California Baptist University

Criteria: In accordance with 34 CFR 685.309(b) and the National Student Loan Data System (NSLDS) Enrollment Reporting Guide published by the Department of Education, schools must review, update, and verify student enrollment statuses, program information, and effective dates that appear on the Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS Professional Access (NSLDSFAP) website. In addition, schools must report enrollment status changes within 30 days of becoming aware of the status change or in its next scheduled enrollment submission if the scheduled submission is within 60 days. Condition: During our testing of 40 students, which is a statistically valid sample, we noted one instance where the change of status was not reported to the NSLDS system in a timely manner. Questioned Costs: None. Context: During our audit procedures, we noted one instance of noncompliance. Cause: The University's internal controls did not identify the error for compliance with the criteria mentioned above. Effect: Inaccurate information is reflected on the NSLDS database. A student’s enrollment data protects the rights of borrowers by ensuring that loan interest subsidies are based on accurate enrollment data, ensures loan repayment dates are accurately based on the last data of attendance, allows in-school deferments to be automatically granted using NSLDS enrollment data, and provides vast amounts of critical data about the effectiveness of Title IV aid programs, including completion data. Repeat Finding: Yes, See Finding 2024-2 Recommendation: We recommend the University review its reporting procedures to ensure that enrollment and program information is accurately reported to NSLDS as required by regulations. Views of responsible officials: Management concurs with the finding.

Recommendation: We recommend the University review its reporting procedures to ensure that enrollment status change is reported timely to NSLDS as required by regulations. Action taken in response to finding: The University’s enrollment verification process includes reviewing a sample of students whose enrollment status changes were submitted to the National Student Clearinghouse to confirm that NSLDS was updated as expected. This process identified the issue noted in the finding, and it was corrected prior to the audit. To further strengthen controls, the University has implemented additional ad hoc NSLDS reporting to confirm that submitted data is processed after NSC transmission, while continuing the established verification process. Names of the contact persons responsible for corrective action: Shawnn Palmer, Director of Academic Technology and Reporting Planned completion date for corrective action plan: As of January 9, 2026, the student record in the finding has already been corrected. The additional audit report is in draft and will be validated prior to the April reporting. If the Department of Education has questions regarding this plan, please call Joshua Morey, Senior Director of Financial Aid, at (951) 343-4236.

2024-002

Criteria: In accordance with 34 CFR Section 668.173 (b) and 2 CFR 200.303, the institutional portion of unearned aid must be returned to the appropriate Title IV, HEA program or Federal Family Education Loan (“FFEL”) lender no later than 45 days after the date of the institution’s determination that the student withdrew. Furthermore, the institution must determine the amount of Title IV grant or loan assistance that the student earned as of the student’s withdrawal date. The Compliance Supplement issued by the Office of Management and Budget requires auditors to review the return of Title IV funds determinations/calculations for conformity with Title IV requirements. Furthermore, according to 34 CFR 668.22, all grant funds relating to post-withdrawal disbursements that are not disbursed to the student’s account, must be disbursed to the student no later than 180 days after the date of the institution’s determination that the student withdrew. Condition: It was noted during our testing of R2T4 calculations that two of 40 students selected for testing had instances of non-compliance. Specifically, one student’s return was not received within the 45-day time limit and one student’s return was not calculated correctly. Questioned Costs: $1,886 Context: During our audit procedures, we noted below instances for R2T4 testing: - One of the 40 total students’ return was not returned within the 45-days requirement. - One of the 40 total student’s R2T4 was incorrectly calculated, resulting in $1,866 in excess funds being returned by the University. Cause: The University implemented controls during the year to improve compliance with Title IV regulations, resulting in a significant reduction in the number of instances of noncompliance (from seven in prior year to one in the current year). Due to the timing of the implementation of these controls, instances of noncompliance with Title IV regulations were still identified. Effect: The cause identified resulted in noncompliance with Title IV regulations. Repeat Finding: Yes, see Finding 2023-001. Recommendation: We recommend that the University improve the existing procedures and controls to ensure compliance with the aforementioned criteria. Views of responsible officials: Management concurs with the finding.

Recommendation: We recommend that the University improve the existing procedures and controls to ensure compliance with the aforementioned criteria. Action taken in response to finding: Counselors have completed an intensive R2T4 NASFAA training late April – May 2024. The misunderstanding of the 45-day rule of one of the counselors has been addressed and corrected. Names of the contact persons responsible for corrective action: Joshua Morey, Senior Director of Financial Aid Planned completion date for corrective action plan: As of March 19, 2025, changes and training have already been implemented.

2023-001

Criteria: In accordance with 34 CFR 685.309(b) and the National Student Loan Data System (NSLDS) Enrollment Reporting Guide published by the Department of Education, schools must review, update, and verify student enrollment statuses, program information, and effective dates that appear on the Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS Professional Access (NSLDSFAP) website. In addition, schools must report enrollment status changes within 30 days of becoming aware of the status change or in its next scheduled enrollment submission if the scheduled submission is within 60 days. Condition: During our testing of 40 students, which is a statistically valid sample, we noted one instance where the program begin date was improperly reported to the NSLDS system. Questioned Costs: None. Context: During our audit procedures, we noted one instance of noncompliance. Cause: The University's internal controls did not identify the error for compliance with the criteria mentioned above. Effect: Inaccurate information is reflected on the NSLDS database. A student’s enrollment data protects the rights of borrowers by ensuring that loan interest subsidies are based on accurate enrollment data, ensures loan repayment dates are accurately based on the last data of attendance, allows in-school deferments to be automatically granted using NSLDS enrollment data, and provides vast amounts of critical data about the effectiveness of Title IV aid programs, including completion data. Repeat Finding: No. Recommendation: We recommend the University review its reporting procedures to ensure that enrollment and program information is accurately reported to NSLDS as required by regulations. Views of responsible officials: Management concurs with the finding.

Recommendation: We recommend the University review its reporting procedures to ensure that enrollment and program information is accurately reported to NSLDS as required by regulations. Action taken in response to finding: The University has added an additional audit report to be run prior to submission of enrollment reports to Clearinghouse and NSLDS. The report will audit for a change in the reported program begin date between reports when the reported program has not changed. The report inaccurate program begin dates calculated by our Student Information System as a result of a code update sent out by the vendor. Names of the contact persons responsible for corrective action: Shawnn Palmer, Director of Academic Technology and Reporting Planned completion date for corrective action plan: As of March 19, 2025, the student record in the finding has already been corrected. The additional audit report is in draft and will be validated prior to the April reporting.

Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 668.22 defines the last date of attendance for schools that are required to take attendance and those that are not required and requires an institution to 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. Condition: For seven of forty R2T4s tested, the University failed to return payments within 45 days of school determination the student withdrawal date. For one of forty R2T4s tested, the improper last date of attendance was used. Questioned Costs: Not determined. Context: The University failed to return payments within 45 days of school determination. Cause: The University's internal controls did not identify the errors for compliance with the criteria mentioned above. Effect: The student’s return of funds calculation was not done correctly and the return of funds back to the federal government was for the incorrect amount. The University failed to return payments within 45 days of school determination the student withdrawal date. Repeat Finding: No Recommendation: We recommend that additional training is provided to staff completing R2T4s to ensure a thorough understanding of governing regulations for each individual program. We also recommend an additional level of review is added to ensure completed R2T4s are properly completed.

Return of Title IV (R2T4) Calculation Student Financial Assistance Cluster – Assistance Listing Number: 84.007, 84.063, and 84.268 Recommendation: We recommend that additional training is provided to staff completing R2T4s to ensure a thorough understanding of governing regulations for each individual program. We also recommend an additional level of review is added to ensure completed R2T4s are properly completed. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Financial Aid administration has signed up our counseling staff to attend NASFAA’s R2T4 credential training. In addition, we have adjusted our review process for R2T4s to have multiple checks along the way by others in the office, so not just one counselor is completing the R2T4. Also, the report now has a built-in clock to monitor the date to ensure if corrections are need that they are done within 45 days of the R2T4. Name(s) of the contact person(s) responsible for corrective action: Joshua Morey, Senior Director of Financial Aid. Planned completion date for corrective action plan: This enhanced review process was put into place in October 2023. Training for counselors with NASFAA will take place in April 2024.

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: The following required elements of the Written Information Security Program were not included: b.3.2 Conduct a periodic inventory of data, noting where it’s collected, stored, or transmitted. b.3.3 Encrypt customer information on the institution’s system and when it’s in transit. b.3.4 Assess apps developed by the institution b.3.6 Dispose of customer information securely b.7 Provides for the evaluation and adjustment of its information security program in light of the results of the required testing and monitoring; any material changes to its operations or business arrangements; the results of the required risk assessments; or any other circumstances that it knows or has reason to know may have a material impact the institution’s information security program (16 CFR 314.4(g)). Questioned costs: None Context: These new GLBA requirements were applicable beginning on June 9, 2023 and there were elements missing from their WISP. Cause: There was not a formal process in place to review against all the new GLBA requirements to ensure compliance. Effect: The student personal information could be vulnerable. Repeat Finding: No Recommendation: We recommend that the College review the updated GLBA requirements and ensure their WISP includes all required elements. Views of responsible officials: There is no disagreement with the audit finding.

Gramm-Leach-Bliley Act Student Financial Assistance Cluster – Assistant Listing Number: 84.007, 84.038, 84.063, and 84.268 Recommendation: We recommend that the University review the updated GLBA requirements and ensure their WISP includes all required elements. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Information Technology team has reviewed the recommendations and is updating the Written Information Security Plan to include recommended elements. These elements have been reviewed with the Accounting and Finance management teams. Name(s) of the contact person(s) responsible for corrective action: Dale Lee, Director for Information Security and Projects. Planned completion date for corrective action plan: The CBU team has begun addressing the elements and will be ready to discuss these further with CLA during the annual audit process this current year.

Finding 2021-001: Return of Title IV Funds Federal Agency: U.S. Department of Education Federal Program title: Student Financial Assistance Cluster Assistance Listing Number: 84.268 Award Period: July 1, 2020 through June 30, 2021 Type of Finding: ? Significant Deficiency in Internal Control over Compliance ? Other Matters Criteria or specific requirement: In accordance with 34 CFR 668.22(j)(1) and 34 CFR 668.22(a)(6)(iii), an institution must return the amount of title IV funds as soon as possible but no later than 45 days after the date of the institution's determination that the student withdrew and the institution must provide within 30 days of the date of the institution's determination that the student withdrew, a written notification to the student, or parent in the case of parent PLUS loan explaining their eligibility for a post-withdrawal direct loan disbursement, respectively. Condition: During our testing of 60 students, which is a statistically valid sample, we noted 4 instances where the University failed to return title IV funds within 45 days of the date the institution determined that the student withdrew and 1 instance where the University failed to provide written notification to the student, of their eligibility for a post-withdrawal direct loan disbursement, within 30 days of the date of the institution?s determination that the student withdrew. Questioned costs: None. Context: 4 out of the 60 students tested did not have title IV funds returned within the required timeframe and 1 out of 60 students did not have written notification of the post-withdrawal direct loan eligibility provided within the required timeframe. Cause: The University?s internal controls did not identify the errors for compliance with the criteria mentioned above. Effect: The University did not return the Title IV funds and did not provide the required post-withdrawal notification within the required timeframe resulting in noncompliance with the applicable Title IV regulations. Repeat Finding: Yes, see finding 2020-001. Recommendation: We recommend the University review the R2T4 requirements and implement procedures to ensure title IV funds are returned and written notification for post-withdrawal disbursements are provided within the required timeframe as required by regulations. Views of responsible officials: Please refer to the attached corrective action plan.

2021-001 Return of Title IV Funds Student Financial Assistance Cluster ? Assistance Listing Number: 84.268 Recommendation: We recommend the University review the R2T4 requirements and implement procedures to ensure title IV funds are returned and written notification for post-withdrawal disbursements are provided within the required timeframe as required by regulations. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Using our reporting software, IBM Cognos, a report was created to pull data from our SIS and provide a status on the completion of PTWs (petitions to withdraw). This report, in conjunction with a shared file between the Office of the University Registrar and the Financial Aid Office, will allow the Financial Aid Office to appropriately monitor PTWs for completion. Name(s) of the contact person(s) responsible for corrective action: Joshua Morey, Director of Financial Aid. Planned completion date for corrective action plan: The corrective action has already been implemented.

Finding 2021-002: NSLDS Enrollment Reporting Federal Agency: U.S. Department of Education Federal Program title: Student Financial Assistance Cluster Assistance Listing Number: 84.063 and 84.268 Award Period: July 1, 2020 through June 30, 2021 Type of Finding: ? Significant Deficiency in Internal Control over Compliance ? Other Matters Criteria or specific requirement: In accordance with 34 CFR 685.309(b) and the National Student Loan Data System (NSLDS) Enrollment Reporting Guide published by the Department of Education, schools must review, update, and verify student enrollment statuses, program information, and effective dates that appear on the Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS Professional Access (NSLDSFAP) website. Condition / Context: During our testing of 60 students, which is a statistically valid sample, we noted 8 instances where the effective date of a student status change was improperly reported at the campus-level record, 1 instance of improper student enrollment status reporting at the campus-level and program-level record, 1 instance where the effective date of a student status change was improperly reported at the campus-level and program-level record, and 2 instances where the program begin date was not properly reported to the NSLDS system. Questioned costs: None. Cause: The University's internal controls did not identify the errors for compliance with the criteria mentioned above. Effect: Inaccurate information is reflected on the NSLDS database. A student?s enrollment data protects the rights of borrowers by ensuring that loan interest subsidies are based on accurate enrollment data, ensures loan repayment dates are accurately based on the last data of attendance, allows in-school deferments to be automatically granted using NSLDS enrollment data, and provides vast amounts of critical data about the effectiveness of Title IV aid programs, including completion data. Repeat Finding: Yes, see finding 2020-002. Recommendation: We recommend the University review its reporting procedures to ensure that enrollment and program information is accurately reported to NSLDS as required by regulations. Views of responsible officials: Please refer to the attached corrective action plan.

2021-002 NSLDS Enrollment Reporting Student Financial Assistance Cluster ? Assistant Listing Number: 84.063 and 84.268 Recommendation: We recommend the University review its reporting procedures to ensure that enrollment and program information is accurately reported to NSLDS as required by regulations. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Audit Reports have been written to validate and correct any necessary data in the SIS prior to submitting enrollment reports to clearinghouse. Data entry guideless have been provided to the user?s processing withdraws and no shows in the SIS to ensure the correct codes and dates are used minimizing the findings on the audit reports. Name(s) of the contact person(s) responsible for corrective action: Joshua Morey, Director of Financial Aid. Planned completion date for corrective action plan: Audit reports began being written upon findings with last reports in suite completed by October 2021. Guidelines provided to users in January 2022.

2020-002

Finding 2021-003: NSLDS Roster File Corrections and Submissions Federal Agency: U.S. Department of Education Federal Program title: Student Financial Assistance Cluster Assistance Listing Number: 84.063 and 84.268 Award Period: July 1, 2020 through June 30, 2021 Type of Finding: ? Significant Deficiency in Internal Control over Compliance ? Other Matters Criteria or specific requirement: In accordance with the National Student Loan Data System (NSLDS) Enrollment Reporting Guide published by the Department of Education, schools are required to respond within 15 days of the date that NSLDS sends a Roster file to the school or its third-party servicer. Any errors identified and returned by NSLDS, in an Error/Acknowledgement file should be corrected and resubmitted within 10 days. Condition / Context: During our testing of the NSLDS SCHER1 report, we noted 3 instances where the University failed to correct and resubmit errors within 10 days. Questioned costs: None. Cause: The University's internal controls did not identify the errors for compliance with the criteria mentioned above. Effect: Roster file submissions, and therefore student status changes, were not reported timely. Repeat Finding: No. Recommendation: We recommend the University review its reporting procedures to ensure that roster file submissions are reported timely to NSLDS as required by regulations. Views of responsible officials: Please refer to the attached corrective action plan.

2021-003 NSLDS Roster File Corrections and Submissions Student Financial Assistance Cluster ? Assistant Listing Number: 84.063 and 84.268 Recommendation: We recommend the University review its reporting procedures to ensure that roster file submissions are reported timely to NSLDS as required by regulations. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Reporting Log was created to document timing of report and resolution of any errors. In addition documentation is included in the log if there were any known technical challenges that could have impacted the reporting timeline. Name(s) of the contact person(s) responsible for corrective action: Joshua Morey, Director of Financial Aid. Planned completion date for corrective action plan: The corrective action has already been implemented. Reporting log was created in March 2022.

Finding 2020-001: Special Tests and Provision: Return of Title IV Funds Federal Agency: Department of Education Federal Program Title: Student Financial Assistance Cluster CFDA Number: 84.063 Award Period: July 1, 2019 through June 30, 2020 Type of Finding: Significant Deficiency in Internal Control over Compliance and Non-Compliance Criteria: In accordance with 34 CFR 668.22(a)(1), when a recipient of Title IV grant or loan assistance withdraws from an institution during a payment period or period of enrolment in which the recipient began attendance, the institution must determined the amount of Title IV grant or loan assistance that the student earned as of the student's withdrawal date. Condition/Context: During our testing of R2TA calculations, we noted that the University is correctly calculating the amount of Title IV aid earned by the student but did not disburse the amount of earned aid for 1 out the 40 students tested, which is statistically valid sample. Thus, the University did not return the proper amount to the Department of Education. Cause: The University's internal controls did not identify the errors for compliance with the criteria mentioned above. Effect: The University did not return the proper amount to the Department of Education based on the calculation performed. Repeat Finding: There was not a finding in the prior year. Recommendation: We recommend the University review the R2TA requirements and implement procedures to ensure earned aid as determined by the R2TA calculations are being properly disbursed to the students and the correct amounts are being returned to the Department of Education. Views of responsible officials: Please refer to the attached corrective action plan.

Student Financial Assistance Cluster - Special Tests and Provisions: Return of Title IV Funds CFDA Number: 84.063 Recommendation: We recommend the University review the R2TA requirements and implement procedures to ensure earned aid as determined by the R2TA calculations are being properly disbursed to the students and the correct amounts are being returned to the Department of Education. Explanation of disagreement with audit findings: There is no disagreement with the audit finding. Action taken in response to finding: The Registrar corrected the student's record to reflect the withdrawal data and the Pell Grant award has been reinstated to reflect the R2T4 amount. The earned portion of the Pell Grant award has been disbursed to the student. Name(s) of the contact person(s) responsible for corrective action: Joshua Morey, Director of Financial Aid. Planed completion date for corrective action plan: The corrective action plan has already been implemented. The earned portion of the grant has been disbursed to the student as of July 2020.

Finding 2020-002: Special Tests and Provisions: Enrollment Reporting Federal Agency: Department of Education Federal Program Title: Student Financial Assistance Cluster CFDA Number: 84.268 Award Period: July 1, 2019 through June 30, 2020 Type of Finding: Significant Deficiency in Internal Control over Compliance and Non-Compliance Criteria: In accordance with 34 CFR 680.309(b) and the NSLDS Enrollment Reporting Guide published by the Department of Education, schools must review, update, and verify student enrollment statuses, program information, and effective dated that appear on the Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS Professional Access (NSLDSFAP) Website. Condition/Context: During our testing of NSLDS enrollment reporting, we noted that 1 out of the 40 students tested, which is a statistically valid sample, did not have the correct program begin date per the institution's record reported to the NSLDS system. Cause: The University's internal controls did not identify the errors for compliance with the criteria mentioned above. Effect: Inaccurate information is reflected on the NSLDS database. A student's reenrollment data protects the rights of borrowers by ensuring that loan interests subsidies are based on accurate enrollment data, ensures loan repayment dates are accurately based on the last data of attendance, allows in-school deferments to be automatically granted using NSLDS enrollment data, and provides vast amounts of critical data about the effectiveness of Title IV aid programs, including completion data. Repeat Finding: There as not a finding in the prior year. Recommendation: We recommend the University review its reporting procedures to ensure that enrollment and program information is accurately reported to NSLDS as required by regulations. Views of responsible officials: Please refer to the attached corrective actions plan.

Student Financial Assistance Cluster - Special Tests and Provisions: Enrollment Reporting CFDA Number: 84.268 Recommendation: We recommend the University review its reporting procedures to ensure that enrollment and program information is accurately reported to NSLDS as required by regulations. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: During the enrollment reporting process, the student system was missing the field that determined the program begin date reported to NSLDS. The Registrar has corrected the data through a manual entry and updated the NSLDS system to reflect the correct program begin date per the University's record. Name(s) of the contact person(s) responsible for corrective action: Joshua Morey, Director of Financial Aid. Planned completion date for corrective action plan: The corrective action plan has already been implemented. The student's program begin date has been updated in the NSLDS system to reflect the correct program begin date per the University's record as of October 2020.