University of the Incarnate Word

Finding 2025‐001 Special Tests and Provisions – Enrollment Reporting Information on the federal program: Federal awarding agency: United States Department of Education (ED) Federal program: Student Financial Assistance Cluster: Federal Pell Grant Program, ALN 84.063 Federal Direct Student Loans, ALN 84.268 Award year: 2024‐2025 Criteria or specific requirement (including statutory, regulatory or other citation): 2 CFR 200.303 requires that a non-federal entity must (a) establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States and the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Institutions are responsible for timely reporting, whether they report directly or via a third-party servicer. Institutions must complete and return within 15 days the Enrollment Reporting roster file placed in their Student Aid Internet Gateway (SAIG) (OMB No. 1845-0002) mailboxes sent by ED via the National Student Loan Data System (NSLDS) (OMB No. 1845-0035). The institution determines how often it receives the Enrollment Reporting roster file with the default set at a minimum of every 60 days. Once received, the institution must update for changes in the data elements for the Campus Record and the Program Record, and submit the changes electronically through the batch method, spreadsheet submittal, or the NSLDS website (Pell, 34 CFR 690.83(b)(2); FFEL, 34 CFR 682.610; Direct Loan, 34 CFR 685.309). NSLDS Enrollment Reporting Guide Chapter 1.4: At a minimum, schools are required to certify enrollment every 60 days, and respond within 15 days of the date that the NSLDS sends a roster file to the school or its third-party servicer. This requirement also applies to schools that report exclusively online. When a Direct Loan was made to or on behalf of a student who was enrolled or accepted for enrollment at the institution, and the student ceased to be enrolled on at least a half-time basis or failed to enroll on at least a half-time basis for the period for which the loan was intended; or a student who is enrolled at the institution and who received a loan under Title IV has changed his or her permanent address, the institution must report the change in its next updated Enrollment Reporting Roster file (due within 60 days of the change). Condition: The University did not provide evidence of an effective review process to ensure accurate and timely reporting of student status changes to NSLDS. The University did not report program enrollment effective date or student status to the NSLDS for 1 of 60 students selected for testing. Cause: The University did not have effective internal controls and procedures in place to ensure status changes were reported to the NSLDS accurately and timely. Effect or potential effect: Lack of timely and accurate enrollment reporting results in inaccurate enrollment status. A student’s enrollment status determines eligibility for in-school status, deferment, and grace periods. Enrollment reporting in a timely and accurate manner is critical for effective management of the programs. Questioned costs: $0 Context: We issued a material weakness related to internal control over compliance with enrollment reporting requirements in the prior year. Based upon the implementation date for the corrective action of May 31, 2025, provided by management, the finding related to this internal control had not been remediated for the period under audit. As such, we did not test the operating effectiveness of this internal control and are issuing a material weakness consistent with the prior year finding. EY selected and tested 60 students from the combined population of 1681 students that withdrew, never attended (no shows), graduated, or had changes in attendance levels during the year ended May 31, 2025. The 60 students, randomly selected, consisted of 35 student graduates, 15 student withdrawals/no shows, and 10 student changes in attendance levels. Of the 10 student changes in attendance levels, 1 student change in attendance level was not reported to the NSLDS. As a result, campus and program level data for program enrollment effective date and status was not reported for this student. For the 35 student graduates and 15 student withdrawals/no shows, the student status changes were reported accurately and timely to NSLDS. Total Student Financial Assistance Cluster expenditures for the year ended May 31, 2025, were $138,008,610, of which $14,477,268 were for Pell and $118,404,580 were for Direct Loans. Identification as a repeat finding, if applicable: Yes – 2024-001; 2023-001; 2022-001; 2021-001; 2020-001; 2019-002 Recommendation: The University should review, revise and implement internal controls and procedures surrounding the accurate and timely reporting of student status changes to the NSLDS. Views of responsible officials: Management agrees with the finding and has developed a corrective action plan which includes the Registrar’s Office and the Office of Financial Assistance working together to eliminate reporting issues and provide for successful data processing for enrollment reporting. The corrective action will be implemented by May 31, 2026.

Finding 2025‐002 Special Tests and Provisions – Return of Title IV Funds Information on the federal program: Federal awarding agency: United States Department of Education (ED) Federal program: Student Financial Assistance Cluster: Federal Pell Grant Program (Pell), ALN 84.063 Federal Direct Student Loans (Direct Loans), ALN 84.268 Award year: 2024‐2025 Criteria or specific requirement (including statutory, regulatory or other citation): 2 CFR 200.303 requires that a non-federal entity must (a) establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States and the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). 34 CFR section 668.173(b) requires timely return of title IV, HEA program funds. “In accordance with procedures established by the Secretary or FFEL Program lender, an institution returns unearned title IV, HEA program funds timely if – (1) The institution deposits or transfers the funds into the bank account it maintains under § 668.163 no later than 45 days after the date it determines that the student withdrew; (2) The institution initiates an electronic funds transfer (EFT) no later than 45 days after the date it determines that the student withdrew; (3) The institution initiates an electronic transaction, no later than 45 days after the date it determines that the student withdrew, that informs a FFEL lender to adjust the borrower’s loan account for the amount returned; or (4) The institution issues a check no later than 45 days after the date it determines that the student withdrew. An institution does not satisfy this requirement if – (i) The institution’s records show that the check was issued more than 45 days after the date the institution determined that the student withdrew; or (ii) The date on the cancelled check shows that the bank used by the Secretary or FFEL Program lender endorsed that check more than 60 days after the date the institution determined that the student withdrew.” Condition: The University did not provide evidence of an effective review process to ensure the timely calculation and return of Title IV funds to ED. The University did not accurately calculate and return Title IV funds in a timely manner to ED, within 45 days after the date the institution determined that a student withdrew. Cause: The University did not have effective internal controls and procedures in place over the return of Title IV funds to prevent noncompliance. Effect or potential effect: The University is not returning Title IV funds within the required time frame to ED, resulting in noncompliance. Questioned costs: $24,214 – Questioned costs were calculated based on the amount of funds not properly returned to ED. Context: We issued a material weakness related to internal control over compliance for the timely calculation and return of Title IV funds in the prior year. Based upon the planned implementation date for the corrective action of May 31, 2025 and then changed to May 1, 2026, as provided by management, the finding related to this internal control had not been remediated for the period under audit. As such, we did not test the operating effectiveness of this internal control and are issuing a material weakness consistent with the prior year finding. EY selected and tested 38 students from the population of 233 students who received Title IV funds, who withdrew during the year ended May 31, 2025. Of the 38 students selected, returns of Title IV funds were required for 26 students, with no returns required for 12 students. For 4 of the 26 students who withdrew, returns of Title IV funds were not returned to ED by the University within 45 days after the date the University determined the student withdrew. For these 4 students Title IV funds were returned to ED within a range of 81 to 142 days after the student withdrew. For 3 of the 26 students who withdrew, no returns of Title IV funds were calculated by the University and therefore no funds were returned to ED by the University. The funds required to be returned but not returned to ED totaled $24,214 for the 3 students. Total Student Financial Assistance Cluster expenditures for the year ended May 31, 2025, were $138,008,610, of which $14,477,268 were for Pell and $118,404,580 were for Direct Loans. Identification as a repeat finding, if applicable: Yes – 2024-002; 2023-002 Recommendation: The University should review and revise its internal controls and procedures surrounding the calculation and timely return of Title IV funds to ensure that the correct amount of federal student financial assistance is returned within the required time frame. Views of responsible officials: Management agrees with the finding and has developed a corrective action plan in which the Director of Financial Assistance has been working on a full review of all withdrawals during fiscal year 2023-2024 and 2024-2025 to ensure calculations were complete, accurate, and funds returned as required. The corrective action will be implemented by May 1, 2026.

Finding 2025‐003 – Special Tests and Provisions – Disbursements to or on Behalf of Students Information on the federal program: Federal awarding agency: United States Department of Education (ED) Federal program: Student Financial Assistance Cluster: Federal Pell Grant Program (Pell), ALN 84.063 Federal Direct Student Loans, Assistance Listing No. 84.268 Award years: 2024‐2025 Criteria or specific requirement (including statutory, regulatory or other citation): 2 CFR 200.303 requires that a non-federal entity must (a) establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States and the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: The University was unable to provide evidence that internal controls were performed in relation to notifications of disbursements, including notification of the amount and type of Title IV funds students are expected to receive, and how and when those disbursements will be made (award letter), and when direct loans are being credited to a student’s account (direct loan notification). Cause: The evidence of the internal control over award letters being sent to students consisted of award letter job completion confirmation emails. The evidence of the internal control over direct loan notifications includes reports of direct loan disbursements and corresponding dates of direct loan notifications received through the reporting tool, Argos, through email. The University indicated an issue with Outlook caused the emails to be deleted, so we were unable to observe some of the emails related to the award letters and any of the emails related to the direct loan notifications for the fiscal year ended May 31, 2025. Effect or potential effect: Evidence of the performance of internal controls over award letters and direct loan notifications did not exist. Award letters may not be sent, resulting in noncompliance, and direct loan notifications may not be made timely which could impact the student’s ability to cancel the loan. Questioned costs: $0 Context: Once the University prepares award packages for students, the award letter chain is triggered. Once the award letter chain is triggered, an award letter job completion confirmation is received via email by the Office of Financial Aid. We observed award letter job completion confirmation emails for 3 of 9 weeks selected for testing; however, we did not observe award letter job completion confirmation emails for the remaining 6 of 9 weeks selected. The University indicated there was a storage issue with Outlook causing emails to be deleted, including those related to award letter job completion emails. Due to the Outlook storage issue, we were unable to verify which weeks did or did not require award letters to be sent to students or which weeks might have been affected by the storage issue. Although, we did not observe the award letter job completion confirmation emails for 6 selected weeks, we did observe award letters were sent to each of the students selected in our disbursement testing, noting no compliance exceptions. The University receives emails from its reporting tool, Argos, of direct loan disbursements made and corresponding direct loan notification dates. We were unable to obtain the Argos emails containing the direct loan notification reports for 25 selected days. As a result, we could not confirm whether the University received the reports or performed the control to determine if any manual notifications should have been made. According to the University, the storage issue with Outlook caused Loan Disbursement Notification Quality Control emails to be deleted. We observed no such emails dated during the fiscal year ended May 31, 2025. Although we did not observe the email documentation and reports from Argos as evidence that internal controls over direct loan notifications were performed, we did observe direct loan notifications were made for the disbursements to students selected in our disbursement testing, noting no compliance exceptions. Total Student Financial Assistance Cluster expenditures for the year ended May 31, 2025, were $138,008,610, of which $14,477,268 were for Pell and $118,404,580 were for Direct Loans. Identification as a repeat finding, if applicable: Not applicable. Recommendation: The University should ensure that evidence of the performance of internal controls related to award letters and direct loan notifications is maintained. Views of responsible officials: Management agrees with the finding and has developed a corrective action plan whereby the Office of Financial Assistance is now able to retain evidence of emails related to internal controls over award letters and direct loan notifications. The corrective action was implemented by May 23, 2025.

Finding 2025‐004 – Special Tests and Provisions – Disbursements to or on Behalf of Students Information on the federal program: Federal awarding agency: United States Department of Education (ED) Federal program: Student Financial Assistance Cluster: Federal Pell Grant Program (Pell), ALN 84.063 Federal Direct Student Loans, Assistance Listing No. 84.268 Award years: 2024‐2025 Criteria or specific requirement (including statutory, regulatory or other citation): 2 CFR 200.303 requires that a non-federal entity must (a) establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States and the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). When Title IV funds are credited to a student account and they exceed the amount of tuition and fees, food and housing, and other authorized charges assessed the student, a credit balance is created. The institution must pay the resulting credit balance directly to the student or parent borrower within 14 days after (1) the first day of class of a payment period if the credit balance occurred on or before that day, or (2) the balance occurred if that was after the first day of class. An institution is permitted to hold credit balances if it obtains a voluntary authorization from the student. Regardless of any authorization obtained by the institution, the institution must pay any remaining loan balance by the end of the loan period and any other remaining Title IV funds by the end of the last payment period in the award year for which the funds were awarded. Condition: The University was unable to provide evidence that internal controls over the return of credit balances to students were performed. Additionally, student credit balances were not identified and refunded to students within 14 days after the credit balance occurred. Cause: The evidence of the internal control over student credit balances includes credit balance reports received through the reporting tool, Argos, through email. The University indicated an issue with Outlook caused the emails to be deleted, so we were unable to observe any of these emails for the fiscal year ended May 31, 2025. Additionally, the University’s internal controls were not effective to ensure that student credit balances were identified and returned to students with 14 days as required. Effect or potential effect: Evidence of the performance of internal controls over the review of student credit balances did not exist. Additionally, due to ineffective controls, the refund of student credit balances were not made timely (within 14 days as required), which resulted in noncompliance. Questioned costs: $0 Context: We were unable to obtain the Argos email containing the report of students with credit balances for the 9 weeks selected. As a result, we could not observe that the University received these reports and performed the internal control of review and inspection of student credit balances to ensure that students received refunds as appropriate. The University indicated there was a storage issue with Outlook causing emails to be deleted, including those related to the credit balance control emails. We observed no such emails dated during the fiscal year ended May 31, 2025. Additionally, we observed noncompliance for 4 of 40 students, whereby 3 students did not receive refunds of credit balances within 14 days and 1 student did not receive a refund of the credit balance, since the University applied the credit to other charges; however, that was done after the 14 day requirement.

Total Student Financial Assistance Cluster expenditures for the year ended May 31, 2025, were $138,008,610, of which $14,477,268 were for Pell and $118,404,580 were for Direct Loans.

Identification as a repeat finding, if applicable: Not applicable. Recommendation: The University should ensure that internal controls over the identification and return of student credit balances are improved and effective and also maintain evidence of the performance of those internal controls. The University should ensure that student credits are identified and returned to students within 14 days, as required. Views of responsible officials: Management agrees with the finding and has developed a corrective action plan whereby the Office of Financial Assistance is now able to retain evidence of emails related to internal controls over award letters and direct loan notifications. Additionally, the Business Office is now running internal reports twice weekly to identify and process credit balances. The corrective action was implemented by May 23, 2025.

Finding 2025‐005 – Cash Management Information on the federal program: Federal awarding agency: United States Department of Education (ED) Federal program: Student Financial Assistance Cluster: Federal Direct Student Loans, Assistance Listing No. 84.268 Award years: 2024‐2025 Criteria or specific requirement (including statutory, regulatory or other citation): 2 CFR 200.303 requires that a non-federal entity must (a) establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States and the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Cash Management Program Requirements for Direct Loans – Monthly Reconciliations Schools participating in the Direct Loan program are required to perform monthly Direct Loan reconciliations (34 CFR 685.300(b)(5)). Electronic Announcements DL-22-07 and GENERAL-22-86 explain that a school must reconcile the funds it received from G5 with actual disbursement records the school submitted to COD. Each month, COD sends the school a School Account Statement, which is ED’s official record of the school’s cash and disbursement records and identifies the difference between the net draws from G5 and the actual disbursement information reported to COD by the school. The school is required to account for any differences by reconciling ED’s records (School Account Statements) with the school’s financial and business records.

Condition: The University did not provide evidence that the School Account Statements (SAS) from ED were used to reconcile to the University’s financial and business records on a monthly basis during the year ended May 31, 2025.

Cause: The University did not have effective internal controls and procedures in place to ensure the use of SAS in monthly reconciliations. The University indicated that they used SAS in their monthly reconciliations; however, they did not retain evidence that the SAS was used, including accounting for differences between SAS and the University’s financial and business records. Effect or potential effect: Lack of external monthly reconciliations between the University’s records and SAS could result in incorrect data in the University’s records and ED systems and cash management and disbursement reporting timelines not being met. Questioned costs: $0

Context: While the University provided evidence of internal daily reconciliations, the University did not provide evidence that they utilized SAS for monthly reconciliations, as required. Total Student Financial Assistance Cluster expenditures for the year ended May 31, 2025, were $138,008,610, of which $118,404,580 were for Direct Loans. Identification as a repeat finding, if applicable: Yes – 2023-003

Recommendation: The University should review and revise its internal controls and procedures surrounding the monthly reconciliations to SAS and retain evidence of such reconciliations, including SAS. Views of responsible officials: Management agrees with the finding and has developed a corrective action plan in which the Office of Financial Assistance will maintain evidence of monthly reconciliations between SAS and the University’s financial and business records. The corrective action was implemented by February 1, 2026.

Finding 2025‐006 Procurement and Suspension and Debarment Information on the federal program: Federal awarding agency: United States Department of Education (ED) Federal program: School Safely National Activities, Assistance Listing No. 84.184X Award year: 2024‐2025 Criteria or specific requirement (including statutory, regulatory or other citation): 2 CFR 200.303 requires that a non-federal entity must (a) establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States and the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). 2 CFR 200.318 (i) General Procurement Standards states, “the non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include, but are not necessarily limited to, the following: Rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price.” Condition: The University did not maintain records for procurements sufficient to detail the history of the procurement, including the rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. Cause: The University did not have effective internal controls and procedures in place to ensure the University maintained records for procurements sufficient to detail the history of the procurement, including the rationale for the method of procurement and other required elements.

Effect or potential effect: The University did not comply with the general procurement standards per the Uniform Guidance to maintain sufficient detail of the history of the procurement, including the rationale of the method of procurement. The University also did not retain evidence of internal controls related to approval of procurements. The performance of internal controls, including approval documentation of the procurement, is necessary to ensure compliance with federal procurement requirements.

Questioned costs: $167,398 – Questioned costs were calculated based on the amount of two procurements for which the history of the procurement, including the rationale of the procurement method, was not documented ($73,980 plus $93,418).

Context: We issued a material weakness related to internal control over compliance with procurement requirements in the prior year. Based upon the implementation date for the corrective action of May 31, 2025, provided by management, the finding related to this internal control had not been remediated for the period under audit. As such, we did not test the operating effectiveness of this internal control and are issuing a material weakness consistent with the prior year finding. We selected and tested the two procurements in the population over $10,000 with expenditures totaling $167,398 for the year ended May 31, 2025 for the School Safely National Activities program. For these procurements of an occupational therapist contractor ($73,980) and another vendor for supplies and materials ($93,418), the University did not obtain quotes or document sole source justification or the history of the procurement, including the rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. We consider the expenditures related to these procurements to be questioned costs due to lack of supporting documentation for the procurement, as noted above. The University’s total School Safely National Activities program expenditures were $1,310,305 for the year ended May 31, 2025. Of this amount, $262,030 related to procurements of goods and services during the year, of which 2 procurements were over $10,000. Identification as a repeat finding, if applicable: Yes – 2024-004; 2023-004

Recommendation: The University should retain written documentation for procurements, documenting the history of the procurement prior to the procurement of goods or services including, but not limited to, the rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. The University should also retain evidence of internal controls, including approval documentation of the procurement, performed prior to entering into procurements. Views of responsible officials: Management agrees with the finding and has developed a corrective action plan in which the University will document the methodology used to select sole source or preferred vendor procurements through completion of the Sole Source/Preferred Vendor Justification Form. The corrective action will be implemented by March 1, 2026.

Finding 2025‐007 Procurement and Suspension and Debarment Information on the federal program: Federal awarding agency: United States Department of Education (ED) Federal program: School Safely National Activities, Assistance Listing No. 84.184X Award year: 2024‐2025 Criteria or specific requirement (including statutory, regulatory or other citation): 2 CFR 200.303 requires that a non-federal entity must (a) establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States and the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). In accordance with 2 CFR part 180 non-federal entities are prohibited from contracting with, or making subawards to parties that are suspended or debarred, or otherwise excluded. “Covered transactions” include contracts for goods and services awarded under a non-procurement transaction that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. When a non-federal entity enters into a covered transaction with an entity at a lower tier, the non-federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. This verification may be accomplished by (1) checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration (GSA) and available at SAM.gov | Home (click on Search Record, then click on Advanced Search-Exclusions) (Note: The OMB guidance at 2 CFR Part 180 and agency implementing regulations still refer to the SAM Exclusions as the Excluded Parties List System (EPLS)), (2) collecting a certification from the entity, or (3) adding a clause or condition to the covered transaction with that entity (2 CFR section 180.300).

Condition: The University did not have evidence that the University performed suspension and debarment checks for contractors on SAM.gov prior to entering into the contracts.

Cause: The University either did not perform and/or retain evidence of checks for suspension and debarment for contractors. The University does not have a clear written policy or effective internal control over compliance with suspension and debarment requirements. Effect or potential effect: The University did not comply with suspension and debarment requirements. Without having effective internal controls over suspension and debarment, procurements could be entered into with a suspended or debarred entity. Questioned costs: $167,398 – Questioned costs were calculated based on the amount of two procurements for which no check for suspension or debarment was made for the vendors ($73,980 plus $93,418).

Context: We issued a material weakness related to internal control over compliance with suspension and debarment requirements in the prior year. Based upon the implementation dates for the corrective action of February 24, 2025 and May 31, 2025, provided by management, the finding related to this internal control had not been remediated for the period under audit. As such, we did not test the operating effectiveness of this internal control and are issuing a material weakness consistent with the prior year finding. We selected and tested 2 procurements over $25,000 each with expenditures totaling $167,398, for the year ended May 31, 2025 for the School Safely National Activities program. The procurements were for an occupational therapist contractor ($73,980) and another vendor of supplies and materials ($93,418). The University had no evidence of suspension and debarment checks being performed prior to entering into the procurements. The University’s total School Safely National Activities program expenditures were $1,310,305 for the year ended May 31, 2025. Of this amount, $167,398 related to contracts or procurements of goods and services over $25,000.

Identification as a repeat finding, if applicable: Yes – 2024-005 Recommendation: The University should develop and implement procedures and internal control to ensure that suspension and debarment requirements are complied with, and that support for the dates and the results of suspension and debarment checks on SAM.gov are retained. Also, the University should revise its procurement policy to include procedures for suspension and debarment. Views of responsible officials: Management agrees with the finding and has developed a corrective action plan which includes retention of documentation of suspension and debarment searches on SAM.gov and adding verbiage to contracts/purchase orders related to suspension and debarment. The corrective action was implemented by May 31, 2025.

Finding 2025-008 – Allowable Costs/Cost Principles and Matching, Level of Effort, and Earmarking Information on the federal program: Federal awarding agency: United States Department of Education (ED) Federal program: School Safely National Activities, Assistance Listing No. 84.184X Award year: 2024‐2025 Criteria or specific requirement (including statutory, regulatory or other citation): 2 CFR 200.303 requires that a non-federal entity must (a) establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States and the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). 2 CFR 200.430 (i) states “Standards for Documentation of Personnel Expenses (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflected the work performed. These records must: (i) be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) be incorporated into the official records of the non-Federal entity; (iii) reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities; (iv) encompass both federal assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non-Federal entity’s written policy; (v) comply with the established accounting policies and practices of the non-Federal entity.” Condition: The University did not have effective internal controls over the timely preparation and approval of employees’ time and effort certifications.

Cause: The University did not execute their internal controls for the timely preparation and approval of employees’ time and effort certifications on a timely basis. Effect or potential effect: Unallowable and/or inaccurate payroll expenditures could be charged to the federal program due to the delay in the preparation and approval of the time and effort certifications. Level of effort per grant award notification and grant proposal documents may not be met as required for the applicable employees with level of effort requirements, the program director/principal investigator and co-investigators, for the School Safely National Activities Program. Questioned costs: None. Context: It is the University’s policy to have time and effort certifications prepared and approved for grant employees on a semesterly basis. For 9 of 14 payroll expenditures selected for testing, the University’s employees prepared their time and effort certifications between 4 and 10 months after the applicable semester ended, with approvals made after that time. The grant documents provide for level of effort requirements for the program for five employees, including the program director/principal investigator with a level of effort of 25% and 4 co-investigators with level of effort of 2.5%. The University’s total School Safely National Activities program expenditures were $1,310,305 for the year ended May 31, 2025. Of this amount, $209,270 related to payroll expenditures, including fringe benefits. Identification of a repeat finding: Not applicable.

Recommendation: We recommend the University execute its internal controls to provide for the preparation and approval of employees’ time and effort certifications on a timely basis after the end of each semester. Views of responsible officials: Management agrees with the finding and has developed a corrective action plan in which the University updated the time and effort reporting form and the Grants Accounting Office will ensure the forms are completed timely. The corrective action was implemented by February 6, 2026.

Finding 2024‐001 Special Tests and Provisions – Enrollment Reporting Information on the federal program: Federal awarding agency: United States Department of Education (ED) Federal Program: Student Financial Assistance Cluster: Federal Pell Grant Program, ALN 84.063 Federal Direct Student Loans, ALN 84.268 Award year: 2023‐2024 Criteria or specific requirement (including statutory, regulatory or other citation): 2 CFR 200.303 requires that a non-federal entity must (a) establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States and the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Institutions are responsible for timely reporting, whether they report directly or via a third-party servicer. Institutions must complete and return within 15 days the Enrollment Reporting roster file placed in their Student Aid Internet Gateway (SAIG) (OMB No. 1845-0002) mailboxes sent by ED via the National Student Loan Data System (NSLDS) (OMB No. 1845-0035). The institution determines how often it receives the Enrollment Reporting roster file with the default set at a minimum of every 60 days. Once received, the institution must update for changes in the data elements for the Campus Record and the Program Record, and submit the changes electronically through the batch method, spreadsheet submittal, or the NSLDS website (Pell, 34 CFR 690.83(b)(2); FFEL, 34 CFR 682.610; Direct Loan, 34 CFR 685.309).

NSLDS Enrollment Reporting Guide Chapter 1.4: At a minimum, schools are required to certify enrollment every 60 days, and respond within 15 days of the date that the NSLDS sends a roster file to the school or its third-party servicer. This requirement also applies to schools that report exclusively online. NSLDS Enrollment Reporting Guide Chapter 4.4.5: If the student enrolls in the summer term (or other non-required terms) at least half time, the student’s actual summer enrollment status is reported. If such a student subsequently withdraws from the summer term, the student’s most recent enrollment status of half time or greater should be reported throughout the remainder of the summer. If the student does not return in the fall as expected, the status must be changed to “Withdrawn” with the date the student withdrew from the summer term as the Enrollment Status Effective Date. When a Direct Loan was made to or on behalf of a student who was enrolled or accepted for enrollment at the institution, and the student ceased to be enrolled on at least a half-time basis or failed to enroll on at least a half-time basis for the period for which the loan was intended; or a student who is enrolled at the institution and who received a loan under Title IV has changed his or her permanent address, the institution must report the change in its next updated Enrollment Reporting Roster file (due within 60 days of the change). Condition: The University did not provide evidence of an effective review process to ensure accurate and timely reporting of student status changes to NSLDS. The University did not timely report student status changes to the NSLDS for 5 of 60 students selected for testing. Cause: The University did not have effective internal controls and procedures in place to ensure status changes were reported to the NSLDS accurately and timely.

Effect or potential effect: Lack of timely and accurate enrollment reporting results in inaccurate enrollment status. A student’s enrollment status determines eligibility for in-school status, deferment, and grace periods. Enrollment reporting in a timely and accurate manner is critical for effective management of the programs. Questioned costs: $0 Context: We issued a material weakness related to internal control over compliance with enrollment reporting requirements in the prior year. Based upon the implementation date for the corrective action of May 31, 2024, provided by management, the finding related to this internal control had not been remediated for the period under audit. As such, we did not test the operating effectiveness of this internal control and are issuing a material weakness consistent with the prior year finding. EY selected and tested 60 students from the combined population of 2,332 students that withdrew, never attended (no shows), graduated, or had changes in attendance levels during the year ended May 31, 2024. The 60 students, randomly selected, consisted of 31 student graduates, 18 student withdrawals/no shows, and 11 student changes in attendance levels. Of the 18 student withdrawals/no shows, 5 student withdrawals were reported after the 60-day reporting requirement. All 5 withdrawals were reported to NSLDS 108 days after the respective withdrawal dates. For the 31 student graduates and 11 student changes in attendance levels, the student status changes were reported accurately and timely to NSLDS. Total Student Financial Assistance Cluster expenditures for the year ended May 31, 2024, were $126,861,327, of which $12,330,584 were for Pell and $109,542,821 were for Direct Loans. Identification as a repeat finding, if applicable: Yes – 2023-001; 2022-001; 2021-001; 2020-001; 2019-002.

Recommendation: The University should review and revise its internal controls and procedures surrounding the accurate and timely reporting of student status changes to the NSLDS and implement these internal controls and procedures. Views of responsible officials: Management agrees with the finding and has developed a corrective action plan which includes working with the National Student Clearinghouse to understand and resolve differences in reported withdrawal data. The corrective action will be implemented in May 2025.

Finding 2024‐002 Special Tests and Provisions – Return of Title IV Funds Information on the federal program: Federal awarding agency: United States Department of Education (ED) Federal Program: Student Financial Assistance Cluster: Federal Pell Grant Program (Pell), ALN 84.063 Federal Direct Student Loans (Direct Loans), ALN 84.268 Award year: 2023‐2024 Criteria or specific requirement (including statutory, regulatory or other citation): 2 CFR 200.303 requires that a non-federal entity must (a) establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States and the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). 34 CFR section 668.173(b) requires timely return of title IV, HEA program funds. “In accordance with procedures established by the Secretary or FFEL Program lender, an institution returns unearned title IV, HEA program funds timely if – (1) The institution deposits or transfers the funds into the bank account it maintains under § 668.163 no later than 45 days after the date it determines that the student withdrew; (2) The institution initiates an electronic funds transfer (EFT) no later than 45 days after the date it determines that the student withdrew; (3) The institution initiates an electronic transaction, no later than 45 days after the date it determines that the student withdrew, that informs a FFEL lender to adjust the borrower’s loan account for the amount returned; or (4) The institution issues a check no later than 45 days after the date it determines that the student withdrew. An institution does not satisfy this requirement if – (i) The institution’s records show that the check was issued more than 45 days after the date the institution determined that the student withdrew; or (ii) The date on the cancelled check shows that the bank used by the Secretary or FFEL Program lender endorsed that check more than 60 days after the date the institution determined that the student withdrew.”Condition: The University did not provide evidence of an effective review process to ensure the timely calculation and return of Title IV funds to ED. The University did not accurately calculate and return Title IV funds in a timely manner to ED, within 45 days after the date the institution determined that a student withdrew. Cause: The University did not have effective internal controls and procedures in place over the return of Title IV funds to prevent noncompliance. Effect or potential effect: The University is not returning Title IV funds within the required time frame to ED, resulting in noncompliance. Questioned costs: $6,566 – Questioned costs were calculated based on the amount of funds not properly returned to ED. Context: We issued a material weakness related to internal control over compliance for the timely calculation and return of Title IV funds in the prior year. Based upon the implementation date for the corrective action of April 1, 2024, provided by management, the finding related to this internal control had not been remediated for the entire period under audit. As such, we did not test the operating effectiveness of this internal control and are issuing a material weakness consistent with the prior year finding. EY selected and tested 40 students from the population of 546 students who withdrew during the year ended May 31, 2024. Of the 40 students selected, returns of Title IV funds were required for 23 students, with no returns required for 17 students. For 5 of the 23 students, returns of Title IV funds were not calculated and returned to ED by the University within 45 days after the date the University determined the student withdrew. Additionally, for 1 of the 23 students, a return of Title IV funds was calculated by the University in the amount of $6,079 but was not returned to ED. For one other of the 23 students, a return of Title IV funds was calculated incorrectly as $0 when it should have been $487, with the $487 not returned to ED. Total Student Financial Assistance Cluster expenditures for the year ended May 31, 2024, were $126,861,327, of which $12,330,584 were for Pell and $109,542,821 were for Direct Loans. Identification as a repeat finding, if applicable: Yes – 2023-002 Recommendation: The University should review and revise its internal controls and procedures surrounding the calculation and timely return of Title IV funds to ensure that the correct amount of federal student financial assistance is returned within the required time frame. Views of responsible officials: Management agrees with the finding and has developed a corrective action plan in which the Director of Financial Assistance will run a full review of all withdrawals during fiscal year 2023-2024 to ensure calculations were complete, accurate, and funds returned as required. The corrective action will be implemented in May 2025.

Finding 2024‐003 – Eligibility Information on the federal program: Federal awarding agency: United States Department of Education (ED) Federal Program: Student Financial Assistance Cluster: Federal Pell Grant Program, Assistance Listing No. 84.063 Federal Direct Student Loans, Assistance Listing No. 84.268 Award years: 2023‐2024 Criteria or specific requirement (including statutory, regulatory or other citation): 2 CFR 200.303 requires that a non-federal entity must (a) establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States and the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Student Financial Assistance Programs, student eligibility requirements include the following: 8. Must maintain good standing, or satisfactory academic progress (34 CFRs 668.16, 668.32(f), 668.34, 690.75, 675.9, 676.9, 685.200, 686.11, 20 USC 1070h; 42 CFR 57.306; 42 USC 293a(d)(2)). The University’s Satisfactory Academic Policy (SAP), Maximum Timeframe states, “the number of credit hours a student attempts may not exceed 150% of the number of hours required for graduation, as published in the university catalog. If the published number of hours required is 120, a student may not attempt more than 180 hours (120 x 1.50 = 180) and continue to receive financial aid. If the number of attempted hours reaches 150% of the hours required for graduation or it becomes mathematically impossible to complete degree requirements within 150%, the student will no longer be eligible for financial aid. Both calculations will be conducted upon each official SAP evaluation period. If it is deemed the student cannot graduate by 150% or has exceeded 150%, the student will be ineligible for Federal financial aid and will be required to submit the SAP Recovery Packet to be considered for aid. Attempted hours include all credit hours the student has transferred from another institution as well as all credit hours the student has registered to take at UIW, whether they earn a grade or not, receive credit, or receive financial aid. Level – maximum timeframe Undergraduate Pursuing a Bachelor’s Degree – Not to exceed 180 attempted credit hours Undergraduate who has a Bachelor’s Degree and is pursuing a 2nd Bachelor’s Degree – Not to exceed 240 attempted credit hours Undergraduate pursuing an Associate Degree – Not to exceed 100 attempted credit hours Undergraduate pursuing a 2nd Associate Degree – Not to exceed 130 attempted credit hours Undergraduate who has a Bachelor’s Degree and is pursuing an Associate Degree – Not to exceed 210 attempted credit hours Graduate Pursuing a Doctorate Degree – Not to exceed 67 attempted credit hours Pharmacy – Not to exceed 236 attempted credit hours Physical Therapy – Not to exceed 185 attempted hours School of Medicine (SOM) – See SOM student handbook If a student is exceeding the maximum timeframe due to being classified as 2nd degree seeking, the student will not need to appeal to receive financial aid if both the quantitative and qualitative measures are being met.” Condition: The University relies on a system application control to identify students who have exceeded their maximum time frame to graduate. For graduate students only, the coding within the system did not appropriately identify the hours the graduate student attempted during the year ended May 31, 2024. Cause: The University’s system application control over identifying the attempted hours that exceed the maximum time frame for graduate students was incorrectly configured to identify the hours earned by the student, not attempted. Effect or potential effect: If the system programming to identify graduate students who have exceeded their attempted hours is not designed properly, the graduate student may be eligible for financial aid even though they do not satisfy SAP. Questioned costs: $0 Context: We issued a material weakness related to internal control over compliance with SAP requirements in the prior year. Based upon the implementation date for the corrective action of April 1, 2024, provided by management, the finding related to this internal control had not been remediated for the entire period under audit. As such, we did not test the operating effectiveness of this internal control and are issuing a material weakness consistent with the prior year finding. The University configures the parameters for identifying students who comply and do not maintain SAP. The University configured these SAP factors into a system application. One factor in determining SAP is that students graduate within the maximum time frame allowed for their program, which is measured in attempted hours. The University did not correctly configure its system to identify graduate students who exceeded their maximum time frame to graduate per their program. Users with access to configure these factors were evaluated to be appropriate. Identification as a repeat finding, if applicable: Yes – 2023-008 Recommendation: The University should review the programming within the system to ensure it is accurate to identify graduate students who have exceeded their attempted hours. Views of responsible officials: Management agrees with the finding and corrected the finding in June 2024 after rules were re-evaluated and fixed, prior to running SAP process for the end of 2023-2024 (to receive aid for 2024-2025).

Finding 2024‐004 Procurement and Suspension and Debarment Information on the federal program: Federal awarding agency: United States Department of Education (ED) Federal Program: School Safely National Activities, Assistance Listing No. 84.184X Award year: 2023‐2024 Criteria or specific requirement (including statutory, regulatory or other citation): 2 CFR 200.303 requires that a non-federal entity must (a) establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States and the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: The University did not have appropriate documentation to evidence approval of a sole source procurement. Cause: The University created and implemented the use of a vendor sole source form to ensure proper documentation and approvals of sole source procurements in December 2023. As a result, the use of the form was not in effect for the entire fiscal year ended May 31, 2024. Effect or potential effect: The University did not retain evidence of internal controls related to approval of procurements. The performance of internal controls, including approval documentation of the procurement, is necessary to ensure compliance with federal procurement requirements. Questioned costs: $0 Context: We selected and tested the one procurement in the population over $10,000 with expenditures totaling $61,996 for the year ended May 31, 2024 for the School Safely National Activities program. While we did observe documentation within the agreement with the vendor and within the grant application, which identified the vendor, including the specialized experience of the vendor and the reasons the vendor was the only vendor that could provide the specific services required according to the needs of the program, the University did not provide evidence of internal control over the sole source procurement. Specifically, we did not see evidence of approval of the procurement by the Procurement department or the Grants Accounting office, the offices at the University knowledgeable of federal procurement requirements. The University’s total School Safely National Activities program expenditures were $1,105,410 for the year ended May 31, 2024. Of this amount, $241,031 related to procurements of goods and services, of which only 1 procurement was over $10,000. Identification as a repeat finding, if applicable: Not Applicable Recommendation: The University should retain evidence of internal controls, including approval documentation of the procurement, performed prior to entering into procurements. Views of responsible officials: Management agrees with the finding and has developed a corrective action plan which includes strengthening policies and procedures for sole source procurements, the use of a sole source form, and the designation of required approvals for sole source requests. The corrective action will be implemented in May 2025.

Finding 2024‐005 Procurement and Suspension and Debarment Information on the federal program: Federal awarding agency: United States Department of Education (ED) Federal Program: School Safely National Activities, Assistance Listing No. 84.184X Award year: 2023‐2024 Criteria or specific requirement (including statutory, regulatory or other citation): 2 CFR 200.303 requires that a non-federal entity must (a) establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States and the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). In accordance with 2 CFR part 180 non-federal entities are prohibited from contracting with, or making subawards to parties that are suspended or debarred, or otherwise excluded. “Covered transactions” include contracts for goods and services awarded under a non-procurement transaction that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. When a non-federal entity enters into a covered transaction with an entity at a lower tier, the non-federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. This verification may be accomplished by (1) checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration (GSA) and available at SAM.gov | Home (click on Search Record, then click on Advanced Search-Exclusions) (Note: The OMB guidance at 2 CFR Part 180 and agency implementing regulations still refer to the SAM Exclusions as the Excluded Parties List System (EPLS)), (2) collecting a certification from the entity, or (3) adding a clause or condition to the covered transaction with that entity (2 CFR section 180.300). Condition: The University did not have evidence that the University performed suspension and debarment checks for contractors on SAM.gov prior to entering into the contracts.

Cause: The University either did not perform and/or retain evidence of checks for suspension and debarment for contractors. The University does not have a clear written policy or effective internal control over compliance with suspension and debarment requirements. Effect or potential effect: The University did not comply with suspension and debarment requirements. Without having effective internal controls over suspension and debarment, procurements could be entered into with a suspended or debarred entity. Questioned costs: $0 Context: We selected and tested 3 contracts with expenditures over $25,000 each, totaling $301,996, for the year ended May 31, 2024 for the School Safely National Activities program. One contract was with a collaborator on the grant with expenditures in the amount of $190,000, one contract was with a vendor for the grant with expenditures in the amount of $61,996, and the other contract was with an individual contractor in the amount of $50,000. The University had no evidence of suspension and debarment checks being performed prior to entering into these 3 contracts. The University’s total School Safely National Activities program expenditures were $1,105,410 for the year ended May 31, 2024. Of this amount, $301,996 related to contracts or procurements of goods and services over $25,000. Identification as a repeat finding, if applicable: Not Applicable

Recommendation: The University should develop and implement procedures and internal control to ensure that suspension and debarment requirements are complied with, and that support for the dates and the results of suspension and debarment checks on SAM.gov are retained. Views of responsible officials: Management agrees with the finding and has developed a corrective action plan which includes retention of documentation of suspension and debarment searches on SAM.gov and adding verbiage to contracts/purchase orders related to suspension and debarment. The corrective action was implemented in February 2025 for retention of documentation of searches and will be implemented in May 2025 for verbiage in contracts/purchase orders.

Finding 2023‐001 Special Tests and Provisions – Enrollment Reporting Information on the federal program: Federal awarding agency: United States Department of Education (ED) Federal Program: Student Financial Assistance Cluster: Federal Pell Grant Program, ALN 84.063 Federal Direct Student Loans, ALN 84.268 Award year: 2022‐2023 Criteria or specific requirement (including statutory, regulatory or other citation): 2 CFR 200.303 requires that a non-federal entity must (a) establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States and the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Under the Pell grant and U.S. Department of Education loan programs, institutions must complete and return within 15 days the Enrollment Reporting roster file placed in their Student Aid Internet Gateway (SAIG) (OMB No. 1845-0002) mailboxes sent by ED via the National Student Loan Data System (NSLDS) (OMB No. 1845-0035). The institution determines how often it receives the Enrollment Reporting roster file with the default set at a minimum of every 60 days. Once received, the institution must update for changes in the data elements for the Campus Record and the Program Record, and submit the changes electronically through the batch method, spreadsheet submittal, or the NSLDS website (Pell, 34 CFR 690.83(b)(2); FFEL, 34 CFR 682.610; Direct Loan, 34 CFR 685.309). Institutions are responsible for timely reporting, whether they report directly or via a third-party servicer. NSLDS Enrollment Reporting Guide Chapter 1.4: At a minimum, schools are required to certify enrollment every 60 days, and respond within 15 days of the date that the NSLDS sends a roster file to the school or its third-party servicer. This requirement also applies to schools that report exclusively online. NSLDS Enrollment Reporting Guide Chapter 4.4.5: If the student enrolls in the summer term (or other non-required terms) at least half time, the student’s actual summer enrollment status is reported. If such a student subsequently withdraws from the summer term, the student’s most recent enrollment status of half time or greater should be reported throughout the remainder of the summer. If the student does not return in the fall as expected, the status must be changed to “Withdrawn” with the date the student withdrew from the summer term as the Enrollment Status Effective Date. Condition: The University did not provide evidence of an effective review process to ensure accurate and timely reporting of student status changes to NSLDS. The University did not accurately or timely report student status changes to the NSLDS for 7 of 60 students selected for testing. Questioned Costs: $0 Context: EY selected and tested 60 students from the combined population of 2,164 students that withdrew, never attended (no shows), graduated, or had changes in attendance levels during the year ended May 31, 2023. The 60 students, randomly selected, consisted of 23 student graduates, 23 student withdrawals/no shows, and 14 student changes in attendance levels. Of the 23 student graduates selected, two graduates were reported after the 60-day reporting requirement. The graduates were reported to NSLDS 136 days after the respective graduation dates. Of the 23 withdrawals/no shows, four withdrawals were reported after the 60-day reporting requirement. The withdrawals were reported to NSLDS 64, 70, 85 and 154 days after the respective withdrawal dates. Of the 14 student changes in attendance levels, for one student, the change in attendance level was not reported to NSLDS. According to the University, the lack of reporting was due to a discrepancy in the student’s social security number. Total Student Financial Assistance Cluster expenditures for the year ended May 31, 2023, were $128,072,878, of which $10,899,812 were for Pell and $111,793,842 were for Direct Loans. Effect: Lack of timely and accurate enrollment reporting results in inaccurate enrollment status. A student’s enrollment status determines eligibility for in-school status, deferment, and grace periods. Enrollment reporting in a timely and accurate manner is critical for effective management of the programs. Cause: The University did not have effective internal controls and procedures in place to ensure status changes were reported to the NSLDS accurately and timely. Identification as a repeat finding, if applicable: Yes – 2022-001; 2021-001; 2020-001; 2019-002. Recommendation: The University should review and revise its internal controls and procedures surrounding the accurate and timely reporting of student status changes to the NSLDS and implement these internal controls and procedures. Views of responsible officials and planned corrective actions: Management agrees with the finding and has developed a plan to correct the finding.

Finding 2023‐002 Special Tests and Provisions – Return of Title IV FundsInformation on the federal program:Federal awarding agency: United States Department of Education (ED) Federal Program: Student Financial Assistance Cluster: Federal Pell Grant Program (Pell), ALN 84.063 Federal Direct Student Loans (Direct Loans), ALN 84.268 Award year: 2022‐2023 Criteria or specific requirement (including statutory, regulatory or other citation):2 CFR 200.303 requires that a non-federal entity must (a) establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States and the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). 34 CFR section 668.173(b) requires timely return of title IV, HEA program funds. “In accordance with procedures established by the Secretary or FFEL Program lender, an institution returns unearned title IV, HEA program funds timely if - (1) The institution deposits or transfers the funds into the bank account it maintains under § 668.163 no later than 45 days after the date it determines that the student withdrew; (2) The institution initiates an electronic funds transfer (EFT) no later than 45 days after the date it determines that the student withdrew; (3) The institution initiates an electronic transaction, no later than 45 days after the date it determines that the student withdrew, that informs a FFEL lender to adjust the borrower’s loan account for the amount returned; or (4) The institution issues a check no later than 45 days after the date it determines that the student withdrew. An institution does not satisfy this requirement if - (i) The institution’s records show that the check was issued more than 45 days after the date the institution determined that the student withdrew; or (ii) The date on the cancelled check shows that the bank used by the Secretary or FFEL Program lender endorsed that check more than 60 days after the date the institution determined that the student withdrew.” Condition: The University did not provide evidence of an effective review process to ensure the timely calculation and return of Title IV funds to ED. The University did not calculate and return Title IV funds in a timely manner to ED, within 45 days after the date the institution determined that a student withdrew. Questioned Costs: $6 Context: After obtaining an understanding of the internal controls over return of Title IV funds, we determined internal controls were not designed sufficiently to ensure compliance with timely calculations and returns of Title IV funds. As such, we did not test the operating effectiveness of the controls over return of Title IV funds and are issuing a material weakness. EY selected and tested 40 students from the population of 1,398 students that withdrew during the year ended May 31, 2023. Of the 40 students selected, returns of Title IV funds were required for 27 students, with no returns required for 13 students. For 17 of the 27 students, returns of Title IV funds were not calculated and returned to ED by the University within 45 days after the date the University determined the student withdrew. Additionally, for one of the 17 students with late returns, the calculation and return of Title IV funds by the University was understated by $6. Total Student Financial Assistance Cluster expenditures for the year ended May 31, 2023, were $128,072,878, of which $10,899,812 were for Pell and $111,793,842 were for Direct Loans. Effect: The University is not returning Title IV funds within the required timeframe to ED, resulting in noncompliance. Cause: The University did not have effective internal controls and procedures in place over the return of Title IV funds to prevent noncompliance. Identification as a repeat finding, if applicable: Not applicable Recommendation: The University should review and revise its internal controls and procedures surrounding the calculation and timely return of Title IV funds, to ensure that the correct amount of federal student financial assistance is returned within the required timeframe. Views of responsible officials and planned corrective actions: Management agrees with the finding and has developed a plan to correct the finding.

Finding 2023‐003 Special Tests and Provisions – Direct Loan Reconciliation Information on the federal program: Federal awarding agency: United States Department of Education (ED) Federal Program: Student Financial Assistance Cluster: Federal Direct Student Loans, ALN 84.268 Award year: 2022‐2023 Criteria or specific requirement (including statutory, regulatory or other citation): 2 CFR 200.303 requires that a non-federal entity must (a) establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States and the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Each month, the ED’s Common Origination and Disbursement (COD) provides institutions with a School Account Statement (SAS) data file which consists of a Cash Summary, Cash Detail, and (optional at the request of the institution) Loan Detail records. The institution is required to reconcile these files to the institution’s financial records. In a Nov. 18, 2020 Electronic Announcement, ED published general information regarding Title IV aid disbursement reporting, excess cash, and reconciliation requirements. In addition, updated disbursement reporting and data submission timelines for all programs were published in Federal Register Notice (see Federal Register Volume 85, Number 135 (Tuesday, July 14, 2020) for the 2020–2021 deadlines). In this announcement, ED provided specific information to assist a school with reconciling the William D. Ford Federal Direct Loan (Direct Loan) Program. The information provided below should be viewed by both the financial aid office and business office. Direct Loan Reconciliation Defined Direct Loan reconciliation is the process by which Direct Loan funds received and disbursed as recorded on the ED’s systems are reviewed and compared with a school’s internal records; AND • Discrepancies are identified and resolved • Reasons for remaining cash balances are documented Direct Loan reconciliation is a mandatory monthly process, as required under 34 CFR 685.300(b)(5). A school should reconcile all cash (drawdowns and refunds of cash) and disbursement records (actual disbursements and adjustments) with information in the COD System on an ongoing basis. There are two types of reconciliation, which can be performed separately or simultaneously during the month, including: • Internal Reconciliation This is the process where the business and financial aid offices compare the monthly financial aid office roster of scheduled and actual disbursements in each office’s system to a monthly business office cash detail report that reflects funds drawn down and funds disbursed for the month. If discrepancies are found, the school must document and resolve them in a timely manner. • External Reconciliation The school compares its reconciled internal records to the ED’s records of funds received and returned, and loans originated and disbursed to students at the school. At a minimum, this reconciliation must be completed at least monthly to ensure that data is correct in all systems and that cash management and disbursement reporting timelines are being met. If you have completed the internal reconciliation first, the school will have fewer discrepancies to resolve when you perform this external reconciliation. ED offers various tools to assist you with external reconciliation. Direct Loan Program Reconciliation Questions and Answers Attachment to December 2020 Electronic Announcement Q4: Where can schools obtain the Department of Education’s (the Department’s) official Direct Loan Ending Cash Balance and other detailed information for use in required monthly reconciliation? A4: The Department provides a School Account Statement (SAS) to all schools on a monthly basis. The SAS is similar to a bank statement and provides the Department’s official Ending Cash Balance as of the end of the reported month, as well as detailed cash and loan or disbursement detail transactions for the reported period. The SAS is the school’s primary tool used in reconciliation and program year closeout and should be compared to both financial aid and business office records. Additional information on the content and formats available for the SAS is available in the COD Technical Reference, Volume VI, Section 8. Additional optional tools for assistance in reconciliation processes are addressed under Q9 below. However, the SAS must be used for required monthly reconciliation. Condition:The University was unable to provide SAS and did not use SAS for monthly reconciliations for any month during the year ended May 31, 2023. Questioned Costs: $0 Context: In accordance with the 2022 OMB Compliance Supplement, we attempted to obtain a sample of the SAS and ascertain that the reconciliations are being performed on a monthly basis. While the University provided evidence of internal reconciliations, the University was unable to provide any SAS and indicated that for the year ended May 31, 2023, the University did not utilize SAS for monthly reconciliations, as required. Total Student Financial Assistance Cluster expenditures for the year ended May 31, 2023, were $128,072,878, of which $111,793,842 was for Direct Loans. Effect: Lack of external monthly reconciliations between the University’s records and SAS could result in incorrect data in the University’s records and ED systems and cash management and disbursement reporting timelines not being met. Cause: The University did not have effective internal controls and procedures in place to ensure the use of SAS in monthly reconciliations. Identification as a repeat finding, if applicable: Not Applicable Recommendation: The University should review and revise its internal controls and procedures surrounding the monthly reconciliations to SAS and retain evidence of such reconciliations, including SAS. Views of responsible officials and planned corrective actions: Management agrees with the finding and has developed a plan to correct the finding.

Finding 2023‐004 Procurement and Suspension and Debarment Information on the federal program: Federal awarding agency: United States Department of Education (ED) Federal Program: COVID-19 – Education Stabilization Fund – Higher Education Emergency Relief Fund (HEERF), ALN 84.425F Award year: 2022‐2023 Criteria or specific requirement (including statutory, regulatory or other citation): 2 CFR 200.303 requires that a non-federal entity must (a) establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States and the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). 2 CFR 200.318 (i) General Procurement Standards states, “the non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include, but are not necessarily limited to, the following: Rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price.” 2 CFR 200.319 (e) Competition states, “the non-Federal entity must ensure that all prequalified lists of persons, firms, or products which are used in acquiring goods and services are current and include enough qualified sources to ensure maximum open and free competition. Also, the non-Federal entity must not preclude potential bidders from qualifying during the solicitation period.” Condition: EY selected and tested five procurements over $10,000 with expenditures totaling $726,538 from a population of 6 procurements over $10,000 with expenditures totaling $750,921 charged to the HEERF program during the year ended May 31, 2023. Of the five procurements tested: • For three procurements totaling $688,771, the procurements were made from a single vendor using noncompetitive procurement – sole source. A sole source justification memo was prepared; however, the memo did not address the history of the procurement and the reasons for lack of solicitation of other vendors in sufficient detail. We did not question these costs, since we did observe supporting documentation for the procurement; however, we did not consider the documentation to be sufficient, as noted above. • For one procurement for $27,567, the University did not obtain quotes or document sole justification or the history of the procurement, including the rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. We consider the expenditures related to this procurement to be questioned costs due to lack of supporting documentation for the procurement, as noted above. Effect: The University did not comply with the general procurement standards per the Uniform Guidance to maintain sufficient detail of the history of the procurement, including the rationale of the method of procurement. Cause: The University did not have effective internal controls and procedures in place to ensure the University maintained records for procurements sufficient to detail the history of procurement, including the rationale for the method of procurement and other required elements. Identification as a repeat finding, if applicable: Yes – 2022-002 Recommendation: The University should retain written documentation for procurements, documenting the history of the procurement prior to the procurement of goods or services including, but not limited to, the rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. Views of responsible officials and planned corrective actions: Management agrees with the finding and has developed a plan to correct the finding.

Finding 2023‐005 Equipment and Real Property Management Information on the federal program: Federal awarding agency: United States Department of Defense United States Department of Health and Human Services Federal Program: Research and Development Cluster Award year: 2022‐2023 Criteria or specific requirement (including statutory, regulatory or other citation): 2 CFR 200.303 requires that a non-federal entity must (a) establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States and the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).

2 CFR 200.1 Definitions. Equipment means tangible personal property (including information technology systems) having a useful life of more than one year and a per-unit acquisition cost which equals or exceeds the lesser of the capitalization level established by the non-Federal entity for financial statement purposes, or $5,000. 2 CFR 200.313 (d) Management requirements. 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: (1) Property records must be maintained that include a description of the property, a serial number or other identification number, the source of funding for the property (including the FAIN), who holds title, the acquisition date, and cost of the property, percentage of Federal participation in the project costs for the Federal award under which the property was acquired, the location, use and condition of the property, and any ultimate disposition data including the date of disposal and sale price of the property. (2) A physical inventory of the property must be taken and the results reconciled with the property records at least once every two years. (3) A control system must be developed to ensure adequate safeguards to prevent loss, damage, or theft of the property. Any loss, damage, or theft must be investigated. UIW FIXED ASSET POLICY, Version 1.0, Effective Date: June 1, 2016: Capitalization of Fixed Assets The University capitalizes the acquisition costs of fixed assets based on the following thresholds. Acquisition costs include the cost of the goods as well as freight and installation. Warranties and maintenance or services contracts related to fixed assets should not be capitalized. Acquisitions costing less than the amounts noted below are considered operating expenses reflective of the University’s business activities. Assets acquired under capital leases should also be capitalized. • Furniture and equipment with a unit cost of $10,000 or more

Equipment Purchased with Sponsored Project/Grant Funds Equipment purchased with sponsored project/grant funds must be placed on the fixed asset listing in accordance with this Fixed Asset Policy, and the project director and department that made the purchase are accountable for the equipment. For federally funded assets, an inventory listing of these assets is maintained by the Grants Accounting Office, and physical inventories of such assets are conducted in accordance with federal regulations. For federally funded assets with a unit cost under $10,000 but greater than or equal to $5,000, these assets are included on the inventory listing but are not capitalized or depreciated since they are below the University’s capitalization threshold. Condition: The University did not conduct a physical inventory of research and development federally funded equipment within the last two years. Additionally, the University's listing of federally funded equipment with a unit cost under $10,000 but greater than or equal to $5,000, was not cumulative from grant inception dates and did not include a serial number or other identifying number, and did not consistently include the location of the equipment and other required information. The University did not have effective internal controls to ensure that a physical inventory of equipment was taken and results reconciled with equipment records at least once every two years and that the listing of federally funded equipment included all required information. Questioned Costs: $0 Context: We obtained a listing of research and development federally funded equipment that had a net book value of $362,515 which included equipment with unit costs of $10,000 or greater, as it is the University’s policy to capitalize equipment with a unit cost of $10,000 or more. We subsequently obtained from the University’s Grants Accounting Office a listing of equipment purchased with grant funds, with unit costs under $10,000 but equal to or greater than $5,000, by year from 2020 through 2023, totaling $42,841 for research and development funded equipment, and we observed that this listing did not include all of the required information. Additionally, we observed that the University did not perform a physical inventory of the equipment within the last two years. Effect: Equipment records were not maintained for all equipment items with a unit cost of $5,000 or greater in accordance with federal requirements and a physical inventory of equipment which must be performed and the results reconciled with equipment records was not completed at least once every two years. This could potentially result in the equipment records not reconciling with the actual equipment present at the University or inappropriate reporting related to the federal equipment. Identification as a repeat finding, if applicable: Not Applicable Recommendation: The University should develop and implement effective internal controls to ensure equipment records are maintained for all equipment with a unit cost of $5,000 or greater in accordance with federal requirements and a physical inventory of equipment be performed and the results reconciled with equipment records at least once every two years. Views of responsible officials and planned corrective actions: Management agrees with the finding and has developed a plan to correct the finding.

Finding 2023‐006 Activities Allowed or Unallowed/Allowable Cost Principles Information on the federal program: Federal awarding agency: United States Department of Defense United States Department of Health and Human Services Federal Program: Research and Development Cluster (Basic, Applied, and Advanced Research in Science and Engineering, ALN 12.630; Biomedical Research and Research Training, ALN 93.859) Award year: 2022‐2023 Criteria or specific requirement (including statutory, regulatory or other citation): 2 CFR 200.303 requires that a non-federal entity must (a) establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States and the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: The University did not have effective internal controls in place to ensure fringe benefits were only charged to research and development grants when the corresponding salaries were also charged to the same grants. Questioned costs: $0 Context: We selected 25 payroll expenditures for testing totaling $73,098. We tested the corresponding fringe benefits for each of our selections. For 4 of 25 payroll expenditures tested, we observed that the University made journal entries, which the University labels “chargebacks,” to charge salaries and fringe benefits to the grants. For each of these 4 payroll expenditures, we observed that the “chargebacks” included fringe benefits charged to the grants in error since the corresponding salaries were not charged to the grants. The University’s total research and development expenditures were $1,086,662, of which $541,841 represented payroll expenditures, including $78,118 in fringe benefits, for the year ended May 31, 2023. “Chargeback” benefits for the year totaled $12,301. Effect: Fringe benefits categorized as “chargeback” benefits were charged to research and development grants in error and are unallowable costs. Cause: The University did not have effective internal controls in place over journal entry preparation to ensure fringe benefits categorized as “chargeback” benefits were not improperly charged to research and development grants. Identification as a repeat finding, if applicable: Not Applicable Recommendation: The University should develop and implement effective internal controls to ensure fringe benefits categorized as “chargeback” benefits are only charged to grants when the corresponding salaries were also charged to those same grants. Views of responsible officials and planned corrective actions: Management agrees with the finding and has developed a plan to correct the finding.

Finding 2023‐007 Reporting Information on the federal program: Federal awarding agency: United States Department of Education (ED) Federal Program: COVID-19 – Education Stabilization Fund – Higher Education Emergency Relief Fund (HEERF), ALN 84.425F Award year: 2022‐2023 Criteria or specific requirement (including statutory, regulatory or other citation): 2 CFR 200.303 requires that a non-federal entity must (a) establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States and the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Higher Education Emergency Relief Fund III Frequently Asked Questions (FAQs): 36. Question: What are the quarterly reporting requirements for HEERF III grants? Answer: Beginning with the second quarter 2022 quarterly report (due July 10, 2022) institutions must complete and post on their websites using a new combined institutional and student reporting form available here. This new form includes new reporting categories on mental health spending, HEERF (a)(2) construction flexibilities, and lost revenue and combines the separate institutional and student reporting requirements. As before, this form must be conspicuously posted on the institutions’ website no later than 10 days after the calendar quarter (January 10, April 10, July 10, and October 10) as long as the institution’s HEERF grant is active. Condition: The University did not submit quarterly reports for the institutional portion of HEERF grant by the required due dates for three of four quarterly reports submitted during the year. Questioned costs: $0 Context: The University submitted the quarterly reports for the institutional portion of HEERF grant during the year as follows: • Quarter Ended June 30, 2022, due by July 10 and submitted on July 11, 2022 (one day late). • Quarter Ended September 30, 2022, due by October 10 and submitted on October 3, 2022 (on time). • Quarter Ended December 30, 2022, due by January 10 and submitted on January 12, 2023 (two days late). • Quarter Ended March 31, 2023, due by April 10 and submitted on April 11, 2023 (one day late). The University’s total HEERF expenditures for institutional portion were $2,566,761, for the year ended May 31, 2023. Effect: The University did not comply with the timing of HEERF institutional portion quarterly reporting requirements. Cause: The University did not have effective internal controls in place to ensure quarterly reports were submitted by the required due dates. Identification as a repeat finding, if applicable: Not Applicable Recommendation: The University should develop and implement effective internal controls to ensure quarterly reports are submitted by the required due dates. Views of responsible officials and planned corrective actions: Management agrees with the finding and has developed a plan to correct the finding.

Finding 2023‐008 – Eligibility Information on the federal program: Federal awarding agency: United States Department of Education (ED) Federal Program: Student Financial Assistance Cluster: Federal Pell Grant Program, Assistance Listing No. 84.063 Federal Direct Student Loans, Assistance Listing No. 84.268 Award years: 2022‐2023 Criteria or specific requirement (including statutory, regulatory or other citation): Student Financial Assistance Programs, student eligibility requirements include the following:

8. Must maintain good standing, or satisfactory academic progress (34 CFRs 668.16, 668.32(f), 668.34, 690.75, 675.9, 676.9, 685.200, 686.11, 20 USC 1070h; 42 CFR 57.306; 42 USC 293a(d)(2)).

The University’s Satisfactory Academic Policy (SAP), Maximum Timeframe states, “the number of credit hours a student attempts may not exceed 150% of the number of hours required for graduation, as published in the university catalog. If the published number of hours required is 120, a student may not attempt more than 180 hours (120 x 1.50 = 180) and continue to receive financial aid. If the number of attempted hours reaches 150% of the hours required for graduation or it becomes mathematically impossible to complete degree requirements within 150%, the student will no longer be eligible for financial aid. Both calculations will be conducted upon each official SAP evaluation period. If it is deemed the student cannot graduate by 150% or has exceeded 150%, the student will be ineligible for Federal financial aid and will be required to submit the SAP Recovery Packet to be considered for aid. Attempted hours include all credit hours the student has transferred from another institution as well as all credit hours the student has registered to take at UIW, whether they earn a grade or not, receive credit, or receive financial aid.

LEVEL – MAXIMUM TIMEFRAME Undergraduate Pursuing a Bachelor’s Degree – Not to exceed 180 attempted credit hours Undergraduate who has a Bachelor’s Degree and is pursuing a 2nd Bachelor’s Degree – Not to exceed 240 attempted credit hours Undergraduate pursuing an Associate Degree – Not to exceed 100 attempted credit hours Undergraduate pursuing a 2nd Associate Degree – Not to exceed 130 attempted credit hours Undergraduate who has a Bachelor’s Degree and is pursuing an Associate Degree – Not to exceed 210 attempted credit hours Graduate Pursuing a Doctorate Degree – Not to exceed 67 attempted credit hours Pharmacy – Not to exceed 236 attempted credit hours Physical Therapy – Not to exceed 185 attempted hours School of Medicine (SOM) – See SOM student handbook If a student is exceeding the maximum timeframe due to being classified as 2nd degree seeking, the student will not need to appeal to receive financial aid if both the quantitative and qualitative measures are being met.” Questioned costs: $0 Context: The University configures the parameters for identifying students who comply and do not maintain Satisfactory Academic Progress (SAP). The University configured these SAP factors into a system application. One factor in determining SAP is that students graduate within the maximum timeframe allowed for their program which is measured in attempted hours. The University did not correctly configure its system to identify graduate students who exceeded their maximum timeframe to graduate per their program. Users with access to configure these factors were evaluated to be appropriate. Effect: If the system programming to identify graduate students who have exceeded their attempted hours is not designed properly, the graduate student may be eligible for financial aid even though they do not satisfy SAP. Cause: The University’s system application control over identifying the attempted hours that exceed the maximum timeframe for graduate students was incorrectly configured to identify the hours earned by the student, not attempted. Identification as a repeat finding, if applicable: Not Applicable Recommendation: The University should review the programming within the system to ensure it is accurate to identify graduate students who have exceeded their attempted hours. Views of responsible officials and planned corrective actions: Management agrees with the finding and has developed a plan to correct the finding.