Corrective Action Plans

Finding ref number: 2022-001 Finding caption: The District did not have adequate internal controls for ensuring compliance with allowable activities and costs, procurement, and restricted purpose requirements. Name, address, and telephone of School District contact person: Stefanie Lowry, 1620 S. Pioneer Way, Moses Lake, WA 98837. (509) 766-2650 Corrective action the auditee plans to take in response to the finding: The District acknowledges the recommendations from the State Auditor?s Office. In good faith, the District followed guidance from the FCC and its e-rate consultant in administering the ECF grant. This grant was unique in that the FCC paid the vendor directly for the hotspots, and it did not run through the Business Office as part of the typical procurement process. The District is committed to improving processes to ensure full compliance with grant requirements in the future. We are working on developing a grant approval form that must be filled out and submitted to the Business Office so that all requirements can be fully vetted before funds are accepted. In addition, we will be providing training and guidance to department heads to ensure they understand procurement requirements. Anticipated date to complete the corrective action: November 2023

FY 2022 Corrective Action Plan Audit Firm: RSM US LLP 30 South Wacker Drive, Suite 3300 Chicago, IL 60606 Audit Period: 07/01/2021 ? 06/30/2022 Contract Number: FCSAK05984 Award Year: 2021 ? 2022 Comments on Findings and Recommendations: Finding 2022-001?Budget Based Salary Allocation (Compliance and Control Finding)? The Jewish Federation of Metropolitan Chicago (the Federation) allocated staff salaries to the federal program based on budget estimates, which alone does not qualify as support for charges to federal awards. The Federation allocated one employees? salary to the program based on a budgeted rate. All other employees have 100% of their salaries allocated to the program. 2 CFR 200.430(i) Standards for Documentation of Personnel Expenses (1) Charges to federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to federal awards, but may be used for interim accounting purposes, provided that the non-federal entity's system of internal controls includes processes to review after-the-fact interim charges made to a federal award based on budget estimates. All necessary adjustment must be made such that the final amount charged to the federal award is accurate, allowable, and properly allocated. Action Taken?As the Federation does not have processes and controls in place for federal program time tracking, the Federation will only allocate staff to the program that spend 100% of their time on the program starting July 1, 2022. The required corrective action for Finding 2022-001 for the period 07/01/2021 ? 06/30/2022 was completed on July 1, 2022. The person responsible for completion of the corrective action plan was James Pinkston, Vice President, Accounting. James Pinkston Date Vice President, Accounting Jewish Federation of Metropolitan Chicago 30 South Wells Street, Chicago, IL 60606 Email: jamespinkston@juf.org

Statement of condition #2022-002: During the year ended December 31, 2022, the Community paid for payroll expenditures on behalf of another community managed by the Agent totaling $13,772. Recommendation: The other community managed by the Agent should reimburse the Community in the amount of $13,772. Action(s) Taken or Planned on the Finding: Agree. The other community managed by the Agent will reimburse the Community $13,772.

2022-003 a. Name of Contact Person Responsible for Corrective Action: Waukesah Townsend ? Business Manager b. Corrective Action Planned: We will implement policies or procedures to establish an internal control system that will ensure strong financial accountability to ensure compliance with all state and federal purchasing requirements. c. Anticipated Completion Date: Immediately.

2022-002 a. Name of Contact Person Responsible for Corrective Action: Waukesah Townsend ? Business Manager b. Corrective Action Planned: We will implement policies or procedures to establish an internal control system that will ensure strong financial accountability to ensure compliance with all state and federal purchasing requirements. c. Anticipated Completion Date: Immediately.

Recommendation: The Company should ensure that finance staff is adequately trained as well as revising and monitoring internal controls. Corrective Actions: The Company will ensure that finance staff is adequately trained as well as revising and monitoring internal controls by engaging an outside certified public accounting firm for assistance.

The Organization billed the federal government for amounts of costs that had not yet been incurred and is at-risk for noncompliance with allowable activities and allowable costs, as well as cash management requirements. Statement of Concurrence or Nonconcurrence: Flower Hill has been billing the US Department of Agriculture 100% of its annual expenses in equal monthly amounts whether the total amount billed was expensed or not. According to audit, this is not allowable under a cost reimbursable contract. The organization agrees with, understands this finding and has already implemented corrective action to this finding. Questioned Costs $186,089 Corrective Action: Corrective action has been taken. FHI has discussed this finding with grantor (USDA Department of Agriculture) as has Auditor. To date, there has been no action taken by the USDA. As of July 2023, FHI has been billing only reimbursable amounts for direct costs incurred and for the approved 10% indirect rate. Name of Contact Person: Person responsible for completing the corrective action plan is Nicole Mast, Director of Operations, nmast@flowerhill.institute. Projected Completion Date: July 2023 Oversight: Billings will be monitored on a monthly basis to ensure full implementation through the end of the current contract (currently March 2026).

SAU 58 had a big transition our office with the replacement of all three of our accounting positions; Business Manager, Payroll/HR and Accounts Payable & Grants. The Accounts Payable position was then vacated for a second time and we found a new replacement in Jan 2022. During this transition period the Time and Effort for two positions that were grant funded, was overlooked. We did provide documentation of payroll from Payroll/HR but did not get the signature of the teacher or other staff member on the Certification form. Typically, we would have been able to rectify the omission but the employees had both left our district at the end of the school year. The Business manager is ultimately responsible for the implementing of the process and internal controls and will follow up with the Accounts Payable clerk to be sure each month all documentation is on file. Since the new AP person came on, she has implemented a spreadsheet to track each employee paid by Federal Funding. This way we know who has submitted their certification, and at what point we are at during the year. We will be looking at electronic documents in the future for easier tracking and getting signatures on certification documents but as of now the spreadsheet has made this process much easier to track and be sure we do not miss documents. If a big transition happens again the Accounts Payable Clerk will be responsible for all grant compliance paper work. The Business Manager will oversee this process. The above processes and procedures have already been implemented and the Business Manager will follow up monthly with the Accounts Payable clerk. Name of Contact Person and Completion Date: Name 1 Heather McMann Name 2 Tiffany Griffin Anticipated Completion Date ? Already implemented.

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: 2022-006 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: 2022-005 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.

Management deposited $1,875 back into the Project?s Reserve for Replacement account on December 9, 2022.

COVID-19 Provider Relief Fund ? Assistance Listing No. 93.498 Recommendation: The Organization should review all expense amounts entered into the reporting portal submission to ensure the amounts are accurate and agree to internal supporting documentation. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Management has implemented a process that should ensure all future reports are accurate and reviewed prior to submission. This includes a review and verification of expenses that are being reported to ensure they are accurately entered and supported by internal records. Further, management has identified additional infection control related costs which were not claimed during the reporting periods submitted. These costs have been isolated to ensure they are not available for use in future periods. Name of the contact person responsible for corrective action: Mark Sperka, CEO Planned completion date for corrective action plan: March 2023

School District U-46 Corrective Action Plan Year Ended June 30 2022 Finding 2022-001 Procurement Finding: The District procured $4,666,376 of food commodities from a vendor without publicizing the procurement opportunity or obtaining sealed bids or competitive proposals. Instead, the District obtained the commodities under a group purchasing agreement through a group purchasing organization in which the District participates. The District also procured $18,797 of goods from a vendor and was unable to provide documentation of how the vendor was selected for the procurement or that the vendor was properly reviewed to determine the vendor was not debarred. Corrective Action Planned: The District will obtain bids for the food commodities for the next school year and review and, if necessary, update its procedures for retaining documentation to support procurement actions. Expected Implementation Date: Spring/Summer 2023 Contact Person: Dale Burnidge

Finding #2022-005 ? Significant Deficiency and Other Non-Compliance Applicable federal programs: U. S. Department of Education Assistance Listing #: 81.165 ? Magnet Schools Assistance Contract Number: U165A170044 U. S. Department of Education Passed through Texas Education Agency Assistance Listing #: 84.010 ? Title I Grants to Local Education Agencies Contract Numbers: 21610141108807; 21610101108807; 226101011008807; 22610141108807 Assistance Listing #: 84.287 Twenty-First Century Community Learning Centers Contract Numbers: 226950267110025; 216950247110016; 216950267110025 Assistance Listing #: 84.027 ? Special Education Grants to States Contract Numbers: 216600011088076000; 226600011088076000 Condition and context: During our testing of internal controls over payroll and compliance we noted the following: ? No documentation of approved pay rate: - Title I Grants to Local Educational Agencies ? 1 of 40 employees tested - Magnet Schools Assistance ? 1 of 40 employees tested ? Timesheet not approved by supervisor: - Magnet Schools Assistance ? 1 of 11 hourly employees tested - Twenty-First Century Community Learning Centers ? 3 of 36 hourly employees tested ? No semi-annual certification of work performed: - Special Education Grants to States ? 1 out of 40 employees tested In our testing of the approval of the payroll registers by the compensation department, we noted 2 of the 13 payroll registers tested for the School were not reviewed and approved by the compensation department. Recommendation: Same as finding #2022-002. Planned corrective action: The Business Office will retrain the staff with duties and responsibilities over payroll in the current policies and procedures to ensure the maintenance of documentation of approved payrate, review of timesheets and semi-annual certifications, and the review of payroll registers. Business Office staff will review source and supporting records to ensure that the required documentation was created and is being maintained. The Senior Vice President of Finance/Controller and Managing Director of Accounting will randomly inspect records to validate the adequacy and completeness of the source and supporting records. Responsible officers: Brittany Perkins, VP of Finance Development Compliance; Stephen Parmer, VP of Finance Operations; Jennifer Meer, VP of Compensation and Benefits; Aybeth Martinez, Director of Payroll; Carlo Hershberger, Senior Vice President of Finance/Controller; Guadalupe Hinojosa, Managing Director of Accounting Estimated completion date: June 30, 2023

Finding 2022-003 Personnel Responsible for Corrective Action: Director of Title III and Compliance ? Dr. Neidra Butler Anticipated Completion Date: July 2022 Corrective Action Plan: The University is working with our third-party payroll provider to automate time and effort reporting.. We are currently using paper forms for reporting until we can implement Time & Effort through ADP. The Director of Title III & Finance Compliance officer to further discuss time and effort.

This appears to be an isolated incident. Management plans to submit corrections for that specific month.

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.

The Village will maintain a spreadsheet of individual amounts claimed and paid by category and vendor to prevent expense from being claimed more than once.

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

Incorrect and Late Returns of Title IV Funds (R2T4) Planned Corrective Action: Executive Director of Financial Aid has reviewed and updated policy and COD system set-up to ensure correct calculations. Executive Director of Financial Aid provided in-house R2T4 training specific to WBU for all staff as well as will ensure all pertinent staff responsible for R2T4 complete R2T4 training provided by FSA and purchased through NASFAA. Audit report is now generated weekly to identify students who have withdrawn and reviewed by appropriate staff to ensure timely R2T4 completions. Executive Director of Financial Aid is working with IT (and others) to integrate BlackBoard course activity data with PowerCampus for most accurate record of course attendance and last date of academically related activity for all students. This implementation is being piloted during Fall 2 session, with plans for full implementation for the Spring 2023 term. WBU has funded a Financial Aid Compliance Specialist position in the Office of Financial Aid. Once filled, this position with be devoted to internal audit and federal/state regulation compliance. Person Responsible for Corrective Action Plan: Christy Miller, Executive Director of Financial Aid Anticipated Date of Completion: January 2023

Finding 2022-001 - (Supportive Housing for the Elderly 14.157); Concur or Do Not Concur with this Finding - Concur; Agree or Disagree with auditor recommendations - Agree; Completion Date or Proposed Completion Date -September 16, 2022; Actions Taken or Planned on the Finding - Management has made the required deposit into the residual receipts account.; Contact Person First Name - Dawn; Contact Person Last Name - Cole.

Concordia University Irvine An Educational Institution of The Luther Church - Missouri Synod Schedule of Findings and Questioned Costs June 30, 2022 Finding 2022-001: Significant Deficiency - Return of Title IV Funds Program: Federal Direct Student Loans Assistance Listing Number: 84.268 Federal Agency: U.S. Department of Education Federal Award Identification Number: P268K223683 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/Context: In a sample of 15 students that withdrew during the fiscal year, the University did not perform the required return to Title IV calculations for four students who completed less than 49% of the payment period. For one additional student, a Title IV calculation was prepared, however the calculation was incorrect and an incorrect amount was returned. The sample was not a statistically valid sample. Cause: The University incorrectly interpreted the period of enrollment to be the one module and not the entire payment period for the withdrawal exemption for successful completion of 49% or more. The University's interpretation was made in May 2021 and therefore impacts students in the 21-22 award year as well as in the 22-23 award year through March 1, 2023 when the error in interpretation was confirmed. Effect: The University incorrectly calculated students as having completed more than 49% and therefore did not perform R2T4 calculations or return unearned loan funds to the Department. Additionally, some R2T4 calculations were incorrect based on the calculation using only the module not the days in the payment period. Questioned costs: Total questioned costs were $10,819 of Direct Student Loan funds. Recommendation: It is recommended that the University review interpretations, policies and procedures in place for withdrawals and R2T4 calculations to ensure that correct dates and institutional charges are being used. Management's Response: Upon discovery of the errors, the University reviewed the population of withdrawn students where the dates for one module were used versus the payment period. The University performed the additional or revised Title IV calculations for five students and returned additional funds. The $10,819 reported as questioned costs identified by the auditors has also been returned. The university will also review 2022-23 award year of when the 49% exemption or one module in a payment period, and make any R2T4 corrections. Anticipated completion date is May 1, 2023 Contact Lori McDonald at lori.mcclonald@cui.eclu or 949-214-3074

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.