ILIFF SCHOOL OF THEOLOGY

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

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

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

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

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

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

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

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

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

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

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

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