recommendation: We recommend the University return funds to the Department of Education as noted in the timeframe established by the Department of Education. University Response: The University is committed to following Federal Guidelines. During the fall the University went through a software conversion process, creating a downtime of two weeks. Due to the need to be able to refund students, funds were drawn directly after census date to cover the refunds using information from the prior system. Reconciliations were unable to be completed in the normal timeframe due to the availability of data.

Cash Management U.S. Department of Education Student Financial Aid Cluster: ALN: 84.063 Pell Grant ALN: 84.007 Supplemental Educational Opportunity Grant ALN 84.033 Federal Work Study ALN 84.038 Federal Perkins Loan Program ALN 84.268 Federal Direct Student Loans Criteria: The Department of Education provides funds to an institution under the advance, reimbursement, or heightened cash monitoring payment methods. With the advance payment method, it permits the institution to draw down Title IV funds prior to disbursing funds to eligible students and parents. The institution’s request must not exceed the amount immediately needed to disburse funds to students or parents. A disbursement of funds occurs on the date an institution credits a student’s account or pays a student or parent directly with either SFA funds or institutional funds. The institution must make the disbursement as soon as administratively feasible, but no later than 3 business days following the receipt of funds. The Department of Education considers excess cash to be any amount of Title IV funds that an institution does not disburse to students or parents by the end of the third business day. The Department of Education allows an institution to retain, for up to seven days, excess cash that does not exceed one percent of the total amount of funds drawn by the institution in the prior award year. The institution must return to the Department of Education any excess cash over the tolerable amount (one percent) and any amount remaining after the tolerance period (seven days). Questioned costs would be those in excess of the one percent threshold. Condition: The University drew $1,334,720 for Direct Loans on September 12, 2024, but drew down too much. They were notified by the Department of Education of the overdrawn portion, and a refund was issued on October 25, 2024, for $75,428. The University held excess cash for longer than the allowed time frame. Context: Funds are drawn from the Department of Education periodically throughout the year. This was the only instance of drawing in advance and not returning the funds timely to Department of Education. Effect: The University did not follow cash management requirements as noted in the criteria. Questioned Costs: Questioned costs are those that were reported by Department of Education of $75,428. Cause: The University converted from Banner to Jenzabar around the time this draw occurred. At this time the Student Financial Aid activity was in Jenzabar, but the other departments were still using Banner modules. The amount drawn came from totals in Banner and not Jenzabar or what had been reported as disbursed in COD (Common Origination and Disbursement system). Auditor Recommendation: We recommend the University return funds to the Department of Education as noted in the timeframe established by the Department of Education. University Response: The University is committed to following Federal Guidelines. During the fall the University went through a software conversion process, creating a downtime of two weeks. Due to the need to be able to refund students, funds were drawn directly after census date to cover the refunds using information from the prior system. Reconciliations were unable to be completed in the normal timeframe due to the availability of data.

U.S. Department of Education Student Financial Aid Cluster: ALN: 84.063 Pell Grant ALN: 84.007 Supplemental Educational Opportunity Grant ALN 84.033 Federal Work Study ALN 84.038 Federal Perkins Loan Program ALN 84.268 Federal Direct Student Loans Criteria: The 2023-2024 Federal Student Aid Handbook, Vol 2, Chapter 3, states that the Financial Aid Administrator must be supported by an adequate number of professional and clerical personnel. The number of staff that is adequate depends on the number of students aided, the number and types of programs in which the school participates, the number of applicants evaluated and processed, the number of funds administered, and the type of financial data delivery system the school uses. Internal controls that pertain to Eligibility and Special Tests and Provisions include the accuracy and completeness of data used to determine eligibility requirements, which are reviewed and agreed to support as necessary by staff and reviewed by a knowledgeable supervisor. Manual checklists or automated processes used when making eligibility determinations are reviewed and approved by a knowledgeable supervisor. Calculations of amounts to be received for or on behalf of participants are reperformed by a knowledgeable supervisor. Segregation of duties exists between those determining a participant’s eligibility and those reviewing/approving eligibility. Condition: During the audit, inadequate internal control procedures were in place for the Student Financial Aid programs for reviewing the financial aid award packages for Eligibility and return of funds calculations for Special Tests and Provisions. This function was performed only by the Financial Aid Director, with no indication of review. Context: For most of the audit period, the Financial Aid Director was the only staff member in the department. Effect: Noncompliance with the Federal Student Aid Handbook for adequate staffing. There is the risk of errors in calculating financial aid award packages and return of funds calculations when there are inadequate internal controls. Questioned Costs: None. Cause: The University's Financial Aid Department was understaffed and did not develop alternative control activities to accommodate the staff size. Auditor Recommendation: We recommend the University evaluate and determine if additional staff members need to be hired and implement adequate internal controls over the Student Financial Aid program. University Response: The University of Providence acknowledges the finding related to internal control procedures in the Financial Aid Department. We take compliance with federal guidelines and ensuring the accuracy of financial aid processes seriously. It is important to note that during the audit period, the University of Providence was short one staff member in the department, a position which has now been filled. Corrective actions taken or planned is as follows: 1. Evaluate Opportunity for Staffing Enhancements: The University will create a working group to evaluate the possibility of adding staff within the Financial Aid Department to ensure adequate segregation of duties and adherence to federal requirements. If this is not possible due to budgetary constraints, the VPEM and Director of Financial Aid will explore opportunities to leverage existing support resources within the University to meet the same goal. 2. Implementation of Internal Control Procedures: o Eligibility Determinations: Manual and automated processes for determining eligibility will be reviewed by designated staff members and supervised by a senior-level administrator (Vice President for Enrollment Management) on a semester basis, to ensure compliance with federal guidelines. o Return of Funds Calculations: Return of funds calculations will undergo a dual-review process each semester by the VPEM to mitigate the risk of errors. 3. Training and Documentation: The Financial Aid team will continue to undergo annual training to stay updated on the Federal Student Aid Handbook's requirements. Comprehensive documentation of processes and supervisory review checklists will be implemented to support compliance and maintain transparency. Commitment to Compliance: The University of Providence is committed to maintaining the integrity of our financial aid processes and ensuring compliance with all federal regulations. We will take the necessary steps to rectify this finding and prevent recurrence in future audit periods. Should further information be required, the University is prepared to provide additional details and updates on our progress.

U.S. Department of Education Student Financial Aid Cluster: ALN: 84.063 Pell Grant ALN: 84.007 Supplemental Educational Opportunity Grant ALN 84.033 Federal Work Study ALN 84.038 Federal Perkins Loan Program ALN 84.268 Federal Direct Student Loans Criteria: Direct Subsidized Loans and Direct Unsubsidized Loans have annual loan limits that vary based on the student's grade level and dependency status (34 CFR 685.203). The annual loan limit is the maximum amount that a student may receive for an academic year. Under 34 CFR 685.203(d) and (e), the aggregate loan limits are listed for Direct Subsidized Loans and Direct Unsubsidized Loans (a borrower's maximum allowable outstanding loan debt, excluding capitalized interest, but including amounts borrowed under the Federal Family Education Loan program prior to 2010). Condition: There were four students who exceeded their subsidized loan limits during the audit period. Context: Reports generated from Banner indicated that only four students exceeded this limit for the audit period. Effect: Noncompliance with the federal regulations on loan limits. Questioned Costs: None. Cause: These students were enrolled and attended spring, summer, and fall programs. When the fall amounts were awarded, the summer award had not yet been processed, so there was no overage at the time of the fall award. Once the summer was processed, the students exceeded the loan limit. This error was not caught or corrected during the audit period. Auditor Recommendation: We recommend the University implement internal control procedures to prevent this overage from occurring in future years. University Response: The four students who exceeded their loan limits were Accelerated Nursing Students. The loan offers were made and disbursed for Fall 2024 prior to receiving updated information from the summer disbursements. This is due to a delay in the information that NSLDS provides, resulting in an overpayment. The new ISIR records were not found until this audit period. Of the four students, one was corrected with the Subsidized Loan reallocated to an Unsubsidized Loan. The amount of the reallocation is $656. Of the remaining three students: • Two could not be reallocated because they had already done consolidations • One did not have an unsubsidized loan to reallocate to. In the future, students subject to this timing issue will be monitored closely for Subsidized Loan usage in the first two semesters as it relates to their full eligibility. Since this will always be a timing issue, the financial aid office will leverage all available tools to prevent recurrence and ensure subsidized loans are not over awarded in future years. Jenzabar, our new Student Information System, has reporting tools available for our office to use, and we will utilize these reports to closely follow the students in the ABSN program.

FINDING #2020-001 Student Financial Aid Cluster, TRIO CFDA Numbers: 84.063, 84.033, 84.007, 84.042, 84.268, 84.379 Condition: The University did not retain adequate support for their cash draws made during the year for the Student Financial Aid Cluster (Title IV), and TRIO-Student Support Services. The University draws down federal funds for these programs periodically during the year. The University drew down $80,442 in excess for Direct Loans as of January 31, 2020. This amount was refunded to the Department of Education (ED) on March 16, 2020, which is after the time frame noted in the criteria. The University drew down $55,250 in TRIO funds in excess as of June 30, 2020. These excess funds were not returned to the ED timely. Criteria: The ED provides funds to an institution under the advance, reimbursement, or heightened cash monitoring payment methods. With the advance payment method, it permits the institution to draw down Title IV funds prior to disbursing funds to eligible students and parents. The institution?s request must not exceed the amount immediately needed to disburse funds to students or parents. A disbursement of funds occurs on the date an institution credits a student?s account or pays a student or parent directly with either SFA funds or institutional funds. The institution must make the disbursement as soon as administratively feasible, but no later than 3 business days following the receipt of funds. (34CFR 668.162) ED considers excess cash to be any amount of Title IV funds, other than Perkins Loan funds, that an institution does not disburse to students or parents by the end of the third business day following the date the institution 1) received the funds from ED or 2) deposited or transferred to its depository account previously disbursed Title I funds received from ED, such as those resulting from award adjustments, recoveries or cancellations. For TRIO, the University must minimize the time elapsing between the transfer of funds from the U.S. Treasury and disbursement by the University for direct program or project costs. (2 CFR 200.305) Context: Funds are drawn from ED periodically throughout the year. Effect: The University is not following cash management requirements as noted in the criteria. Questioned Costs: No questioned costs. Cause: The cause for these overdrawn amounts is inadequate review of the draws and agreement of the draw amount to expenses incurred. The 2019 audit was issued in February 2020 and included a similar finding for cash management. The University did not fully implement this recommendation due to timing of the prior audit completion, and not implementing changes to their procedures until mid-year 2020. The overdrawn Direct Loan amounts were noted during the February 2020 reconciliation, but not returned until March 2020. Auditor Recommendation: We recommend the University 1) establish written procedures outlining when to draw for federal funds and what information should be retained to support the draw, 2) retain support for each cash draw made to ensure compliance with the cash management requirements above, and 3) reconcile expenses incurred against funds drawn to determine if amounts need to be returned to ED.

RUS ? Distance Learning and Telemedicine Grant CFDA Number: 10.855 Condition: Our audit identified a deficiency in controls over the preparation of the schedule of expenditures of federal awards (SEFA), which is supplementary information required by the federal government. The information for the U.S. Department of Agriculture, Rural Utility Services Distance Learning and Telemedicine Grant was omitted from the SEFA. Criteria: The auditee must prepare the schedule of expenditures of federal awards (SEFA) for the period covered by the auditee?s financial statements. In accordance with the Uniform Guidance, 2 CFR 200.510(b), the SEFA must include the total amount of federal awards expended. Context: The total amount expended for the year ending June 30, 2020, was $99,504. Effect: Non-compliance with the Uniform Guidance regarding SEFA presentation. The client corrected the SEFA, and it is accurately presented in the report. Questioned Costs: None Cause: When the SEFA information was put together for the audit, the activity for this program was left off the SEFA. Auditor Recommendation: We recommend the University review the SEFA information for completeness and use Banner to adequately code federal programs so they are easily identifiable.

Student Financial Aid Cluster, TRIO and Title III CFDA Numbers: 84.031, 84.063, 84.033, 84.007, 84.042, 84.268 Condition: The University did not retain support for their cash draws made during the year for the Student Financial Aid Cluster (Title IV), TRIO-Student Support Services, or Title III. The University drew down $5,799 in excess for the SEOG program as of June 30, 2019. These excess funds were not returned to the Department of Education (ED) timely. The University drew down $163,308 in excess for Direct Loans as of June 30, 2019. This amount was refunded to ED on July 25, 2019, which is after the time frame noted in the criteria. The University drew down $124,340 in Title III funds in excess as of June 30, 2019. These excess funds were not returned to the ED timely. Criteria: The ED provides funds to an institution under the advance, reimbursement, or cash monitoring payment methods. With the advance payment method, it permits the institution to draw down Title IV funds prior to disbursing funds to eligible students and parents. The institution?s request must not exceed the amount immediately needed to disburse funds to students or parents. A disbursement of funds occurs on the date an institution credits a student?s account or pays a student or parent directly with either SFA funds or institutional funds. The institution must make the disbursement as soon as administratively feasible, but no later than 3 business days following the receipt of funds. Any amounts not distributed by the end of the third business day are considered to be excess cash and generally are required to be promptly returned to ED. However, an excess cash balance tolerance is allowed if that balance is 1) less than 1% of its prior-year drawdowns and 2) is eliminated within the next 7 calendar days. (34 CFR 668.166). For Title III and TRIO, the University must minimize the time elapsing between the transfer of funds from the U.S. Treasury and disbursement by the University for direct program or project costs. (2 CFR 200.305) Context: Funds are drawn from ED periodically throughout the year. Effect: The University is not following cash management requirements as noted in the criteria. Questioned Costs: No questioned costs. Cause: The University had employee turnover in the finance department during the audit period. Adequate support for the draws occurring during the year was not retained. New staff attempted to re-create the disbursements to students and expenses and were unable to get adequate support for all draw amounts made during the year. For the Student Financial Aid Cluster, reconciliations were not done routinely during the year between the general ledger and the accounts receivable module in Banner, which shows support for the student financial aid awards distributed. Auditor is Recommendation: We recommend the University retain support for each cash draw made to ensure compliance with the cash management requirements above and perform routine reconciliations between the general ledger and the accounts receivable module in Banner. University Response: As of 02.05.20, all reconciliations have been developed and reconciled to current period ending 01.31.20 and will continue to be reconciled on a monthly basis. Other departments involved with developing funds needing to be drawn from Dept of Education have been notified of process enforcement and they intend to provide all documentation necessary to comply with Dept of Education going forward.

TRIO ? Student Support Services CFDA Number: 84.042 Condition: The University did not retain adequate information to support the services provided to TRIO Student Support Services (SSS) participants. Criteria: Services and activities that a SSS project must provide include: ? Academic tutoring; ? Advice and assistance in postsecondary course selection; ? Information on the full range of Federal student financial aid programs and benefits and resources for locating public and private scholarships; ? Education or counseling services designed to improve the financial and economic literacy of students; ? Activities designed to assist participants enrolled in a 4-year institution in applying for admission to graduate and professional programs. Services and activities that a SSS project may provide include: ? Individualized counseling for personal, career and academic matters provided by assigned counselors; ? Information activities and instruction designed to acquaint students with the range of career options available to students; ? Exposure to cultural events and academic programs not usually available to disadvantaged students; ? Mentoring programs involving faculty or upper-class students, or a combination thereof; ? Securing temporary housing during breaks in the academic year; ? Other activities designed to meet the purposes of the SSS program. Context: The University retains hard copy files as well as digital files for students. Counselors may also take notes on their interactions with students. We tested 25 students enrolled in TRIO during the audit period and of those tested, three did not have information showing the services provided. Effect: From the documentation provided by the University, we are unable to determine if those three students received the services required under the SSS program. Questioned Costs: No questioned costs. Cause: There were no hard copy files for these three students, and personnel could not find support for services rendered to them. Auditor is Recommendation: We recommend the University retain support for each student to demonstrate the University?s compliance with the SSS program and that each student is receiving the required services. University Response: As a result of this finding the University will scan and upload all student documents to www.studentaccess.com for Student Support Services (www.studentaccess.com in a secure site that houses student data, and is the tool used by the director to submit the annual performance reports to the Department of Education). The electronic record keeping is in addition to ensuring that hard copy files exist for all students being served by the grant. Documentation for services provided will also be tracked by each counselor in www.studentaccess.com. New student applications will be received electronically and uploaded to www.studentaccess.com within 48 business hours of receipt. A thorough review of all student files electronic and hard copy will take place at the conclusion of each semester to ensure compliance.

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