Arizona Christian UniversityHigher Education

Federal Agency: Department of Education Federal Program Title: Student Financial Assistance Cluster ALN Numbers: Various Award Period: July 1, 2024 through June 30, 2025 Type of Finding: • Significant Deficiency in Internal Control Over Compliance • Other Matters Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 685.309 requires that enrollment status changes for students be reported to NSLDS within 30 days or within 60 days if the student with the status change will be reported on a scheduled transmission within 60 days of the change in status. Condition: During our testing, we noted 1 out of 40 students in which their roster update was not submitted within 60 days. Questioned Costs: None Context: During our testing, it was noted the University does not have a process in place to ensure timeliness of NSLDS reporting. Cause: The University did not have a process in place to ensure students were reported timely. Effect: The University did not comply with Department of Education (ED) regulations by reporting student enrollment status changes timely and timely. Repeat Finding: Yes - 2024-001 Recommendation: We recommend the University review its reporting procedures to ensure that students’ statuses are timely reported to NSLDS as required by regulations. Views of Responsible Officials: There is no disagreement with the audit finding.

Federal Agency: Department of Education Federal Program Title: Student Financial Assistance Cluster ALN Numbers: Various Award Period: July 1, 2024 through June 30, 2025 Type of Finding: • Significant Deficiency in Internal Control Over Compliance • Other Matters Criteria or Specific Requirement: The Code of Federal Regulations 34 CFR 668.22, states that when students withdraw from a school, institutions are required to determine earned and unearned portions of Title IV aid as of the date the student ceased attendance based on the amount of time the student spent in attendance. Up through the 60% point in each payment period or period of enrollment, a pro rate schedule is used to determine the amount of Title IV funds the students earned at the time of withdrawal. After the 60% point in the payment period or period of enrollment, a student has earned 100% of the Title IV funds the student was scheduled to receive during the period. Condition: During our testing we noted that following errors in R2T4 reporting: • 1 out of 22 students tested had the wrong withdrawal date used in calculating their R2T4. This resulted in the student having three extra completed days of the term in their R2T4 calculation leading to ACU not returning enough PELL back to the Department of Education in the amount of $38.12. • 1 out of 22 students tested did not have enough days included for their scheduled break in their R2T4 calculation. ACU had this students withdrawal date be in the middle of spring break instead of the last date of attendance. This resulted in ACU returning too much Subsidized loan funds back to the Department of Education in the amount of $69.17. Questioned Costs: $31.05 Context: The University did not properly calculate R2T4's in all cases where it should have. Cause: The University did not have proper procedures in place to correctly calculate and timely return appropriate funds. Effect: Funds were not disbursed to students or returned to the Department of Education as they should have been. Repeat Finding: Yes - 2024-002 Recommendation: We recommend the University implement a formal review process as it relates to withdrawn students to ensure R2T4 calculations are being performed accurately and timely. Views of Responsible Officials: There is no disagreement with the audit finding.

Federal Agency: Department of Education Federal Program Title: Student Financial Assistance Cluster ALN Numbers: Various Award Period: July 1, 2024 through June 30, 2025 Type of Finding: • Significant Deficiency in Internal Control Over Compliance • Other Matters Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 685.203 specifies the annual and aggregate loan limits the Institutions may not exceed for an academic year of study under the Direct Loan program and also requires loans to be prorated for a program of student that is less than a full academic year in length. This regulation also requires institutions to ensure students are awarded up to their full need and eligibility of subsidized loans. Condition: During our testing, we noted 1 out of 40 students that was not awarded their full eligible amount of subsidized loans. Questioned Costs: $1,000 Context: The University under awarded a student and did not correctly package this student’s financial aid for the 24-25 award year. Cause: The University did not have proper procedures in place to ensure all students were properly awarded up to their annual limit in subsidized loans based on their grade level. Effect: The Institution is not awarding subsidized Stafford loans for which the student is eligible. Repeat Finding: No Recommendation: We recommend the University review their awarding procedures and implement procedures to ensure the subsidized direct loans loans are awarded within the annual and aggregate limits. Views of Responsible Officials: There is no disagreement with the audit finding.

Federal Agency: Department of Education Federal Program Title: Student Financial Assistance Cluster ALN Numbers: Various Award Period: July 1, 2023 through June 30, 2024 Type of Finding: • Significant Deficiency in Internal Control Over Compliance • Other Matters Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 685.309 requires that enrollment status changes for students be reported to NSLDS within 30 days or within 60 days if the student with the status change will be reported on a scheduled transmission within 60 days of the change in status. Regulations require the status include an accurate effective date. In addition, regulations require that an institution make necessary corrections and return the records within 10 days for any roster files that don’t pass the NSLDS enrollment reporting edits. Condition: During our testing, we noted the following items: • Two students in which their roster update was not submitted within 60 days; • Six students’ enrollment effective date per the institution's records did not match the enrollment effective date per NSLDS; • One student's program enrollment effective date per the institution's records did not match the -enrollment effective date per NSLDS; • Three students were reported as full time even though they had officially withdrawn from the University; and • One student did not have their status certified as required every 60 days Questioned Costs: None Context: During our testing, it was noted the University does not have a process in place to ensure timeliness and accuracy of NSLDS reporting. Cause: The University did not have a process in place to ensure the student who graduated or withdrew were reported timely and accurately. Effect: The University did not comply with Department of Education (ED) regulations by reporting student enrollment status changes timely and timely. Repeat Finding: Yes - 2023-003 Recommendation: We recommend the University review its reporting procedures to ensure that students’ statuses are accurately and timely reported to NSLDS as required by regulations. Views of Responsible Officials: There is no disagreement with the audit finding.

Federal Agency: Department of Education Federal Program Title: Student Financial Assistance Cluster ALN Numbers: Various Award Period: July 1, 2023 through June 30, 2024 Type of Finding: • Significant Deficiency in Internal Control Over Compliance • Other Matters Criteria or Specific Requirement: The Code of Federal Regulations 34 CFR 668.22, states that when students withdraw from a school, institutions is required to determine earned and unearned portions of Title IV aid as of the date the student ceased attendance based on the amount of time the student spent in attendance. Up through the 60% point in each payment period or period of enrollment, a pro rate schedule is used to determine the amount of Title IV funds the students earned at the time of withdrawal. After the 60% point in the payment period or period of enrollment, a student has earned 100% of the Title IV funds the student was scheduled to receive during the period. Condition: During our testing, for one out of 26 students, an R2T4 calculation was not performed even though they attended classes. All of their aid was returned; however, the student did earn a portion that was improperly returned to ED. Questioned Costs: $527.25 Context: The University did not properly calculate R2T4's or timely return funds in all cases where it should have. Cause: The University did not have proper procedures in place to correctly calculate and timely return appropriate funds. Effect: Funds were not disbursed to students as they should have been. Repeat Finding: No Recommendation: We recommend that the University implement a formal review process as it relates to withdrawn students to ensure R2T4 calculations are being performed accurately and timely. Views of Responsible Officials: There is no disagreement with the audit finding.

Federal Agency: Department of Education Federal Program Title: Student Financial Assistance Cluster ALN Numbers: Various Award Period: July 1, 2024 through June 30, 2024 Type of Finding: • Significant Deficiency in Internal Control Over Compliance • Other Matters Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 668.164(h) states a title IV, HEA credit balance occurs whenever the amount of title IV, HEA program funds credited to a student's ledger account for a payment period exceeds the amount assessed the student for allowable charges associated with that payment period. A title IV, HEA credit balance must be paid directly to the student or parent as soon as possible, but – (1) No later than 14 days after the balance occurred if the credit balance occurred after the first day of class of a payment period; or (2) No later than 14 days after the first day of class of a payment period if the credit balance occurred on or before the first day of class of that payment period. Condition: During our testing of credit balances resulting from federal funds, we noted three out of 40 tested where the credit balance was not refunded within the 14-day period. Questioned Costs: None Context: The students had credit balances after aid adjustments that were not refunded timely. Cause: The University did not have proper procedures in place to ensure all credit balances are refunded within the 14-day period. Effect: The University did not refund students within 14 days for credit balances that arose from federal funds as required by ED regulations. Repeat Finding: No Recommendation: We recommend the University review their current policies and procedures around credit balances and ensure the processes in place are sufficient to ensure student credit balances due to federal funds are refunded within 14 days. Views of Responsible Officials: There is no disagreement with the audit finding.

2023-002 Common Origination and Disbursement (COD) Federal Agency: Department of Education Federal Program Title: Student Financial Assistance Cluster ALN Numbers: Various Award Period: July 1, 2022 through June 30, 2023 Type of Finding: • Significant Deficiency in Internal Control Over Compliance • Other Matters Criteria or Specific Requirement: The Department of Education requires the University to report the disbursement dates and amounts to the Common Origination and Disbursement (COD) system within 15 days of disbursing Pell (34 CFR 690.83(b)(2) and Direct Loan (34 CFR 685.309) funds to a student. Condition: During our testing of 40 disbursements, we noted one Pell disbursement date per COD did not align with the student account disbursement date. Questioned costs: None Context: During our testing, it was noted the University did not properly follow the process to ensure disbursements are accurately reported to COD. Cause: The University did not follow the procedure to meet the requirement that disbursements made to students must be reported to COD within 15 days of the disbursement date. Effect: Students interest accrues based on disbursement date reported to COD for Pell disbursements, thus interest calculation could be skewed due to the discrepancy in disbursement dates reported. Repeat Finding: No Recommendation: We recommend the University evaluate its procedures and policies around reporting disbursements to COD to ensure that student information is reported accurately and timely. Views of Responsible Officials: There is no disagreement with the audit finding.

2023-003 National Student Loan Data System (NSLDS) Enrollment Reporting Federal Agency: Department of Education Federal Program Title: Student Financial Assistance Cluster ALN Numbers: Various Award Period: July 1, 2022 through June 30, 2023 Type of Finding: • Significant Deficiency in Internal Control Over Compliance • Other Matters Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 685.309 requires that enrollment status changes for students be reported to NSLDS within 30 days or within 60 days if the student with the status change will be reported on a scheduled transmission within 60 days of the change in status. Condition: During our testing, we noted 16 out of the 40 students tested where the student was not reported in a timely manner after the school determined the students change in status. Questioned Costs: None Context: During our testing, it was noted the University does not have a process in place to ensure timeliness of NSLDS reporting. Cause: The University did not have a process in place to ensure the student who graduated or withdrew were reported timely. Effect: The University did not comply with Department of Education (ED) regulations by reporting student enrollment status changes timely. Repeat Finding: Yes - 2022-001 Recommendation: We recommend the Institute review its reporting procedures to ensure that students’ statuses are timely reported to NSLDS as required by regulations. Views of Responsible Officials: There is no disagreement with the audit finding

2023-004 Eligibility Federal Agency: Department of Education Federal Program Title: Student Financial Assistance Cluster ALN Numbers: Various Award Period: July 1, 2022 through June 30, 2023 Type of Finding: • Significant Deficiency in Internal Control Over Compliance • Other Matters Criteria or Specific Requirement: Per the Code of Federal Regulations, 34 CFR 673.5, students may not be awarded need based aid in excess of their calculated need. In addition, 34 CFR 685.203(j) states that in no case may a loan amount exceed the student’s estimated cost of attendance for the period of enrollment for which the loan is intended less the student’s estimated financial assistance for that period and in the case of Direct Subsidized Loans, the borrower’s expected family contribution for that period. Condition: During our testing, we noted for 2 out of 40 students tested, we noted an over award. For one of these students, it was an over award of need-based aid in the amount of $672 as total aid paid was greater than the student's total need in the 2022-23 academic year. For the other student, we noted an over award of $1,467 of overall aid during the 2022-23 academic year that was greater than the student’s cost of attendance. Questioned Costs: $2,139 Context: During our testing, it was noted an erroneous computation of the student’s financial need and cost of attendance thus causing an over award in need based and overall aid. Cause: Management incorrectly awarded these students based on their financial need and cost of attendance. Effect: The University is not in compliance with Department of Education requirements. Repeat Finding: Yes – 2022-002 Recommendation: We recommend the University implements policies to review all student award packages at the start of the academic year to ensure no over awards exist. Views of Responsible Officials: There is no disagreement with the audit finding.

2023-005 Special Test: 240 Day Checks Federal Agency: Department of Education Federal Program Title: Student Financial Assistance Cluster ALN Numbers: Various Award Period: July 1, 2022 through June 30, 2023 Type of Finding: • Significant Deficiency in Internal Control Over Compliance • Other Matters Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 668.164(h)(2) states that an institution that attempts to disburse funds by check and the check is not cashed, the institution must return the funds to the Secretary no later than 240 days after the date it issued that check. Condition: Twenty checks totaling $12,138.00 related to student refunds of Title IV federal financial aid were outstanding more than 240 days as of June 30, 2023. Questioned Costs: $12,138 Context: During our testing, it was noted the University does not have a process in place to ensure checks are refunded to ED after 240 days outstanding. Cause: The University did not have a process in place to ensure all outstanding checks over 240 days was properly returned to the ED. Effect: The University is not in compliance with Department of Education requirements that all student refund checks that are outstanding for more than 240 days be returned to the Department. Repeat Finding: No Recommendation: We recommend that the University review its procedures related to outstanding student refund checks to ensure they are being returned to the Department of Education after 240 days. Views of Responsible Officials: There is no disagreement with the audit finding.

2023-006 Eligibility – First Time Borrower Federal Agency: Department of Education Federal Program Title: Student Financial Assistance Cluster ALN Numbers: Various Award Period: July 1, 2022 through June 30, 2023 Type of Finding: • Significant Deficiency in Internal Control Over Compliance • Other Matters Criteria or Specific Requirement: An institution may not make a disbursement of a Direct Loan to a first-year undergraduate who is a first-time borrower until 30 days after the first day of classes of the payment period (34 CFR 668.164(i)(2)(i) and 34 CFR 685.303(b)(5)) Condition: During our testing, we noted 2 out of the 40 students were first time borrowers who received a disbursement of Direct Loans within 30 days after the first day of classes. The University was required to wait until after 30 days of the first day of classes. For both cases, the student remained enrolled, so there was no need to issue a refund. Questioned Costs: None Context: During our testing, it was noted the University does not have a process in place to comply with the federal regulations. Cause: The University did not have a process in place to ensure compliance with federal regulations. Effect: The University is not in compliance with Department of Education requirements in regards to first-time borrowers receiving Direct Loans. Repeat Finding: No Recommendation: We recommend that the University review its procedures related to first-time borrowers to ensure they are in compliance with the Department of Education's regulations. Views of Responsible Officials: There is no disagreement with the audit finding.

2022-001 National Student Loan Data System (NSLDS) Enrollment Reporting Federal Agency: Department of Education Federal Program Title: Student Financial Assistance Cluster ALN Numbers: Various Award Period: July 1, 2021 through June 30, 2022 Type of Finding: ?Significant Deficiency in Internal Control Over Compliance ?Other Matters Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 685.309(b), states schools must have some arrangement to report student enrollment data to the National Student Loan Data System (NSLDS) through an enrollment roster file. The University is required to report changes in the student?s enrollment status, the effective date of the status, and an anticipated completion date as well as program enrollment effective date. In addition, at a minimum, schools are required to certify enrollment every 60 days, and respond within 15 days of the date that NSLDS sends a Roster file to the University or its third-party servicer. Condition: During our testing, we noted for 1 out of the 40 students tested, the program enrollment effective date did not match the University?s records. For 1 out of the 40 students tested, the enrollment effective date and program enrollment effective date did not match the University?s records. We also noted 3 out of the 40 students tested, the enrollment effective date did not match the enrollment effective date per the University?s records. Furthermore, we noted 3 out of the 40 students tested where the student as not reported in a timely manner. These issues impacted 8 out of the 40 students tested. Questioned costs: None Context: During our testing, it was noted the University does not have a process in place to ensure timeliness and accuracy of NSLDS reporting. Cause: The University did not have a process in place to ensure the effective dates reported matched the University?s records as well as that these changes were reported timely. Effect: The enrollment effective date reported to NSLDS is used to determine when the student?s grace period should begin. By not reporting an incorrect effective date, the grace period begin date for the student will be incorrect. In addition, the University did not comply with Department of Education (ED) regulations by reporting student enrollment status changes timely. Repeat Finding: Yes, 2021-001 Recommendation: We recommend the University reevaluate its procedures and review policies surrounding reporting status changes to NSLDS to put a process in place to ensure the enrollment effective date reported to NSLDS on the campus and program level is aligning with the University. Views of Responsible Officials: There is no disagreement with the audit finding.

2022-002 Eligibility Federal Agency: Department of Education Federal Program Title: Student Financial Assistance Cluster ALN Numbers: Various Award Period: July 1, 2021 through June 30, 2022 Type of Finding: ?Significant Deficiency in Internal Control Over Compliance ?Other Matters Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 690.62, states the amount of a student's Pell Grant for an academic year is based upon the payment and disbursement schedules published by the Secretary for each award year. In addition, the Code of Federal Regulations, 34 CFR 686.11, states to be eligible for a TEACH grant, a student beyond the first year of an undergraduate program must have a cumulative GPA of at least 3.25. Lastly, the Code of Federal Regulations, 34 CFR 682.604 states a school must ensure that exit counseling is conducted with each direct loan borrower within 30 days after learning the student borrower has withdrawn from school. Condition: During our testing, we noted for 1 out of 40 students tested, they were over awarded and over disbursed Pell grant funds. In addition, for 1 out of 40 students tested, we noted they were not meeting the minimum GPA requirements to be eligible for a TEACH grant. Furthermore, 2 out of 40 students did not receive their exit counseling timely. Questioned Costs: $6,000 Context: During our testing, it was noted an erroneous computation of the student?s eligibility resulted in a Pell grant over award. It was noted all the eligibility requirements were not reviewed for TEACH grants. Lastly, exit counseling was not done timely. Cause: The University did not have procedures in place to detect these eligibility issues. Effect: The University is not in compliance with Department of Education requirements. Repeat Finding: No Recommendation: We recommend the University review their procedures surrounding eligibility and exit counseling to ensure all students are receiving federal aid they are eligible for as well as being sent exit counseling timely upon leaving the University. Views of Responsible Officials: There is no disagreement with the audit finding

2022-003 Cash Management Disbursement (G5 Drawdown) Federal Agency: Department of Education Federal Program Title: Student Financial Assistance Cluster ALN Numbers: Various Award Period: July 1, 2021 through June 30, 2022 Type of Finding: ?Significant Deficiency in Internal Control Over Compliance ?Other Matters Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 668.166 requires institutions to disburse FSA funds as soon as administratively feasible but no later than three business days following the date the institution received those funds. Condition: The University drew excess financial funds during the Fall 2021 and did not return the excess cash within the three-day requirement. Questioned Costs: $351,837 Context: During our testing, we noted the University overdrew financial aid funds from the Department of Education in the amount of $351,837 which was not returned within three days to the Department of Education. The Department of Education had contacted the University on multiple occasion until the funds were returned in December 2021. Cause: The University did not have administrative capability to be able to account for all federal student financial aid dollars expended. Effect: The University is not complying with federal requirements regarding excess cash. This resulted in questioned costs that include return of funds on excess funds drawn down. Repeat Finding: No Recommendation: The University should implement a procedure to ensure federal aid drawn down are accounted for timely and returned within 3 days. Views of Responsible Officials: There is no disagreement with the audit finding.

2021-001 National Student Loan Data System (NSLDS) Enrollment Reporting Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Aid ALN Number: Student Financial Aid Cluster Award Period: July 1, 2020 to June 30, 2021 Type of Finding: - Significant Deficiency in Internal Control Over Compliance - Other Matters Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless of if they receive aid from the institution or not. Changes to said status are required to be reported within 30 days of becoming aware of the status change, or with the next scheduled transmission of statuses if the scheduled transmission is within 60 days. This includes the enrollment effective date and related enrollment status, which must be reported for both the Campus-Level and the Program-Level. In addition, at a minimum, schools are required to certify enrollment every 60 days, and respond within 15 days of the date that NSLDS sends a Roster file to the school or its third-party servicer. In addition, regulations require that an institution make necessary corrections and return the records within 10 days for any roster files that do not pass the NSLDS enrollment reporting edits. Condition: During our testing, we noted for six out of the 40 students tested, the enrollment effective date did not match the enrollment effective date per the University?s records. We noted for four out of the 40 students tested, the change was not reported in a timely manner. We noted for one out of the 40 students tested, the enrollment status was reported incorrectly. Lastly, we noted for two out of 40 students tested, the enrollment was not verified every 60 days. In addition, we noted that the rosters returned for the University yielded error reports that were not corrected and resubmitted within the required 10 days. Questioned Costs: None Context: During our testing, it was noted the University does not have a process in place to ensure timeliness and accuracy of NSLDS reporting. Cause: The University did not timely or properly report student status changes to NSLDS through their third-party servicer, National Student Clearinghouse (NSC). Effect: The University did not comply with Department of Education?s regulations regarding enrollment reporting as well as the NSLDS system is not updated with the student information which can cause over awarding should the student transfer to another institution and the students may not properly enter the repayment period. Repeat Finding: Yes, 2020-002, 2020-005, and 2020-007 Recommendation: We recommend the University reevaluate its procedures and review policies surrounding reporting status changes and other enrollment information to NSLDS to ensure timely and accurate reporting. We also recommend the University review its reporting procedures to ensure all errors are corrected with the appropriate timeframe as required by regulations. Views of responsible officials: There is no disagreement with the audit finding.

2021-002 Common Origination Disbursement (COD) Reporting Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Aid ALN Number: Student Financial Aid Cluster Award Period: July 1, 2020 to June 30, 2021 Type of Finding: - Significant Deficiency in Internal Control Over Compliance - Other Matters Criteria or Specific Requirement: The Department of Education requires the University to report the disbursement dates and amounts to the Common Origination and Disbursement (COD) system within 15 days of disbursing Pell (34 CFR 690.83(b)(2) and Direct Loan (34 CFR 685.309) funds to a student. Condition: During our testing, we noted 37 of the 40 students tested had disbursements that were not applied in COD within the required 15 days. Questioned Costs: None Context: During our testing, it was noted the University did not properly follow the process to ensure disbursements are accurately reported to COD. Cause: The University did not follow the procedure to meet the requirement that disbursements made to students must be reported to COD within 15 days of the disbursement date. Effect: Students interest accrues based on disbursement date reported to COD for Direct Loan disbursements, thus interest calculation could be skewed due to the discrepancy in disbursement dates reported. Repeat Finding: No Recommendation: We recommend the University evaluate its procedures and policies around reporting disbursements to COD to ensure that student information is reported accurately and timely. Views of responsible officials: There is no disagreement with the audit finding.

2021-003 Eligibility Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Aid ALN Number: Student Financial Aid Cluster Award Period: July 1, 2020 to June 30, 2021 Type of Finding: - Significant Deficiency in Internal Control Over Compliance - Other Matters Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 685.203(a) outline the maximum subsidized loan amounts for students based on their dependency status, year of education, and other factors. In addition, the Code of Federal Regulations, 34 CFR 673.5, states students may not be awarded need based aid in excess of their calculated need. Condition: During our testing, we noted that one of 40 students tested was overawarded subsidized direct loan funds and one of 40 students tested was underawarded subsidized direct loan funds. Additionally, we noted one of 40 students tested was awarded federal work study and had no remaining need. Questioned Costs: Overaward: $4,600; Underaward: $1,000 Context: During our testing, it was noted an erroneous computation of the student?s eligibility resulted in underawards and overawards. The University has resolved the above over and under awards with the Department of Education. Cause: The University did not address a student?s need properly which led to improper awards. Effect: The University is not in compliance with Department of Education requirements. Repeat Finding: No Recommendation: We recommend the University review the procedures surrounding Direct Loan and Federal Work Study awarding to ensure the proper cost of attendance is used so that amounts awarded do not exceed calculated financial need and awards are proper. Views of responsible officials: There is no disagreement with the audit finding.

2021-004 Procurement and Suspension and Debarment Federal Agency: U.S. Department of Education Federal Program Title: Higher Education Emergency Relief Funds ALN Number: 84.425 Award Period: July 1, 2020 to June 30, 2021 Type of Finding: - Significant Deficiency in Internal Control Over Compliance - Other Matters Criteria or specific requirement: The Code of Federal Regulations section 215.44 states written selection procedures require solicitations for goods or services incorporate a clear and accurate description of the technical requirements for the material, product, or service to be procured, identify all requirements for the material, product, or service to be procured, identify all requirements that the offerors must fulfill, and include all other factors to be used in evaluating bids or proposals. In addition, per Uniform Guidance 2 CFR sections 200.212 and 200.318(h); 2 CFR section 180.300; 48 CFR section 52.209-6, a nonfederal entity must have procedures for verifying that an entity with which it plans to enter into a covered transaction is not debarred, suspended, or otherwise excluded. Condition: During our testing, we noted the University did not have properly documented procurement regulations that met the federal requirements. They also did not have a conflict of interest policy that met federal requirements. We were unable to verify any procurement methods used for the five vendors tested. In addition, during our testing, we noted for five of the five vendors over $25,000 tested, there was not documented suspension and debarment procedures. Questioned Costs: None Context: The University did not have documented procurement procedures or procedures in place to verify vendors had not been suspended or debarred. They were not following procurement requirements under Uniform Guidance. Cause: The University was not aware of the requirements of the Uniform Guidance. Effect: The lack of documented procurement regulations and policies over these compliance requirements provides an opportunity for noncompliance. In addition, the University could enter into a covered transaction with a vendor who is suspended or debarred. Repeat Finding: No Recommendation: We recommend the University document suspension and debarment procedures going forward for any vendors with federal expenditures over $25,000. We also recommend a procurement policy be implemented that meets the requirements of Uniform Guidance as well as the conflict of interest policy is updated to conform with Uniform Guidance. Lastly, we recommend documentation be retained as it relates to the methodology chosen for procurement in accordance with the procurement policy. Views of responsible officials: There is no disagreement with the audit finding.

2021-005 Reporting Federal Agency: U.S. Department of Education Federal Program Title: Higher Education Emergency Relief Funds ALN Number: 84.425 Award Period: July 1, 2020 to June 30, 2021 Type of Finding: - Significant Deficiency in Internal Control Over Compliance - Other Matters Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, federal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations and program compliance requirements. The initial reporting for this grant requires the report to be submitted to the college or university?s website within 30 days of the signed Certification Agreement or 30 days after the electronic announcement dated May 6, whichever is later. Colleges and universities were then required to update their websites every 45 days after initial upload. This was changed to quarterly on August 31, 2020. In addition, an annual report is required. Condition: During our testing, we noted: - For the September 30, 2020 quarterly institutional support, the supporting documentation provided did not tie to the expenditures reported by $977. The report was also not reviewed and approved prior to submission. - For the December 31, 2020 quarterly institutional support, the supporting documentation provided did not tie to the expenditures reported by $977. The report was also not reviewed and approved prior to submission. - For the March 31, 2021 quarterly institutional support, the report included $815,157 of expenditures that were later unallocated to HEERF and should never have been reported. The report was also not reviewed and approved prior to submission. - For the September 30, 2020, December 31, 2020, and March 31, 2021 student quarterly reports, there was no documentation saved for the website upload, so there was no way to test if they were uploaded timely. The reports were also not reviewed and approved prior to submission. - For the December 31, 2020 annual report, the count of eligible students reported was actually the students who were disbursed HEERF and not the total count of eligible students at the University. Questioned Costs: None Context: A control system to prevent and detect errors in the reporting process was not created at the time the reports were filed and the University did not have a process to track the reporting requirements. In addition, there was a general lack of guidance from ED on reporting requirements. Cause: The University did not have someone tracking the requirements to ensure that they posted the reporting timely and accurately. Effect: The University did not comply with ED regulations by reporting accurate information as well as retaining support for the information reported to ensure accuracy. Repeat finding: No Recommendation: We recommend the University review their reporting procedures to ensure all required steps are included as well as the supporting documentation to prepare the report is retained. The reports should be reviewed by someone other than the preparer of the report and this review should be documented. Views of responsible officials: There is no disagreement with the audit finding.

2020-002 National Student Loan Data System (NSLDS) Enrollment Reporting Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Aid CFDA Number: Student Financial Aid Cluster Award Period: July 1, 2019 to June 30, 2020 Type of Finding: ? Significant Deficiency in Internal Control over Compliance ? Other Matters Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless if they receive aid from the institution or not. Changes to said status are required to be reported within 30 days of becoming aware of the status change, or with the next scheduled transmission of statuses if the scheduled transmission is within 60 days. Condition: During our testing, we noted that 16 out of 40 students tested where the student was not reported in a timely manner. Questioned costs: None Context: During our testing, it was noted the University does not have a process in place to ensure timeliness and accuracy of NSLDS reporting. Cause: The University did not timely or properly report student status changes to NSLDS through their third-party servicer, National Student Clearinghouse (NSC). Effect: The University did not comply with Department of Education (ED) regulations by reporting student enrollment status changes timely. Repeat finding: 2019-001 Recommendation: We recommend the University reevaluate its procedures and review policies surrounding reporting status changes to NSLDS to ensure timely reporting. Views of responsible officials: There is no disagreement with the audit finding.

2020-003 Student Refund of Credit Balance within 14 Days Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Aid CFDA Number: Student Financial Aid Cluster Award Period: July 1, 2019 to June 30, 2020 Type of Finding: ? Significant Deficiency in Internal Control over Compliance ? Other Matters Criteria: The Code of Federal Regulations, 34 CFR 668.164(e) states that whenever an institution disburses title IV, HEA program funds by crediting a student?s account and the total amount of all title IV, HEA program funds credited exceeds the amount of tuition and fees, room and board, and other authorized charges the institution assessed the student, the institution must pay the resulting credit balance directly to the student or parent as soon as possible but? (1) No later than 14 days after the balance occurred if the credit balance occurred after the first day of class of a payment period; or (2) No later than 14 days after the first day of class of a payment period if the credit balance occurred on or before the first day of class of that payment period. Condition: During our testing, we noted 4 of 40 students tested did not have the credit balance resulting from federal funds refunded within the 14-day period. Questioned Costs: None Context: During our testing it was noted that the University failed to refund students within the 14-day period. Cause: The University did not post adjustments to student accounts within the University?s add/drop period. Noted adjustments were made to student ledgers after 14 days. Effect: The University did not refund students within 14 days for credit balances that arose from federal funds as required by Department of Education regulations. Repeat finding: 2019-005 Recommendation: We recommend the University put a process in place to refund student credit balances that arise from federal funds within 14 days. We also recommend posting to student accounts for institutional charges for each payment period be posted and dated prior to disbursing federal funds to limit the number of refund checks. View of Responsible Officials: There is no disagreement with the audit finding.

2020?004 Gramm-Leach-Bliley Act Federal agency: Department of Education Federal program title: Student Financial Aid CFDA Numbers: Student Financial Aid Cluster Award Period: July 1, 2019 through June 30, 2020 Type of Finding: ? Significant Deficiency in Internal Control over Compliance ? Other Matters 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). Condition: Under an institution?s Program Participation Agreement with the 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 Department or otherwise obtained in support of the administration of the federal student financial aid programs. Questioned costs: None Context: During our audit procedures, it was noted that the University did not 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 and document safeguards for identified risks. Cause: The organization uses a third-party IT service provider for IT related tasks and relied on that service provider to ensure all compliance requirements are met. However, the organization should have an individual designated internally to assure compliance with the requirements of the Gramm-Leach-Bliley Act. The organization did not perform an IT risk assessment tailored specifically to the organization, identify risks, or address risks identified as required by the Gramm-Leach-Bliley Act. Effect: The student personal information could be vulnerable. Repeat finding: 2019-007 Recommendation: We recommend that the University engage a third party or perform the risk assessment for the three areas required by the Gramm-Leach-Bliley Act and ensure that there are documented safeguards for identified risks. Views of responsible officials: There is no disagreement with the audit finding.

2020?005 NSLDS Error Correcting Federal agency: Department of Education Federal program title: Student Financial Aid CFDA Numbers: Student Financial Aid Cluster Award Period: July 1, 2019 through June 30, 2020 Type of Finding: ? Significant Deficiency in Internal Control over Compliance ? Other Matters Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 685.309 requires that enrollment status changes for students be reported to NSLDS within 30 days or within 60 days if the student with the status change will be reported on a scheduled transmission within 60 days of the change in status. Regulations require the status include an accurate effective date. In addition, regulations require that an institution make necessary corrections and return the records within 10 days for any roster files that do not pass the NSLDS enrollment reporting edits. Condition: During our testing, we noted that the rosters returned for the University yielded error reports that were not corrected and resubmitted within the required 10 days. Questioned costs: None Context: During our review of the SCHER1 reports, we noted error records were not being corrected and resubmitted within the required 10 days. Cause: The University did not have processes and controls in place to ensure that student status changes were properly and timely reported to NSLDS. Effect: The NSLDS system is not updated with the student information which can cause over awarding should the student transfer to another institution and the students may not properly enter the repayment period. Repeat finding: No Recommendation: We recommend the University review its reporting procedures to ensure that students? statuses are accurately and timely reported to NSLDS and all errors are corrected with the appropriate timeframe as required by regulations. Views of responsible officials: There is no disagreement with the audit finding.

2020?006 Eligibility Certification Approval Report (ECAR) Federal agency: Department of Education Federal program title: Student Financial Aid CFDA Numbers: Student Financial Aid Cluster Award Period: July 1, 2019 through June 30, 2020 Type of Finding: ? Significant Deficiency in Internal Control over Compliance ? Other Matters Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 668.25(e) states that an institution must notify the Department of Education by way of the ECAR within 10 days of a change in position of an official at the University. Condition: During our testing, we noted that the change in Chief Financial Officer (CFO) was not reported timely to the Department of Education. Questioned costs: None Context: During our testing, we noted the CFO was updated on the ECAR twice during 2020; however, the first instance was not done within 10 days. Cause: There was two changes in the CFO position during 2020 and when the first CFO left, the determination to add a temporary CFO was not made until after the 10 day mark; therefore, the removal of the previous CFO was not done timely. Effect: The University is not in compliance with Department of Education requirements that state the ECAR must have accurately reported information. Repeat finding: No Recommendation: We recommend the University review its reporting procedures surrounding updating the ECAR to ensure reporting is accurate and completed. Views of responsible officials: There is no disagreement with the audit finding.

2020-007 National Student Loan Data System (NSLDS) Enrollment Reporting Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Aid CFDA Number: Student Financial Aid Cluster Award Period: July 1, 2019 to June 30, 2020 Type of Finding: ? Significant Deficiency in Internal Control over Compliance ? Other Matters Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless if they receive aid from the institution or not. This includes the enrollment effective date and related enrollment status, which must be reported for both the Campus-Level and the Program-Level as well as the program begin date. In addition, at a minimum, schools are required to certify enrollment every 60 days, and respond within 15 days of the date that NSLDS sends a Roster file to the school or its third-party servicer. Condition: During our testing, we noted for 14 out of the 40 students tested, the enrollment effective date did not match the enrollment effective date per the University?s records. We also noted for 22 out of the 40 students tested, the program begin date reported to NSLDS did not match the University?s records for first date of attendance in the corresponding reported program. Lastly, we noted for 26 out of the 40 students tested, the enrollment was not verified every 60 days. Questioned costs: None Context: During our testing, it was noted the University does not have a process in place to ensure timeliness and accuracy of NSLDS reporting. Cause: The University did not timely or properly report student enrollment information to NSLDS through their third-party servicer, National Student Clearinghouse (NSC). Effect: The University did not comply with Department of Education (ED) regulations by reporting student enrollment status changes accurately and timely. Repeat finding: No Recommendation: We recommend the University reevaluate its procedures and review policies surrounding reporting status changes and other enrollment information to NSLDS to ensure timely and accurate reporting. Views of responsible officials: There is no disagreement with the audit finding.

2019-001 National Student Loan Data System (NSLDS) Enrollment Reporting Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Aid CFDA Number: Student Financial Aid Cluster Award Period: July 1, 2018 to June 30, 2019 Type of Finding: ? Significant Deficiency in Internal Control over Compliance ? Other Matters Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless if they receive aid from the institution or not. Changes to said status are required to be reported within 30 days of becoming aware of the status change, or with the next scheduled transmission of statuses if the scheduled transmission is within 60 days. Condition: During our testing, we noted 11 instances out of 25 tested where the student was not reported to NSLDS by the University in a timely manner. In addition, we noted 11 students with timing issues also had instances where the change in status did not match the student enrollment status. Questioned costs: None Context: During our testing, it was noted the University does not have a process in place to ensure timeliness and accuracy of NSLDS reporting. Cause: The University did not timely or properly report student status changes to NSLDS through their third-party servicer, National Student Clearinghouse (NSC). Effect: The University did not comply with Department of Education (ED) regulations by reporting student enrollment status changes timely. Repeat finding: 2018-001 Recommendation: We recommend the University reevaluate its procedures and review policies surrounding reporting status changes to NSLDS to ensure timely reporting. Views of responsible officials: There is no disagreement with the audit finding.

2019-002: COD Reporting Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Aid CFDA Number: Student Financial Aid Cluster Award Period: July 1, 2018 to June 30, 2019 Type of Finding: ? Significant Deficiency in Internal Control over Compliance ? Other Matters Criteria or specific requirement: The Department of Education requires the University to report the disbursement dates and amounts to the Common Origination and Disbursement (COD) system within 15 days of disbursing Pell (34 CFR 690.83(b)(2) and Direct Loan (34 CFR 685.309) funds to a student. Condition: During our testing, we noted 3 of the 50 students tested had disbursement dates per COD that did not match the student account, 1 student disbursement was not reported to COD within 15 days of the disbursement date, and 2 of the 50 students tested had disbursement balances per COD that did not match the student account. There were a total of 3 out of 50 students affected by these issues. Questioned costs: None Context: During our testing, it was noted the University did not properly follow the process to ensure disbursements are accurately reported to COD. Cause: The University did not follow the procedure to meet the requirement that the disbursement date and balance per the student?s account must match the disbursement date and balance in COD. In addition, the University did not follow the procedure to meet the requirement that disbursements made to students must be reported to COD within 15 days of the disbursement date. Effect: Students interest accrues based on disbursement date reported to COD for Direct Loan disbursements, thus interest calculation could be skewed due to the discrepancy in disbursement dates reported. Repeat finding: 2018-002 Recommendation: We recommend the University evaluate its procedures and policies around reporting disbursements to COD to ensure that student information is reported accurately and timely. Views of responsible officials: There is no disagreement with the audit finding.

019-003: Notification of Disbursements Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Aid CFDA Number: Student Financial Aid Cluster Award Period: July 1, 2018 to June 30, 2019 Type of Finding: ? Significant Deficiency in Internal Control over Compliance ? Other Matters 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 University obtains active confirmation. If the University 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: During our testing, we noted that 35 of 40 students tested had no evidence of disbursement notifications being sent before the required deadline established by the Department of Education. Questioned costs: None Context: During our testing, we noted there were three different financial aid software systems used throughout the year. Due to this transition, the University had issues retaining proper documentation. Cause: It was noted there was no documentation to show evidence of these notifications. Effect: Student may not have been aware of when their federal aid was disbursed and therefore may not know their rights to be able to return loan funds. The University is not in compliance with Department of Education requirements. Repeat finding: 2018-003 Recommendation: We recommend the University review and strengthen its procedures for notifying students of their Direct Loan disbursements within the required time frame and that documentation of the letters sent is maintained. Views of responsible officials: There is no disagreement with the audit finding.

019-004 Awarding of Pell, Direct Loan and TEACH Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Aid CFDA Number: Student Financial Aid Cluster Award Period: July 1, 2018 to June 30, 2019 Type of Finding: ? Significant Deficiency in Internal Control over Compliance ? Other Matters Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 690.62, states the Pell grant for an academic year is based upon the payment and disbursement scheduled published by the Secretary for each award year. The payment schedules take into account the cost of attendance, the student?s EFC and the enrollment status of the student. Additionally, the Code of Federal Regulations, 34 CFR 685.203(a) outline the maximum subsidized loan amounts for students based on their dependency status, year of education, and other factors. The Code of Federal Regulations, 34 CFR 686, states that the maximum TEACH grant should be $4,000. As required by the Budget Control Act of 2011, any TEACH Grant that is first disbursed on or after Oct. 1, 2017, and before Oct. 1, 2018, must be reduced by 6.6% from the award amount for which a recipient would otherwise have been eligible. Any TEACH grant that is first disbursed on or after Oct. 1, 2018, and before Oct. 1, 2019, must be reduced by 6.2% from the award amount for which a recipient would otherwise have been eligible. Condition: During our testing, we noted that 1 of 40 students tested was over awarded TEACH grant funds. Also, we noted 2 of 40 students tested were under awarded Pell grant funds. Additionally, we noted 11 of 40 students tested were under awarded or over awarded their subsidized Stafford loan funds. Questioned costs: Over award: $17,598; Under award: $21,619 Context: During our testing, it was noted an erroneous computation of the student?s eligibility resulted in under awards and over awards. The University has resolved the above over and under awards with the Department of Education. Cause: During our testing, it was noted 8 of the 14 students were improperly awarded and disbursed subsidized loans despite having no further need. It was also noted 1 of the 14 students was improperly awarded as a junior when they should have been awarded as a sophomore based on number of credits completed. In addition, it was noted 1 of the 14 students was improperly awarded over their cost of attendance. Due to a lack of education and knowledge of changes to the program, it was noted 1 of the 14 students was over awarded TEACH grant funds. It was also noted 1 of the 14 students was under awarded based on not addressing a student?s proper need. Finally, it was 2 of the 14 students were under awarded based on the fact the disbursements were missed during the awarding process. Effect: Two students were under awarded Pell grants and multiple students were under awarded or over awarded direct loans. The University is not in compliance with Department of Education requirements. Repeat finding: 2018-004 Recommendation: We recommend the University review the procedures surrounding Direct Loan, TEACH and Pell grant awarding to ensure all loans are awarded at the proper amounts and disbursed timely. Views of responsible officials: There is no disagreement with the audit finding.

2019-005 Student Refund of Credit Balance within 14 Days Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Aid CFDA Number: Student Financial Aid Cluster Award Period: July 1, 2018 to June 30, 2019 Type of Finding: ? Significant Deficiency in Internal Control over Compliance ? Other Matters Criteria: The Code of Federal Regulations, 34 CFR 668.164(e) states that whenever an institution disburses title IV, HEA program funds by crediting a student?s account and the total amount of all title IV, HEA program funds credited exceeds the amount of tuition and fees, room and board, and other authorized charges the institution assessed the student, the institution must pay the resulting credit balance directly to the student or parent as soon as possible but? (1) No later than 14 days after the balance occurred if the credit balance occurred after the first day of class of a payment period; or (2) No later than 14 days after the first day of class of a payment period if the credit balance occurred on or before the first day of class of that payment period. Condition: During our testing, we noted 3 of 40 students tested did not have the credit balance resulting from federal funds refunded within the 14-day period. Questioned Costs: None Context: During our testing it was noted that the University failed to refund students within the 14-day period. Cause: The University did not post adjustments to student accounts within the University?s add/drop period. Noted adjustments were made to student ledgers after 14 days. Effect: The University did not refund students within 14 days for credit balances that arose from federal funds as required by Department of Education regulations. Repeat finding: No Recommendation: We recommend the University put a process in place to refund student credit balances that arise from federal funds within 14 days. We also recommend posting to student accounts for institutional charges for each payment period be posted and dated prior to disbursing federal funds to limit the number of refund checks. View of Responsible Officials: There is no disagreement with the audit finding.

2019?006 Satisfactory Academic Progress Federal agency: Department of Education Federal program title: Student Financial Aid CFDA Numbers: Student Financial Aid Cluster Award Period: July 1, 2018 through June 30, 2019 Type of Finding: ? Significant Deficiency in Internal Control over Compliance ? Other Matters Criteria: The Code of Federal Regulations, 34 CFR 668.34 requires an institution to have a satisfactory academic progress (SAP) policy for purposes of determining student eligibility for assistance under the Title IV, HEA programs. The institution must establish, publish, and apply reasonable standards for measuring whether an otherwise eligible student is maintaining SAP in his or her educational program. The institution must also notify students who fail to meet SAP requirements. Condition: The University must retain documentation of communication made to students notifying them that they are failing to meet SAP requirements. Questioned costs: None Context: During our testing, we noted there were three different financial aid software systems used throughout the year. Due to this transition, for 4 of the 40 students tested no documentation was retained for communication made to the student that they were failing to meet SAP requirements. Cause: The University did not retain documentation of compliance with their written SAP policy. Effect: The University could improperly award financial aid and the student was potentially unaware that they were not meeting SAP requirements. Repeat finding: No Recommendation: We recommend that the University review their SAP policies to ensure the proper documentation is retained for notifications relating to SAP requirements. Views of responsible officials: There is no disagreement with the audit finding.

2019?007 Gramm-Leach-Bliley Act Federal agency: Department of Education Federal program title: Student Financial Aid CFDA Numbers: Student Financial Aid Cluster Award Period: July 1, 2018 through June 30, 2019 Type of Finding: ? Significant Deficiency in Internal Control over Compliance ? Other Matters 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). Condition: Under an institution?s Program Participation Agreement with the 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 Department or otherwise obtained in support of the administration of the federal student financial aid programs. Questioned costs: None Context: During our audit procedures, it was noted that the University did not 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 and document safeguards for identified risks. Cause: The organization uses a third-party IT service provider for IT related tasks and relied on that service provider to ensure all compliance requirements are met. However, the organization should have an individual designated internally to assure compliance with the requirements of the Gramm-Leach-Bliley Act. The organization did not perform an IT risk assessment tailored specifically to the organization, identify risks, or address risks identified as required by the Gramm-Leach-Bliley Act. Effect: The student personal information could be vulnerable. Repeat finding: No Recommendation: We recommend that the University engage a third party or perform the risk assessment for the three areas required by the Gramm-Leach-Bliley Act and ensure that there are documented safeguards for identified risks. Views of responsible officials: There is no disagreement with the audit finding.

2019?008 Reporting Federal agency: Department of Education Federal program title: Student Financial Aid CFDA Numbers: Student Financial Aid Cluster Award Period: July 1, 2018 through June 30, 2019 Type of Finding: ? Significant Deficiency in Internal Control over Compliance ? Other Matters Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 675.19(b)(3) states that accurate information be populated and submitted on the Fiscal Operations Report and Application to Participate (FISAP). Condition: During our testing of reporting, we noted the FISAP information failed to report the institutional dollars spend for Federal Work Study, and therefore shows that the University is not meeting the proper 25% match requirements. Questioned costs: None Context: During our audit procedures, we noted the FISAP failed to report that the University was meeting the 25% Federal Work Study match requirements. Cause: There were no institutional dollars for Federal Work Study reported on the FISAP. Effect: The University is not in compliance with Department of Education requirements that state the FISAP must report institutional dollars spent for Federal Work Study in order to comply with the 25% match requirements. Repeat finding: 2018-007 Recommendation: We recommend the University review their policies and procedures surrounding FISAP reporting to ensure reporting is accurate and completed. Views of responsible officials: There is no disagreement with the audit finding.

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