Corrective Action Plans

Pacific understands finding #2023-002 and we agree that the University will enhance its internal controls to ensure all Pell disbursements are reported to COD within 15 days from the initial disbursement. Finding #2023-001 Action: The University notes that in the fall of 2022, there were students whose Pell Grant disbursements were not reported within the 15-day requirement to the Common Origination and Disbursement (COD)system. A Banner system issue allowed the origination of the Pell Grant to be sent to COD, however the disbursements were not. There was no indication this was occurring. To prevent future instances of late Pell Grant reporting, we will take the following action, effective February 6, 2024: • Adding an internal reconciliation component to the 10 day Pell Grant processing reminder • Reconciliation will be completed by the Assistant Director of Financial Aid, Operations of Analytics • Reconciliation will be reviewed and approved by Senior Assistant Director of Financial Aid, Operations and Analytics or Director of Financial Aid, Operations and Analytics Person(s) responsible: Aquila Galgon | Assistant Vice President of Financial Aid and Enrollment Strategy

Pacific understands finding #2023-001 and although the University failed to post the HEERF quarterly reports on its website by the required dates, the reports have been posted and will remain available for any interested parties to view through June 30, 2025. Finding #2023-001 Action: The university notes that throughout the two years that HEERF was available it maintained an active application process which was published on its website through which students could submit applications to request funding. Thus, although the quarterly reports should have been made available, we do not believe that any students were harmed by their absence. The university’s HEERF allocation for students was fully expended as of June 30, 2023, thus no further corrective action is required to resolve this funding. Person(s) responsible: Aquila Galgon | Assistant Vice President of Financial Aid and Enrollment Strategy

Condition: On the March 31, 2023 Project and Expenditure report the Town reported $625,231 of obligations for items that did not meet the definition of an obligation. Corrective Action Planned: Correct in next open reporting period Anticipated Completion Date: March 31, 2024 Contact: April Steward, Town Administrator

Enrollment Reporting Name of contact person responsible for Corrective Action Plan: Whitney Costner, Registrar Corrective Action Plan: We concur with the finding. The University is currently implementing additional controls and procedures to ensure that all student roster files are reviewed, updated, and submitted in accordance with applicable compliance requirements. Anticipated Completion Date: January 2024

Description of Finding: The University publicly posted the required institutional reports for HEERF to their website using actual grants disbursed to student data, rather than disbursement only reimbursed by the G5 drawn downs during the quarters. No other issues were noted with the accuracy of the reports. Statement of Concurrence or Nonconcurrence: Management agrees the reports were incomplete due to lack of uncertainty with the HEERF reporting requirements and the disbursements made in the current accounting system. The previous year Finding for 2022 was noted to the institution after the 2023 quarter in question was over and resulted in a continuing comment. Corrective Action: Management will adjust reports noting the required quarterly reports on the website and only use quarterly funds received for providing all of the student report information for HEERF. Name of Contact Person: Julee Sherman, VP for Finance and Administration, Fayette MO 660-248-6203 Projection Completion Date: May 2024

The financial records that supported our ESSER annual report were provided and maintained in accordance with our records retention policy. The district utilizes sources such as CASBO's records retention manual in determining how long to maintain documentation. When completing the 2022 annual ESSER report for resource codes 3213 and 3214, incorrect values were entered. The District considered this a typo and will utilize this information when completing future reports to lessen the chance of a reoccurrence.

Management agrees with the finding and acknowledges the incorrect account code was used. The oversight was related to a change of School Business Managers and the error went unnoticed. Jeff Froehlich, School Business Manager has made the correction on February 2, 2024 and going forward the Federal Award has been coded to the correct account. After each deposit, a review is completed to ensure the correct account was utilized.

Finding Number: 2023-006 Condition: Of the 9 students selected for enrollment reporting testing, the Seminary did not properly update student enrollment Information for 1 student in a timely manner. Planned Corrective Action: For students who finish their degree in December, they are reported as "withdrawn" as there is no option to confer in December (institutional policy). The student status is updated to "graduated" and reported to Clearinghouse in May when students are conferred. Contact person responsible for corrective action: Vince McGlothin-Eller, Registrar Anticipated Completion Date: 05/31/2024

Adams County Housing Authority 40 E. High Street, Gettysburg, PA 17325 Phone (717) 334-1518 Fax (717) 334-8326 TDD/TTY Relay Service: 1-800-654-5984 www.adamscha.org CORRECTIVE ACTION PLAN February 28, 2024 Adams County Housing Authority respectfully submits the following corrective action plan for the year ended on June 30, 2023 Cognizant or Oversight Agency for Audit: Section 8 Housing Choice Vouchers, CFDA #14 .871 Name and address of independent public accounting firm: Hamilton & Musser, PC 176 Cumberland Parkway Mechanicsburg, PA 17055 Audit Period: July 1, 2022 -June 30, 2023 The finding from June 30, 2023, schedule of findings and questioned costs is discussed below. The finding is numbered consistently with the number assigned in the schedule. Findings - Financial Statement Audit: NONE Findings and Questioned Cost- Major Federal Award Programs Audit # 2023-001- Significant Deficiency- Housing Assistance Payments Section 8 Housing Choice Vouchers , CFDA #14.871 Recommendation We recommend that the Authority implement additional review procedures over the HAP contract and documentation prior to or soon after the file is finalized. View of responsible officials and planned corrective action We agree that this compliance requirement is listed in the compliance supplement. We will implement additional review procedures to capture any missing information or errors in the reporting. Additional training has been provided to the HCV Staff. If the PA Housing Finance Agency has any questions regarding this plan, please call Adams County Housing Authority Executive Director, Stephanie Mcllwee at (717) 334-1518 . Stephanie Mcllwee Executive Director

Corrective Action Plan To: Federal Awarding Agency: U.S Department of Education; Passed-Through Commonwealth of Massachusetts, Department of Elementary and Secondary Education From: Heidi M. Paluk – Executive Director Date: 10.25.2023 Subject: Annual Performance Report Issue to be corrected: The Organization must follow the standards set out in the OMB 2 CFR section 200.239. The Organization must submit an annual performance report (OMB. No. 1810-0749) for the Elementary and Secondary School Emergency Relief (ESSER) funding with data on expenditures, planned expenditures, subrecipients, and uses of funds, including for mandatory/reservations. The expenditures disclosed on the report must match the expenditures stated in the Schedule of Expenditures of Federal Awards (SEFA). The total ESSER expenditures reported within the annual performance report did not agree back to the ESSER expenditures recorded on the SEFA for the year ended June 30, 2022, by approximately $435,000. Action to be taken: Management plans to follow its internal controls as intended to ensure the annual performance reports agrees back to the SEFA for applicable reporting periods. Management has notified its reporting contact of the error and inquired regarding amending the annual performance report. The annual performance report is not able to be amended at this time, however, management has a plan to correct this report once the reporting amendments area allowed. Signature___________________________________ Heidi M. Paluk 508-854-8400 ext. 3656

Housing and Urban Development Morehouse Place Cooperative respectfully submits the following corrective action plan for the year ended December 31, 2023. Westberg Eischens, PLLP 2630 1st Street South P.O. Box 362 Willmar, MN 56201 Audit Period: December 31, 2023 The finding from the December 31, 2023 schedule of findings and questioned costs and the summary schedule of prior audit findings is discussed below. The finding is numbered consistently with the number assigned in the schedules. Summary of audit results does not include findings and is not addressed. Finding 2023-001 Recommendation: We recommend that the Cooperative continue to review the auditor prepared adjusting journal entries and financial statements with the intention of understanding and acceptance of responsibility for reporting under generally accepted accounting principles. Action Taken: The Cooperative will continue to review the auditor prepared adjusting journal entries and financial statements with the intention of understanding and acceptance of responsibility for reporting under generally accepted accounting principles. Planned Completion Date: Not Applicable.

The City agrees with the finding. The Treasury Portal automatically fills in the amounts for revenue loss for 2022 with amounts reported in 2020. The Treasury portal has many flaws that would cause errors in reporting. In addition, the portal has changed every quarter, which makes it challenging to report accurately. The City will implement controls to ensure that a second review is completed prior to certification of the report. Additionally, the Grant Administrator will work with department staff responsible for reporting and ensure that each report's supporting documentation is complete and ties to underlying subrecipient reports, the general ledger and grantor reports. All supporting documentation, along with a copy of the submitted report, will be stored in a central location to ensure that they are available for subsequent reviews and audits. This will be completed by June 30, 2024.

Finding 2023-004 Internal control deficiency and noncompliance over Activities Allowed or Unallowed, Allowable Costs/Cost Principles, and Reporting related to expenses attributable to coronavirus reported in the provider relief fund reports. The entity has excess lost revenues to cover all payments received (excluding the expenses submitted). Therefore, no refund is required for any payments received. Since the program has ended, the management has implemented the following procedures for future grants: 1) An education session occurred on February 15, 2024, with the relevant parties across Huntington Health entities to formally implement a review process whereby the Controller will review the support files prior to filings being made related to grant applications/programs across any of Huntington’s entities. Documentation of this review will be retained in the central file repository. These steps and controls will be updated and documented in the departmental policy. 2) A central folder on the Huntington Hospital’s main accounting drive has been created. This folder will be populated with all support for filed figures related to grant applications/programs across the hospital’s various entities. The support will be validated as having been placed into this folder as part of the reporting out process by the accounting manager and Controller handling the reporting. Files will be retained in this central drive for a minimum of 7 years. These steps and controls will be updated and documented in the departmental policy. Contact Person: Byron Davis, Controller and Steven Mohr, Senior Vice President and Chief Financial Officer, Huntington Hospital Anticipated Completion Date: Completed

06/30/2023 Corrective Action Plan Reference Number: 2023-001 Program Information: Student Financial Assistance Cluster – Federal Direct Loan Program, Federal Pell Grant Program Contact Person: Donna Lane Anticipated Completion: 08/30/2024 Fiscal year in which finding occurred: 2023 Condition Certain students with enrollment changes were not timely transmitted to National Student Loan Data System (“NSLDS’). Management View Management recognizes the importance of reporting enrollment status changes in a timely manner for lenders and servicers of student loans to determine in-school status, deferments, grace periods, and repayment schedules, as well as the federal government’s payment of interest subsidies. Corrective Action The University has taken the following steps to improve the accuracy and timeliness of enrollment reporting with respect to federal requirements: • In addition to the National Student Clearinghouse’s implementation of new password reset requirements, the University will verify the staff representatives on the NSC FTP-site communication list are current. The NSC Enrollment Reporting procedures have been updated to include the FTP communication list and the steps to add or remove members if there are staff changes in the future. • For students who initiate a withdrawal prior to the end of the spring term, the Registrar’s Office will maintain a list to submit manual updates after the final spring enrollment file has been processed. This will ensure timely reporting of the withdrawal without overwriting the spring enrollment submission. • Summer withdrawals will now be reported directly to NSC at the time of withdrawal, ensuring timely and accurate reporting. The Registrar's Office will submit a manual enrollment status change to NSC.

Corrective Action Plan: Reimbursement of Department of Agriculture cash has been completed for year-end 2022-2023. District Administration will assess staffing needs to determine separation of duties and to determine additional staffing needs to meet the requirements of duty separation. Currently, the Finance Department consists of one Payroll/Benefits position, one Accounts Payable/Receivable Position, one Grants Specialist Position, and one Finance Director. In prior years, the Finance Department had two additional positions that have since been eliminated, causing position duties to be absorbed amongst the remaining staff. Journal postings to reimburse shown below. Anticipated Completion Date: March 29, 2024

Prior to the completion of the audit, the Organization has entered a contract with a CPA firm, CLA, to outsource its accounting functions. This will allow the Organization to have qualified accounting professionals perform and oversee accounting activity. The finding was shared with CLA and CLA has committed to working with the audit firm to meet deadlines so that all entries are recorded prior to fieldwork and if there are any open items that may result in an entry, those items are clearly communicated to the audit firm prior to fieldwork.

We categorically reject the assessment that our county “did not establish and maintain effective internal controls over compliance with coronavirus State and Local Recovery Fund requirement”. The transactions cited happened before state auditors finally clarified how they believed interfund transfers of those funds should have been handled. Before that moment, there had been little to no clear, written guidance from the state on the proper procedure for utilizing these funds for other needs within our budgets (in our case, fixing roads). Our staff spent weeks combing through and attempting to understand federal documents issued with spending rules that changed often and continue to change today. We have traced and will track every penny of those monies were spend and account for them in any way we are required. I believe it is not fair to our county to suggest otherwise in this finding, but we will certainly follow your instructions on interfund transfers, now that we finally know what those are.

INTERNAL CONTROLS OVER TRANSPARENCY ACT REPORTING Division of Emergency Management (DEM) Assistance Listing Number 97.036, COVID-19 97.036 To correct the finding, DEM met with federal partners in February 2023 to ensure understanding of what was to be reported, and ensured all staff managing grants with reportable awards knew the requirements. In March 2023, DEM implemented an internal control review between the Program Manager and the Section Chief for FFATA reporting. To ensure this finding is resolved, DEM will continue to utilize the internal control review that has been put in place.

SPECIAL TESTS AND PROVISIONS – ADP RISK ANALYSIS & SYSTEM SECURITY REVIEW Department of Health and Human Resources (DHHR) Assistance Listing Number 93.775, 93.777, COVID-19 93.777, 93.778, ARRA 93.778 The Condition section within prior year finding 2022-037 recognized that the DHHR has policies and procedures in place for performing periodic risk assessments and security reviews over the Recipient Automated Payment and Information Data System (RAPIDS), which is an internal system; however, the Condition section also proclaimed that the DHHR does not have policies and procedures to perform periodic risk assessments and security reviews over the Medicaid Management Information System (MMIS). The first sentence of the corrective action plan for prior year finding 2022-037 indicates that the MMIS is designed, developed, implemented, and operated by an external service organization. Within the last two paragraphs of the corrective action plan for prior year finding 2022-037, the DHHR opined that it was in compliance with 45 CFR 95.621 since it receives the SOC 1 Type 2 report from the MMIS service organization and since the report documents that the service organization establishes and maintains a program for conducting periodic risk analyses to ensure appropriate, cost effective safeguards are incorporated into new and existing systems or whenever significant system changes occur, as required per 45 CFR 95.621. However, the DHHR also recognized the underlying concern expressed within the finding, in that the DHHR does not include the SOC 1 Type 2 report as part of its own policies and procedures for ADP security over the MMIS. To enhance its controls, the DHHR Bureau for Medical Services (BMS) was going to develop a policy and procedures to document MMIS compliance with 45 CFR 95.621. The procedures were to include but not be limited to a requirement to review and approve the SOC 1 Type 2 report from the MMIS service organization and document the review and approval process (e.g., for such matters as the service organization’s assertions, descriptions of its systems and controls, control objectives, and related controls, and the service auditor’s description of tests of controls and results). Although the DHHR BMS has not developed a comprehensive policy or any written procedures to date, they have developed a form to document internal review of the SOC 1 Type 2 report for such matters as the control environment, systems development and maintenance, logical security, physical access, computer operations, and input controls. The BMS has also discussed this issue with an independent consulting firm that is under contract with the BMS for Medicaid expertise and performs existing services related to information technology and security; modernization and planning for the overall Medicaid Enterprise Systems (MES); organization development, including alignment strategies; project management; and data architecture and governance, which includes managing the availability, usability, integrity, and security of data with comprehensive standards and policies. The BMS and its independent consulting firm will work together to develop a statement of work for an independent review of the existing control environment, if deemed necessary, and any additional services that might need performed in order to ensure the DHHR maintains full compliance with 45 CFR 95.621 and can document compliance for future HHS reviewers, independent auditors, or other authorized officials.

TRANSPARENCY ACT REPORTING Department of Health and Human Resources (DHHR) Assistance Listing Number 93.558, COVID-19 93.558, 93.568, COVID-19 93.568 The DHHR enhanced its controls over Transparency Act reporting for LIHEAP during State Fiscal Year 2023 and met with various staff members internal and external to the DHHR (e.g., at other State agencies) to ensure everyone was aware and understood their roles in ensuring compliance on behalf of the State. Although those controls are in full effect for fiscal year 2024, the DHHR will revisit and enhance the controls to the maximum extent possible. Furthermore, the DHHR will reopen its previous submissions to the FSRS and revise the data elements to those assigned by the other State agency to their subrecipients; considering the need to consult with the DHHR spending unit and the other State agency, the anticipated date for completion is April 1, 2024.

CASH MANAGEMENT Bluefield State University and West Virginia State University Assistance Listing Number 84.425J Bluefield State University (BSU) response Effective June 2024, BSU will draw down funds on appropriate expenditures that have already been disbursed to avoid any cash management violations. West Virginia State University (WVSU) response Currently all funds have been disbursed for HEERF awards P425E201113, P425F201736, and P425J200056. WVSU will reconcile the SEFA receipts and disbursements to internal data to locate the discrepancy and make the necessary corrections. Further, WVSU will review and update internal controls related to cash management rules to ensure compliance for drawdowns and disbursements.

REPORTING Department of Education (DOE) Assistance Listing Number COVID-19 84.425D, 84.425R 84.425U, 84.425V Effective February 2024, the DOE plans to continue to enforce the existing policies and procedures in place along with ensuring all required documentation is retained for review. The DOE plans to review the ESSER Reporting Workbook by testing several indicator values i.e. expenditure amounts, demographic data, etc. There will be an approval process put in place once the Local Education Agency (LEA) submits the reports to the state. This approval process will include reviewing the edit checks with the LEA prior to final certification of data. Certification data will include an email from the LEA approving the final copy of the ESSER Reporting Workbook.

TRANSPARENCY ACT REPORTING Department of Education (DOE) Assistance Listing Number COVID-19 84.425C, COVID-19 84.425D The West Virginia Department of Education, Office of Internal Operations have established internal controls and procedures over the FFATA reporting and were set in place as of July 1, 2023. These procedures involve a second reviewer of the monthly FFATA reports and a signature of approval prior to reporting each month.

INTERNAL CONTROLS OVER SPECIAL TESTS AND PROVISIONS – ENROLLMENT REPORTING Bluefield State University, Blueridge Community and Technical College, Concord University, Fairmont State University, Marshall University, Mountwest Community and Technical College, New River Community and Technical College, Pierpont Community and Technical College, Shepherd University, West Liberty University, West Virginia Northern Community College, West Virginia State University, West Virginia University, and West Virginia University at Parkersburg Assistance Listing Number 84.063, 84.268 Bluefield State University (BSU) response Effective February 2024, BSU will review the final enrollment report and approvals will be signed off to submit the report to NSC, the third party will consistently retain a copy within our institution. BSU will retain the record count reconciliation between the final enrollment report, text file, and the number of files received by the NSC, including documentation on how any rejected records were addressed. BSU will retain the details of the validation of the student’s information included in the report for accuracy. BSU will consistently retain the NSC automated emails used as a quality checklist regarding due dates, and receipt of the text files by the NSC. The availability and completion of the Error Resolution Report, as well as the confirmation of certification and processing by the NSC report, will all be retained. Blueridge Community and Technical College (BRCTC) response BRCTC asserts that the Enrollment Reporting process is accurate and reviewed in a timely manner; BRCTC further asserts that the emails from the National Student Clearinghouse are reviewed. As a result of this finding, BRCTC will expand its internal control to include documentation of reviews internally and externally with the NSC. This update to the internal control process was implemented in February 2024. Concord University (CU) response Effective February 2024, the internal controls at CU over the review and approval of the enrollment report sent to the National Student Clearinghouse (NSC) have been updated to include the following control measures in addition to the current controls on file: 1. CU has contacted NSC to begin generating the email response for the receipt of the .txt file when submitting it to the NSC FTP portal. This email notification will be kept on file with the other report documentation. 2. CU has implemented a new checklist sheet to accompany the report and its documentation to provide a clear and organized outline of required documents and to ensure these requirements are provided. This sheet will be part of the Spot Check Letter that is included in the current control method and signed off on by two members of the Registrar’s Office staff. 3. CU has also included in this new checklist a space to document the number of student files submitted to NSC and the number of files submitted to NSLDS as noted by NSC. The printout of this notation provided by NSC will also serve as documentation attached to the report. Fairmont State University (FSU) response Effective February 2024, FSU will retain a screen shot of the record count received by the NSC and will document any rejected records and what the plan is to address the rejected records. FSU will review a portion of the enrollment records being submitted before the submission is uploaded to NSC. This review will include detailed documentation, for a select few, of how we validated the student’s enrollment status. FSU will keep a spreadsheet of the students that are validated and the Banner screens that are used to do so.   Marshall University (MU) response Effective February 2024, MU will document that a record count reconciliation has been completed between the enrollment submission file and the number of files received by the NSC. MU will document and retain how any rejected records were addressed. MU will also document and retain records of the spot check validation for accuracy of student information included in the enrollment submission files. Mountwest Community and Technical College (MCTC) response Effective February 2024, a record count reconciliation between the final enrollment report and the number of files received by the National Student Clearinghouse (NSC) will be completed. MCTC will have the NSC query historical data and have it provided in Excel format. This will be a new source of data that will be collected and retained. This file will be generated after every rejection error report that is returned to the NSC. Each file will be saved, and a copy will be sent to the Registrar’s Office. Transmission history can also be saved by table, that can be exported to Excel. These files will also be saved, and a copy sent to the Registrar’s Office. For validation of student information, MCTC will being the process to collect data for the NSC submission first begin in audit mode. This will allow for review of the data to make any corrections that appear in the first stage of the report. Next, a second row of audits processed by the Associate Registrar will be conducted and confirm the data integrity. After this is complete, a copy of the final submission will be sent to the Registrar for final review and authorization. When approval is returned to the Associate Registrar, the data will be uploaded to the NSC. New River Community and Technical College (NRCTC) response Effective August 2024, the Registrar's office will run a random selection of 20 students from NSLDS to ensure students are correct in the clearinghouse, which will be done at least 50 days out from the time students were initially reported. The Registrar’s office will keep documentation of the sampled students. The Registrar’s office will keep records of how many files were accepted and how many were rejected. The Registrar’s office will provide documentation of validation of student information included in the enrollment report and retain emails by providing a file specially for NSC enrollment reporting emails received and sent regarding enrollment reporting. Emails to be retained are error resolution and confirmation of certification and processing by the NSC. The Registrar’s office will also create a checklist to follow and use as documentation to ensure all steps throughout the process are completed and checked off the list. Pierpont Community and Technical College (PCTC) response Effective February 2024, PCTC will complete the review of the file before it is submitted, not after it’s submitted. The Associate Registrar will pull the report prior to the due date to give those in the review process ample time to review the files before the Associate Registrar submits the document to the NSC. PCTC will keep track of the due date of submission, the date the text file was sent to the NSC, the date the error resolution report was received, the date it was sent back, and the date the report was certified by the NSC. A new tab in the worksheet in Teams has been created that will be completed each time an enrollment verification is submitted to the NSC. PCTC will note the actual enrollment count as of the time of the NSC submission, the enrollment count on the TXT file, the number of files received by the NSC, and the number of rejected files. This is to verify that all of the files intended to be submitted to the NSC were actually received by the NSC and processed. This information will be kept on each spreadsheet used to verify the information sent to the NSC. Shepherd University (SU) response Effective February 2024, SU will add a checklist to the existing reporting and retention structure that had already been established for Clearinghouse data transmission. The checklist will be completed with each transmission, organizing data retention efforts to ensure inclusion of the additional elements required.   West Liberty University (WLU) response To comply with internal control over the review and approval of the enrollment reporting to NSC, WLU will enhance their policies and procedures. The update of these policies and procedures will be effective February 2024 and carry forward into future academic years. WLU will ensure that enrollment reporting policies and procedures are compliant with the US DOE standards and retain evidence of the internal controls. Currently, WLU is reorganizing the processing of enrollment reporting from our IT System Administrator to our Enrollment Services Coordinator. This employee will add to the current policy a process by which a record count reconciliation will happen between the final enrollment report text file and the number of files received by NSC. There will also be documentation kept showing how many rejected records were addressed with each report. Proper documentation will also kept of a final review and approval signoff to submit the enrollment report to NSC. Lastly, WLU will create an email specific to enrollment reporting where all communication from NSC will be stored for auditing and record keeping purposes. West Virginia Northern Community College (WVNCC) response Effective February 2024, the enrollment reporting to the Clearinghouse (NSC) is being moved from the Registrar/Records office to the Institutional Research (PIER office). All reports including determination of reporting intervals per Clearinghouse and SFA guidelines, will be scheduled by the IR office with the Clearinghouse. The following items will be retained to match internal controls for each file sent to the Clearinghouse: 1) Retain internal emails or approval document regarding review and approval from two persons for file prior to sending to NSC 2) Retain verification of count of student record in file matching student enrollment at that time 3) Retain verification of record count with records received by NSC 4) Retain a spot check of students (approx. 8-10) from the file which were tested for accuracy including printout of where this was matched (usually SFAREGS time status page is printed) 5) Retain NSC Error Report for each file prior to resolution and document of resolution 6) Retain reminder email from NSC that the submission file is due 7) Retain initial txt file receipt email from NSC 8) Retain NSC posted error resolution report notification email 9) Retain NSC Completed Error Resolution report notification email 10) Retain NSC final processing email The following information for each file will also need maintained (this information is usually obtained from the NSC reporting page under the enrollment reporting link for approximately an 18 month time frame, header records on the files also show file generation date and term date information for the students reported). 1) Scheduled transmission date 2) File certification date 3) NSC received date 4) NSC processed date 5) Academic term the file is sent for 6) Submission type of the file (first of term, subsequent of term, graduate only, etc.) West Virginia State University (WVSU) response WVSU utilizes the National Student Clearinghouse (NSC) to update student’s enrollment and its effects on student’s direct loan and Pell statuses. Thorough edit checks of student data for each semester will be produced by IT on a regular basis. The Office of the Registrar, in coordination with Admissions, Dual Enrollment, and other contributors of student data, will make sure these errors are corrected. Special focus will be placed on resolving these errors before each enrollment file is produced. (initial data integrity, first check). On or around the 25th of each month, IT will produce the NSC enrollment file. Each time the file is produced, the file will be sent to the Registrar for review to ensure accuracy of the data being pulled from Banner. Registrar sends approval for upload to NSC. Emails from NSC, IT, and files with student checks to be retained. (process integrity, second check) The file will be uploaded to the NSC by IT, ensuring NSC received the appropriate number of records. The data will then be reviewed and any discrepancies in the data, when compared with past data, will be resolved in a timely manner. The NSC error report will be reviewed and any errors corrected. The NSC process makes sure these errors are resolved before the data is reported to the NSLDS, it is the responsibility of the Registrar to make sure these are resolved with accurate data. Emails from NSC, and screenshots of errors will be retained. (data integrity, third check) After resolution of errors, the NSC will perform a final review of data before sending to the NSLDS. This will be reported on the NSLDS Reporting tab of the Enrollment Reporting screen in the NSC website. If data is satisfactory, the submission will be marked with “Congrats. No Errors!” by the originator clearinghouse. The NSC sends emails whenever these items are updated. It is the responsibility of the Registrar to review and resolve any errors in a timely manner. Emails from NSC and screenshot of NSLDS reporting dashboard to be retained. (data integrity, fourth check) The enrollment data is then submitted to the NSLDS. After NSLDS reviews the data, any errors will be reported back through the NSC in the same manner as NSC errors. Resolution of these errors is of special importance and will be given top priority. The NSC sends emails whenever these items are updated. It is the responsibility of the registrar to review and resolve any errors in a timely manner. Emails from NSC and any error documentation to be retained. (data integrity, fifth check). These policies and procedures will be implemented in August 2024. West Virginia University (WVU) response WVU’s Registrar’s office reviews rejected records and takes appropriate action to clear the rejections. Many of these rejections require additional information from students, therefore resolution is based on student discretion in providing documentation. Effective February 2024, WVU will ensure that documentation of the submission record count and rejection follow up is maintained. West Virginia University at Parkersburg (WVU-P) response Effective February 2024, WVU-P will reconcile the record count of enrollment records processed by taking the following actions: 1. Highlighting the record count at the end of the Banner-generated enrollment report file as part of the spot-checking review process. 2. Screenshotting the number of files received by NSC once they acknowledge that the file has been received. 3. Retaining documentation to show that if for some reason the file count does not match, research was done to locate the reason for the discrepancy, and the discrepancy was either resolved or WVU-P is able to document why it could not be resolved. Records and Financial Aid are working together now to develop procedures to properly document the error resolution process. WVU-P will have this process in place by April 2024, in time for the new process to be fully implemented beginning with the Summer 2024 term. WVU-P will retain all documentation, including all emails sent by NSC throughout each enrollment reporting process, within a folder in a secure drive. The name of the folder will be the date that the enrollment report was sent to NSC.

INTERNAL CONTROLS OVER FINANCIAL REPORTING Pierpont Community and Technical College (PCTC) Assistance Listing Number 84.063, 84.268 Beginning October 2022, PCTC has performed the updated monthly reconciliation process that was originally to take place beginning July 1, 2022. Due to the loss of the Information Systems Specialist (ISS), PCTC failed to begin on the intended date. The DLSAS reports from COD are downloaded by the 10th of each month, as before, by the ISS. The reports are provided to the Assistant Director of Financial Aid (Asst.) and then reconciled to both Banner paid and Common Origination and Disbursement (COD). The Asst. takes screen captures of both Banner and COD for a monthly reconciliation of the Federal Pell Grant and DL programs. Screen captures are printed, and comparisons are made by the Asst. All necessary adjustments are performed to student accounts by the Asst. or Director of Financial Aid (Director) until balanced. Reports verifying reconciliation are then completed, initialed, and saved by the Asst. and then reviewed and signed by the Director for completion and accuracy. PCTC will maintain the documentation of the DLSAS statements each month and the reconciliation report along with evidence of said review. The completed reconciliation information files are in our shared drive. This process has been in place, ongoing and has been effectively followed since October 2022.