Corrective Action Plans

2024-002: Missing Exit Counseling Documentation - Student Financial Aid Cluster - Assistance Listing #s 84.007, 84.033, 84.063, 84.268 - Grant Period - Year Ended June 30, 2024 Condition Found During our student file testing, we noted two students out of 40 did not have documentation in their file that exit counseling was sent thirty days after the student withdrew. We consider the missing exit counseling to be an instance of non-compliance with the Eligibility Compliance Requirement. Corrective Action Plan We have updated our Loan Procedures to include running an internal report on all loan students on the 1st and 15th of every month, or the next work day following those dates if they land on a day the campus is closed. If a student with loans has withdrawn completely and stopped attending, we will send an exit letter within 7 business days of discovering that the student has ceased attending. Responsible Person for Corrective Action Plan Isamar Taylor - Director of Financial Aid and Jill Wohrley - Financial Aid Reconciliation and Compliance Specialist Implementation Date of Corrective Action Plan 10/16/2024

For ALN 93.959, a Financial Assessment Form was not properly signed for 1 of the 60 clients tested. Additionally, 2 of the 60 clients tested had service dates that did not fall within one year of the Financial Assessment Form completion date. Obtaining a client's signature on the form has been challenging, particularly during recent years as use of telehealth services has expanded. As a corrective action, team members will be trained in how to properly document receipt of verbal approval. Our internal tracking of completion of the Financial Assessment Form at admission indicates that compliance with this requirement occurs about 89% of the time. As a corrective action plan, SMA will include the completion of the Financial Assessment Form both at admission and annually to be reviewed monthly by the programs. In addition, an action plan will be required to be present at the quarterly Quality Assurance Committee meeting if not at 100%.

For ALN 93.958, the discount fee that was shown on their Financial Assessment Form was not used for 7 of the 60 clients tested. Additionally, 8 of the 60 clients tested had service dates that did not fall within one year of the Financial Assessment Form. Our internal tracking of completion of the Financial Assessment Form at admission indicates that compliance with this requirement occurs about 89% of the time. As acorrective action, the Client Service Specialist will be trained to ensure data is entered accurately. SMA will also include the completion of the Financial Assessment Form both at admission and annually to be reviewed monthly by the programs. In addition, an action plan will be required to be present at the quarterly Quality Assurance Committee meeting if not at 100%.

2024-001 - Nonmaterial Noncompliance - Eligibility Program: Child Nutrition Cluster (ALN 10.553 and 10.555) - United States Department of Agriculture; Federal Award Year: 2024 Responsible Officials: John Wack, Chief Financial Officer, Henrico County Public Schools Planned Corrective Action: School Nutrition Services Leadership has put a new process in place, to run a report from the point-of-sale system weekly, that will catch any "Manual" updates to lunch statuses. This report will be run weekly and verified by either the Dietitian or Controller. The report will be initialized and kept on file. Expected Completion Date: 12/31/24

Corrective Action Plan: The District established written procedures to ensure that we are using current eligibility verification through our Skyward Food Service Program. Anticipated Corrective Action Plan Completion Date: June 27, 2024 Contact Information: For additional information regarding this finding please contact Bill Trewyn, Business Manager, at 262-741-9143.

Finding 2024-001 – Tenant Files Auditee’s Response and Planned Corrective Action HHA will take measures establish and utilize a check list as an internal control to be used by Housing Assistants to use during the recertification process to ensure all compliance requirements are met. The checklist will be signed or initialed by the Housing Assistant, reviewed and signed by a member of management, and maintained in the tenants file. This checklist will serve as documentation that all compliance requirements are met. Planned Implementation Date of Corrective Action: December 5, 2023 Person Responsible for Corrective Action: Shereen Goodson, Executive Director Village of Hempstead Housing Authority Shereen Goodson, Executive Director

To Whom It May Concern, Please accept this letter as a formal Corrective Action Plan for the district regarding the audit finding 2024-003, as listed in the FY 2024 Audit. During the 2024-2025 school year either a free and reduced application was misplaced/lost or the district incorrectly qualified the household children of a foster residence to be automatically qualified for free meals as is done with homeless households. Regardless, the district will take the following corrective actions to address the issue in the future: 1. The district has already begun using an electronic lunch application process through the new Student Information System, which should address the issue moving forward. This started with enrollment in the Fall of 2024. AND 2. The superintendent will review the qualification requirements with all staff members that are involved with the free and reduced lunch application process, as well as the district foster care liaison. The person responsible to provide this training will be the superintendent and the training will be completed by December 21, 2024. Sincerely, John French Superintendent of Schools Lewis County C-1 School District

Disbursements to Ineligible Students Planned Corrective Action: The new SIS has been additional filters added that will have two data points to confirm student enrollment before processing disbursements. New packaging and disbursement rules are being added to ensure that this data is captured earlier in the disbursement process. This will be used when packaging for 2025-2026 academic year. Person Responsible for Corrective Action Plan: Stephanie Castillo, Director of Financial Aid Anticipated Date of Completion: Fall 2025

Incorrect Enrollment Reporting to National Student Loan Data System (NSLDS) Planned Corrective Action: ABU started working on partnering with the National Clearing House in the fall 2023 for NSLDS reporting. Due to a system conversion at the time this process took longer than anticipated. However, the first error free report was uploaded 09/01/2024. ABU now has a schedule with set reminders from the clearinghouse to ensure timely and regular reporting. Person Responsible for Corrective Action Plan: Stephanie Castillo, Director of Financial Aid Anticipated Date of Completion: Fall 2024

Internal Control over Compliance and Other Matters Recommendation: The organization should design and implement controls to ensure an adequate review process is in place to review compliance with LSC Regulation 45 C.R.F. Part 1611 Eligibility as it relates to obtaining and maintaining signed retainer agreements and eligibility forms for cases requiring such documentation. There is no disagreement with the audit finding. Action taken in response to finding: NNJLS created a Case File Checklist Form and implemented a procedure in which all supervising attorneys must complete the form weekly by reviewing cases to ensure that required signed retainer agreements and eligibility documentation are obtained by the client and uploaded to the case management system. The supervising attorney must report their findings of the review weekly to the Executive Director, obtain any necessary signatures and/or documents, and upload the Case File Checklist Form and documents to the case management system. The supervising attorneys receive a weekly-generated report of cases from the case management system. Name of the contact person responsible for corrective action: Leah Ashe, Executive Director Planned completion date for corrective action plan: As of September 30, 2024, this procedure became effective for all supervising attorneys and will remain in effect with no anticipated expiration.

Planned Corrective Action: DHNP will create a checklist for all staff, to ensure all documents are maintained in the file. DHNP has an effective Quality Control review process that was implemented February 2024. The audit findings were based on files completed in FY 23/24. All files go through the QC process and if errors are found, they must be corrected before payments are approved to be released. Anticipated Completion Date: March 31, 2025 Responsible Contact Person: Ruth Hill, Director

2024-003 – Student Financial Assistance Cluster – (a) Federal Supplemental Educational Opportunity Grants (b) Federal Work-Study Program (c) Federal Perkins Loan (d) Federal Pell Grant Program (e) Federal Direct Student Loans (f) Teacher Education Assistance for College and Higher Education Grants (TEACH Grants) (a) 84.007 (b) 84.033 (c) 84.038 (d) 84.063 (e) 84.268 (f) 84.379 – Year Ended June 30, 2024 Criteria: 34 CFR 685.203 states, "A first (second) (third) year student can receive up to $3,500 ($4,500) ($5,500) in subsidized loans in one academic year (34 CFR 685.203).” Condition: We tested 40 files, 37 of which were Federal Direct Loan recipients, and 1 student did not receive the full amount of her Federal Direct Subsidized Loans. Questioned Costs: $1,375 Cause and Effect: The result is a student received unsubsidized loans prior to receiving full subsidized loans. Recommendation: We recommend the College evaluate policies and procedures to ensure students receive the proper amount of Title IV aid. Views of Responsible Officials: Management agrees with this Single Audit Finding. All members of the Financial Aid Office staff will complete the loan learning track on the FSA training site. There will also be a refresher on steps to take prior to awarding a student to ensure the right credit hours are being used for Direct Loan recipients.

Recommendation: The College should update its procedures and related calculations to factor in the current semester enrollment status when a student is close to the Lifetime Eligibility Usage max in order to ensure proper disbursement amounts. Action Taken: The Financial Aid office at SCC is in the process of developing a comprehensive policy and set of procedures that will provide detailed, step-by-step instructions for managing cases involving students who are approaching or have reached their Pell Lifetime Eligibility Used (LEU). The identified error has been thoroughly reviewed with the relevant employee. We expect the updated policy and procedures to be in place by March 2025. Upon completion and approval of the policy and procedures, the office will conduct in-house training to ensure all staff members are well-informed and equipped to implement these guidelines effectively.

Recommendation: We recommend that the organization review the changes in income limits published by HUD during the tenant certification and recertification process to update form HUD-50059 income limits accordingly. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Management to update income limits in Onesite to reflect HUD income limits applicable as of the tenant’s application date. Name(s) of the contact person(s) responsible for corrective action: Brad Hughes Planned completion date for corrective action plan: 09/30/24

Recommendation: We recommend that the organization review the changes in income limits published by HUD during the tenant certification and recertification process to update form HUD-50059 income limits accordingly. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Management to update income limits in Onesite to reflect HUD income limits applicable as of the tenant’s application date. Name(s) of the contact person(s) responsible for corrective action: Brad Hughes Planned completion date for corrective action plan: 09/30/24 2024

Recommendation: We recommend that the organization review the changes in income limits published by HUD during the tenant certification and recertification process to update form HUD-50059 income limits accordingly. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Management to update income limits in Onesite to reflect HUD income limits applicable as of the tenant’s application date. Name(s) of the contact person(s) responsible for corrective action: Brad Hughes Planned completion date for corrective action plan: 09/30/24

Recommendation: We recommend that the organization review the changes in income limits published by HUD during the tenant certification and recertification process to update form HUD-50059 income limits accordingly. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Management to update income limits in Onesite to reflect HUD income limits applicable as of the tenant’s application date. Name(s) of the contact person(s) responsible for corrective action: Brad Hughes Planned completion date for corrective action plan: 09/30/24

The District is reviewing its policy and procedures to explore various options for enhancements to our current enrollment management business practices. The District is currently working on building targeted, automated email messages that would go out before and after the grade deadline to reduce the number of RD grades. The District has contracted with consulting services to further evaluate our financial aid policies and procedures, enhance our system reports and provide best practices to ensure compliancy in accurate withdrawal calculations.

2024-001 Eligibility – Tenant Files Section 8 Housing Choice Vouchers Program – CFDA Number 14.871 Mainstream – Vouchers CFDA Number 14.879 Material Weakness in Internal Control and Material Noncompliance This is a repeat finding (the prior year finding was a significant deficiency) of 2023-002 from March 31, 2023 (initially occurred as Finding 2021-003, Significant Deficiency) Condition: Out of a total tenant population of approximately 1,775 tenants, 25 files were selected for testing. Exceptions were noted as follows: • 1 tenant file had the following errors: o Miscalculation of social security income reported on the form 50058 (used a prior year SSI instead of the current year). Correcting this error would decrease the HAP rent from $1,610 to $1,567. o One missing 214-affidavit form for a member of the household. However, based on the birth certificate, the member of the household is a U.S. citizen. • 1 tenant file had the following errors: o Two members of the household did not check the checkbox on the 214-affidavit form indicating their immigration status. However, based on the birth certificates, the two household members are U.S. citizens. o The 9886 form was not dated. Thus, we do not know if the 9886 form was signed within 15 month required timeframe. • 1 tenant file had the following errors: o Missing 214-affidavit form for a member of the household. However, based on the birth certificate, the member of the household is a U.S. citizen. o The tenant did not sign and date the Form 9886. • 1 tenant file had the following errors and correcting the errors would increase the HAP rent from $1,130 to $1,159: o Miscalculation of social security income reported on the 50058. o Miscalculation of medical expense reported on the 50058. • 1 tenant file error where a member of the household over the age of 18 did not sign the Form 9886. • 1 tenant file error where social security income was calculated incorrectly. Correcting the income would decrease the HAP rent from $1,155 to $1,153. • 1 tenant file error where a member of the household over the age of 18 did not sign the 9886. • 1 tenant file error where the tenant dated the year on the 9886 form 2013 when it should be 2023. • 1 tenant file error where a member of the household over 18 years old did not sign Form 9886. • 1 tenant file error where the tenant’s wage income was miscalculated. However, correcting the error would have no effect on the HAP rent amount. • 1 tenant file error where there was no EIV form for the recertification period. • 1 tenant file error where tenant wage income was calculated incorrectly. Correcting these income issues would decrease the HAP rent from $1,207 to $896. • 1 tenant file had the following errors and correcting the errors would decrease the HAP rent from $1,378 to $1,030: o An incorrect utility allowance was reported on the Form 50058. o Income support was not reported correctly on the Form 50058. • 1 tenant file had the following errors: o A member of the household did not check the checkbox on the 214-affidavit form indicating their immigration status. However, based on the birth certificate, the household member is a U.S. citizen. o Support for tenant’s pension income was over 12 months old. • 1 tenant file error where child support income was calculated incorrectly. However, correcting the error would have no effect on the HAP rent amount. Recommendation: The Authority should correct the deficiencies noted in the tested files and utilize an ongoing quality control review process on the entire tenant population to ensure proper compliance with the requirements related to tenant eligibility. Ongoing staff training and timely management reviews should be utilized to ensure staff is aware of acceptable procedures. In addition, the Authority should review staffing levels, skill sets and case load. Action Taken: We concur with the recommendation. Due to the COVID-19 pandemic and related staff absences and turnover, we were unable to provide an ongoing quality control review processes and provide ongoing staff training and timely management reviews. We are focused on implementing such procedures and will review staffing levels, skill sets, and case load for each employee.1 tenant file error where the Form 50058 reported an incorrect utility allowance, but correcting the allowance would not change the HAP rent amount.

Finding 2024-001 Eligibility Management agrees with the summarized findings. Management has reviewed the current policies and procedures to ensure that the steps to be performed are clearly stated for the underwriting and disbursement staff. Management has discussed the findings with staff members and will provide additional training as deemed necessary.

U.S. Department of Agriculture Pass-through Entity: North Carolina Department of Health and Human Services Program Name: Special Supplemental Nutrition Program for Women, Infants, and Children Federal Assistance Listing Number 10.557 Material Weakness – Eligibility Finding 2024-003 Criteria: Per Section 200.303 of the Uniform Grant Guidance, a non-federal entity must 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. Condition: For the WIC program, we were unable to obtain evidence to corroborate the review of the Senior Quality Training Specialist eligibility determinations. Questioned Costs: None Effect: By not having the required documentation to support the review by the Senior Quality Training Specialist, the County is unable to support their assertion the cases are properly reviewed by an individual other than the preparer. Cause: County does not have a formal policy for documenting evidence of the review by the Senior Quality Training Specialist. Recommendation: We recommend the County implement a policy to ensure the review by the Senior Quality Training Specialist is properly documented and retained. Views of Responsible Officials: Management agrees with the finding and is implementing procedures to correct this which is further discussed in the Corrective Action Plan. Corrective Action Plan: See below Corrective Action Plan prepared by the County. Program leadership will collaborate The Total Quality Team i.e. Compliance Coordinator and Quality Assurance Coordinator to revise current internal monitoring policies and procedures. Internal monitoring tools will be created to align with state and federal guidelines. Following review with Total Quality, staff will be trained on revised monitoring processes, policy, and procedures. WIC Policy A-19 mandates the use of the State Agency's WIC program monitoring tool for conducting record audits. To ensure proper implementation, this policy will be reviewed with the Senior Quality and Training Specialist. The WIC Senior Quality Training Specialist and WIC leadership will maintain audit documentation in accordance with Policy A-13, Retention of Administrative Documents, established by Mecklenburg County Health Department. The following the phases of the corrective action plan will be completed by March 31st, 2025. Phase1: Review of Federal Guidelines Phase 2: Review Of State Guidelines Phase 3: Internal Policy Review Phase 4: Creation and Implementation of new internal monitoring processes. Phase 5: Staff Training Completion Date: March 31, 2025 Responsible Person(s): WIC Director, Ali Raza and Senior Quality and Training Specialist, Tamika Moore

U.S. Department of Health and Human Services Pass-through Entity: North Carolina Department of Health and Human Services Program Name: Medical Assistance Federal Assistance Listing Number: 93.778 Material Weakness and Nonmaterial Noncompliance – Eligibility Finding 2024-001 – Repeat Finding Criteria or Specific Requirement: Per Section 200.303 of the Uniform Grant Guidance, a nonfederal entity must 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. The County should have adequate documentation for each participant that supports each eligibility determination and the information entered into NCFAST. We noted several errors related to the following compliance criteria: a) Self-attestation wages should be compared to information in NC FAST. b) All countable resources should be confirmed and recalculated and ensure they are computed accurately in NC FAST. c) An OVS inquiry must be completed and agreed to information reported in NC FAST. d) An ex parte review is required every six (6) to twelve (12) months. e) Forced eligibility cases should maintain the proper documentation within NC FAST to support the determination for the required forced eligibility. f) For Aged, Blind, or Disabled cases or MQB programs the Register of Deeds is required to be verified and documented in the case file g) The caseworker should prepare and submit a DMA-5097 form in the case of incompatible income verification and self-attestation income as described in the Eligibility Review Document. h) For countable earned and unearned income, income conversion and computation was done in accordance with policy manuals, and have to agree to amounts in NC FAST. Condition: The following are the results of nonmaterial noncompliance noted for each criteria listed above out of the 122 program participants selected for testing: a) There were four instances where the participants self-attest wages did not agree to the wages entered into NC FAST. b) There were three instances where the countable resources were inaccurate within NC FAST. c) There was one instance where the OVS query was not run at the time of the determination. d) There were two instances where the ex parte review was not completed timely. e)There were two instances where the support for the forced eligibility was not properly maintained in NC FAST. f) There was one instance where the Register of Deeds support was not maintained in NC FAST. g) There were five instances where the income was incompatible between the income verification and self-attestation income but no DMA-5097 was sent. h) There were two instances where countable income was not properly included in NC FAST. Lastly, there were 6 instances out of 60 program participants tested for control testing where the County did not remediate the errors identified within their internal review timely. Context: There were 14 out of 124 unique participants tested with the errors noted above. Questioned Costs: None noted. Effect: By not having the required documentation in the files or information being incorrectly documented, eligibility cannot be readily substantiated and there is a risk the County could provide funding to individuals who are not eligible. Cause: County oversight when performing reviews over applications. Additionally, the County does not have a formal process in place to ensure issues identified during the review process are appropriately corrected on a consistent and timely basis. Recommendation: Although these issues will occur from time to time considering the volume of case files, the County should review their processes to ensure proper supporting documentation of eligibility is maintained within each case file. Additionally, Mecklenburg County should consider implementing a formal policy for the requirements of having documentation corrected within a specific timeframe once identified. Views of Responsible Officials: Management agrees with the finding and is implementing procedures to correct this which is further discussed in the Corrective Action Plan. Corrective Action Plan: The County will take a multi-faceted approach to mitigating such errors in the future. Training: The Staff Development Unit within the Economic Services Division (ESD) will review the findings and create and deliver training to staff that determine Medicaid eligibility and their supervisors and managers to address the specific errors identified. This training will be delivered by the end of January 2025. Responsible Individual(s): Staphon Snelling, Training and Development Manager Anticipated Completion Date: January 31, 2025 Process Improvement: The Economic Services Division (ESD) has trained new hires in one function of the Medicaid program, for example, processing applications or recertifications/changes. This has built a stronger foundation before they learn the second function of their assigned program. Our Supervisors and Quality and Training Specialists are working even more closely together to follow up on errors and help ensure identified challenges in training and mentoring are addressed before they are released from mentoring. Ex parte reviews are directly assigned for Family and Children’s Medicaid and for Adult Medicaid, renewals are placed into Current for workers to get next and work as soon as possible. Family and Children’s Medicaid will provide second-function training for current employees on recertifications. Adult Medicaid has 10 currently in mentoring for recertifications. Kim Konior is responsible for monitoring ex-parte review reports and MAGI cases are being assigned out by Supervisor Collin Smith and Jannicia Austin for Adult Medicaid. Each month the Medicaid managers Kim Konior and Lynn Martin review the progress and update the Assistant Division Director on the current status and plans to continually improve in this area. Supervisors will ensure that second party reviews are reviewed and corrected for any internal control and eligibility errors within 5 business days of receipt. Supervisors ensure that updates to the quality sampling tracking log are completed by the 20th day of the following month. Responsible Individual(s): Kim Konior and Lynn Martin Medicaid Program Managers and Staphon Snelling, Training and Development Manager Anticipated Completion Date: Will begin Family and Children’s Medicaid recertification training in third Quarter of FY25 (Jan 2025) and end by the end of 2nd quarter of FY 2025 (December 2025). Quality Sampling and Accountability: The Quality and Training Unit complete monthly quality sampling for Medicaid. Error trends are shared with the managers and their supervisors, who work collaboratively with Quality and Training staff to coordinate appropriate strategies to train and coach staff to mitigate errors moving forward. Supervisors review specific quality sampling results with their staff. The supervisor when necessary and appropriate, address continued errors using an individual Corrective Action Plan with the worker to include refresher training, additional second party review and/or initiating the formal documentation process. Managers review quality sampling results with supervisors quarterly to follow up on errors addressed, trainings completed and progress with individual Corrective Action Plans. Supervisors, front line, and Managers have quality measure on their workplan to ensure timely response and accountability is held. All levels are to achieve an average quality score of 80% quarterly. Note that this error was found at a much higher rate last year. We are continuing to reinforce this importance and expect the improvement that we have achieved within one year will continue to grow as we keep reinforcing quality into our everyday work culture. Protocol for second party reviews provided 08/2024 in place for ESD. Cases will be checked by Quality and Training by the last day of each business month. Quality and Training will check and provide feedback to workers within 2 business days of the case being checked. Corrections of errors and rebuttals for QS errors should be submitted within 5 business days of feedback being provided and a response will be received within 3 business days of receipt. The Quality Assurance team in OSI/CFAS conduct an independent evaluation and review the second party review process at the divisional level to ensure review was accurate and errors were corrected timely. This team reports out to ESD Leadership quarterly on findings. Responsible Individual(s): Kim Konior and Lynn Martin, Medicaid Program Managers & Julio Rosales, Quality Assurance Supervisor, Staphon Snelling Training and Development Manager Anticipated Completion Date: Currently Ongoing

Finding – Special Tests and Provisions: Enrollment Reporting – Federal Direct Student Loan Program, Assistance Listing Number 84.268; June 30, 2024 Award Year; U.S. Department of Education Criteria or Specific Requirement Enrollment information, including the effective date of separation from the institution, must be accurately reported within 30 days whenever attendance changes for a student, unless a roster will be submitted within 60 days. The changes include reductions or increases in attendance levels, withdrawals, graduations, and approved leaves-of absence. It is the institution’s responsibility, as a participant in the Title IV aid programs, to monitor and report these changes to the National Student Loan Data System (“NSLDS”). (NSLDS Enrollment Reporting Guide November 2022 and 34 CFR 682.610) Condition Found Of the 15 students selected for enrollment reporting testing, one student within the sample was reported to NSLDS outside the maximum 60-day window. This was not a statistically valid sample. Upon further inquiry, there were an additional 7 students included in the same batch reported to NSLDS that were not reported timely. Views of Responsible Officials and Planned Corrective Actions The School concurs with the finding. The School intends to report student status changes at year end. Names of Contact Person Responsible for Corrective Action: Andy Vidal, Chief Financial Officer, and Daniel Miller, Director on Financial Aid Anticipated Completion Date: December 31, 2024 Summary Schedule of Prior Audit Findings None

We acknowledge and accept the findings presented above. The District will immedicately implement an additional detailed review by Denise Zapata, District Accountant, of the support worksheets and calculators for future maintenance of effort submissions, beginning with the compliance calculator that is due March 31, 2025. Per guidance received from the State, the District will correct the 2022-23 compliance information on the compliance calculator that is due March.

Disbursements to Ineligible Students Planned Corrective Action: The new SIS has been additional filters added that will have two data points to confirm student enrollment before processing disbursements. New packaging and disbursement rules are being added to ensure that this data is captured earlier in the disbursement process. This will be used when packaging for 2025-2026 academic year. Person Responsible for Corrective Action Plan: Stephanie Castillo, Director of Financial Aid Anticipated Date of Completion: Fall 2025