BETHESDA UNIVERSITY

Criteria: 2 CFR 200.512 requires that the audit must be completed and the data collection form described in paragraph (b) of this section and reporting package described in paragraph (c) of this section must be submitted within the earlier of 30 calendar days after receipt of the auditor?s report (s), or nine months after the end of the audit period. Condition: The University did not submit the required data and reporting package by March 31, 2023 which is nine months after the end of the audit period. Questioned Costs: Not applicable

The University will develop adequate policies and procedures for the reporting requirements of the Federal Awards and the management monitors and oversee the compliance requirements. Bethesda University was not aware of the submission of the audit because several transitions in all key personnel and insufficient oversight have led to untimely reporting. The University will ensure that the management of the University reviews the reporting requirements of the Federal Awards and determines the level of an organization?s adherence to regulatory guidelines. The management acknowledged that the audit must be completed and the reporting required within the earlier of 30 calendar days after receipt of the auditor?s report or nine months after the fiscal period end date which would be March 31. The University will monitor and oversee the compliance requirement and make sure it is properly performed and submitted in timely manner. Person Responsible for Corrective Action Plan: Sheng Wang, Chief Financial Officer Anticipated Date of Completion: June 30, 2023

Criteria: 2 CFR 200.303 requires that non-federal entities receiving federal awards establish and maintain internal control over the federal awards that provides reasonable assurance that the non-federal entity is managing the federal awards in compliance with federal statutes, regulations, and the terms and conditions of the federal awards. Condition: The University did not detect several material noncompliance due to the ineffective internal control over compliance. Questioned Costs: Not applicable

The University evaluated and updated its internal control monitoring procedures so that the procedures will be properly followed and documented. The University have two basic categories of internal control ? preventive and detective. An effective internal control system will have both types as each serves a different purpose. Preventive controls aim to decrease the chance of errors and fraud before they occur. Preventive controls are essential because they are proactive and focused on quality. Preventive controls include pre-approval of actions and transactions, access controls, employee screening and training etc. To protect those who handle finances from mistakes, false accusations or temptations, the following procedures have been enacted. Bethesda University checks require at least one signature. Money received from students is recorded in two places on the computer: QuickBooks (accounting software program), and Populi (school management system). In each transaction, money is received and recorded by the accountants. Bank deposits are conducted by the accountants, and all deposit records are kept in a binder with copies of all deposit slips and canceled checks. Once a month, the accountant does bank reconciliation by comparing QuickBooks records with bank stubs, bank statements, cleared checks, and monthly payment records. The expenditures are categorized in the appropriate budget category. Detective controls are designed to find errors or problems after the transaction has occurred. Detective controls are essential because they provide evidence that preventive controls are operating as intended, as well as offer an after the fact chance to detect irregularities. Detective controls include monthly reconciliations of departmental transactions, reviewing organizational performance, physical inventories. The University makes sure that the internal control over the accounting process and the federal awards and institutionally and adequately operate monitoring activities to monitor the internal control system over compliance. The Finance Committee at Bethesda University is responsible for the review, and the quality assurance. Person Responsible for Corrective Action Plan: Sheng Wang, Chief Financial Officer Anticipated Date of Completion: June 30, 2023

Criteria: 34 CFR 668.22 requires that when a recipient of Title IV grant or loan assistance withdraws from an institution during a payment period or period of enrollment in which the recipient began attendance, the institution must determine the amount of Title IV grant or loan assistance that the student earned as of the student?s withdrawal date in accordance with Federal regulations and return the unearned portion of the grant or loan funds to the Title IV programs as soon as possible but no later than 45 days after the withdrawal date. Condition: One student out of sixteen students tested had missing calculations. Four students out of sixteen students tested had not retuned the aid back to the U.S. Department of Education within the required 45 days. Questioned Costs: Not applicable

The University will make sure the student enrollment status change notifies the Academics and Financial Aid officials in correct so that the officials review all students who withdraw during a germ are identified in timely manner and the refund calculation is correctly made in timely. The University have updated and modified Financial Aid department manual to reflect the changes made to ensure the followings: 1. Regularly (every 2nd and 4th Tuesdays of the month) running the report including the student?s enrollment status, number of units in progress, Program enrolled, Overall GPA, Last Day of Attendance and Attendance Rate. 2. A Physical copy of the JobForm for each Financial Aid student whose status has changed on Populi, which includes the name and date of who made that change and approval will be provided to the Financial Aid department for any necessary corrections. This physical copy would be filed in the student file in Academics and Financial Aid. 3. Create an internal record indicating the changes made regarding the students? enrollment status 4. Designate personnel monitoring and reporting any changes made to students? enrollment status. Person Responsible for Corrective Action Plan: Sheng Wang, Chief Financial Officer Anticipated Date of Completion: June 30, 2023

Criteria: 34 CFR 685.304 requires that the University must ensure that entrance counseling is conducted with each Direct Subsidized Loan or Direct Unsubsidized Loan student borrower prior to making the first disbursement of the proceeds of a loan to a student borrower. In addition, the University must ensure that exit counseling is conducted with each Direct Subsidized Loan or Direct Unsubsidized Loan borrower shortly before the student borrower ceases at least half-time study at the school. Condition: Sixteen of the Sixteen federal student financial aid recipients in our sample did not complete the exit interview. Questioned Costs: Not applicable

The University have reviewed and modified the Financial Aid (F/A) manual to make sure it is up-to-date. F/A manual will be reviewed annually to ensure that it reflects the recent changes, if any, as a part of the institutional practice. After the carefully reviewing our policy regarding the ?Exit Interview?, we concluded that we have the policy and procedure in place. However, there was no consistency on following the written policy and procedures. We will implement the following changes to ensure that BU follows the policies and procedures: 1. Designate personnel in charge of informing Financial Aid department when student exits from the program 2. Designate personnel in Financial Aid department to inform the student and conduct the exit interview 3. Financial Aid department makes sure that the student completes the exit interview and the student?s graduation request won?t be approved until the student completes the exit interview. Financial Aid department will follow up the students who need to complete the exit counseling. Person Responsible for Corrective Action Plan: Sheng Wang, Chief Financial Officer Anticipated Date of Completion: June 30, 2023

Criteria: Per U.S. Department of Education (ED) regulations, all schools participating (or approved to participate) in the Federal Student Assistance programs must have an arrangement to report student enrollment data to the National Students Loan Data System (NSLDS) through a roster file. Condition: Certain students? enrollment information was not reported accurately and timely to the NSLDS. Questioned Costs: Not applicable

The University ensures that Campus IVY reporting writes to NSLDS in timely and correct. The University will send enrollment transmissions to the Campus IVY and make sure the reporting is submitted according to the following schedule to maintain compliance with federal regulations. The University makes sure the current NSLDS enrollment reporting applies its procedures in overseeing submissions to the NSLDS. Fall and Spring Semesters 1) First of Term: 30 days after the term start date 2) Subsequent of Term: 60 days after term start date 3) Subsequent of term: 90 days after term start date 4) End of Term: two weeks after term end date Summer Semesters 1) First of Term: one week after term start date 2) End of Term: two weeks after term end date Information is collected directly from the University Populi system and any adjustments are verified by the Registrar and Financial Aid Officer will send any adjustments electronically to the Campus IVY SURE Reporting Person Responsible for Corrective Action Plan: Sheng Wang, Chief Financial Officer Anticipated Date of Completion: June 30, 2023