ILIFF SCHOOL OF THEOLOGY

Assistance Listing Number, Federal Agency, and Program Name 84.268; U.S. Department of Education; Student Financial Assistance Cluster; Federal Direct Student Loan Program Federal Award Identification Number and Year June 1, 2024 to May 31, 2025 Pass through Entity N/A Finding Type Significant deficiency and material noncompliance with laws and regulations Repeat Finding Yes 2021 011, 2022 007, 2023 007, 2024 004 Criteria In accordance with 34 CFR 685.300(b)(9) and electronic announcement November 13, 2013, Direct Loan Quality Assurance Requirement Reminder, institutions of higher education are requested to document a Direct Loan quality assurance program. Condition The School did not have a documented Direct Loan quality assurance program in place during a significant portion of the year under audit. Questioned Costs None If Questioned Costs Are Not Determinable, Description of Why Known Questioned Costs Were Undetermined or Otherwise Could Not Be Reported Finding relates to a policy not in place, which would not impact award amounts. Identification of How Questioned Costs Were Computed N/A Context During our testing, management stated that the School implemented its Direct Loan quality assurance program in March 2025; therefore, the policy was not in place during a significant portion of the year. Cause and Effect During a significant portion of the year, the School did not have a policy in place to ensure that its Direct Loan quality assurance efforts are documented in accordance with federal regulations. Recommendation We recommend the School establish the required Direct Loan quality assurance program and that contemporaneous evidence of consistent adherence to such a program be maintained. Views of Responsible Officials and Corrective Action Plan There is no disagreement with the audit finding. The Iliff School of Theology has contracted with a professional third party processing company to administer its student assistance programs. The School coordinated with this third party processor to ensure that a documented quality assurance program was put into place in March 2025 and regularly exercised for compliance purposes. All documentation will be maintained.

Assistance Listing Number, Federal Agency, and Program Name - 84.268; U.S. Department of Education; Student Financial Assistance Cluster; Federal Direct Student Loan Program Federal Award Identification Number and Year - June 1, 2023 to May 31, 2024 Pass through Entity - N/A Finding Type - Material weakness and material noncompliance with laws and regulations Repeat Finding - Yes 2020-003, 2021-003, 2022-002, 2023-002 Criteria - Schools are required to report enrollment information under the Direct Loan program via the National Student Loan Data System (NSLDS). The administration of the Title IV Student Financial Assistance programs depends heavily on the accuracy and timeliness of the enrollment information reported by institutions. Institutions must review, update, and verify student enrollment statuses, program information, and effective dates that appear on the Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS Professional Access (NSLDSFAP) website. There are two categories of enrollment information, campus level and program level, both of which need to be reported accurately. Condition - Our audit procedures identified instances of untimely reporting of enrollment information to NSLDS. Questioned Costs - None If Questioned Costs are not Determinable, Description of Why Known Questioned Costs were Undetermined or Otherwise could not be Reported - Finding relates to the timeliness of enrollment reporting, which does not impact award amounts. Identification of How Questioned Costs Were Computed - N/A Context - During our testing of a sample of four students, we noted the student enrollment was not reported within the required 60 day time period for two students. Cause and Effect - The School has neither a process nor controls in place to ensure that campus level data and program level student enrollment information is reported to NSLDS in a timely manner. Untimely reporting of student enrollment data to NSLDS results in noncompliance with federal regulations and untimely data listed within NSLDS. Student information within NSLDS is used to determine award packaging for students attending multiple institutions and repayment periods on direct student loans; stale data within NSLDS could lead to improper award packaging and repayment period determinations. Recommendation - We recommend the School implement a control to ensure all campus level and program level student enrollment information is reported to NSLDS timely in accordance with the federally required timelines. Views of Responsible Officials and Corrective Action Plan - There is no disagreement with the audit finding. The Iliff School of Theology has contracted with a professional, third party processing company to administer its student assistance programs. The School has also ensured that this third party processor is properly coordinated with the registrar’s office to meet federal requirements for NSLDS enrollment reporting.

Assistance Listing Number, Federal Agency, and Program Name - 84.033, 84.038, 84.268; U.S. Department of Education; Student Financial Assistance Cluster Federal Award Identification Number and Year - June 1, 2023 to May 31, 2024 Pass through Entity - N/A Finding Type - Material weakness and material noncompliance with laws and regulations Repeat Finding - Yes 2021-006, 2022-004, 2023-004 Criteria - Institutions of higher education are required to submit a Fiscal Operations Report and Application to Participate (FISAP) to the U.S. Department of Education. This electronic report is submitted annually to receive funds for the campus based programs. The School uses the Fiscal Operations Report portion to report its expenditures in the previous award year and the Application to Participate portion to apply for the following year. Condition - The School submitted a FISAP to the U.S. Department of Education that reported inaccurate information in several data fields within the report. In addition, there was no evidence that an individual other than the preparer reviewed the report. Questioned Costs - None If Questioned Costs are not Determinable, Description of Why Known Questioned Costs were Undetermined or Otherwise could not be Reported - Finding relates to inaccurate information included in the FISAP, which does not impact award amounts. Identification of How Questioned Costs Were Computed - N/A Context - During our testing, we noted inaccurate information in data field Part II, Section D (Information for Enrollment), Line 7b: The School reported 150 graduates enrolled for fiscal year 2022 2023. This figure did not agree to supporting documentation, and management determined that the number reported was based on the unduplicated graduate count for fall 2022. Management noted that the number that should have been reported for the 2022 2023 school year was 209. Management also noted that there was not a formal and documented review process of the FISAP report by someone other than the preparer. Cause and Effect - The School did not have a control in place to ensure that accurate information was submitted to the U.S. Department of Education in the FISAP report. Submission of inaccurate information in the FISAP report may result in noncompliance with federal regulations and inaccurate awarding of federal student financial assistance amounts in subsequent fiscal years. Recommendation - We recommend the School implement a reconciliation and review control where an individual with sufficient student financial assistance and financial understanding reviews the FISAP report to underlying institutional information to ensure accurate information is submitted with the FISAP report. Evidence of such a review and documentation supporting information reported in the FISAP should be documented and maintained. Views of Responsible Officials and Planned Corrective Actions - There is no disagreement with the audit finding. The Iliff School of Theology has contracted with a professional, third party processing company to administer its student assistance programs. Preparation and submission of the FISAP will be completed with coordination between the VP of business and the third party processor. This includes a quality review process for accuracy.

Assistance Listing Number, Federal Agency, and Program Name - 84.268; U.S. Department of Education; Student Financial Assistance Cluster; Federal Direct Student Loan Program Federal Award Identification Number and Year - June 1, 2023 to May 31, 2024 Pass through Entity - N/A Finding Type - Material weakness and material noncompliance with laws and regulations Repeat Finding - Yes 2021-011, 2022-007, 2023-007 Criteria - In accordance with 34 CFR 685.300(b)(9) and electronic announcement November 13, 2013, Direct Loan Quality Assurance Requirement Reminder, institutions of higher education are requested to document a Direct Loan quality assurance program. Condition - The School does not have a documented Direct Loan quality assurance program. Questioned Costs - None If Questioned Costs are not Determinable, Description of Why Known Questioned Costs were Undetermined or Otherwise could not be Reported - Finding relates to a policy not in place, which would not impact award amounts. Identification of How Questioned Costs Were Computed - N/A Context - During our testing, management stated that the School does not have a documented Direct Loan quality assurance program. Cause and Effect - The School does not have a process in place to ensure that its Direct Loan quality assurance efforts are documented in accordance with federal regulations. The lack of a documented Direct Loan quality assurance program for the School results in noncompliance with federal regulations. Recommendation - We recommend the School establish the required Direct Loan quality assurance program and that contemporaneous evidence of consistent adherence to such a program be maintained. Views of Responsible Officials and Planned Corrective Actions - There is no disagreement with the audit finding. The Iliff School of Theology has contracted with a professional, third party processing company to administer its student assistance programs. The School will coordinate with this third party processor to ensure that there is a documented quality assurance program that is regularly exercised for compliance purposes. All documentation will be maintained.

Assistance Listing Number, Federal Agency, and Program Name - 84.268; U.S. Department of Education; Student Financial Assistance Cluster; Federal Direct Student Loan Program Federal Award Identification Number and Year - June 1, 2022 to May 31, 2023 Finding Type - Material weakness and material noncompliance with laws and regulations Repeat Finding - Yes 2020-003, 2021-003, 2022-002 Criteria - Schools are required to report enrollment information under the Direct Loan program via the National Student Loan Data System (NSLDS). The administration of the Title IV Student Financial Assistance programs depends heavily on the accuracy and timeliness of the enrollment information reported by institutions. Institutions must review, update, and verify student enrollment statuses, program information, and effective dates that appear on the Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS Professional Access (NSLDSFAP) website. There are two categories of enrollment information, campus level and program level, both of which need to be reported accurately. Condition - Our audit procedures identified instances of inaccurate or untimely reporting of enrollment information to NSLDS. Questioned Costs - None Context - During our testing of a sample of seven students, we noted the following exceptions: 1) For five students, student enrollment was not certified within the required 60 day time period. 2) For two students, the students were reported inaccurately as withdrawn and should have been reported as graduated. Cause and Effect - The School has neither a process or controls in place to ensure that campus level data and program level student enrollment information is reported to NSLDS in a timely and accurate manner. Untimely and inaccurate reporting of student enrollment data to NSLDS results in noncompliance with federal regulations and untimely or inaccurate data listed within NSLDS. Student information within NSLDS is used to determine award packaging for students attending multiple institutions and repayment periods on direct student loans; inaccurate or stale data within NSLDS could lead to improper award packaging and repayment period determinations. Recommendation - We recommend the School implement a control to ensure all campus level and program level student enrollment information is reported to NSLDS timely and accurately in accordance with the federally required timelines. Views of Responsible Officials and Corrective Action Plan - There is no disagreement with the audit finding. The Iliff School of Theology has contracted with a professional, third party processing company to administer its student assistance programs. The School has also ensured that this third party processor is properly coordinated with the registrar’s office to meet federal requirements for NSLDS enrollment reporting.

Assistance Listing Number, Federal Agency, and Program Name - 84.033, 84.038, 84.268; U.S. Department of Education; Student Financial Assistance Cluster Federal Award Identification Number and Year - June 1, 2022 to May 31, 2023 Finding Type - Material weakness and material noncompliance with laws and regulations Repeat Finding - Yes 2020-004, 2021-004, 2022-003 Criteria - An institution must ensure that its administrative procedures for the Title IV HEA programs include an adequate system of internal checks and balances (34 CFR 668.16(c)). This system, at a minimum, must separate the functions of authorizing payment and disbursing or delivering funds so that no single person or office exercises both functions for any student receiving FSA funds. Condition - Due to the limited number of personnel within the financial assistance department, the director of financial assistance is solely responsible for packaging, awarding, and disbursing to student accounts federal student financial assistance (Title IV) as well as calculating return of Title IV funds for students who withdraw from the School to student accounts. The packaging of Title IV assistance and the return of Title IV funds are complex calculations that are not formally reviewed by another employee. Questioned Costs - None Context - During our discussions with management and through review of supporting documentation of the audit, we noted the director of financial assistance is solely responsible for packaging and awarding Title IV assistance, as well as calculating and determining return of Title IV funds for students who withdraw from the School. Cause and Effect - The School currently does not have a process in place to sufficiently segregate duties within its financial assistance department. Nor does it have compensating controls in place to mitigate the risks of the lack of segregation of duties. The financial assistance director can unilaterally package, award, and disburse Title IV assistance to student accounts and calculate and refund return of Title IV funds to student accounts. This increases the risk that noncompliance with federal regulations, questioned costs, inaccuracies, and improprieties could occur and not be detected on a timely basis. Recommendation - We recommend the School implement adequate segregation of duties within the financial assistance department. If segregating duties within the financial assistance department is not practical, we recommend that management implement controls to ensure that actions unilaterally performed by one individual are reviewed by another knowledgeable individual. Evidence of such review should be documented and maintained. Views of Responsible Officials and Planned Corrective Actions - There is no disagreement with the audit finding. The Iliff School of Theology has contracted with a professional, third party processing company to administer its student assistance programs. This third party processing company is structured to properly segregate financial processing and includes a quality review function.

Assistance Listing Number, Federal Agency, and Program Name - 84.033, 84.038, 84.268; U.S. Department of Education; Student Financial Assistance Cluster Federal Award Identification Number and Year - June 1, 2022 to May 31, 2023 Finding Type - Material weakness and material noncompliance with laws and regulations Repeat Finding - Yes 2021-006, 2022-004 Criteria - Institutions of higher education are required to submit a Fiscal Operations Report and Application to Participate (FISAP) to the U.S. Department of Education. This electronic report is submitted annually to receive funds for the campus based programs. The School uses the Fiscal Operations Report portion to report its expenditures in the previous award year and the Application to Participate portion to apply for the following year. Condition - The School submitted a FISAP to the U.S. Department of Education that reported inaccurate information in several data fields within the report. In addition, there was no evidence that an individual other than the preparer reviewed the report. Questioned Costs - None Context - During our testing, we noted the following instances of inaccurate information in several data fields: • Part II, Section D (Information for Enrollment), Line 7b: The School reported 172 graduates enrolled for fiscal year 2021 2022. This figure did not agree to supporting documentation, and management determined that the number reported was based on the unduplicated graduate count for fall 2021. Management noted that the number that should have been reported for the 2021 2022 school year was 176. • Part II, Section F (Information on Eligible Aid Applicants Enrolled in Your School for Award Year 2021 2022). Certain information related to students taxable and untaxable information did not agree to the underlying supporting documentation. • Part III, Section A (Fiscal Report (Cumulative) as of June 30, 2022). Certain information related to students Perkins Loan information did not agree to the underlying supporting documentation. Management noted that there was not a formal and documented review process of the FISAP report by someone other than the preparer. Cause and Effect - The School did not have a control in place to ensure that accurate information was submitted to the U.S. Department of Education in the FISAP report. Submission of inaccurate information in the FISAP report may result in noncompliance with federal regulations and inaccurate awarding of federal student financial assistance amounts in subsequent fiscal years. Recommendation - We recommend the School implement a reconciliation and review control hereby an individual with sufficient student financial assistance and financial understanding reviews the FISAP report to underlying institutional information to ensure accurate information is submitted with the FISAP report. Evidence of such a review and documentation supporting information reported in the FISAP should be documented and maintained. Views of Responsible Officials and Planned Corrective Actions - There is no disagreement with the audit finding. The Iliff School of Theology has contracted with a professional, third party processing company to administer its student assistance programs. Preparation and submission of the FISAP will be completed with coordination between the VP of business and the third party processor. This includes a quality review process for accuracy.

Assistance Listing Number, Federal Agency, and Program Name - 84.268; U.S. Department of Education; Student Financial Assistance Cluster; Federal Direct Student Loan Program Federal Award Identification Number and Year - June 1, 2022 to May 31, 2023 Finding Type - Material weakness and material noncompliance with laws and regulations Repeat Finding - Yes 2021-007, 2022-005 Criteria - The Code of Federal Regulations, 34 CFR 685.300(b)(5), requires the School, on a monthly basis, to reconcile the institutional records with the Direct Loan funds received from the secretary of the U.S. Department of Education and the Direct Loan disbursement records submitted to and accepted by the secretary of the U.S. Department of Education. Condition - The School does not reconcile institutional records with Direct Loan funds received from the secretary of the U.S. Department of Education and the Direct Loan disbursement records submitted to and accepted by the secretary of the U.S. Department of Education. Questioned Costs - None Context - During our testing, management stated that the School did not reconcile institutional records with Direct Loan funds received from the secretary of the U.S. Department of Education and the Direct Loan disbursement records submitted to and accepted by the secretary of the U.S. Department of Education for the entire fiscal year ended May 31, 2023. Cause and Effect - The School does not have a control in place to ensure Direct Loan program reconciliations are performed on a monthly basis. The lack of a control in place to ensure Direct Loan program reconciliations are performed on a monthly basis results in noncompliance with federal regulations. Recommendation - We recommend that the School implement a control to ensure Direct Loan program reconciliations are performed on a monthly basis. Views of Responsible Officials and Planned Corrective Actions - There is no disagreement with the audit finding. The Iliff School of Theology has contracted with a professional, third party processing company to administer its student assistance programs who will ensure that Direct Loan reconciliations are conducted on a monthly basis in coordination with the business office.

Assistance Listing Number, Federal Agency, and Program Name - 84.268; U.S. Department of Education; Student Financial Assistance Cluster; Federal Direct Student Loan Program Federal Award Identification Number and Year - June 1, 2022 to May 31, 2023 Finding Type - Material weakness and material noncompliance with laws and regulations Repeat Finding - Yes 2021-008, 2022-006 Criteria - When a recipient of Title IV grant or loan assistance withdraws from an institution during a payment period or period of enrollment in which the recipient began attendance, the institution must determine the amount of Title IV assistance earned by the student as of the student’s withdrawal date. If the total amount of Title IV assistance earned by the student is less than the amount that was disbursed to the student or on his or her behalf as of the date of the institution’s determination that the student withdrew, the difference must be returned to the Title IV programs as outlined in this section, and no additional disbursements may be made to the student for the payment period or period of enrollment. If the amount the student earned is greater than the amount disbursed, the difference between the amounts must be treated as a postwithdrawal disbursement (34 CFR 668.22(a)(1) through (a)(5)). Condition - Our audit procedures identified an instance where the School could not locate evidence that the required Return to Title IV Funds (R2T4) calculations under federal regulation was complete. The total assistance disbursed to this student was $13,596. Questioned Costs - $13,596 Identification of How Questioned Costs Were Computed - As of the date of the report, the School has not completed the required R2T4 calculation. Therefore, the questioned cost is equal to the total assistance disbursed to this student. Context - During our testing, we noted that for one student tested, management could not locate evidence that an R2T4 calculation was performed as required by federal regulations and the proper amount of assistance was returned. Cause and Effect - The School does not have a process in place to ensure that all required R2T4 calculations under federal regulations are performed accurately and on a timely basis and that all funds are returned within the required time frame. The lack of a process to ensure that all required R2T4 calculations under federal regulations are performed accurately and timely results in noncompliance with federal regulations. Recommendation - We recommend that management implement processes and controls to ensure that all required R2T4 calculations under federal regulations are performed accurately and on a timely basis. Such calculations should be reviewed by an individual other than the preparer, and contemporaneous evidence of such a review should be maintained. Views of Responsible Officials and Planned Corrective Actions - There is no disagreement with the audit finding. The Iliff School of Theology has contracted with a professional, third party processing company to administer its student assistance programs. This third party processor is adequately skilled to complete Return of Title IV calculations and includes an established review process for quality control. All documentation will be maintained.

Assistance Listing Number, Federal Agency, and Program Name - 84.268; U.S. Department of Education; Student Financial Assistance Cluster; Federal Direct Student Loan Program Federal Award Identification Number and Year - June 1, 2022 to May 31, 2023 Finding Type - Material weakness and material noncompliance with laws and regulations Repeat Finding - Yes 2021-011, 2022-007 Criteria - In accordance with 34 CFR 685.300(b)(9) and electronic announcement November 13, 2013, Direct Loan Quality Assurance Requirement Reminder, institutions of higher education are requested to document a Direct Loan quality assurance program. Condition - The School does not have a documented Direct Loan quality assurance program. Questioned Costs - None Context - During our testing, management stated that the School does not have a documented Direct Loan quality assurance program. Cause and Effect - The School does not have a process in place to ensure that its Direct Loan quality assurance efforts are documented in accordance with federal regulations. The lack of a documented Direct Loan quality assurance program for the School results in noncompliance with federal regulations. Recommendation - We recommend the School establish the required Direct Loan quality assurance program and that contemporaneous evidence of consistent adherence to such a program be maintained. Views of Responsible Officials and Planned Corrective Actions - There is no disagreement with the audit finding. The Iliff School of Theology has contracted with a professional, third party processing company to administer its student assistance programs. The School will coordinate with this third party processor to ensure that there is a documented quality assurance program that is regularly exercised for compliance purposes. All documentation will be maintained.

Assistance Listing Number, Federal Agency, and Program Name - 84.268; U.S. Department of Education; Student Financial Assistance Cluster; Federal Direct Student Loan Program Federal Award Identification Number and Year - June 1, 2022 to May 31, 2023 Finding Type - Material weakness and material noncompliance with laws and regulations Repeat Finding - Yes 2021-012, 2022-008 Criteria - Institutions of higher education are required to establish written policies and procedures that incorporate the provisions of 34 CFR 668.51 through 668.61 for verifying applicant information. Institutions shall require each applicant whose application is selected by the U.S. Department of Education to verify the information required for the Verification Tracking Group to which the applicant is assigned. Condition - The School does not have written policies and procedures that incorporate the provisions of 34 CFR 668.51 through 668.61. Questioned Costs - None Context - During our testing, management noted that the School does not have written verification procedures. Cause and Effect - The School does not have a process in place to ensure that its verification procedures are documented in accordance with federal regulations. The lack of written verification procedures of the School results in noncompliance with federal regulations. Recommendation - We recommend the School establish written verification procedures and that contemporaneous evidence of consistent adherence to such procedures be maintained. Views of Responsible Officials and Planned Corrective Actions - There is no disagreement with the audit finding. The Iliff School of Theology has contracted with a professional, third party processing company to administer its student assistance programs. All verification procedures are established, and documentation will be maintained to demonstrate compliance.

Assistance Listing Number, Federal Agency, and Program Name - 84.268; U.S. Department of Education; Student Financial Assistance Cluster; Federal Direct Student Loan Program Federal Award Identification Number and Year - June 1, 2022 to May 31, 2023 Finding Type - Material weakness and material noncompliance with laws and regulations Repeat Finding - Yes 2021-013, 2022-009 Criteria - In accordance with 34 CFR 682.604, a Direct Loan student borrower who is graduating, leaving school, or dropping below half time enrollment is required to complete exit counseling. Condition - The School does not have evidence that exit counseling was provided to students who withdrew or graduated, as required by 34 CFR 682.604. Questioned Costs - None Context - During our testing, the School was unable to provide evidence that exit counseling was completed for eight students who withdrew or graduated during the audit period. Cause and Effect - The School does not have a process in place to ensure that student borrowers who graduate, withdraw, or drop below half time enrollment complete exit counseling in accordance with federal regulations. The lack of controls to ensure student borrowers who graduate, withdraw, or drop below half time enrollment complete exit counseling results in noncompliance with federal regulations. Recommendation - We recommend management implement controls to ensure that student borrowers who graduate, withdraw, or drop below halftime enrollment complete exit counseling in accordance with federal regulations. Views of Responsible Officials and Planned Corrective Actions - There is no disagreement with the audit finding. The Iliff School of Theology has contracted with a professional, third party processing company to administer its student assistance programs. The School has also ensured that this third party processor is properly coordinated with the registrar’s office to meet federal requirements for exit counseling when status changes are processed.

Assistance Listing Number, Federal Agency, and Program Name - 84.268; U.S. Department of Education; Student Financial Assistance Cluster; Federal Direct Student Loan Program Federal Award Identification Number and Year - June 1, 2021 to May 31, 2022 Finding Type - Material weakness and material noncompliance with laws and regulations Repeat Finding - Yes 2020-003; 2021-003 Criteria - Schools are required to report enrollment information under the Direct Loan program via the National Student Loan Data System (NSLDS). The administration of the Title IV Student Financial Assistance programs depends heavily on the accuracy and timeliness of the enrollment information reported by institutions. Institutions must review, update, and verify student enrollment statuses, program information, and effective dates that appear on the Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS Professional Access (NSLDSFAP) website. There are two categories of enrollment information, campus level and program level, both of which need to be reported accurately. Condition - Our audit procedures identified instances of inaccurate or untimely reporting of enrollment information to NSLDS. Questioned Costs - None Context - During our testing of a sample of eight students, we noted the following exceptions: 1) For one student, student enrollment was not certified within the required 60 day time period. 2) For four students, program codes (CIP) in NLSDS did not agree to the description of the students’ enrolled program at the School (program level data). Cause and Effect - The School has neither a process nor controls in place to ensure that campus level data and program level student enrollment information is reported to NSLDS in a timely and accurate manner. Untimely and inaccurate reporting of student enrollment data to NSLDS results in noncompliance with federal regulations and untimely or inaccurate data listed within NSLDS. Student information within NSLDS is used to determine award packaging for students attending multiple institutions and repayment periods on direct student loans; inaccurate or stale data within NSLDS could lead to improper award packaging and repayment period determinations. Recommendation - We recommend the School implement a control to ensure all campus level and program level student enrollment information is reported to NSLDS timely and accurately in accordance with the federally required timelines. Views of Responsible Officials and Planned Corrective Actions - There is no disagreement with the audit finding. The Iliff School of Theology has contracted with a professional, third party processing company to administer its student assistance programs. The School has also ensured that this third party processor is properly coordinated with the registrar’s office to meet federal requirements for NSLDS enrollment reporting.

Assistance Listing Number, Federal Agency, and Program Name - 84.033, 84.038, 84.268; U.S. Department of Education; Student Financial Assistance Cluster Federal Award Identification Number and Year - June 1, 2021 to May 31, 2022 Finding Type - Material weakness and material noncompliance with laws and regulations Repeat Finding - Yes 2020-004, 2021-004 Criteria - An institution must ensure that its administrative procedures for the Title IV HEA programs include an adequate system of internal checks and balances (34 CFR 668.16(c)). This system, at a minimum, must separate the functions of authorizing payment and disbursing or delivering funds so that no single person or office exercises both functions for any student receiving FSA funds. Condition - Due to the limited number of personnel within the financial assistance department, the director of financial assistance is solely responsible for packaging, awarding, and disbursing to student accounts federal student financial assistance (Title IV) as well as calculating return of Title IV funds for students who withdraw from the School to student accounts. The packaging of Title IV assistance and the return of Title IV funds are complex calculations that are not formally reviewed by another employee. Questioned Costs - None Context - During our discussions with management and through review of supporting documentation of the audit, we noted the director of financial assistance is solely responsible for packaging and awarding Title IV assistance, as well as calculating and determining return of Title IV funds for students who withdraw from the School. Cause and Effect - The School currently does not have a process in place to sufficiently segregate duties within its financial assistance department. Nor does it have compensating controls in place to mitigate the risks of the lack of segregation of duties. The financial assistance director can unilaterally package, award, and disburse Title IV assistance to student accounts and calculate and refund return of Title IV funds to student accounts. This increases the risk that noncompliance with federal regulations, questioned costs, inaccuracies, and improprieties could occur and not be detected on a timely basis. Recommendation - We recommend the School implement adequate segregation of duties within the financial assistance department. If segregating duties within the financial assistance department is not practical, we recommend that management implement controls to ensure that actions unilaterally performed by one individual are reviewed by another knowledgeable individual. Evidence of such review should be documented and maintained. Views of Responsible Officials and Planned Corrective Actions - There is no disagreement with the audit finding. The Iliff School of Theology has contracted with a professional, third party processing company to administer its student assistance programs. This third party processing company is structured to properly segregate financial processing and includes a quality review function.

Assistance Listing Number, Federal Agency, and Program Name - 84.033, 84.038, 84.268; U.S. Department of Education; Student Financial Assistance Cluster Federal Award Identification Number and Year - June 1, 2021 to May 31, 2022 Finding Type - Material weakness and material noncompliance with laws and regulations Repeat Finding - Yes 2021-006 Criteria - Institutions of higher education are required to submit a Fiscal Operations Report and Application to Participate (FISAP) to the U.S. Department of Education. This electronic report is submitted annually to receive funds for the campus based programs. The School uses the Fiscal Operations Report portion to report its expenditures in the previous award year and the Application to Participate portion to apply for the following year. Condition - The School submitted a FISAP to the U.S. Department of Education that reported inaccurate information in several data fields within the report. In addition, there was no evidence that an individual other than the preparer reviewed the report. Questioned Costs - None Context - During our testing, we noted the following instances of inaccurate information in several data fields: • Part I, Section A (Identifying Information), Line 3 (Type of School): We noted that the School was listed as a “public institution,” when it is actually operating as a “private/non profit institution.” • Part II, Section D (Information for Enrollment), Line 7b: The School reported 166 graduates enrolled for fiscal year 2020-2021. This figure did not agree to supporting documentation, and management determined that the number reported was based on the unduplicated graduate count for fall 2020. Management noted that the number that should have been reported for the 2020-2021 school year was 188. The School updated this figured in a revised FISAP report that was filed on December 15, 2021. • Part V, Section A (Federal Funds Authorized for Federal Work Study), Line 1: In its revised FISAP submitted on December 15, 2021, we noted that the School listed the total amount of federal work study funds disbursed during the 2020-2021 fiscal year as opposed to the final authorized federal work study funds for the 2020-2021 fiscal year. Management noted that there was not a formal and documented review process of the FISAP report by someone other than the preparer. Cause and Effect - The School did not have a control in place to ensure that accurate information was submitted to the U.S. Department of Education in the FISAP report. Submission of inaccurate information in the FISAP report may result in noncompliance with federal regulations and inaccurate awarding of federal student financial assistance amounts in subsequent fiscal years. Recommendation - We recommend the School implement a reconciliation and review control whereby an individual with sufficient student financial assistance and financial understanding reviews the FISAP report to underlying institutional information to ensure accurate information is submitted with the FISAP report. Evidence of such a review and documentation supporting information reported in the FISAP should be documented and maintained. Views of Responsible Officials and Planned Corrective Actions - There is no disagreement with the audit finding. The Iliff School of Theology has contracted with a professional, third party processing company to administer its student assistance programs. Preparation and submission of the FISAP will be completed with coordination between the VP of business and the third party processor. This includes a quality review process for accuracy.

Assistance Listing Number, Federal Agency, and Program Name - 84.268; U.S. Department of Education; Student Financial Assistance Cluster; Federal Direct Student Loan Program Federal Award Identification Number and Year - June 1, 2021 to May 31, 2022 Finding Type - Material weakness and material noncompliance with laws and regulations Repeat Finding - Yes 2021-007 Criteria - The Code of Federal Regulations, 34 CFR 685.300(b)(5), requires the School, on a monthly basis, to reconcile the institutional records with the Direct Loan funds received from the secretary of the U.S. Department of Education and the Direct Loan disbursement records submitted to and accepted by the secretary of the U.S. Department of Education. Condition - The School does not reconcile institutional records with Direct Loan funds received from the secretary of the U.S. Department of Education and the Direct Loan disbursement records submitted to and accepted by the secretary of the U.S. Department of Education. Questioned Costs - None Context - During our testing, management stated that the School did not reconcile institutional records with Direct Loan funds received from the secretary of the U.S. Department of Education and the Direct Loan disbursement records submitted to and accepted by the secretary of the U.S. Department of Education for the entire fiscal year ended May 31, 2022. Cause and Effect - The School does not have a control in place to ensure Direct Loan program reconciliations are performed on a monthly basis. The lack of a control in place to ensure Direct Loan program reconciliations are performed on a monthly basis results in noncompliance with federal regulations. Recommendation - We recommend the School implement a control to ensure Direct Loan program reconciliations are performed on a monthly basis. Views of Responsible Officials and Planned Corrective Actions - There is no disagreement with the audit finding. The Iliff School of Theology has contracted with a professional, third party processing company to administer its student assistance programs who will ensure that Direct Loan reconciliations are conducted on a monthly basis in coordination with the business office.

Assistance Listing Number, Federal Agency, and Program Name - 84.268; U.S. Department of Education; Student Financial Assistance Cluster; Federal Direct Student Loan Program; Federal Direct Student Loan Program Federal Award Identification Number and Year - June 1, 2021 to May 31, 2022 Finding Type - Material weakness and material noncompliance with laws and regulations Repeat Finding - Yes 2021-008 Criteria - When a recipient of Title IV grant or loan assistance withdraws from an institution during a payment period or period of enrollment in which the recipient began attendance, the institution must determine the amount of Title IV assistance earned by the student as of the student’s withdrawal date. If the total amount of Title IV assistance earned by the student is less than the amount that was disbursed to the student or on his or her behalf as of the date of the institution’s determination that the student withdrew, the difference must be returned to the Title IV programs as outlined in this section, and no additional disbursements may be made to the student for the payment period or period of enrollment. If the amount the student earned is greater than the amount disbursed, the difference between the amounts must be treated as a postwithdrawal disbursement (34 CFR 668.22(a)(1) through (a)(5)). Condition - Our audit procedures identified an instance where the School could not locate evidence that the required Return to Title IV Funds (R2T4) calculation under federal regulation was completed. The total assistance disbursed to this student was $5,125. Questioned Costs - $5,125 Identification of How Questioned Costs Were Computed - As of the date of the report, the School has not completed the required R2T4 calculation. Therefore, the questioned cost is equal to the total assistance disbursed to this student. Context - During our testing, we noted that for one student tested, management could not locate evidence that an R2T4 calculation was performed as required by federal regulations and the proper amount of assistance was returned. Cause and Effect - The School does not have a process in place to ensure that all required R2T4 calculations under federal regulations are performed accurately and on a timely basis and that all funds are returned within the required time frame. The lack of a process to ensure that all required R2T4 calculations under federal regulations are performed accurately and timely results in noncompliance with federal regulations. Recommendation - We recommend management implement processes and controls to ensure that all required R2T4 calculations under federal regulations are performed accurately and on a timely basis. Such calculations should be reviewed by an individual other than the preparer, and contemporaneous evidence of such a review should be maintained. Views of Responsible Officials and Planned Corrective Actions - There is no disagreement with the audit finding. The Iliff School of Theology has contracted with a professional, third party processing company to administer its student assistance programs. This third party processor is adequately skilled to complete Return of Title IV calculations and includes an established review process for quality control. All documentation will be maintained.

Assistance Listing Number, Federal Agency, and Program Name - 84.268; U.S. Department of Education; Student Financial Assistance Cluster; Federal Direct Student Loan Program Federal Award Identification Number and Year - June 1, 2021 to May 31, 2022 Finding Type - Material weakness and material noncompliance with laws and regulations Repeat Finding - Yes 2021-011 Criteria - In accordance with 34 CFR 685.300(b)(9) and electronic announcement November 13, 2013, Direct Loan Quality Assurance Requirement Reminder, institutions of higher education are requested to document a Direct Loan quality assurance program. Condition - The School does not have a documented Direct Loan quality assurance program. Questioned Costs - None Context - During our testing, management stated that the School does not have a documented Direct Loan quality assurance program. Cause and Effect - The School does not have a process in place to ensure that its Direct Loan quality assurance efforts are documented in accordance with federal regulations. The lack of a documented Direct Loan quality assurance program for the School results in noncompliance with federal regulations. Recommendation - We recommend the School establish the required Direct Loan quality assurance program and that contemporaneous evidence of consistent adherence to such a program be maintained. Views of Responsible Officials and Planned Corrective Actions - There is no disagreement with the audit finding. The Iliff School of Theology has contracted with a professional, third party processing company to administer its student assistance programs. The School will coordinate with this third party processor to ensure that there is a documented quality assurance program that is regularly exercised for compliance purposes. All documentation will be maintained.

Assistance Listing Number, Federal Agency, and Program Name - 84.268; U.S. Department of Education; Student Financial Assistance Cluster; Federal Direct Student Loan Program Federal Award Identification Number and Year - June 1, 2021 to May 31, 2022 Finding Type - Material weakness and material noncompliance with laws and regulations Repeat Finding - Yes 2021-012 Criteria - Institutions of higher education are required to establish written policies and procedures that incorporate the provisions of 34 CFR 668.51 through 668.61 for verifying applicant information. Institutions shall require each applicant whose application is selected by the U.S. Department of Education to verify the information required for the Verification Tracking Group to which the applicant is assigned. Condition - The School does not have written policies and procedures that incorporate the provisions of 34 CFR 668.51 through 668.61. Questioned Costs - None Context - During our testing, management noted that the School does not have written verification procedures. Cause and Effect - The School does not have a process in place to ensure that its verification procedures are documented in accordance with federal regulations. The lack of written verification procedures of the School results in noncompliance with federal regulations. Recommendation We recommend the School establish written verification procedures and that contemporaneous evidence of consistent adherence to such procedures be maintained. Views of Responsible Officials and Planned Corrective Actions - There is no disagreement with the audit finding. The Iliff School of Theology has contracted with a professional, third party processing company to administer its student assistance programs. All verification procedures are established, and documentation will be maintained to demonstrate compliance.

Assistance Listing Number, Federal Agency, and Program Name - 84.268; U.S. Department of Education; Student Financial Assistance Cluster; Federal Direct Student Loan Program Federal Award Identification Number and Year - June 1, 2021 to May 31, 2022 Finding Type - Material weakness and material noncompliance with laws and regulations Repeat Finding - Yes 2021-013 Criteria - In accordance with 34 CFR 682.604, a Direct Loan student borrower who is graduating, leaving school, or dropping below half time enrollment is required to complete exit counseling. Condition - The School does not have evidence that exit counseling was provided to students who withdrew or graduated, as required by 34 CFR 682.604. Questioned Costs - None Context - During our testing, the School was unable to provide evidence that exit counseling was completed for eight students who withdrew or graduated during the audit period. Cause and Effect - The School does not have a process in place to ensure that student borrowers who graduate, withdraw, or drop below half time enrollment complete exit counseling in accordance with federal regulations. The lack of controls to ensure student borrowers who graduate, withdraw, or drop below half time enrollment complete exit counseling results in noncompliance with federal regulations. Recommendation - We recommend management implement controls to ensure that student borrowers who graduate, withdraw, or drop below half time enrollment complete exit counseling in accordance with federal regulations. Views of Responsible Officials and Planned Corrective Actions - There is no disagreement with the audit finding. The Iliff School of Theology has contracted with a professional, third party processing company to administer its student assistance programs. The School has also ensured that this third party processor is properly coordinated with the registrar’s office to meet federal requirements for exit counseling when status changes are processed.

Assistance Listing Number, Federal Agency, and Program Name - 84.038; U.S. Department of Education; Student Financial Assistance Cluster; Federal Perkins Loan Program Federal Award Identification Number and Year - June 1, 2021 to May 31, 2022 Finding Type - Significant deficiency and material noncompliance with laws and regulations Repeat Finding - No Criteria - In accordance with 34 CFR 674.19.(e), institutions must retain true and exact copies of promissory and master promissory notes (MPN), repayment records, and cancellation and deferment requests for each Perkins loan (including Defense, NDSL) made. Condition - Our audit procedures identified instances of MPNs not being properly maintained. Questioned Costs - None Context - During our testing of nine students, we noted one student for whom a MPN could not be located. Cause and Effect - The School does not have a process in place to ensure all MPNs are maintained as required. Improper maintenance of MPNs resulted in noncompliance with federal regulations. Recommendation - We recommend the School strengthen its processes and controls over the maintenance of MPNs. Views of Responsible Officials and Corrective Action Plan - There is no disagreement with the audit finding. The Iliff School of Theology has contracted with a professional, third party processing company to administer its student assistance programs. The School has also ensured that this third party processor is properly reviewing MPNs to meet federal requirements.

2021 ? 003: NSLDS Enrollment Reporting Federal agency: U.S. Department of Education Federal program title: Student Financial Aid Cluster Assistance Listing Number: 84.033, 84.038, 84.268 Award Period: June 1, 2020 to May 31, 2021 Type of Finding: ? Material Weakness in Internal Control over Compliance ? Material Noncompliance (Modified Opinion) Criteria or specific requirement: Institutions are required to report enrollment information under the Direct loan program via the National Student Loan Data System (NSLDS). The administration of the Title IV Student Financial Aid programs depends heavily on the accuracy and timeliness of the enrollment information reported by institutions. Institutions must review, update, and verify student enrollment statuses, program information, and effective dates that appear on the Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS Professional Access (NSLDSFAP) website. There are two categories of enrollment information; ?Campus Level? and ?Program Level,? both of which need to be reported accurately. Condition: Our audit procedures identified instances of inaccurate or untimely reporting of enrollment information to NSLDS. Questioned costs: None. Context: During our testing of a sample of 12 students, we noted the following exceptions: ? For nine students, student enrollment was not certified within the required 60-day time period (campus level data); ? For five students, student graduation in Spring 2021 was not reported within the the required 60-day time period (campus level data); ? For seven students, program codes (CIP) in NLSDS did not agree to the description of the students? enrolled program at the institution (program level data) ? For one student, their program enrollment status per the NSLDS enrollment detail was full-time while the student was listed as less-than-half time in the institution?s enrollment records and per campus level records within NSLDS (program level data); ? For four students, the enrollment effective date per the NSLDS campus-level enrollment detail did not agree to the program enrollment effective date per the NSLDS program-level enrollment detail (program level data); ? For one student, enrollment status changes were not reported within the required 30 day time period (campus level data); ? For two students, the length of their enrolled program per institution records was three years while the length of their enrolled program reported to and listed in NSLDS was two years (program level data). Cause: The School does not have a process in place to ensure that campus level data and program level student enrollment information is reported to NSLDS in a timely and accurate manner. Effect: Untimely and inaccurate reporting of student enrollment data to NSLDS results in noncompliance with federal regulations, and untimely or inaccurate data listed within NSLDS. Student information within NSLDS is used to determine award packaging for students attending multiple institutions and repayment periods on direct student loans; inaccurate or stale data within NSLDS could lead to improper award packaging and repayment period determinations. Repeat Finding: This finding is a repeat of a finding in the prior year. The prior year finding number was 2020-003. Recommendation: We recommend that the School consider implementing a control to ensure all campus level and program level student enrollment information is reported to NSLDS timely and accurately in accordance with the federally required timelines. Views of responsible officials: There is no disagreement with the audit finding.

2021 ? 004: Lack of Segregation of Duties in the Financial Aid Department Federal agency: U.S. Department of Education Federal program title: Student Financial Aid Cluster Assistance Listing Number: 84.033, 84.038, 84.268 Award Period: June 1, 2020 to May 31, 2021 Type of Finding: ? Material Weakness in Internal Control over Compliance Criteria or specific requirement: An essential part of internal control is that procedures are properly segregated and the results of their performance be adequately reviewed. This is normally accomplished by assigning duties so that 1) no one person handles a transaction from beginning to end, and 2) incompatible duties between functions are not handled by the same person. In addition, a review of completed duties and functions should be performed by an individual independent of those duties and functions to ensure their propriety overall, and with federal regulations. Condition: Due to the limited number of personnel within the Financial Aid Department, the director of financial aid is solely responsible for packaging, awarding, and disbursing to student accounts Federal Student Financial Aid (Title IV) as well as calculating return of Title IV funds for students who withdraw from the School to student accounts. The packaging of Title IV aid and the return of Title IV funds are complex calculations that are not formally reviewed by another employee. Questioned costs: None. Context: During our discussions with management and through review of supporting documentation of the audit, we noted the Director of Financial Aid is solely responsible for packaging and awarding Title IV aid as well as calculating and determining return of Title IV funds for students who withdraw from the School. Cause: The School currently does not have a process in place to sufficiently segregate of duties within its Financial Aid Department. Nor does it have compensating controls in to mitigate the risks of the lack of segregation of duties. Effect: The financial aid director can unilaterally package, award, and disburse Title IV aid to student accounts; and calculate and refund return of Title IV funds to student accounts. This increases the risk that noncompliance with federal regulations, questioned costs, inaccuracies, and improprieties could occur and not be detected on a timely basis. Repeat Finding: This finding is a repeat of a finding in the prior year. The prior year finding number was 2020-004. Recommendation: We recommend that the School consider segregating duties within the Financial Aid Department. If segregating duties within the Financial Aid Department is not practical, we recommend that management implement control processes to ensure that actions unilaterally performed by one individual are reviewed by another knowledgeable individual to ensure of their reasonable and propriety. Evidence of such review should be documented and maintained. Views of responsible officials: There is no disagreement with the audit finding.

2021 ? 005: Overdraw of Federal Work-Study Funds Federal agency: U.S. Department of Education Federal program title: Student Financial Aid Cluster Assistance Listing Number: 84.033, 84.038, 84.268 Award Period: June 1, 2020 to May 31, 2021 Type of Finding: ? Material Weakness in Internal Control over Compliance ? Material Noncompliance (Modified Opinion) Criteria or specific requirement: The Institution operates on an advance payment method which permits, but does not require, institutions to draw down Title IV Student Financial Aid funds prior to disbursing funds to eligible students and parents, or for other allowable activities. Under this method, an institution?s request must not exceed the amount it immediately needs for disbursements the institution has made or will make to eligible students or parents, or for other allowable activities. A disbursement of funds occurs on the date an institution credits a student?s account or pays a student or parent directly with either Title IV funds or institutional funds. The institution must make the disbursements as soon as administratively feasible, but no later than three business days following the receipt of funds (34 CFR 668.162(a)). Condition: The Institution disbursed $50,358 of federal work study funds to students during fiscal year 2021, but drew down $58,883 of cash for federal work study disbursements from the federal G5 grant payment system at the end of fiscal year 2021. These funds were not disbursed within three days of drawdown of the funds. As a result, the Institution overdrew $8,525 of cash related to federal work study. Questioned costs: Known questioned costs are not greater than $25,000. Context: For one selection of our sample of seven cash draws tested, we noted that the Institution overdrew cash of $8,525 as these funds were not disbursed within three days of drawdown of the funds. Cause: The Institution?s cash draw review controls did not prevent or detect a cash draw that exceed expenditures incurred related to the federal work study program. Effect: Overdrawing federal funds results in noncompliance with federal regulations. Repeat Finding: This is not a repeat finding. Recommendation: We recommend that the Institution strengthen its review controls over cash draws to ensure that cash draws are in compliance with federal regulations. Views of responsible officials: There is no disagreement with the audit finding.

2021 ? 006: Accuracy and Review of FISAP Reporting Federal agency: U.S. Department of Education Federal program title: Student Financial Aid Cluster Assistance Listing Number: 84.033, 84.038, 84.268 Award Period: June 1, 2020 to May 31, 2021 Type of Finding: ? Significant Deficiency in Internal Control over Compliance ? Compliance, Other Matter Criteria or specific requirement: Institutions of higher education are required to submit a Fiscal Operations Report and Application to Participate (FISAP) to the U.S. Department of Education. his electronic report is submitted annually to receive funds for the campus-based programs. The institution uses the Fiscal Operations Report portion to report its expenditures in the previous award year and the Application to Participate portion to apply for the following year. Condition: The institution submitted a FISAP to the U.S. Department of Education that reported inaccurate information in several data fields within the report. In addition, there was no evidence that an individual other than the preparer reviewed the report. Questioned costs: None. Context: During our testing, we noted the following instances of inaccurate information in several data fields: ? Part I, Section A (Identifying Information), Line 3 (Type of School) - we noted that the institution was listed as a ?public institution,? when it is actually operating as a ?private/non-profit institution.? ? Part II, Section D (Information on Enrollment), Line 7b - The institution reported 166 graduates enrolled for fiscal year 2020-21. This figure did not agree to supporting documentation and management determined that the number reported was based on the unduplicated graduate count for Fall 2020. Management noted that the number that should have been reported for the 2020-21 school year was 188. The institution updated this figured in a revised FISAP report that was filed on December 15, 2021. ? Part V, Section A (Federal Funds Authorized for Federal Work Study), Line 1 ? In its revised FISAP submitted on December 15, 2021, we noted that the institution listed the total amount of federal work study funds disbursed during the 2020-21 fiscal year as opposed to the final authorized federal work study funds for the 2020-21 fiscal year. ? Management noted that there was not a formal and documented review process of the FISAP report by someone other than the preparer. Cause: The Institution did not have a control in place to ensure that accurate information was submitted to the U.S. Department of Education in the FISAP report. Effect: Submission of inaccurate information in the FISAP report may result in noncompliance with federal regulations and inaccurate awarding of federal student financial aid amounts in subsequent fiscal years. Repeat Finding: This is not a repeat finding. Recommendation: We recommend that the Institution implement a reconciliation and review control whereby an individual with sufficient student financial aid and financial understanding reviews the FISAP report to underlying institutional information to ensure accurate information is submitted with the FISAP report. Evidence of such a review and documentation supporting information reported in the FISAP should be documented and maintained. Views of responsible officials: There is no disagreement with the audit finding.

2021 ? 007: Reconciliations of Direct Loan Program Federal agency: U.S. Department of Education Federal program title: Student Financial Aid Cluster Assistance Listing Number: 84.033, 84.038, 84.268 Award Period: June 1, 2020 to May 31, 2021 Type of Finding: ? Material Weakness in Internal Control over Compliance ? Material Noncompliance (Modified Opinion) Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 685.300(b)(5) requires the College on a monthly basis, to reconcile the institutional records with the Direct Loan funds received from the Secretary of the U.S. Department of Education and the Direct Loan disbursement records submitted to and accepted by the Secretary of the U.S. Department of Education. Condition: The Institution does not reconcile institutional records with Direct Loan funds received from the Secretary of the U.S. Department of Education and the Direct Loan disbursement records submitted to and accepted by the Secretary of the U.S. Department of Education. Questioned costs: None. Context: During our testing, management stated that the Institution does not reconcile institutional records with Direct Loan funds received from the Secretary of the U.S. Department of Education and the Direct Loan disbursement records submitted to and accepted by the Secretary of the U.S. Department of Education. Cause: The Institution does not have a control in place to ensure direct loan program reconciliations are performed on a monthly basis. Effect: The lack of a control in place to ensure direct loan program reconciliations are performed on a monthly basis results in noncompliance with federal regulations. Repeat Finding: This is not a repeat finding. Recommendation: We recommend that the Institution implement a control to ensure direct loan program reconciliations are performed on a monthly basis. Views of responsible officials: There is no disagreement with the audit finding.

2021 ? 008: Return of Title IV (R2T4) Errors Federal agency: U.S. Department of Education Federal program title: Student Financial Aid Cluster Assistance Listing Number: 84.033, 84.038, 84.268 Award Period: June 1, 2020 to May 31, 2021 Type of Finding: ? Material Weakness in Internal Control over Compliance ? Material Noncompliance (Modified Opinion) Criteria or specific requirement: When a recipient of Title IV grant or loan assistance withdraws from an institution during a payment period or period of enrollment in which the recipient began attendance, the institution must determine the amount of Title IV aid earned by the student as of the student?s withdrawal date. If the total amount of Title IV assistance earned by the student is less than the amount that was disbursed to the student or on his or her behalf as of the date of the institution?s determination that the student withdrew, the difference must be returned to the Title IV programs as outlined in this section and no additional disbursements may be made to the student for the payment period or period of enrollment. If the amount the student earned is greater than the amount disbursed, the difference between the amounts must be treated as a post-withdrawal disbursement (34 CFR 668.22(a)(1) through (a)(5)). Condition: Our audit procedures identified instances where the Institution did not perform required R2T4 calculations under federal regulations and did not return unearned aid of $2,770 to Title IV programs in accordance with federal regulations. Questioned costs: Known questioned costs are not greater than $25,000. Context: During our testing, we noted that for 3 of 6 R2T4 students tested management did not perform R2T4 calculations as required by federal regulations. For two students, management believed that such calculations were not necessary as they believed these students were continuously enrolled and therefore exempted from such calculations as is allowed for credit-hour nonterm programs if such students re-enroll. However, the students were enrolled in in a credit hour term program and did not re-enroll. For one student, management did not perform an R2T4 calculation due to an oversight. Cause: The Institution does not have a process in place to ensure that all required R2T4 calculations under federal regulations are performed accurately and on a timely basis. Effect: The lack of a process to ensure that all required R2T4 calculations under federal regulations are performed accurately and timely results in noncompliance with federal regulations. Repeat Finding: This is not a repeat finding. Recommendation: We recommend that management implement processes and procedures to ensure that all required R2T4 calculations under federal regulations are performed accurately and on a timely basis. Such calculations should be reviewed by an individual other than the preparer and contemporaneous evidence of such a review should be maintained. Views of responsible officials: There is no disagreement with the audit finding.

2021 ? 009: Awarding of Direct Loans and Federal Work Study Federal agency: U.S. Department of Education Federal program title: Student Financial Aid Cluster Assistance Listing Number: 84.033, 84.038, 84.268 Award Period: June 1, 2020 to May 31, 2021 Type of Finding: ? Significant Deficiency in Internal Control over Compliance ? Compliance, Other Matter Criteria or specific requirement: The Code of Federal Regulations (34 CFR 685.203) describes the maximum loan amounts students are eligible to receive in Title IV funding based on their expected family contribution, estimated financial assistance, cost of attendance and other factors. The Code of Federal Regulations, 34 CFR 685.203(j) states that in no case may direct unsubsidized or direct plus loan amounts exceed the student?s estimated cost of attendance for the period of enrollment for which the loan is intended less the student?s estimated finance assistance for that period. The Code of Federal Regulations, 34 CFR 675.26(a)(4) stated that an institution may not use FWS funds to pay a student after he or she has, in addition to other estimated financial assistance, earned $300 or more over his or her financial need. Condition: The Institution awarded federal Title IV amounts that exceeded students? expected family contribution, estimated financial assistance, cost of attendance and other factors under federal regulations. Questioned costs: Known questioned costs are not greater than $25,000. Context: During our testing, we noted: ? one instance of 16 students tested where the student was awarded direct unsubsidized and direct plus loans in an amount that exceeded their cost of attendance less their estimated financial assistance by $2,727; ? one instance of 16 students tested where the student was awarded federal work study in an amount that exceeded their cost of attendance less their estimated financial assistance by $9,050. The student also earned $1,080 more in federal work study funds than they were awarded. Cause: The Institution does not have controls in place to ensure that students are awarded Title IV student financial aid in accordance with federal regulations. Effect: The lack of controls to ensure students are awarded Title IV student financial aid in accordance with federal regulations results in noncompliance with federal regulations. Repeat Finding: This is not a repeat finding. Recommendation: We recommend that management implement controls to ensure that students are awarded Title IV student financial aid in accordance with federal regulations. Views of responsible officials: There is no disagreement with the audit finding.

2021 ? 010: Notification of Disbursements Federal agency: U.S. Department of Education Federal program title: Student Financial Aid Cluster Assistance Listing Number: 84.033, 84.038, 84.268 Award Period: June 1, 2020 to May 31, 2021 Type of Finding: ? Material Weakness in Internal Control over Compliance ? Material Noncompliance (Modified Opinion) Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 668.165(a)(2) requires notification be sent to students no earlier than 30 days before the disbursement and no later than 30 days after the Direct Loans are disbursed to their accounts if the College obtains active confirmation. If the College does not obtain active confirmation, notifications are required to be sent no earlier than 30 days before the disbursement and not later than seven days to the student when loan funds are disbursed to their accounts. Condition: The Institution submitted a FISAP to the U.S. Department of Education that reported inaccurate information in several data fields within the report. In addition, there was no evidence that an individual other than the preparer reviewed the report. Questioned costs: None. Context: During our testing, we were unable to see evidence that 16 of 16 students tested received disbursement notifications before the required deadline established by the U.S. Department of Education. Cause: The Institution does not have a process in place to ensure notification of disbursements are sent to students within the required deadline established by the U.S. Department of Education. Effect: The lack of evidence of notification of disbursements within the required deadline established by the U.S. Department of Education results in noncompliance with federal regulations. Repeat Finding: This is not a repeat finding. Recommendation: We recommend the Institution review and strengthen its procedures for notifying students of financial aid disbursements within the required time frame and that documentation of notifications be maintained. Views of responsible officials: There is no disagreement with the audit finding.

2021 ? 011: Direct Loan Quality Assurance Program Federal agency: U.S. Department of Education Federal program title: Student Financial Aid Cluster Assistance Listing Number: 84.033, 84.038, 84.268 Award Period: June 1, 2020 to May 31, 2021 Type of Finding: ? Material Weakness in Internal Control over Compliance ? Material Noncompliance (Modified Opinion) Criteria or specific requirement: In accordance with 34 CFR 685.300(b)(9) and Electronic Announcement November 13, 2013, Direct Loan Quality Assurance Requirement Reminder, institutions of higher education are requested to document a Direct Loan quality assurance program. Condition: The Institution does not have a documented Direct Loan quality assurance program. Questioned costs: None. Context: During our testing, management stated that the institution does not have a documented Direct Loan quality assurance program. Cause: The Institution does not have a process in place to ensure that its Direct Loan quality assurance efforts are documented in accordance with federal regulations. Effect: The lack of a documented Direct Loan quality assurance program for the Institution results in noncompliance with federal regulations. Repeat Finding: This is not a repeat finding. Recommendation: We recommend that the Institution implement a process to document its Direct Loan quality assurance program and that contemporaneous evidence of consistent adherence to such a program be maintained. Views of responsible officials: There is no disagreement with the audit finding.

2021 ? 012: Documentation of Verification Procedures Federal agency: U.S. Department of Education Federal program title: Student Financial Aid Cluster Assistance Listing Number: 84.033, 84.038, 84.268 Award Period: June 1, 2020 to May 31, 2021 Type of Finding: ? Material Weakness in Internal Control over Compliance ? Compliance, Other Matter Criteria or specific requirement: Institutions of higher education are required to establish written policies and procedures that incorporate the provisions of 34 CFR 668.51 through 668.61 for verifying applicant information. Institutions shall require each applicant whose application is selected by the U.S. Department of Education to verify the information required for the Verification Tracking Group to which the applicant is assigned. Condition: The Institution does not have written policies and procedures that incorporate the provisions of 34 CFR 668.51 through 668.61. Questioned costs: None. Context: During our testing, management noted that the Institution does not have written verification procedures. Cause: The Institution does not have a process in place to ensure that its verification procedures are documented in accordance with federal regulations. Effect: The lack of written verification procedures of the Institution results in noncompliance with federal regulations. Repeat Finding: This is not a repeat finding. Recommendation: We recommend that the Institution implement a process to document its verification procedures and that contemporaneous evidence of consistent adherence to such procedures be maintained. Views of responsible officials: There is no disagreement with the audit finding.

2021 ? 013: Documentation of Exit Counseling for Direct Loans Federal agency: U.S. Department of Education Federal program title: Student Financial Aid Cluster Assistance Listing Number: 84.033, 84.038, 84.268 Award Period: June 1, 2020 to May 31, 2021 Type of Finding: ? Material Weakness in Internal Control over Compliance ? Compliance, Other Matter Criteria or specific requirement: In accordance with 34 CFR 682.604, a Direct Loan student borrower who is graduating, leaving school, or dropping below half-time enrollment is required to complete exit counseling. Condition: The Institution does not have evidence that exit counseling was provided to students who withdrew or graduated as required by 34 CFR 682.604. Questioned costs: None. Context: During our testing, the Institution was unable to provide evidence that exit counseling was completed for three students who withdrew or graduated during the audit period. Cause: The Institution does not have a process in place to ensure that student borrowers who graduate, withdraw, or drop below half-time enrollment complete exit counseling in accordance with federal regulations. Effect: The lack of controls to ensure student borrowers who graduate, withdraw, or drop below half-time enrollment complete exit counseling results in noncompliance with federal regulations. Repeat Finding: This is not a repeat finding. Recommendation: We recommend that management implement controls to ensure that students borrowers who graduate, withdraw, or drop below half-time enrollment complete exit counseling in accordance with federal regulations. Views of responsible officials: There is no disagreement with the audit finding.

2021 ? 014: Uneven Direct Loan Disbursements Federal agency: U.S. Department of Education Federal program title: Student Financial Aid Cluster Assistance Listing Number: 84.033, 84.038, 84.268 Award Period: June 1, 2020 to May 31, 2021 Type of Finding: ? Significant Deficiency in Internal Control over Compliance ? Compliance, Other Matter Criteria or specific requirement: In accordance with 34 CFR 685.303(d)(5), institutions must disburse loan proceeds in substantially equal installments. Condition: The Institution did not disburse loan proceeds in substantially equal installments in accordance with 34 CFR 685.303(d)(5). Questioned costs: None. Context: During our testing we noted that for one student of a sample of sixteen, the Institution disbursed direct loan proceeds across two terms, despite student attending all three terms. Cause: The Institution does not have controls in place to ensure that student direct loan proceeds are disbursed in substantially equal installments. Effect: The lack of controls to ensure that student direct loan proceeds are disbursed in substantially equal installments results in noncompliance with federal regulations. Repeat Finding: This is not a repeat finding. Recommendation: We recommend that management implement controls to ensure that direct student loan proceeds are disbursed in substantially equal installments in accordance with federal regulations. Views of responsible officials: There is no disagreement with the audit finding.

2020 ? 002: Reporting of Direct Student Loan Disbursement Information (COD Reporting) Federal agency: U.S. Department of Education Federal program title: Student Financial Aid Cluster CFDA Number: 84.268 Award Period: June 1, 2019 to May 31, 2020 Type of Finding: ? Significant Deficiency in Internal Control over Compliance ? Compliance, Other Matter Criteria or specific requirement: The U.S. Department of Education requires institutions of higher education to report direct student loan disbursement dates and amounts to the Common Origination and Disbursement (COD) system within 15 days of disbursing direct student loan funds to students (OMB No. 1845-0021). Condition: Our audit procedures identified instances of untimely reporting of direct student loan information to COD by the School. Questioned costs: None. Context: During our testing, we noted 3 instances of 45 samples tested where direct student loan information was reported to COD after the required 15-day reporting window. Cause: The School does not have a process in place to ensure that all direct student loan disbursement information is reported to COD within the required 15 days. Effect: Untimely reporting of direct student loan information to COD results in noncompliance with federal regulations. Direct student loans accrue interest based on disbursement dates reported to COD. Untimely reporting of disbursement information could lead to inaccurate interest calculations on outstanding direct student loans. Repeat Finding: This is not a repeat finding. Recommendation: We recommend that the School consider implementing a control to ensure all student loan disbursement information is reported to COD in accordance with the federally required reporting window of 15 days after the date of disbursement. Views of responsible officials: There is no disagreement with the audit finding.

2020 ? 003: Reporting of Student Enrollment Statuses (NSLDS Enrollment Reporting) Federal agency: U.S. Department of Education Federal program title: Federal Direct Loans CFDA Number: 84.268 Award Period: June 1, 2019 to May 31, 2020 Type of Finding: ? Significant Deficiency in Internal Control over Compliance ? Compliance, Other Matter Criteria or specific requirement: The Code of Federal Regulations (CFR) 34 CFR 685.309 requires that enrollment status changes for students be reported to the National Student Loan Data System (NSLDS) within 30 days or within 60 days if students with status changes will be reported on a scheduled transmission within 60 days of the date of the change in status. Regulations also require accurate reporting of effective dates of enrollment status changes. Condition: Our audit procedures identified an instance of an enrollment status change not being reported to NSLDS. Questioned costs: None. Context: During our testing, we noted 1 instance of 7 samples tested where an enrollment status change was not reported to NSLDS. Cause: The School does not have a process in place to ensure that all student status changes are reported to NSLDS. Effect: Untimely reporting of student enrollment data to NSLDS results in noncompliance with federal regulations. Untimely or inaccurate reporting of enrollment data to NSLDS leads results in untimely or inaccurate data within NSLDS. Student information within NSLDS is used to determine award packaging for students attending multiple institutions and repayment periods on direct student loans; inaccurate or stale data within NSLDS could lead to improper award packaging and repayment period determinations. Repeat Finding: This is not a repeat finding. Recommendation: We recommend that the School consider implementing a control to ensure all student enrollment information is reported to NSLDS in accordance with the federally required timelines. Views of responsible officials: There is no disagreement with the audit finding.

2020 ? 004: Lack of Segregation of Duties in the Financial Aid Department Federal agency: U.S. Department of Education Federal program title: Student Financial Aid Cluster CFDA Number: 84.033, 84.268 Award Period: June 1, 2019 to May 31, 2020 Type of Finding: Material Weakness in Internal Control over Compliance Criteria or specific requirement: An essential part of internal control is that procedures are properly segregated and the results of their performance be adequately reviewed. This is normally accomplished by assigning duties so that 1) no one person handles a transaction from beginning to end, and 2) incompatible duties between functions are not handled by the same person. In addition, a review of completed duties and functions should be performed by an individual independent of those duties and functions to ensure their propriety overall, and with federal regulations. Condition: Due to the limited number of personnel within the Financial Aid Department, the Director of Financial Aid is solely responsible for packaging, awarding, and disbursing to student accounts Federal Student Financial Aid (Title IV) as well as calculating return of Title IV funds for students who withdraw from the School to student accounts. The packaging of Title IV aid and the return of Title IV funds are complex calculations that are not formally reviewed by another employee. Questioned costs: None. Context: During our discussions with management and through review of supporting documentation of the audit, we noted the Director of Financial Aid is solely responsible for packaging and awarding Title IV aid as well as calculating and determining return of Title IV funds for students who withdraw from the School. Cause: The School currently does not have a process in place to sufficiently segregate of duties within its Financial Aid Department. Nor does it have compensating controls in to mitigate the risks of the lack of segregation of duties. Effect: The Financial Aid Director can unilaterally package, award, and disburse Title IV aid to student accounts; and calculate and refund return of Title IV funds to student accounts. This increases the risk that noncompliance with federal regulations, questioned costs, inaccuracies, and improprieties could occur and not be detected on a timely basis. Repeat Finding: This is not a repeat finding. Recommendation: We recommend that the School consider segregating duties within the Financial Aid Department. If segregating duties within the Financial Aid Department is not practical, we recommend that management implement control processes to ensure that actions unilaterally performed by one individual are reviewed by another knowledgeable individual to ensure of their reasonable and propriety. Evidence of such review should be documented and maintained. Views of responsible officials: There is no disagreement with the audit finding.

2020 ? 005: Gramm-Leach-Bailey Act Compliance Federal agency: U.S. Department of Education Federal program title: Student Financial Aid Cluster CFDA Number: 84.033, 84.268 Award Period: June 1, 2019 to May 31, 2020 Type of Finding: ? Significant Deficiency in Internal Control over Compliance ? Compliance, Other Matter Criteria or specific requirement: The Gramm-Leach-Bliley Act (Public Law 106-102) requires financial institutions to explain their information-sharing practices to their customers and to safeguard sensitive data. (16 CFR 314) The Federal Trade Commission considers Title IV-eligible institutions that participate in Title IV Educational Assistance Programs as ?financial institutions? and subject to the Gramm-Leach-Bliley Act (16 CFR 313.3(k)(2)(vi). Under an institution?s Program Participation Agreement with the U.S. Department of Education and the Gramm-Leach-Bliley Act, schools must protect student financial aid information, with particular attention to information provided to institutions by the U.S. Department of Education or otherwise obtained in support of the administration of the federal student financial aid programs. Requirements of the Act include: ? An institution to designate an individual to coordinate the information security program. ? An institution to perform a risk assessment that addresses the three required areas noted in 16 CFR 314.4 (b), which are: (1) Employee training and management; (2) Information systems, including network and software design, as well as information processing, storage, transmission and disposal; and (3) Detecting, preventing and responding to attacks, intrusions, or other systems failures. ? An institution to document a safeguard for each risk identified above. Condition: While the School had certain information security controls in place, documentation to support compliance with the Act was not produced by the School. Questioned costs: None. Context: During our audit procedures, it was noted that the School did not designate an individual to coordinate the information security program; perform a risk assessment that addresses the three areas noted in 16 CFR 314.4 (b) which are (1) Employee training and management, (2) Information systems, including network and software design, as well as information processing, storage, transmission and disposal, and (3) Detecting, preventing and responding to attacks, intrusions, or other systems failures; nor document safeguards for identified risks. Cause: The School did not designate an individual to coordinate the information security program, perform a risk assessment that addresses the three areas noted in 16 CFR 314.4 (b), nor document safeguards for identified risks. Effect: The School is not in compliance with all regulatory requirements as it pertains to safeguarding sensitive data under The Gramm-Leach-Bliley Act. Repeat Finding: This is not a repeat finding. Recommendation: We recommend that the school designate an individual to coordinate the information security program, perform a risk assessment that addresses the three areas noted in 16 CFR 314.4 (b), and document safeguards for identified risks. Views of responsible officials: There is no disagreement with the audit finding.

Finding 2019-001 ? Restatement of Classification of Net Assets as of May 31, 2018 (Material Weakness) Criteria: The School is required to properly classify donations as ?with donor restrictions? or ?without donor restrictions? when received per accounting principles generally accepted in the United States of America. Condition: Management found approximately $5.7 million in net assets that were determined to be improperly recorded or did not have sufficient support as ?with donor restrictions? in prior years, which resulted in a restatement of classification of net assets as of May 31, 2018. Effect: Net assets with donor restrictions and without donor restrictions were incorrectly reported as of May 31, 2018. Cause: There was a lack of oversight and strong controls in previous time periods related to the identification of donor restrictions, including obtaining and retaining supporting documentation of such restrictions. Context: Of the approximately $22.1 million net assets with donor restrictions as of May 31, 2018, approximately $5.7 million was reclassified as without donor restrictions. Recommendation: We recommend that the School develop processes for communication of donor restrictions between institutional advancement and business affairs to accurately record donor restrictions. In addition, we recommend that business affairs keep a record of all donations recorded as with donor restrictions. Views of responsible officials and planned corrective actions: The restatement was due to a re-evaluation of the classification of all net assets due to the implementation of Topic 958. This is a one-time correction based on deficiencies of a several decades that compounded into a material adjustment. The School has implemented several changes over the past decade to ensure proper accounting in accordance with the accounting guidance and is developing additional procedures to synchronize institutional advancement and business affairs on donor restrictions.