Langston UniversityHigher Education

Federal Agency: U.S. Department of Agriculture and U.S. Department of Health and Human Services Federal Program Name: Research and Development Assistance Listing Number: 10.215 and 93.433 Federal Award Identification Number and Year: 90RTEM0009 - 2025, 20213864034724 - 2025, 90RTST0002 - 2025 Award Period: July 1, 2024 to June 30, 2025 Type of Finding: - Significant Deficiency in Internal Control over Compliance - Other Matters Criteria or specific requirement: The Federal Government requires that when the reimbursement method is used, the Federal awarding agency or pass-through entity must make payment within 30 calendar days after receipt of the billing, unless the Federal awarding agency or pass-through entity reasonably believes the request to be improper (2 CFR section 200.305(b)(3)). Per Uniform Guidance 2 CFR 200.303, nonfederal 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. Condition: The University did not make payments to subrecipients within 30 days after receipt of invoices. Questioned costs: None. Context: During our testing we identified 4 out of 14 subrecipient payments that did not process payment requests from the subrecipients timely. Cause: The University did not have an effective control in place to ensure subrecipient payments were paid timely. Effect: Subrecipients on federal awards do not receive timely payment for federal contract work. Repeat Finding: Yes, 2024-001 Recommendation: We recommend the University review and update policies and procedures to allow for more timely payment to subrecipients for work the University contracts them to perform. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.

Federal Agency: Federal Government Federal Program Name: Research & Development, Agriculture Extension at 1890 Land-grant Institutions, and Higher Education Institutional Aid Assistance Listing Number: Multiple Federal Award Identification Number and Year: Multiple Award Period: July 1, 2024 to June 30, 2025 Type of Finding: - Material Weakness in Internal Control over Compliance Criteria or specific requirement: Uniform Grant Guidance, 2 CFR 200.313(d)(2), procedures for managing equipment (including replacement equipment), whether acquired in whole or in part under a Federal award, until disposition takes place will, as a minimum, meet the following requirements, a physical inventory of the property must be taken and the results reconciled with the property records at least once every two years. Per Uniform Guidance 2 CFR 200.303, nonfederal 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. Condition: The University did not have documentation of physical inventory of the equipment purchased with Federal funds. Questioned costs: None. Context: During inquiries with management, the University had been unable to fill a staffing position to help implement correct action of tracking equipment purchased with Federal funds. Cause: The University did not have an effective control in place to ensure physical inventory over equipment was completed every two years. Effect: Failure to maintain accurate inventory records inhibits the University from properly safeguarding and maintaining equipment. Repeat Finding: Yes, 2024-002 Recommendation: We recommend the University ensures that a physical inventory over equipment is completed at least every two years. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.

Federal Agency: U.S. Department of Agriculture, and U.S. Department of Education Federal Program Name: Research & Development, Agriculture Extension at 1890 Land-grant Institutions, and Higher Education Institutional Aid Assistance Listing Number: 10.205, 10.512, 84.031 Federal Award Identification Number and Year: NI241445XXXXG012 - 2025, NI221444XXXXG019 - 2025, NI211444XXXXG016 - 2025, P031B220009 - 2025 Award Period: July 1, 2024 to June 30, 2025 Type of Finding: - Significant Deficiency in Internal Control over Compliance - Other Matters Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.318(i), the recipient must maintain records sufficient to detail the history of each procurement transaction. These records must include the rationale for the procurement method, contract type selection, contractor selection or rejection, and the basis for the contract price. Per Uniform Guidance 2 CFR 200.303, nonfederal 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. Condition: The University did not go through procurement procedures prior to entering into a contract with the vendor. Questioned costs: None. Context: During our testing of the Research & Development Cluster, we identified 1 out of 8 transactions that did not go through the proper procurement procedures. During our testing of the Higher Education Institutional Aid Program, we identified 1 out of 8 transactions that did not go through the proper procurement procedures. During our testing of the Extension Services at 1890 Colleges and Tuskegee University, West Virginia State College, and Central State University Program, we identified 3 out of 8 transactions that did not go through the proper procurement procedures. Cause: The University did not have an effective control in place to ensure that the purchases went through the procurement procedures. Effect: The University was not in compliance with the regulation to go through the procurement procedures prior to entering a contract. Repeat Finding: No Recommendation: We recommend that the University review policies and procedures for procurement to ensure that every applicable transaction is going through the proper procurement procedures. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.

Federal Agency: U.S. Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Number: 84.379 Federal Award Identification Number and Year: P379T250352 - 2025 Award Period: July 1, 2024 to 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 686.11(a)(5), states that if the student is beyond the first year of a program of undergraduate education as determined by the institution, a cumulative undergraduate GPA of at least 3.25 on a 4.0 scale, or the numeric equivalent, through the most-recently completed payment period, is a requirement to be eligible to receive a TEACH Grant. Per Uniform Guidance 2 CFR 200.303, nonfederal 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. Condition: The University awarded the TEACH Grant to a student who did not meet the GPA requirement. Questioned costs: None. Context: During our testing of eligibility, we identified one student that was only maintaining a 2.75 GPA even though the federal requirements states the student should be maintaining at least a 3.25 GPA to be eligible for the TEACH Grant funds. Cause: The University did not thoroughly review federal regulations for eligibility requirements prior to awarding the student the TEACH Grant. Effect: Failure to follow eligibility requirements may result in noncompliance of federal regulations. Repeat Finding: No Recommendation: We recommend the University review and update current procedures to ensure that students meet eligibility requirements prior to receiving the TEACH Grant. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.

Federal Agency: U.S. Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Number: 84.063, 84.268, 84.007, 84.033, 84.379 Federal Award Identification Number and Year: P063P240352- 2025, P268K250352 - 2025, P007A243424 - 2025, P033A243424 – 2025, P379T250352 - 2025 Award Period: July 1, 2024 to June 30, 2025 Type of Finding:  Material Weakness in Internal Control over Compliance 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. The Code of Federal Regulations, 34 CFR 685.309(b), states the school is required to report changes in the student’s enrollment status, the effective date of the status, and an anticipated completion date. Per Uniform Guidance 2 CFR 200.303, nonfederal 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. Condition: The University did not properly report student enrollment changes for students who received federal student aid to the National Student Loan Data System (NSLDS). Questioned costs: None. Context: During our testing of 60 students, we identified 7 students whose campus enrollment status change was not reported, 15 students whose program enrollment status change was not reported correctly, 2 students with incorrect effective dates reported for campus enrollment, 8 students with incorrect effective dates reported for program enrollment, and 26 students whose status changes were not reported timely. We also identified that for 3 of the selected students, the program-level enrollment does not show student participating in correct program per institutional records. Cause: The University didn't have effective controls in place to verify students' status in NSLDS matched the institutions records accurately or in a timely manner. Effect: The University was not in compliance with the requirements to properly report student enrollment data correctly. Incorrect dates submitted to NSLDS may be used to determine the grace period for the repayment and interest of outstanding Title IV student loans. Repeat Finding: Yes, 2024-006 Recommendation: We recommend the University review current processes for reporting to NSLDS and implement additional procedures to ensure submissions are reported timely and accurately. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.

Federal Agency: U.S. Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Number: 84.063, 84.268 Federal Award Identification Number and Year: P063P240352- 2025, P268K250352 - 2025 Award Period: July 1, 2024 to 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(j)(1), states that an institution must return the amount of title IV funds for which it is responsible as soon as possible but no later than 45 days after the date of the institution's determination that the student withdrew. Per Uniform Guidance 2 CFR 200.303, nonfederal 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. Condition: The University did not return Title IV funds within 45-days. Questioned costs: None. Context: During our testing of 9 students’ Return of Title IV (R2T4) calculations, we identified 2 with refunds that were not returned within the 45-day requirement. Cause: The University has not implemented precise controls to ensure timely return of funds related to withdrawals. Effect: The University was not in compliance with the requirements to properly return refunds within the 45-day requirement. Repeat Finding: No Recommendation: We recommend the University review its current procedures for Title IV funds and implement additional procedures to ensure refunds are returned timely. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.

Federal Agency: Federal Government Federal Program Name: Research & Development Assistance Listing Number: 10.205, 10.216, 12.630, 93.859 Federal Award Identification Number and Year: Multiple Award Period: 7/1/2023-6/30/2024 Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: The Federal Government requires that when the reimbursement method is used, the Federal awarding agency or pass-through entity must make payment within 30 calendar days after receipt of the billing, unless the Federal awarding agency or pass-through entity reasonably believes the request to be improper (2 CFR section 200.305(b)(3)). Per Uniform Guidance 2 CFR 200.303, nonfederal 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. Condition: The University did not make payments to subrecipients within 30 days after receipt of invoices. Questioned costs: N/A Context: CLA tested a sample of 19 subrecipient payments and discovered that 7 of the 19 payments had exceptions. Cause: The University did not have an effective control in place to ensure subrecipient payments were paid timely. Effect: The University was not in compliance with the regulation to make payments to subrecipients within the required timeframe. Repeat Finding: Yes, 2023-014. Recommendation: We recommend that the University review and update current procedures to ensure subrecipient payments are paid timely. Views of responsible officials: There is no disagreement with the audit finding.

Federal Agency: Federal Government Federal Program Name: Research & Development; Extension Services at 1890 Colleges and Tuskegee University, West Virginia State College, and Central State University; Higher Education Institutional Aid Assistance Listing Number: Multiple Federal Award Identification Number and Year: Multiple Award Period: 7/1/2023-6/30/2024 Type of Finding: Material Weakness in Internal Control over Compliance Criteria or specific requirement: Uniform Grant Guidance, 2 CFR 200.313(d)(2), procedures for managing equipment (including replacement equipment), whether acquired in whole or in part under a Federal award, until disposition takes place will, as a minimum, meet the following requirements, a physical inventory of the property must be taken and the results reconciled with the property records at least once every two years. Per Uniform Guidance 2 CFR 200.303, nonfederal 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. Condition: The University did not have documentation of physical inventory of the equipment purchased with Federal funds. Questioned costs: N/A Context: Due to the previous audit concluding after substantially all the fiscal year had passed, the University was unable to completely implement the corrective action plan by the fiscal year ended June 30, 2024. As such, we were unable to obtain complete populations and test the related compliance requirements for equipment funded by federal awards. Cause: The University did not have an effective control in place to ensure physical inventory over equipment was completed every two years. Effect: Failure to maintain accurate inventory records inhibits the University from properly safeguarding and maintaining equipment Repeat Finding: Yes, 2023-017. Recommendation: We recommend the University ensure that a physical inventory over equipment is completed at least every two years. Views of responsible officials: There is no disagreement with the audit finding.

Federal Agency: Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Number: 84.007, 84.033, 84.063, 84.268 Federal Award Identification Number and Year: P007A233438 - 2024, P033A233438 - 2024, P063P232047 - 2024, P268K242047 - 2024 Award Period: 7/1/2023-6/30/2024 Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: 34 CFR 668.165, states that an institution must notify the student, or parent, in writing of (1) the date and amount of the disbursement; (2) the student’s right, or parent’s right, to cancel all or a portion of that loan or loan disbursement and have the loan proceeds returned to the holder of that loan or the TEACH Grant payments returned to ED; and (3) the procedure and time by which the student or parent must notify the institution that he or she wishes to cancel the loan, TEACH Grant, or TEACH Grant disbursement. The notification requirement for loan funds applies only if the funds are disbursed by EFT payment or master check. Per 2 CFR 200.303, nonfederal 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. Condition: The University did not properly notify students when loans were credited to the student's ledger account. Questioned costs: N/A Context: During our Eligibility testing of 60 students, we noted that there were 48 students that received loan disbursements; however, 8 students did not receive the required notification for each loan disbursement. Cause: The University did not send loan disbursement notifications. Effect: Students were not made aware of the anticipated date and amount of loan disbursement for the right to cancel all or a portion of the loan in the required amount of time. Repeat Finding: Yes, 2023-019. Recommendation: We recommend the University evaluate its procedures around disbursements of loans and ensure that notifications of disbursements are sent and contain all the required elements outlined in the FSA handbook. Views of responsible officials: There is no disagreement with the audit finding.

Federal Agency: Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Number: 84.007, 84.033, 84.063, 84.268 Federal Award Identification Number and Year: P007A233438 - 2024, P033A233438 - 2024, P063P232047 - 2024, P268K242047 - 2024 Award Period: 7/1/2023-6/30/2024 Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 682.604, states that a school must ensure that exit counseling is conducted with each Stafford Loan borrower and graduate or professional student PLUS Loan borrower either in person, by audiovisual presentation, or by interactive electronic means. In each case, the school must ensure that this counseling is conducted shortly before the student borrower ceases at least half-time study at the school. Per 2 CFR 200.303, nonfederal 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. Condition: The University did not properly have documentation of exit counseling notification. Questioned costs: N/A Context: During our testing of 60 students, we identified 5 students that did not have documentation of exit counseling notification. Cause: The University did not have proper procedures in place to ensure that notification of required exit counseling was sent to applicable students. Effect: Exit counseling helps federal student loan borrowers understand how to repay their loans and reviews deferment and repayment plans options. If students are not notified of exit counseling, they could be at risk of not understanding their rights and responsibilities regarding loan repayment. Repeat Finding: Yes, 2023-024. Recommendation: We recommend the University review reporting processes to ensure all students that require exit counseling receive it in a timely manner. Views of responsible officials: There is no disagreement with the audit finding.

Federal Agency: Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Number: 84.007, 84.033, 84.063, 84.268 Federal Award Identification Number and Year: P007A233438 - 2024, P033A233438 - 2024, P063P232047 - 2024, P268K242047 - 2024 Award Period: 7/1/2023-6/30/2024 Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: Per 2 CFR 200.303, nonfederal 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. Per 34 CFR 668.22(f)(2)(i), the total number of calendar days in a payment period or period of enrollment includes all days within the period that the student was scheduled to complete, except that scheduled breaks of at least five consecutive days are excluded from the total number of calendar days in a payment period or period of enrollment and the number of calendar days completed in that period. Condition: The University incorrectly calculated Return to Title IV (R2T4) calculations, did not have documentation of withdrawal and did not have formal procedures in place to review the R2T4 calculations. Questioned costs: N/A Context: During our testing of 16 students, we identified 1 student whose calculation used the incorrect amount of break days. Cause: The University was using the incorrect number of scheduled break days for Spring Term. Effect: The University could return incorrect amounts based off of their calculations, which could affect student repayment amounts based off of amount earned. Repeat Finding: Yes, 2023-022. Recommendation: We recommend that the University review policies and procedures related to R2T4 calculations to ensure calculations are performed correctly and timely. We also recommend the University implement formal review procedures to document the Return of Title IV calculations are being performed to minimize the likelihood that errors may go undetected and not be corrected in a timely manner. Views of responsible officials: There is no disagreement with the audit finding.

Federal Agency: Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Number: 84.007, 84.033, 84.063, 84.268 Federal Award Identification Number and Year: P007A233438 - 2024, P033A233438 - 2024, P063P232047 - 2024, P268K242047 - 2024 Award Period: 7/1/2023-6/30/2024 Type of Finding: Material Weakness in Internal Control over Compliance Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal 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 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. The Code of Federal Regulations, 34 CFR 685.309(b), states the school is required to report changes in the student’s enrollment status, the effective date of the status, and an anticipated completion date. Condition: The University did not properly report student enrollment changes for students who received federal student aid to the National Student Loan Data System (NSLDS). Questioned costs: N/A Context: During our testing of 60 students, we identified 1 student whose enrollment status change was not reported, 6 students with incorrect effective dates reported for campus enrollment, 13 students with incorrect effective dates reported for program enrollment, and 33 students whose status changes were not reported timely. We also note that for 55 of the selected students, enrollment status was not certified every 60 days. We also note that the University did not document any evidence of review. Cause: The University didn't have proper procedures in place to verify students’ status in NSLDS matched the institutions records in a timely manner. Effect: The University was not in compliance with the requirements to properly report student enrollment data correctly. Incorrect dates submitted to NSLDS may be used to determine the grace period for the repayment and interest of outstanding Title IV student loans. Repeat Finding: Yes, 2023-023. Recommendation: We recommend the University review current processes for reporting to NSLDS and implement procedures to ensure submissions are reported timely and accurately. Views of responsible officials: There is no disagreement with the audit finding.

Federal Agency: Federal Government Federal Program Name: Research & Development Assistance Listing Number: 10.205, 10.216, 12.630, 93.859 Federal Award Identification Number and Year: Multiple Award Period: 7/1/2023-6/30/2024 Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal 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. Per 2 CFR 200.344(b), unless the Federal awarding agency or pass-through entity authorizes an extension, a non-Federal entity must liquidate all financial obligations incurred under the Federal award no later than 120 calendar days after the end date of the period of performance as specified in the terms and conditions of the Federal award. Condition: The University does not have adequate procedures in place to ensure federal awards are closed in a timely manner. Questioned costs: $125,035.65 Context: During our testing, we identified 10 transactions out of 60 that were incurred after the period of performance date. Additionally, during our testing, we identified 23 transactions out of 60, that was paid over 120 days after the period of performance had ended. Cause: The University does not have an effective control in place to ensure costs are properly incurred prior to the end of the federal awards period of performance. Effect: Failure to close federal awards and process necessary cost transfers in a timely manner may result in inaccurate periodic financial reports and unallowable costs. Repeat Finding: Yes, 2023-016. Recommendation: We recommend the University review its current close out procedures and implement additional procedures to monitor the timeliness of federal account close outs. Views of responsible officials: There is no disagreement with the audit finding.

Federal Agency: Department of Education, Department of Agriculture, and Department of Defense Federal Program Title: Education Stabilization Fund & Research and Development Cluster Assistance Listing Number: 84.425F, 10.205, and 12.630 Federal Award Identification Number: P425F200986-2023, NI211445XXXXG001-2023, NI201445XXXXG009-2023, W911NF-22 Award Period: 7/1/22-6/30/23 Type of Finding: Material Weakness in Internal Control over Compliance; Compliance, Material Noncompliance Condition: The University does not review the work or internal control reports of their third-party servicer who performs suspension and debarment checks against the federal exclusion list. Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal 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. Per 2 CFR 180.300 nonfederal entities entering into a covered transaction are required to verify the entity whom they intend to do business with are not excluded or disqualified. Context: The University uses a third party to perform their suspension and debarment checks for covered transactions. The University does not review internal control reports, such as SOC1 reports, or perform other documented reviews of the third-party servicer's work. Questioned costs: N/A Cause: The University did not have a control in place to review the controls and accuracy of the third-party servicer's work. Effect: The third-party servicer could experience control deficiencies which may impact compliance and the University would be unaware and unable to make timely reviews of the work provided by the servicer. Repeat finding: Yes, 2022-019 Recommendation: We recommend the University review internal control reports and implement review controls for work performed by third party servicers. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.

Federal Agency: Department of Agriculture, National Aeronautics and Space Administration, and Department of Health and Human Services Federal Program Title: Research and Development Cluster Assistance Listing Number: 10.216, 43.008, and 93.433 Federal Award Identification Number: 2021388213586-2023, NNX15AP43A-2023, 90RTST0001-2023, 90RTEM0009-2023 Award Period: 7/1/22-6/30/23 Type of Finding: Significant Deficiency in Internal Control over Compliance; Compliance, Other Matters Condition: The University did not obtain timely documentation for subrecipient monitoring and did not include required information in the subrecipient subawards. Criteria or specific requirement: Uniform Guidance (2 CFR section 200.331 (a)) requires all pass-through entities ensure that every subaward is clearly identified to the subrecipient as a subaward and include information to comply with Federal statutes, regulations, and the terms and conditions of the award. The required information includes the subrecipient’s DUNS number, ALN and name, federal award date, and further additional requirements. When some of this information is not available, the pass-through entity shall provide the best information available to describe the Federal award. Uniform Grant Guidance (2 CFR 200.331(d)) requires nonfederal entities receiving Federal awards monitor the activities of the subrecipient as necessary to ensure the subaward is used for authorized purposes, in compliance with compliance with Federal statutes, regulations and the terms and conditions of the subaward and the performance goals are achieved. Pass-through entity monitoring of the subrecipient must include: (1) reviewing financial reports and performance reports required by the pass–through entity and (2) following up and ensuring the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on site reviews and other means. Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Context: During our testing of 6 subrecipients, we identified that 6 did not have timely documentation for subrecipient monitoring. The University did not follow up when responses were not received from subrecipients for the subrecipient monitoring process. Additionally, we identified 2 subrecipients did not have the required information included in the subaward agreement. Questioned costs: N/A Cause: The University did not have an effective control in place to ensure subrecipient monitoring was complete and timely. Effect: Failure to monitor subaward may result in unauthorized uses of federal funds passed-through to subrecipients. Repeat finding: No Recommendation: We recommend the University review its procedures for the subrecipient monitoring process to ensure the reviews are completed timely and implement procedures necessary to ensure information is included in the subrecipient award documents at the time of funding. Views of responsible officials: Management agrees with the finding and has developed a plan to correct

Federal Agency: Various Federal Program Title: Research and Development Cluster Assistance Listing Number: 43.008 and 93.433 Federal Award Identification Number: NNX15AP43A-2023, 90RTEM0009-2023 Award Period: 7/1/22-6/30/23 Type of Finding: Significant Deficiency in Internal Control over Compliance; Compliance, Other Matters Condition: The University did not make payments to subrecipients within 30 days after receipt of invoices. Criteria or specific requirement: Uniform Grant Guidance (2 CFR 200.305(b)(3)) when the reimbursement method is used, the Federal awarding agency or pass-through entity must make payment within 30 calendar days after receipt of the billing, unless the Federal awarding agency or pass-through entity reasonably believes the request to be improper. Per Uniform Guidance 2 CFR 200.303, nonfederal 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. Context: During our testing of 28 subrecipient payments, from a statistically valid sample, we identified 2 payments were not submitted within 30 days after receiving invoice from the subrecipients. One payment was 39 days beyond the required 30 days and the second payment was 565 days beyond the required 30 days. Questioned costs: N/A Cause: The University did not have an effective control in place to ensure subrecipient payments were paid timely. Effect: The University was not in compliance with the regulation to make payments to subrecipients within the required timeframe. Repeat finding: No Recommendation: We recommend that the University review and update current procedures to ensure subrecipient payments are paid timely. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.

Federal Agency: Department of Agriculture Federal Program Title: Research and Development Cluster Assistance Listing Number: 10.205, 10.512, 10.443, 10.215 Federal Award Identification Number: NI211445XXXXG001, NI221445XXXXG019, NI191444XXXXG019, NI201444XXXXG009, A0192501X443G023, SUB00002488 PASS THRU 2019- 38640-29878 Award Period: 7/1/22-6/30/23 Type of Finding: Significant Deficiency in Internal Control over Compliance; Compliance, Other Matters Condition: The University does not have adequate procedures in place to ensure that USDA federal funds were not spent on disallowed costs. Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal 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. As required by 2 CFR 200.403 expenditures of federal awards should be necessary and reasonable for the performance of the Federal award and be allocable thereto under these principles. Context: During testing, we were made aware of thirteen individuals whose salaries were improperly coded to a teaching code in USDA federal and state match funds. A total of $256,940 in federal funds and $160,791 in state match funds were coded to a teaching account salary code. Additionally, during our testing of 40 payroll we identified 1 transaction that was improperly coded to the incorrect account code. Questioned costs: $256,940 Cause: The University does not have an effective control in place to ensure payroll transactions are properly coded between federal and nonfederal funds. Effect: Failure to properly record federal and nonfederal funds may result in inaccurate reporting of disallowed costs on the Schedule of Expenditures of Federal Awards. Repeat finding: No Recommendation: We recommend the University review its current procedures to ensure non-federal costs are not being allocated to federal fund codes. Also, the University should process retro-active cost transfers or payroll adjustments to ensure that no teaching salaries are coded to USDA grant funds. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.

Federal Agency: Department of Agriculture Federal Program Title: Research and Development Cluster Assistance Listing Number: 10.205, 10.215 Federal Award Identification Number: 2019-38640-29878, NI201445XXXXG009 Award Period: 7/1/22-6/30/23 Type of Finding: Significant Deficiency in Internal Control over Compliance; Compliance, Other Matters Condition: The University does not have adequate procedures in place to ensure federal awards are closed in a timely manner. Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal 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. Per 2 CFR 200.344(b), unless the Federal awarding agency or pass-through entity authorizes an extension, a non-Federal entity must liquidate all financial obligations incurred under the Federal award no later than 120 calendar days after the end date of the period of performance as specified in the terms and conditions of the Federal award. Context: During our testing, we identified 9 transactions out of 40 that were incurred after the period of performance date. Additionally, during our testing, we identified 1 transaction out of 27, that was paid over 120 days after the period of performance had ended. Questioned costs: N/A Cause: The University does not have an effective control in place to ensure costs are properly incurred prior to the end of the federal awards period of performance. Effect: Failure to close federal awards and process necessary cost transfers in a timely manner may result in inaccurate periodic financial reports and unallowable costs. Repeat finding: No Recommendation: We recommend the University review its current close out procedures and implement additional procedures to monitor the timeliness of federal account close outs. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.

Federal Agency: Various Federal Program Title: Research and Development Cluster Assistance Listing Number: 10.205, 10.216, 12.630, 93.859 Federal Award Identification Number: NI211445XXXXG001, NI221445XXXXG019, 2020-38821-31093, 5P20GM103418-21, W911NF-22-1-0200, 5P20GM103447-23, P20CA233391, NNX15AP43A Award Period: 7/1/22-6/30/23 Type of Finding: Material Weakness in Internal Control over Compliance; Compliance, Material Noncompliance Condition: The University did not have documentation of physical inventory of the equipment purchased with Federal funds. Criteria or specific requirement: Uniform Grant Guidance, 2 CFR 200.313(d)(2), procedures for managing equipment (including replacement equipment), whether acquired in whole or in part under a Federal award, until disposition takes place will, as a minimum, meet the following requirements, a physical inventory of the property must be taken and the results reconciled with the property records at least once every two years. Per Uniform Guidance 2 CFR 200.303, nonfederal 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. Context: During our testing of 30 equipment totaling $1,066,219, we observed 29 instances totaling $1,058,721 did not have documentation of a physical inventory completed. Questioned costs: N/A Cause: The University did not have an effective control in place to ensure physical inventory over equipment was completed every two years. Effect: Failure to maintain accurate inventory records inhibits the University from properly safeguarding and maintaining equipment. Repeat finding: No Recommendation: We recommend the University ensure that a physical inventory over equipment is completed at least every two years. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.

Federal Agency: Department of Education Federal Program Title: Student Financial Assistance Cluster Assistance Listing Number: 84.007, 84.033, 84.063, 84.268 Federal Award Identification Number: P007A223424-2023, P033A223424-2023, P063P220352-2023, and P268K220352-2023 Award Period: 7/1/22-6/30/23 Type of Finding: Material Weakness in Internal Control over Compliance Condition: The University does not review the work or internal control reports of their third-party servicer who performs eligibility verification procedures. Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal 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. Context: The University uses a third party to perform their verification procedures to assess Title IV student eligibility. The University does not review internal control reports, such as SOC1 reports, or perform other documented reviews of the third-party servicer's work. Questioned costs: N/A Cause: The University did not have a control in place to review the controls and accuracy of the third-party servicer's work. Effect: The third-party servicer could experience control deficiencies which may impact compliance and the University would be unaware and unable to make timely reviews of the work provided by the servicer. Repeat finding: Yes, 2022-018 Recommendation: We recommend the University review internal control reports and implement review controls for work performed by third party servicers. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.

Federal Agency: Department of Education Federal Program Title: Student Financial Assistance Cluster Assistance Listing Number: 84.007, 84.033, 84.063, 84.268 Federal Award Identification Number: P007A223424-2023, P033A223424-2023, P063P220352-2023, and P268K220352-2023 Award Period: 7/1/22-6/30/23 Type of Finding: Material Weakness in Internal Control over Compliance; Compliance, Material Noncompliance Condition: The University did not properly notify students when loans were credited to the student's ledger account. Criteria or specific requirement: 34 CFR 668.165, states that an institution must notify the student, or parent, in writing of (1) the date and amount of the disbursement; (2) the student’s right, or parent’s right, to cancel all or a portion of that loan or loan disbursement and have the loan proceeds returned to the holder of that loan or the TEACH Grant payments returned to ED; and (3)the procedure and time by which the student or parent must notify the institution that he or she wishes to cancel the loan, TEACH Grant, or TEACH Grant disbursement. The notification requirement for loan funds applies only if the funds are disbursed by EFT payment or master check. Additionally per 2 CFR 200.303, nonfederal 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. Context: During our Eligibility testing of 60 students, we noted that there were 43 students that received loan disbursements however, all 43 students did not receive the required notification for each loan disbursement. Questioned costs: N/A Cause: The University did not send loan disbursement notifications. Effect: Students were not made aware of the anticipated date and amount of loan disbursement for the right to cancel all or a portion of the loan in the required amount of time. Repeat finding: Yes, 2022-013 Recommendation: We recommend the University evaluate its procedures around disbursements of loans and ensure that notifications of disbursements are sent and contain all the required elements outlined in the FSA handbook. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.

Federal Agency: Department of Education Federal Program Title: Student Financial Assistance Cluster Assistance Listing Number: 84.007, 84.033, 84.063, 84.268 Federal Award Identification Number: P007A223424-2023, P033A223424-2023, P063P220352-2023, and P268K220352-2023 Award Period: 7/1/22-6/30/23 Type of Finding: Significant Deficiency in Internal Control over Compliance; Compliance, Other Matters Condition: The University has a Written information Security Program; however, the University did not meet the minimum requirements stated in the Gramm-Leach-Bliley Act. Additionally, the University did not designate a qualified individual responsible for overseeing and implementing the information and security program. Criteria or specific requirement: The Gramm-Leach Bliley Act (GLBA) requires financial institutions to explain their information-sharing practices to their customers and to safeguard sensitive data (16 CFR 314). The regulation states that the college must designate a qualified individual responsible for overseeing and implementing your information security program and enforcing your information security program. (16 CFR 314.4(a)). The entity shall have a Written Information Security Program (WISP) that outlines the design and implementation of the risk assessment procedures. (16 CFR 314.4(b)). At a minimum, the institution’s written information security program must address the implementation of the minimum safeguards identified in 16 CFR 314.4(c)(1) through (8) including: Assess apps developed by the institution. In addition, the written security program provides for the institution to regularly test or otherwise monitor the effectiveness of the safeguards it has implemented (16 CFR 314.4(d)). Per 2 CFR 200.303, nonfederal 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. Context: These new GLBA requirements were applicable beginning on June 9, 2023, and there were seven elements missing from their Written Information Security Program. Questioned costs: N/A Cause: There was not a formal process in place to review against all the new GLBA requirements to ensure compliance. Effect: The University was not in compliance with Gramm-Leach-Bliley compliance standards. Repeat finding: Yes, 2022-017 Recommendation: We recommend that the University review the updated GLBA requirements and ensure their WISP includes all required elements. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.

Federal Agency: Department of Education Federal Program Title: Student Financial Assistance Cluster Assistance Listing Number: 84.007, 84.033, 84.063, 84.268 Federal Award Identification Number: P007A223424-2023, P033A223424-2023, P063P220352-2023, and P268K220352-2023 Award Period: 7/1/22-6/30/23 Type of Finding: Significant Deficiency in Internal Control over Compliance; Compliance, Other Matters Condition: Langston University had 2 instance of Title IV refund checks to students that were outstanding longer than 240 days as of June 30, 2023. 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. The Code of Federal Regulations, 2 CFR 200.303, required that entities must establish and maintain internal controls which provide reasonable assurance that federal award expenditures are in compliance with Federal statutes, regulations, and the terms and conditions of the Federal Award. Context: During the testing of the outstanding Title IV student check listing CLA observed two instances of stale checks at Langston that were aged greater than 240 days. Questioned costs: N/A Cause: The University did not return checks that were not cashed within 240 days. Effect: Funds are not returned to the Department of Education in a timely manner. Repeat finding: No Recommendation: We recommend that the University establish and maintain internal controls which provide reasonable assurance that federal award expenditures are in compliance with Federal statutes, regulations, and the terms and conditions of the Federal Award and that stale federal aid checks are returned to the Department of Education with 240 days after the date of issuance if not cashed. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.

Federal Agency: Department of Education Federal Program Title: Student Financial Assistance Cluster Assistance Listing Number: 84.007, 84.033, 84.063, 84.268 Federal Award Identification Number: P007A223424-2023, P033A223424-2023, P063P220352-2023, and P268K220352-2023 Award Period: 7/1/22-6/30/23 Type of Finding: Significant Deficiency in Internal Control over Compliance; Compliance, Other Matters Condition: The University incorrectly calculated Return to Title IV (R2T4) calculations, did not have documentation of withdrawal and did not have formal procedures in place to review the R2T4 calculations. Criteria or specific requirement: Per 2 CFR 200.303, nonfederal 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. Per 34 CFR 668.22(f)(2)(i), the total number of calendar days in a payment period or period of enrollment includes all days within the period that the student was scheduled to complete, except that scheduled breaks of at least five consecutive days are excluded from the total number of calendar days in a payment period or period of enrollment and the number of calendar days completed in that period. Context: During our testing of 13 R2T4 calculations, we identified that 7 had mechanically incorrect calculations by using the incorrect number of scheduled break days in the Spring term. Also, during our testing, we identified 2 instances of no documentation to support withdrawal date used for the R2T4 calculation. Furthermore, we were unable to identify a formal control procedure related to Return to Title IV transactions. Questioned costs: $1,363 Cause: The University was using the incorrect number of scheduled break days for Spring Term. Effect: The University could return incorrect amounts based off of their calculations, which could affect student repayment amounts based off of amount earned. Repeat finding: Yes, 2022-015 Recommendation: We recommend that the University review policies and procedures related to R2T4 calculations to ensure calculations are performed correctly and timely. We also recommend the University implement formal review procedures to document the Return of Title IV calculations are being performed to minimize the likelihood that errors may go undetected and not be corrected in a timely manner. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.

Federal Agency: Department of Education Federal Program Title: Student Financial Assistance Cluster Assistance Listing Number: 84.007, 84.033, 84.063, 84.268 Federal Award Identification Number: P007A223424-2023, P033A223424-2023, P063P220352-2023, and P268K220352-2023 Award Period: 7/1/22-6/30/23 Type of Finding: Material Weakness in Internal Control over Compliance; Compliance, Material Noncompliance Condition: The University did not properly report student enrollment changes for students who received federal student aid to the National Student Loan Data System (NSLDS). Criteria or specific requirement: Per 2 CFR 200.303, nonfederal 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. Additionally, 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. Context: During our testing of 60 students, we identified 5 students had the incorrect effective date, 44 students were reported past the 60-day reporting timeframe, 7 students did not have matching status change for Campus and Program enrollment, 2 students did not have campus enrollment updated for withdrawal status change, 2 students with the incorrect effective date on program enrollment and 1 student where graduate status was not properly updated. Additionally, there is no evidence of review documented. Questioned costs: N/A Cause: The University didn't have proper procedures in place to verify students’ status in NSLDS matched the institutions records in a timely manner. Effect: The University was not in compliance with the requirements to properly report student enrollment data correctly. Incorrect dates submitted to NSLDS may be used to determine the grace period for the repayment and interest of outstanding Title IV student loans. Repeat finding: Yes, 2022-012 Recommendation: We recommend the University review current processes for reporting to NSLDS and implement procedures to ensure submissions are reported timely and accurately. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.

Federal Agency: Department of Education Federal Program Title: Student Financial Assistance Cluster Assistance Listing Number: 84.007, 84.033, 84.063, 84.268 Federal Award Identification Number: P007A223424-2023, P033A223424-2023, P063P220352-2023, and P268K220352-2023 Award Period: 7/1/22-6/30/23 Type of Finding: Significant Deficiency in Internal Control over Compliance; Compliance, Other Matters Condition: The University did not properly have documentation of exit counseling notification. Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 682.604, states that a school must ensure that exit counseling is conducted with each Stafford Loan borrower and graduate or professional student PLUS Loan borrower either in person, by audiovisual presentation, or by interactive electronic means. In each case, the school must ensure that this counseling is conducted shortly before the student borrower ceases at least half-time study at the school. Per 2 CFR 200.303, nonfederal 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. Context: During our testing of 40 students, we identified 3 students that did not have documentation of exit counseling notification. Questioned costs: N/A Cause: The University did not have proper procedures in place to ensure that notification of required exit counseling was sent to applicable students. Effect: Exit counseling helps federal student loan borrowers understand how to repay their loans and reviews deferment and repayment plans options. If students are not notified of exit counseling, they could be at risk of not understanding their rights and responsibilities regarding loan repayment. Repeat finding: No Recommendation: We recommend the University review reporting processes to ensure all students that require exit counseling receive it in a timely manner. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.

Federal Agency: US Department of Education Federal Program Title: Education Stabilization Fund Assistance Listing Number: 84.425E, 84.425F Federal Award Identification Number: P425E200082 - 2022, P425F200986 - 2022 Award Period: July 1, 2021 to June 30, 2022 Type of Finding: • Compliance, Other Matter • Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal 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. Per the CARES Act 18004(e) and the CRRSAA 314(e) institutions receiving funds under HEERF I and HEERF II to submit a report for the programs. Condition: Langston University incorrectly reported information under the student and institutional portions of the 2021 HEERF Annual Report. Additionally, there was 1 instance of no documentation of review on the 8/15/21 quarterly public disclosure report. Context: During our testing of Langston University's 2021 HEERF Annual report we noted, the student portion expenditures that were reported did not agree to support and on the institutional portion, expenditures were incorrectly reported on sections 8a and 9b causing institutional expenses to be overstated by $2,491,398. Additionally, during our testing of 2 student quarterly reports, we noted 1 instance of no documentation of review on the 8/15/21 quarterly public disclosure report. Questioned costs: N/A Cause: The University has not implemented appropriate controls to ensure that the information reported agrees with supporting documentation or to maintain evidence of such review. Effect: Failure to prepare reports in accordance to grant requirements may result in reporting error to the funding agency. Repeat finding: No Recommendation: We recommend the University implement procedures to ensure the information reported on the annual reports are complete and accurate. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.

Federal Agency: US Department of Education Federal Program Title: Student Financial Assistance Cluster Assistance Listing Number: 84.007, 84.033, 84.063, 84.268 Federal Award Identification Number: P007A213424 - 2022, P033A123424 - 2022, P063P210352 - 2022, P268K220352 - 2022 Award Period: July 1, 2021 to June 30, 2022 Type of Finding: • Material Weakness in Internal Control over Compliance; Compliance, Material Noncompliance Criteria or specific requirement: Per 2 CFR 200.303, nonfederal 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. Additionally, 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. Condition: The University did not properly report student enrollment changes for students who received federal student aid to the National Student Loan Data System (NSLDS). Context: During our testing of 40 students, we noted 13 students had the incorrect effective date, 10 students were reported past the 60-day reporting timeframe and 1 student had the incorrect program begin date reported to NSLDS. Questioned costs: N/A Cause: The University didn't have proper procedures in place to verify students’ status in NSLDS matched the institutions records in a timely manner. Effect: The University was not in compliance with the requirements to properly report student enrollment data correctly. Incorrect dates submitted to NSLDS may be used to determine the grace period for the repayment and interest of outstanding Title IV student loans. Repeat finding: No Recommendation: We recommend the University review current processes for reporting to NSLDS and implement procedures to ensure submissions are reported timely and accurately. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.

Federal Agency: US Department of Education Federal Program Title: Student Financial Assistance Cluster Assistance Listing Number: 84.007, 84.033, 84.063, 84.268 Federal Award Identification Number: P007A213424 - 2022, P033A123424 - 2022, P063P210352 - 2022, P268K220352 - 2022 Award Period: July 1, 2021 to June 30, 2022 Type of Finding: • Material Weakness in Internal Control over Compliance; Compliance, Material Noncompliance Criteria or specific requirement: 34 CFR 668.165, states that an institution must notify the student, or parent, in writing of (1) the date and amount of the disbursement; (2) the student’s right, or parent’s right, to cancel all or a portion of that loan or loan disbursement and have the loan proceeds returned to the holder of that loan or the TEACH Grant payments returned to ED; and (3)the procedure and time by which the student or parent must notify the institution that he or she wishes to cancel the loan, TEACH Grant, or TEACH Grant disbursement. The notification requirement for loan funds applies only if the funds are disbursed by EFT payment or master check. Additionally, per 2 CFR 200.303, nonfederal 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. Condition: The University did not properly notify students when loans were credited to the student's ledger account. Context: During our Eligibility testing of 60 students, we noted that there were 39 students that received loan disbursements however, all 39 students did not receive the required notification for each loan disbursement. Questioned costs: N/A Cause: The University did not send loan disbursement notifications. Effect: Tailored loan disbursement notifications inform the student or parent of the right to cancel all or a portion of that loan or loan disbursements, and to have the loan proceeds returned to the holder of that loan. The notifications also outline the procedure and time by which the student or parent must notify the institution that he or she wishes to cancel the loan. Repeat finding: No Recommendation: We recommend the University evaluate its procedures around disbursements of loans and ensure that notifications of disbursements are sent and contain all the required elements outlined in the FSA handbook. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.

Federal Agency: US Department of Education Federal Program Title: Student Financial Assistance Cluster Assistance Listing Number: 84.007, 84.033, 84.063, 84.268 Federal Award Identification Number: P007A213424 - 2022, P033A123424 - 2022, P063P210352 - 2022, P268K220352 - 2022 Award Period: July 1, 2021 to June 30, 2022 Type of Finding: • Compliance, Other Matter • Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: The Department of Education requires institutions 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. Additionally, per 2 CFR 200.303, nonfederal 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. Condition: During testing of Common Origination and Disbursement reporting, we noted 2 instance of noncompliance. Context: During our testing of 60 COD disbursements we noted, 1 disbursement was not reported within the required 15 days and 1 disbursement had a different disbursement date than the date disbursed to the student. Questioned costs: N/A Cause: Management has not implemented precise review controls to ensure compliance with accurate and timely reporting or disbursement dates and amounts. Effect: Student interest accrues based on disbursement date reported to COD, thus interest calculation could be misstated due to the discrepancy in disbursement dates reported. Repeat finding: No Recommendation: We recommend that the student financial aid department work to ensure disbursements are reported to COD within 15 days of the disbursement date and that disbursements date reported in COD matches the disbursement date to the student. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.

Federal Agency: US Department of Education Federal Program Title: Student Financial Assistance Cluster Assistance Listing Number: 84.007, 84.033, 84.063, 84.268 Federal Award Identification Number: P007A213424 - 2022, P033A123424 - 2022, P063P210352 - 2022, P268K220352 - 2022 Award Period: July 1, 2021 to June 30, 2022 Type of Finding: • Material Weakness in Internal Control over Compliance; Compliance, Material Noncompliance Criteria or specific requirement: 34 CFR 668.22(j)(1), states that an institution must return the amount of title IV funds for which it is responsible as soon as possible but no later than 45 days after the date of the institution's determination that the student withdrew. Additionally, per 2 CFR 200.303, nonfederal 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. Condition: The University did not return Title IV funds within 45-days or have adequate documentation of review. Context: During our testing of 8 student's Return of Title IV (R2T4) calculations, we noted 4 with refunds that were not returned within the 45-day requirement. Additionally, 7 of the R2T4 calculations did not have documentation of review. Questioned costs: N/A Cause: The University did not establish precise controls to ensure timely return of funds related to withdrawals and the documentation of the review of calculation. Effect: The lack of documented review of the Return of Title IV calculations being performed by the student financial aid staff could result in errors going undetected by the University. Repeat finding: No Recommendation: We recommend the University review its current procedures for Title IV funds and implement additional procedures to ensure refunds are returned timely. We also recommend the University implement formal review procedures to document the Return of Title IV calculations are being performed to minimize the likelihood that errors may go undetected and not be corrected in a timely manner. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.

Federal Agency: US Department of Education Federal Program Title: Student Financial Assistance Cluster Assistance Listing Number: 84.007, 84.033, 84.063, 84.268 Federal Award Identification Number: P007A213424 - 2022, P033A123424 - 2022, P063P210352 - 2022, P268K220352 - 2022 Award Period: July 1, 2021 to June 30, 2022 Type of Finding: • Material Weakness in Internal Control over Compliance; Compliance, Material Noncompliance Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal 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 Code of Federal Regulations, 34 CFR 685.309(b), states the school is required to report changes in the student’s enrollment status, the effective date of the status, and an anticipated completion date. Condition: The University did not have a control process in place to identify potential enrollment status change for students that did not receive a passing grade at the end of the Spring 2022 term. Context: Students that did not receive a passing grade at the end of the Spring 2022 term, were not identified or evaluated timely for potential enrollment status change. Questioned costs: N/A Cause: The University did not have a control in place to identify potential enrollment status changes for students that did not receive a passing grade at the end of the Spring 2022 term. Effect: Failure to evaluate students without a passing grade in a given term may result in unearned title IV funds not being returned timely and inaccurate enrollment reporting. Repeat finding: No Recommendation: We recommend the student financial aid department review its current procedures for evaluating students that did not receive a passing grade in a term to ensure enrollment status changes are determined timely and accurately. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.

Federal Agency: US Department of Education Federal Program Title: Student Financial Assistance Cluster Assistance Listing Number: 84.007, 84.033, 84.063, 84.268 Federal Award Identification Number: P007A213424 - 2022, P033A123424 - 2022, P063P210352 - 2022, P268K220352 - 2022 Award Period: July 1, 2021 to June 30, 2022 Type of Finding: • Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal 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. Condition: The University did not have a formal review process related to GLBA. Context: The University completes the "Oklahoma Risk Assessment" and reports to Office of Management and Enterprise Services (OMES). The risk assessment is completed by the CIOs of the university and submitted to OMES. Through inquiries with management, the risk assessment has no documented review process on the risk assessment. Questioned costs: N/A Cause: The University was submitting their Information Technology Risk Assessment to OMES without a formal documentation process. Effect: The University could fail to address risks related to the University’s IT safeguards as stated in the Gramm-Leach-Bliley act. Repeat finding: No Recommendation: We recommend the University implement procedures to ensure that the risk assessment used to determine compliance with the Gramm-Leach-Bliley act is properly reviewed. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.

Federal Agency: US Department of Education Federal Program Title: Student Financial Assistance Cluster Assistance Listing Number: 84.007, 84.033, 84.063, 84.268 Federal Award Identification Number: P007A213424 - 2022, P033A123424 - 2022, P063P210352 - 2022, P268K220352 - 2022 Award Period: July 1, 2021 to June 30, 2022 Type of Finding: • Material Weakness in Internal Control over Compliance; Compliance, Material Noncompliance Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal 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. Condition: The University does not review the work or internal control reports of their third-party servicer who performs eligibility verification procedures. Context: The University uses a third party to perform their verification procedures to assess Title IV student eligibility. The University does not review internal control reports, such as SOC1 reports, or perform other documented reviews of the third-party servicer's work. Questioned costs: N/A Cause: The University did not have a control in place to review the controls and accuracy of the third-party servicer's work. Effect: The third-party servicer could experience control deficiencies which may impact compliance and the University would be unaware and unable to make timely reviews of the work provided by the servicer Repeat finding: No Recommendation: We recommend the University review internal control reports and implement review controls for work performed by third party servicers. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.

Federal Agency: US Department of Education Federal Program Title: Education Stabilization Fund Assistance Listing Number: 84.425E, 84.425F Federal Award Identification Number: P425E200082 - 2022, P425F200986 - 2022 Award Period: July 1, 2021 to June 30, 2022 Type of Finding: • Material Weakness in Internal Control over Compliance; Compliance, Material Noncompliance Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal 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. Condition: The University does not review the work or internal control reports of their third-party servicer who performs eligibility verification procedures. Context: The University uses a third party to perform their verification procedures to review covered vendors for suspension and debarment. The University does not review internal control reports, such as SOC2 reports, or perform other documented reviews of the third-party servicer's work. Questioned costs: N/A Cause: The University did not have a control in place to review the controls and accuracy of the third-party servicer's work. Effect: The third-party servicer could experience control deficiencies which may impact compliance and the University would be unaware and unable to make timely reviews of the work provided by the servicer. Repeat finding: No Recommendation: We recommend the University review internal control reports and implement review controls for work performed by third party servicers. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.

Student Financial Assistance Cluster, Federal Direct Loan Program, CFDA No. 84.268 and Federal Pell Grant Program, CFDA No. 84.063, Award Year 2020 Criteria or Specific Requirement ? Special Tests and Provisions ? Enrollment Reporting ? 34 CFR ? 690.83(b)(2) and ? 685.309 Condition ? Student status changes were not communicated to the National Student Loan Data System (NSLDS) timely and accurately, in accordance with 34 CFR ? 690.83(6)(2), and ? 685.309. Additionally, student status change errors between the NSLDS and the University?s records on the SCHER1 report were not being corrected within the required 15-day timeframe. Questioned Costs ? None Context ? Out of the population of 561 enrollment status changes requiring reporting to NSLDS, a sample of 40 student enrollment status changes was selected for testing. 18 student enrollment status changes were not reported to NSLDS within the required 60 days. An additional 11 student data attributes on nine students did not agree between NSLDS and institutional records. In addition, for six different SCHER1 reports, errors were not corrected within the required 15 days. Our sample was not, and was not intended to be, statistically valid. Effect ? NSLDS was not notified of student enrollment status changes for Direct Loan and Pell Grant recipients in a timely or accurate manner. Cause ? The University did not have effective internal control processes in place to ensure the accurate collection, review, and reporting of student status changes. Recent turnover in personnel resulted in a lack of oversight and documentation of control environment related to enrollment reporting. Indication as a Repeat Finding ? 2019-006 and 2018-002 Recommendation ? The University should review its procedures for reporting student enrollment status changes for students receiving Direct Loans and Pell Grants. Views of Responsible Officials and Planned Corrective Actions ? The University has formalized the National Student Clearinghouse process, which allows the University to quickly access data for the NSLDS. The Office of the Registrar has created standard operating procedures (SOP) to ensure information is quickly and accurately reported. In addition, the SOPs address the follow up on any data that may need correction. The SOPs include a calendar for important deadlines as well as delegating the responsibilities to the newly created Assistant Registrar.

Student Financial Assistance Cluster, Federal Direct Loan Program, CFDA No. 84.268, Award Year 2020 Criteria or Specific Requirement ? Special Tests and Provisions ? Borrower Data and Reconciliation (Direct Loan) ? 34 CFR ? 685.300 Condition ? The University did not consistently perform its monthly Direct Loan reconciliation in order to reconcile institutional records with Direct Loan funds received from the Secretary and Direct Loan disbursement records submitted to and accepted by the Secretary. Questioned Costs ? None Context ? Out of the population of 12 monthly Direct Loan reconciliations, a sample of two reconciliations was selected for testing. One reconciliation was not performed. Our sample was not, and was not intended to be, statistically valid. Effect ? Required monthly reconciliation between institutional records and the Common Origination Disbursement System was not performed. Cause ?There was recent turnover in personnel in the financial aid department and, due to the pandemic, certain aspects of training were not able to be completed prior to the transition. Identification as a Repeat Finding, if Applicable ? N/A Recommendation ? The University should review its internal controls around performing Direct Loan reconciliations monthly to ensure they are being completed. Views of Responsible Officials and Planned Corrective Actions ? As the finding occurred due to turnover, management has addressed this by ensuring the new employee in this position has received appropriate training and instruction on performing the monthly reconciliations and management will review periodically to ensure they are completed timely.

COVID-19 Education Stabilization Fund Under the Coronavirus Aid, Relief, and Economic Security Act, Higher Education Emergency Relief Fund Student Aid Portion, CFDA No. 84.425E, Award Year 2020 Criteria or Specific Requirement ? Reporting ? Section 18004(a)(1) Student Aid Portion Quarterly Public Reporting ? 85 FR 53802 Condition ? The University did not file the required public disclosures relating to the student portion of funding within 30 days of the award date or May 6, 2020, which was the date the requirement was published in the Federal Register. Questioned Costs ? None Context ? The University signed the Certification and Agreement on April 10, 2020, and received a notice of award dated April 20, 2020. On May 6, 2020, the Department of Education issued a requirement to publicly post specified information no later than 30 days after the publication of the notice or the date the Department of Education obligated funds. The University posted information on its website on June 25, 2020, with information effective as of June 12, 2020. Effect ? The public disclosure was not filed timely. Cause ? At the time the Department of Education published guidance requiring public disclosure of funds, the University was in the process of establishing a process and infrastructure to effectively compile and report the public disclosure information. Identification as a Repeat Finding, if Applicable ? N/A Recommendation ? The University should review its internal controls around preparing and posting required information to ensure they are being completed accurately and timely. Views of Responsible Officials and Planned Corrective Actions ? The University acknowledges the delayed initial posting of the required public disclosures. To ensure the accuracy and timeliness of future disclosures and requirements, the University appointed a multi-stakeholder committee responsible for managing internal controls related to CARES and HEERF funding. The committee has since developed processes and protocols to compile and review the data necessary for the public disclosures and ensure the accuracy of the data. Further, the committee will take steps to consult with OSU Grants and Contracts Financial Administration and OSU Scholarships and Financial Aid to fully understand reporting requirements and ensure that publication of public disclosures on CARES and HEERF funding are done in an accurate and timely manner moving forward.

Federal Program ? Student Financial Assistance Cluster, Federal Direct Loan Program, CFDA No. 84.268 and Federal Pell Grant Program, CFDA No. 84.063, Award Year 2019 Criteria or Specific Requirement ? Special Tests and Provisions ? Enrollment Reporting ? 34 CFR ? 690.83(b)(2) and ? 685.309 Condition ? Student status changes were not communicated to the National Student Loan Data System (NSLDS) accurately, in accordance with 34 CFR ? 674.19, ? 690.83(6)(2) and ? 685.309. Additionally, student status change errors between the NSLDS and the University records were not being corrected within the required 15- day timeframe. Questioned Costs ? None Context ? Out of a population of 1,310 students with enrollment status changes requiring reporting to NSLDS, a sample of 40 students with enrollment status changes was selected for testing. Of those 40 students, nine student status changes were not reported to NSLDS within the required 60 days. Our sample was not, and was not intended to be, statistically valid. Effect ? NSLDS was not notified of student enrollment status changes for Direct Loan and Pell Grant recipients in a timely or accurate manner. Cause ? The University did not have effective internal control processes in place to ensure the accurate collection, review and reporting of student status changes. Recent turnover in personnel resulted in a lack of oversight and documentation of control environment related to enrollment reporting. Identification as a Repeat Finding, if Applicable ? 2018-002 Recommendation ? The University should implement documented internal control processes specific to the aggregation and evaluation of all student status changes as well as for the roster uploads and subsequent error corrections to ensure proper oversight of these processes so that reporting is timely and accurate. Views of Responsible Officials and Planned Corrective Actions - Management concurs. The Office of the Registrar and Financial Aid office will work together to implement improved processes and controls over student status changes to ensure reporting is timely and accurate.

Federal Program ? Research & Development Cluster, Payments to 1890 Land-Grant Colleges and Tuskegee University, CFDA No. 10.205, 1890 Institution Capacity Building Grants, CFDA No. 10.216, Cooperative Extension Service, CFDA No. 10.500 Criteria or Specific Requirement ? Period of Performance ? 2 CFR ? 215.71 Condition ? The University can charge costs to federal awards during the funding period authorized by the federal agency. Obligations are required to be liquidated no later than 90 days after the end of the funding period. Questioned Costs ? CFDA 10.500 ? $115, calculated as the amount incurred outside of the grant period. Context ? The University did not liquidate obligated funds within the required 90-day time period. In addition, some costs were not obligated during the funding period. Effect ? Federal funds were not liquidated within the required time frame and questioned costs resulted from items obligated after the funding period. Cause ? The University did not have effective internal control processes in place to monitor grant spending, which resulted in significant funds being obligated at the end of the grant period. Some of these items were not received within 90 days of the end of the funding period. The University did not have controls in place to monitor the subsequent payment of funds to ensure funds were disbursed within the required timeframe. Identification as a Repeat Finding, if Applicable ? N/A Recommendation ? The University should enhance internal control processes to monitor grant funding periods and implement additional controls to ensure that funds are obligated and liquidated within federal guidelines. Views of Responsible Officials and Planned Corrective Actions ? Management concurs. While the University had communications with the federal agency regarding expenditures nearing the project?s end in September 2018, future spend-down activities near or after the project end date will be closely monitored for allowability through the integrated services partnership with OSU. Oversight will include limiting the final month?s expenditures to those costs necessary to finalize the project?s timely completion.

Federal Program ? Research & Development Cluster, Award years 2017 and 2018 Criteria or Specific Requirement ? Allowable Costs ? 2 CFR ? 200.430(i) Condition ? The University is required to implement a system of internal controls that provide reasonable assurance that charges to federal grants are accurate, allowable and reasonable and properly allocated. Questioned Costs ? Unknown Context ? Time and effort reporting was not completed within the University?s Department of Agriculture for the first quarter of FY 2019. Time and effort reporting was completed for subsequent quarters. Effect ? Complete documentation regarding employee time charged to grants was not available. Cause ? For the first quarter of FY 2019, the University did not have internal controls for all departments to prepare documentation supporting time and effort for grants. Identification as a Repeat Finding, if Applicable ? 2018-005 and 2017-002 Recommendation ? The University should ensure internal controls related to documenting effort and certification are aligned with Uniform Guidance standards. Views of Responsible Officials and Planned Corrective Actions ? Management concurs. The University has partnered with OSU to provide integrated services for the University fiscal office. As part of the integrated services, processes and controls have been developed for effort reporting to meet federal requirements.

Federal Program ? Research & Development Cluster, Award years 2017 and 2018 Criteria or Specific Requirement ? Cash Management ? 2 CFR ? 215.22 Condition ? The University drew grant funds in excess of immediate cash needs for two grants. Questioned Costs ? CFDA No. 10.216 ? $600,352; CFDA Nos. 10.205 and 10.500 ? Unknown, calculated as the federal awards were drawn down but remained unspent as of the end of the fiscal year. Context ? Out of a population of 28 grant draws, a sample of six was selected for testing. For two of those draws, funds were still unspent ten days after the draw. Our sample was not, and was not intended to be, statistically valid. Effect ? The University did not minimize the time elapsing from the time the federal funds were drawn down to the time they were expended. Cause ? The University did not have a good control process in place to monitor grant disbursements and ensure that grant funds were not drawn in excess of immediate cash needs. Identification as a Repeat Finding, if Applicable ? N/A Recommendation ? The University should implement controls specific to the grant draw process to ensure that grant project funds are reconciled and are not drawn prior to incurring or paying the expenditures. Views of Responsible Officials and Planned Corrective Actions ? Management concurs. The University has partnered with OSU to provide integrated services for the University fiscal office. Cash management controls have been initiated to monitor and consistently reconcile financial activities within federal program administration. The previous practice of drawdown prior to expenditure ceased under the integrated services partnership. Allowable funds are drawn after-the-fact and also within tolerances of cost-share requirements.

Federal Program ? Research & Development Cluster, Award years 2017 and 2018 Criteria or Specific Requirement ? Activities Allowed or Unallowed and Allowable Costs/Cost Principles ? 2 CFR ? 215.27 Condition ? The University charged unallowable costs to the grants and some grant expenditures were not documented as being approved. Questioned Costs ? CFDA No. 10.216 ? $116; CFDA No. 10.205 ? $45,548; CFDA No. 10.500 ? $62,760, calculated as the unallowable costs in the sample in addition to self-identified unallowable costs. Context ? Out of a population of 4,709 expenditures, a sample of 60 expenditures was selected. Of the 60, four were noted as being unallowable and approvals of invoices were not documented. Our sample was not, and was not intended to be, statistically valid. In addition, the University had identified various expenses as unallowable through a self-study. Effect ? Federal grant funds were used for unallowable costs. Cause ? The University did not have a good control process in place to ensure that grant expenditures were approved and appropriately reviewed for allowable purposes. Identification as a Repeat Finding, if Applicable ? 2018-005 Recommendation ? The University should implement controls to ensure that expenditures charged to grants are documented as approved and reviewed for allowability prior to charging to the grant. Views of Responsible Officials and Planned Corrective Actions ? Management concurs. The University has partnered with OSU to provide integrated services for the University fiscal office. The integrated services partnership has focused on continuous monitoring of expenditures within grant programs. These new processes and controls include pre-purchase reviews (with authority to reject) of requisitions on grant-related and cost share expenditures.

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