The King's University

Information on the Federal Program – Department of Education, Student Financial Assistance Cluster, Federal Pell Grant Program, 84.063; Federal Direct Student Loan Program, 84.268. Program Year – July 1, 2024 – June 30, 2025 Criteria or Specific Requirement – Special Tests and Provisions – Enrollment Reporting – Under the Pell grant and loan programs, colleges must complete and return within 30 days the Enrollment Reporting roster file. Once received, the institution must update for changes in student status, report the date the enrollment status was effective, enter the new anticipated completion date and submit the changes electronically through the batch method or the NSLDS web site. Institutions are responsible for timely reporting, whether they report directly or via a third-party servicer. Unless the school expects to complete its next roster within 60 days, the University must notify the lender or the guaranty agency within 30 days, if it discovers that a student who received a loan either did not enroll or ceased to be enrolled on at least a half-time basis. (Pell, 34 CFR Section 690.83(b)(2); Direct Loan, 34 CFR Section 685.309(2)(i)). Condition – Notification of the student status change (graduated, withdrew, less than half-time) was not reported to the NSLDS within the required timeframe. Questioned Costs – None Context – Out of a sample of four students from a population of 43 students who had changes in status during the year, NSLDS was not provided timely notification for three of the student status changes reviewed. Our sample was not, and was not intended to be, statistically valid. Cause – Information between the University and NSLDS was not updated timely. This was a result of the remittance schedule between the Clearinghouse and NSLDS not being properly established to allow for timely remittance. Effect – The status change was ultimately reported correctly to NSLDS but was not performed timely. Identification as a Repeat Finding – N/A Recommendation – We recommend the University verify the remittance schedule is properly established to allow for timely remittance. Views of Responsible Officials and Planned Corrective Actions – A new Student Information System was implemented in the 2024-25 fiscal year. In conjunction with the National Student Clearinghouse, the issue was identified, and it was determined that the new system was not tracking the student enrollment status correctly. The issue was resolved in collaboration with the Student Information System implementation team and system adjustments were made to ensure accurate and timely reporting.

Need Analysis and Transfer Credits Significant Deficiency DEPARTMENT OF EDUCATION ALN #: 84.268 Federal Award Identification #: 2023-2024 Award Year Condition: Students were not initially appropriately awarded subsidized aid based on need and credits earned. Criteria: 34 CFR 685.203 Questioned Costs: $0 Context: 6 students out of 60 were under awarded subsidized loans based on the number of credits earned due to an inadvertent exclusion of transfer credits not being part of the earned credit calculation. These students have not yet been adjusted. Cause: The University uses a third party to assist with awarding federal aid, and the reports pulling earned credits did not include transfer credits that were applied to the student. Effect: Students were awarded less subsidized federal aid than they were eligible for. Identification as repeat finding, if applicable: Not applicable. Recommendation: We recommend the University update the report that pulls all credits as all earned credits and not just those credits earned at the University. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.

Common Origination and Disbursement (COD) Reporting DEPARTMENT OF EDUCATION ALN #: 84.268 and 84.063 Federal Award Identification #: 2023-2024 Award Year Condition: The dates and amounts that Pell and FDL awards were posted to student accounts did not always agree to disbursement records reported to Common Origination and Disbursement (COD). Criteria: 34 CFR 668.164(a) Questioned Costs: $0 Context: 4 of 60 students tested had COD loan and Pell disbursement date errors ranging from 7 to 15 days, including one student who did not have the correct amount of Pell reported on COD compared to what was accurately disbursed on the student account. The students that COD allowed corrections to occur have been corrected. Cause: Reconciliations are completed by the third party administrator with the third party’s system of disbursement. Adjustments that occurred on the student account did not always get transferred to the third party system and were not identified in the reconciliation process. Effect: Inaccurate reporting of disbursements to COD can impact accrued interest for FDL as well as the monitoring of Pell lifetime limits and FDL aggregate limits for subsidized and unsubsidized loans. Identification as repeat finding, if applicable: Not applicable Recommendation: We recommend that procedures be implemented to ensure that disbursement reporting to COD be reflective of the actual disbursement dates and amounts with the University’s student information system. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.

Inaccurate Return of Title IV Funds Calculations Significant Deficiency DEPARTMENT OF EDUCATION ALN #: 84.268 and 84.063 Federal Award Identification #: 2022-2023 Financial Aid Year Condition: There were 2 incorrect calculations of returned funds for students that withdrew during the term. Criteria: 34 CFR 668.22 Questioned Costs: $0 Context: Out of 7 students, 2 students who withdrew during the audit period tested had funds returned incorrectly. One student was a modular student and had met an exemption, and the other student had an incorrect calculation. Additionally, 1 student had funds returned 87 days late. Additionally, one student had funds returned on the student account but the returns were not reflected in Common Origination and Disbursement (COD). Cause: These were oversights by the University in conjunction with the third-party administrator who assists in processing return calculations. Effect: The incorrect amount of Title IV funds was returned. Identification as repeat finding, if applicable: Yes, 2022-001 Recommendation: We recommend the University and the third-party processor work together to determine how to best complete return calculations. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.

Incorrect Pell Calculations Significant Deficiency DEPARTMENT OF EDUCATION ALN #: 84.063 Federal Award Identification #: 2022-2023 Financial Aid Year Condition: 2 students out of 31 were not properly awarded Pell based on enrollment status. Criteria: 34 CFR 690.63(b) Questioned Costs: $1,187 Context: One student was inadvertently awarded and paid Pell when they were officially less than half time for summer 2023 term under year round Pell, resulting in an over award of $1,187. This was corrected during the audit. Additionally, one student added a class and was not paid their Pell eligibility of $861 for that class. This student was also corrected during the audit. Cause: These were oversights. Effect: There was an incorrect amount of Pell paid to these two students. Identification as repeat finding, if applicable: Not applicable. Recommendation: We recommend a process be used to adjust Pell to be paid in alignment with enrollment status. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.

Gramm-Leach-Bliley Act (GLBA) Compliance Significant Deficiency DEPARTMENT OF EDUCATION ALN #: 84.268, 84.063, 84.007, and 84.033 - Student Financial Assistance Cluster Federal Award Identification #: 2022-2023 Financial Aid Year Condition: The University did not sufficiently comply with all the requirements of GLBA. Criteria: 16 CFR 314.3, 16 CFR 314.4 Questioned Costs: $0 Context: The University has not: • fully updated its written information security program in compliance with the revised regulations and with organizational practices • sufficiently documented its security risk assessment and safeguards • implemented multi-factor authentication on all systems containing personally identifiable information (PII) • implemented continuous monitoring, such as penetration testing and vulnerability scanning • implemented sufficient vendor management policies and reviews • provided a written, annual report to the board. Cause: The University shares information technology resources with another organization and is in the process of determining which pieces are fully addressed with that organization and which pieces the University will need to address and document compliance with the requirements of GLBA. Effect: The University has not adequately addressed the requirements of GLBA, which may lead to unintended exposure of student information to security risks. Identification as repeat finding, if applicable: Not applicable. Recommendation: We recommend the University allocate sufficient resources to address all requirements of GLBA. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.