Corrective Action Plans

State Agency: Department of Labor Single Audit Contact: Samantha Doran Title: Auditor 3 Telephone: 518-457-9475 E-mail Address: Samantha.Doran@labor.ny.gov Federal Program(s) (ALN # [s]): Unemployment Insurance (ALN 17.225) Audit Report Reference: 2022-005 Anticipated Completion Date: 12/1/2023 Corrective Action Planned: Corrective Action is in progress. NYSDOL is currently engaged in a multi-year project to update the Unemployment Insurance system. The modernized system will assist in future implementation of temporary federal programs and strengthen internal controls over the payment process.

State Agency: Department of Labor Single Audit Contact: Samantha Doran Title: Auditor 3 Telephone: 518-457-9475 E-mail Address: Samantha.Doran@labor.ny.gov Federal Program(s) (ALN # [s]): Unemployment Insurance (ALN 17.225) Audit Report Reference: 2022-004 Anticipated Completion Date: 12/1/2023 Corrective Action Planned: NYSDOL expects this issue will be resolved with the implementation of a modernized Unemployment Insurance System. The modernized system will include improved data marker capabilities for any future temporary benefit programs that need to be implemented; therefore, the BAM sample selection will only include appropriate cases. Additionally, the time lapse requirement will be improved in upcoming fiscal year as staff resources will not be diverted to pandemic efforts and work will be monitored to ensure that time lapse requirements are met.

Sacred Heart University Corrective Action Plan Year ended June 30, 2022 Finding 2022-001: Significant Deficiency and Noncompliance: Special Tests and Provisions ? Enrollment Reporting Corrective Action Planned Sacred Heart University has implemented a corrective action plan which involved collaboration with our enterprise resource provider, Ellucian, the Registrar?s Office, and the Department of Information Technology (IT). Sacred Heart University acknowledges that published program lengths reported on National Student Loan Data System (NSLDS) records did not conform with reporting requirements. The University?s ERP, Ellucian, provided instruction on updating the code for programs with ?years to complete,? which enabled the IT department to identify and correct existing active programs. To prevent future errors the Registrar?s Office can access the mnemonic (screen) to code new program records in ?years to complete.? Sacred Heart University processed and submitted the first two branches, 00 and 81, on 3/24/23, and Clearinghouse took steps to update the records. Sacred Heart University acknowledges incorrectly reporting the Graduated status effective date as the last day of classes instead of the last day of final exams at the NSLDS program level for two students sampled during our FY22 Federal Single audit. The University has amended its procedures to avoid potential errors causing nonconformities. The updated procedures will ensure the utilization of the last day of final exams as the Graduated status effective date at the program level and strengthen the review of the graduate file before submitting it to the Clearinghouse. Sacred Heart University acknowledges incorrectly reporting the student program begin date for one student sampled during our FY22 Federal Single audit. The University reported the student in the incorrect branch, discovered the error upon graduation, and moved the student to the correct branch. As a result of the branch correction, the University reported to the NSLDS the start date of the student?s last trimester instead of the actual program start date. The Registrar?s office, working with the Clearinghouse, is taking steps to correct the branch reporting which will fix the reported program start date for this particular student. The University is amending its procedures to prevent further noncompliance. The Registrar?s office is amending the report used to ensure students are selected and reported in the correct branches. The Registrar is also enhancing the report to include data identifying potential erroneous reporting before enrollment data is reported to the Clearinghouse. Contact Person(s) Responsible for Corrective Action Angela Pitcher, University Registrar Lori Jo McEwan, Senior Systems Analyst Anticipated Completion Date April 25, 2023

Finding 2022-013 Personnel Responsible for Corrective Action: Director of Financial Aid, James Green Anticipated Completion Date: June 2023 Corrective Action Plan: The Financial Aid staff will ensure systems are setup to prevent the over award of federal financial aid. The financial aid counselor will prepare and award the student. Upon completion, the financial aid counselor will submit the file to the Director of Financial Aid for the second review. The University Financial Aid officers will undergo a series of trainings and certifications through the National Association of Student Financial Aid Administrators to assist with understanding aggregate limits for federal student aid.

Finding 2022-006 Personnel Responsible for Corrective Action: Director of the TRIO Program ? Jasmine Lewis Anticipated Completion Date: June 2023 Corrective Action Plan: The University's TRIO Division has implemented a process across all three programs in which Educational Advisors provide brochures which outline eligibility requirements as well as the services offered to student participants. Educational Advisors also track services provided to program participants through participant sign-in. At the conclusion of each grant year, the Executive Director will solicit the services of a third-party to conduct an external review to ensure the program's compliance.

Finding 2022-005 Personnel Responsible for Corrective Action: Director of the TRIO Program ? Jasmine Lewis Anticipated Completion Date: June 2023 Corrective Action Plan: The University's TRIO Division has implemented a process which consists of the Educational Advisors for each program (Educational Talent Search, Upward Bound, and Student Support Services) creates a file which includes documents to determine student participant eligibility for their respective programs. Once the student participants complete all required forms from the checklist, the Educational Advisors then determine the students eligibility for the program. Once eligibility has been established the file is escalated to the Director of the respective programs for a 2nd review for accuracy. At the conclusion of each grant year, the Executive Director will solicit the services of a third-party to conduct an external review to ensure the program's compliance.

Holy Family University respectfully submits the following corrective action plan for the year ended June 30, 2022. Name and address of independent public accounting firm: Baker Tilly US, LLP 1650 Market Street, Suite 4500 Philadelphia, Pennsylvania 19103 Audit period: June 30, 2022 The findings from the June 30, 2022 schedule of findings and questioned costs are discussed below. Finding 2022-001: Special Tests and Provisions - Gramm-Leach Bliley Act (?GLBA?) 84.268 Federal Direct Loan Program; 84.063 Federal Pell Grant Program, 84.033 Federal Work Study Program, 84.007 Federal Supplemental Education Opportunity Grant; 84.038 Federal Perkins Loan Program Recommendation: The University should perform and document an annual risk assessment to determine the University's specific risks relevant to protecting consumer nonpublic personal information. At a minimum, the University should have at least one risk statement aligned or referenced to each of the three required areas noted in the GLBA law at 16 CFR 314.4 (b). Finally, the University should identify and document at least one safeguard (i.e., control) for each of the risks identified and document in the risk assessment. Each control should be aligned or referenced to the risk(s) to which the safeguard applies. Action Taken: The institution acknowledges and understands the requirements set forth by the Gramm-Leach-Bliley Act (GLBA) and is in the process of selecting a qualified individual for the partner role. Our team is actively developing a timeline to ensure full compliance with GLBA by June 9, 2023. In order to prioritize our efforts, we have identified areas of risk and implemented risk-based priorities to strengthen our network security, including firewalls, email access with Multi-Factor Authentication (MFA), applications, and policies/procedures. As part of our compliance efforts, our team will conduct a risk assessment to address three areas of concern, including 1. employee training and management 2. information systems (including network and software design 3. as well as information processing, storage, transmission, and disposal), and detecting, preventing and responding to attacks, intrusions, or other systems failures. We will document safeguards for identified risks by June 30, 2023. Name(s) of Contact Person(s) Responsible for Corrective Action: Mark Green, Associate Vice President Institutional Effectiveness, IT, and Innovation Anticipated Completion Date: June 9, 2023 If there are any questions regarding this corrective action plan please contact Eric Nelson, Vice President for Finance & Administration, at enelson@holyfamily.edu.

Federal Awards Finding 2022-007 - Emergency Rental Assistance Eligibility Corrective Action Plan: Please see responses to 2022-002, 2022-004, and 2022-005. Responsible Official: Devon Manning, Director of Policy & Planning and Brian Rossello, Director of Housing Finance Completion Date: August 2021

Federal Awards Finding 2022-006 - Emergency Rental Assistance Eligibility Corrective Action Plan: Please see responses to 2022-002, 2022-004, and 2022-005. Responsible Official: Devon Manning, Director of Policy & Planning and Brian Rossello, Director of Housing Finance Completion Date: August 2021 Financial Statement Finding 2022-002 - Internal Control Over Compliance - United States Emergency Rental Assistance Program Corrective Action Plan: DSHA has implemented a Corrective Action Plan which it believes fully addresses the internal control weaknesses identified in connection with the audit finding of a material weakness related to DSHA?s operation of the Emergency Rental Assistance (?ERA?) program. The Corrective Action Plan is comprised of three key elements: 1. Implementation of a new software system that fully addresses certain process issues encountered with its existing software application. 2. Implementation of new process workflows and approvals performed by DSHA personnel to ensure proper approval of case applications and payment of approved applications to proper vendors. 3. Engaging an external consultant to analyze, verify and remediate, as required, applications processed in the predecessor software system. Each of these three elements is further discussed below. In August 2021, DSHA implemented a new software application to accept and process applications for the ERA program and replace its existing application. DSHA implemented this system as a means to correct and resolve the issues it was experiencing with respect to timely and accurate payment processing. The new system included significant improvements in workflow related to payment processing and account verification, as well as other needed program features. With the new software application, one of the root causes of DSHA?s application payment issues was immediately addressed, by eliminating the need to manually upload vendor payment information from its predecessor application to DSHA?s accounting system for payment. The prior manual upload process resulted in various vendor payment issues and erroneous payments. The new software application is a completely self-contained application, with workflow approvals that span from application submittal and approval to vendor payment. Each week all approved applications are automatically batched and sent to DSHA for approval prior to payment. This workflow has resolved previous issues where payments were not made timely for approved applications. The new software application incorporates significant improvements to payment processing and account verification. As mentioned above, there is no need to transfer or upload data between new software application and the accounting system to effect payments of approved applications. The new software application includes a verification process whereby the vendor ACH information is verified by a ?penny test? or small deposit that the user must verify. ACH payments can only be made to accounts that are verified. Once payments are made through new software application, batch details are imported to the accounting software via a custom interface for accounting system transaction reporting. Implementation of New Process Workflows, Approvals and Verifications by DSHA Coupled with the new software application implementation, DSHA implemented updated ERA Program Guidelines and new internal policy and process manuals to ensure its internal controls and processes appropriately addressed the compliance requirements of the ERA program and to ensure properly approved applications are paid to proper vendors. All cases in Approved Status are batched each week by the new software application and sent to DSHA for approval. DSHA reviews each of the approved applications within the batch and approves the batch once verified. At that point, requested funds are wired and payments issued by the new software application. This process has resolved previous instances of non-payment of approved cases. DSHA has developed new Case Auditor and Case Supervisor Process Guides and Checklists, which now standardize the processes used to review, verify and approve applications prior to payment. The new software application case management workflow requires separate Case Auditor and Case Supervisor verification of program requirements and payments prior to approval and payment of an application. Remediation of Prior Case Applications Processed in the predecessor application DSHA has engaged a third-party external consultant to assist it in ensuring that the applications processed in the predecessor application system resulted in payments to appropriate vendors for proper, compliant applications. The objective of this assessment is to identify any applications processed within predecessor application that resulted in either over or under payment to the vendor recipient. Once identified, these over and/or under payments will be remediated. These action plans have been implemented beginning August 2021 for the 2022 Fiscal Year and will remain in effect going forward. Responsible Official: Marlena Gibson, Director of Policy and Planning. Responsible Official: Marlena Gibson, Director of Policy and Planning. Financial Statement Finding 2022-004 ? Internal Control Over Compliance ? United States Emergency Rental Assistance Program Corrective Action Plan: DSHA will take these recommendations under advisement, and review program policies and procedures to ensure they are in accordance with statutory requirements. DSHA will ensure that staff responsible for processing DEHAP applications are training effectively in how to interpret and apply program policies and procedures, and will clearly communicate the expectation that review staff adhere to program policies and procedures consistently. DSHA would like to request clarification on Belfint's interpretation of the statutory requirement around security deposits. To our knowledge, UST has suggested applying a limit of one month's rent as guidance, but has not made this an actual requirement of the federal Emergency Rental Assistance Program. Responsible Official: Marlena Gibson, Director of Policy and Planning.

COUNTY OF BERNALILLO CORRECTIVE ACTION PLAN YEAR ENDED JUNE 30, 2022 United States Department of Housing and Urban Development The County of Bernalillo respectfully submits the following corrective action plan for the year ended June 30, 2022. Audit period: July 1, 2021 ? June 30, 2022 The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. FINDINGS?FEDERAL AWARD PROGRAMS AUDITS UNITED STATES DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT 2022-002 Section 8 Housing Choice Vouchers ? Assistance Listing Number 14.871 Recommendation: The County continue to review internal processes and policies to better ensure compliance with HUD requirements for participant eligibility. Staff should be trained to better ensure consistency in program participant file documentation and compliance with documentation required by HUD. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: All program staff will attend a HUD approved HCV and rent calculation training to ensure compliance with all HUD regulations including EIV and rent calculations. In addition, staff will be trained on our internal checklist to ensure consistency of documentation retained in each client?s file. Name(s) of the contact person(s) responsible for corrective action: Betty Valdez, Housing Director Planned completion date for corrective action plan: June 2023 If the Department of Housing and Urban Development has questions regarding this plan, please call Betty Valdez, Housing Director, at 505-314-0235.

Finding 2022-006 Name of contact person: Lyn Saunders- IMC Supervisor II Corrective Action: Training to be provided to all caseworkers to include review of SSI Medicaid- County DSS Responsibility Policy Section MA-1100 during November 2022 monthly meeting and caseworker sign off sheet for timely review of SSI Termination. Proposed completion date: Ongoing ? Management will continue to monitor progress of SSI Termination Review process.

Finding 2022-005 Name of contact person: Melissa McDaniels ? IMC Supervisor III Corrective Action: "Training to be provided to all caseworkers to include TWN and OVS learning gateway webinars. Review of policy for exparte process and system reviews. Training to include retaining manual OLV hits. Including covering in detail the documentation template that is required to be completed for each case. Target 2nd parties will be complete at 2 per worker per week of cases processed within the month. Feedback shared with worker to ensure training was effective" Proposed completion date: Training will occur Nov. 2022, once the training is provided the additional 2nd parties of cases will begin and continue for 2 months into Jan 2023.

Finding 2022-004 Name of contact person: Melissa McDaniels ? IMC Supervisor III Corrective Action: "Training to be provided to cover IV-D Referral Policy and Process, this will include OVS ACTS review, review of policy to know when a referral is required to include if a client requests to be referred. A laminated desk reference will be provided at the time of training, this will have examples of when a referral is needed along with how to enter the referral within NCFAST. Update documentation template to ensure IV-D referral reason is documented within case notes as to why the referral was needed or not. This will be shared with staff at the training provided and guidelines presented as to how this is a required documentation addition. Medicaid Supervisor, Team Leads and Staff Development will complete target 2nd parties on 2 cases per worker per week that have been processed within the same month to ensure each worker is following the process of reviewing ACTs and submitting IV-D referrals when required. " Proposed completion date: Training will occur Nov. 2022, once the training is provided the additional 2nd parties of cases will begin and continue for 2 months into Jan 2023.

Finding 2022-003 Name of contact person: Lyn Saunders- IMC Supervisor II Corrective Action: "Training to be provided to all caseworkers to include AVS and OVS learning gateway webinars. Training will also include Financial Resources Policy and will be provided during Nov. 2022 monthly meeting for evidence entry on the dashboard. Accuracy check point will be completed by the caseworker by reviewing the case determinations to ensure correct tax value and liquid resource balance are entered and counted correctly prior to redetermination/application processing is completed. Second Party reviews will continue to be completed to monitor continued progress by caseworkers. " Proposed completion date: Ongoing ? Management will continue to monitor progress of inaccurate information entry.

Finding 2022-002 Name of contact person: Melissa McDaniels ? IMC Supervisor III, Lyn Saunders- IMC Supervisor II Corrective Action: "Training to be provided to all caseworkers to include TWN and OVS learning gateway webinars. Review of policy for exparte process and system reviews. Training to also include Income Policy, how to review for self-employment income and utilize the income wizard to enter weekly, bi-weekly and monthly income amounts so the system will calculate the income and leave less room for user error. Documentation of what income is being evaluated to also include why certain incomes are not counted. Training to include review of Household Composition, tax filing status and how to review the determinations of each case before completing/ releasing auto holds. Target 2nd parties will be complete at 2 per worker per week of cases processed within the month. Feedback shared with worker to ensure training was effective. Training to be provided to all caseworkers to include TWN and OVS learning gateway webinars. Training will also include Income Policy and updated Job Aids will be provided during Nov. 2022 monthly meeting for evidence entry on the dashboard. Accuracy check point will be completed by the caseworker by reviewing the case determinations to ensure correct income are entered and counted correctly prior to redetermination/application processing is completed. Second Party reviews will continue to be completed to monitor continued progress by caseworkers. " Proposed completion date: Training will occur Nov. 2022, once the training is provided the additional 2nd parties of cases will begin and continue for 2 months into Jan 2023. Management will continue to monitor progress of inaccurate information entry.

2022-004 Eligibility ? Assistance Listing No. 84.063 Recommendation: We recommend the College design controls to ensure an adequate review process is in place to ensure compliance with reporting requirements. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Policy and Procedures of reporting deadlines and requires has been put into action by the director of financial aid. Name(s) of the contact person(s) responsible for corrective action: Grant Pollard, Director of Financial Aid Planned completion date for corrective action plan: 11/1/2022

2022-009 Eligibility ? Assistance Listing No. 84.268 Recommendation: We recommend the College design controls to ensure an adequate review process is in place to ensure compliance with reporting requirements. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Policy and Procedures of reporting deadlines and requires has been put into action by the director of financial aid. Name(s) of the contact person(s) responsible for corrective action: Grant Pollard, Director of Financial Aid Planned completion date for corrective action plan: 11/1/2022

2022-003 Eligibility ? Assistance Listing No. 84.063, 84.268 Recommendation: We recommend the College provide additional resources to ensure all compliance requirements are met. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The director of financial aid reviews the funding estimate (award package) put together by the third party servicer and signs/e-signs it to document his review. Name(s) of the contact person(s) responsible for corrective action: Grant Pollard, Director of Financial Aid Planned completion date for corrective action plan: 11/1/2022

Finding 2022-003, Significant Deficiency - Eligibility Corrective Action Plan: Goal: To ensure necessary Medicaid corrections are made by caseworkers in a timely manner and verified as completed by Medicaid management and/or Quality Assurance staff. Plan: The County will include a due date to the auditing tool so that correction tasks request can be tracked and monitored for completion and accurateness. Eligibility errors will be given five business days to be completed by workers and Internal Controls will be completed in 10 business days as they may require streamlining or revamping of internal processes. Performance Improvement Strategies: 1. Training will be given to supervisors, lead workers, and QA staff on proper usage and monitoring of due date requirements added to the audit tool. 2. Copies of reports will be stored in the shared Teams Channel for Medicaid Services. Responsible Parties: Marissa D. Adams, Medicaid Services Division Director Timeframes: Training for the usage of an audit tool is to be held no later than June 30, 2023, and usage of to begin immediately after is completed.

Finding 2022-002, Material Weakness - Eligibility Corrective Action Plan: Goal: To ensure eligibility determination related to income documentation and calculation is completed appropriately for all applications by auditing a minimum of 5% of all applications completed monthly per employee and retaining electronic copies of the audits in One Drive. Plan: Designated Supervisors/Managers, Senior Income Maintenance Caseworkers, and Quality Assurance staff will be tasked with auditing cases using the state audit form. Performance Improvement Strategies: 1. Errors will be discussed individually with staff via monthly conferences with their supervisor or member of the supervisory team. 2. Copies of audit forms will be shared with staff which will identify trends, areas of improvement and progress. 3. In-service training will be developed based on common errors offered throughout the fiscal year and for all staff who are responsible for administering this program. 4. The QA/Training department will collaborate with Economic Services to develop a checklist to review approved applications that includes income documentation and calculation to ensure timely benefits to customers. Responsible Parties: Energy Programs Team and Customer Care Center Team management as well as the Quality Assurance Team will perform second party audits on 5% of all processed Low-Income Household Energy Assistance Program applications. Timeframes: Audits will be completed and retained on a monthly basis by IMC III (Lead Worker), and supervisor.

Finding No: 2022-001 Response: Agree Planned Corrective Action: An age waiver has been submitted to HUD and is currently being reviewed. We are awaiting their decision. While we await a decision, Meadow Lane will review all existing applications for eligibility and advise any existing applicants who are not of age that they are no longer eligible via mail. Anticipated Completion Date: Pending HUD approval of age waiver Contact Person: Christina Villanueva, CFO United Hebrew Geriatric Center

Finding #2022-002 ? Significant Deficiency Applicable federal programs: U. S. Department of Justice Assistance Listing #16.575 Passed through Office of the Governor, Criminal Justice Division Crime Victim Assistance Contract #: 3521203 Contract year: 10/01/21 ? 09/30/22 Crime Victim Assistance Contract #?s: 4219601 and 4219602 Contract years: 10/01/21 ? 09/30/22 and 10/01/22 ? 09/30/23 Recommendation: Provide additional staff training to ensure that HAWC?s internal control procedures that require review of client files are followed. Planned corrective action: Management will review and ensure compliance with policies and procedures regarding the review and approval of client files to ensure that reviews are completed. Responsible officer: Chief Quality Officer Estimated completion date: August 20, 2023

1. Finding 2022-001 a. Comments on the Finding and Each Recommendation We recommend that the Board of Directors continues to work with HUD to resolve the outstanding balance. b. Action(s) Taken or Planned on the Finding The Board of Directors has continued to work with HUD to resolve the outstanding balance. The last communication from HUD was on July 28, 2022 noting the issue is currently under review.

November 17, 2022 To: Chair of the Audit Committee From: Debra Martin, Vice President for Finance and Administration RE: Response to Baker Tilly Audit Communication ? Uniform Guidance Audit Findings Finding 2022-001: Significant Deficiency - Return of Title IV Fund Calculations Program: Student Financial Assistance Cluster Assistance Listing Number (ALN): Various Federal Agency: U.S. Department of Education Federal Award Identification Number: Various Federal Award Year: June 30, 2022 Criteria: 34 CFR 668.22 requires that when a recipient of Title IV grant or loan assistance withdraws from an institution during a payment period or period of enrollment in which the recipient began attendance, the institution must determine the amount of Title IV grant or loan assistance that the student earned as of the student's withdrawal date in accordance with Federal regulations and return the unearned portion of the grant or loan funds to the Title IV programs as soon as possible but no later than 45 days after the withdrawal date. Condition: Two students of five students tested had incorrect/missing calculations. One student was disqualified during the term after the first 8 week session in the Associate Degree of Nursing and could not continue into the second 8 week session. The University did not note the disqualification and withdrawal timely and did not perform an R2T4 calculation as required and the $2,473.53 of direct loans calculated by the auditor was not returned. One student's number of days attended (numerator) was calculated incorrectly at 25 days but should have been 26 days and therefore $59.53 too much Pell was returned. The auditors noted that a total of four students withdrew from the Associate Degree of Nursing program from the population file provided, and two students were not selected by the auditors. The University reviewed these students and noted one student completed more than 60.01% although the auditors learned that the student was disqualified at the end of the first 8 week session and therefore should have had an R2T4 calculation and return, and one student the R2T4 calculation was performed, however the auditor noted the number of days attended (numerator) was calculated incorrectly at 51 days but should have been 52 days and included a negative amount of Pell grant that ?could have been disbursed?. The University noted that an estimated term end date of May 7, 2022 was input in the system and was not updated to the actual term end date of May 6, 2022. As this could impact all students who withdrew during the Spring 2022 term, the auditors noted 21 students in the population file provided who withdrew during spring 2022, and four of those students were noted as withdrawing before 60% and were not tested by the auditors. The University reviewed these students and noted two additional students with incorrect denominators used in their calculations, the auditor reviewed only the denominators for these students and agrees. The sample was not a statistically valid sample. Cause: The University?s controls surrounding completing timely and accurate refund calculations did not operate as designed and resulted in exceptions. Effect: The calculations of funds to be returned to the Department of Education did not occur or were incorrect. Questioned costs: Questioned costs of $2,301.70 (ALN No. 84.268), and $59.53 (ALN No. 84.063) were noted during testing. Context: Exceptions were noted for 2 of the 5 students selected for testing. There were a total of 33 students who withdrew during fiscal year 2022 that received Title IV aid. Recommendation: It is recommended that University personnel review the calculations generated by the University's software system to ensure they are timely and accurate. It is also recommended that the control structure be reviewed to ensure all student who withdraw during a term are identified in a timely manner. Management?s Response: The University will review withdrawal controls and procedures so that students who withdraw are identified and correctly processed in a timely manner. The University will also engage our software system Consultant to examine system settings to ensure accurate and timely Return of Title IV calculations occur. Further, management reviewed and performed the same recalculations for the remaining 28 students in the population. Of those, 24 had no findings or errors and the remaining only had a small amount of excess available Pell funding or loan eligibility. The Pell amounts were awarded and students with loan availability were notified and asked to respond if they wished to borrow the additional funds. All amounts were not material. Correction Action: The Registrar?s Office will provide the Financial Aid Office with final academic calendars in advance to ensure that proper start and end dates of academic periods are correct in the Financial Aid System. Multiple employees (as opposed to a single person) in the Financial Aid office will be tasked with confirming the accuracy of the calendar set-up in advance of the start of each semester. We have also reminded the Nursing department of timely communication of student disqualifications to the Registrar?s office to assist in recognizing students who may fall into this category. In addition to these steps, the University is exploring systematic changes in colleague that will split the ADN and ABSN programs into two separate 8 week sessions with separate start/end dates, as opposed to one 16 week semester that has two sessions within. An RT24 output report will now be automatically generated and reviewed by the Director of Financial Aid every two weeks. Furthermore, the University will apply the same refund calculation policy to ADN students who are academically disqualified, as we do all other student populations. This will ensure accuracy when determining the number days attended and earned amounts of federal aid when processing R2T4 calculations. The University will dedicate additional resources, staff and technology, to manage withdrawal notifications and to process then in a timely manner.

2022-001 - Non-compliance Specific steps to be taken to correct the situation (including a timetable for performance of the CAP) or reason why corrective action is not necessary (including disagreement with the finding): NTMA has recently adopted a new student financial management system that will assist in determining correct calculated awards and is a State of the art financial aid packing system. We are retiring Transcripts, a very antiquated system that was not set up to provide the error free outcomes required. Jenzabar Financial Aid, our new SMS, enacts group processing and direct data imports from the DoE, manages funds to and from the COD system. Flexibility to award using federal and institutional methodologies, automates COA calculations etc.. Jenzabar is a Financial Aid System built by financial aid people. It was set up in manner that is meant to be more compliant and more robust streamline process. It has automated the entire financial aid process. In addition, we are also considering the use of a servicer and requiring financial aid staff to take an additional continuing education and they will be attending virtual workshops that the DoE offers each year.