Corrective Action Plans

Condition: The University does not have all of the minimum safeguards written down within its information security program. Planned Corrective Action: This finding has already been addressed. During the current year testing, we updated our “GLBA Information Security Program”. While it does contain all elements required, technically the policy was not updated until 7/25/2024. LTU followed up with the FSA Cyber Compliance Team regarding this finding from last year. We received the following response on August 15th, 2024: Thank you for providing evidence artifacts to the Federal Student Aid (FSA) Cybersecurity Compliance Team indicating that you have satisfied the minimum information security requirements of Gramm-Leach-Bliley Act (GLBA) at Lawrence Technological University for the audit year of 2023. As a courtesy, we remind you that all the GLBA Cybersecurity requirements are to be satisfied each audit year. Protecting student data is an utmost priority for FSA and we are committed to ensuring the safety and security of student information. We have reviewed the information you provided and determined it sufficient to close the case. Contact person responsible for corrective action: Linda L Height, VP Finance Anticipated Completion Date: July 25, 2024

The District had new staff and reporting documentation was not compiled in order to reconcile the amounts. Moving forward all documentation will be kept by two fiscal team members. The District was never notified by the California Department of Education or the Auditors that there was an obligation to correct prior year FTE amounts in the next reporting period and therefor this has not yet been corrected. During the next open reporting period, the District will recreate all of the FTE reports and enter new data as required by the Audit team.

Name of Contact Person: Nia Broadway, Medicaid Manager Corrective Action: Proposed Completion Date: Name of Contact Person: Nia Broadway, Medicaid Manager Corrective Action: Proposed Completion Date: Name of Contact Person: Nia Broadway, Medicaid Manager Corrective Action: Proposed Completion Date: Inaccurate Resources Entry The County met with all Adult Medicaid Staff to discuss inaccurate resource entry and the policy associated with the findings. The County will continue Second Party Reviews and conduct trainings based on findings. Meeting held 10/28 through 10/29/24 Finding: 2024-004 Corrective Actions for findings 2024-002, 2024-003, 2024-004, 2024-005, and 2024-006 also apply to the State Award findings. Finding: 2024-005 Inaccurate Information Entry The County met with All MAGI and Adult Medicaid Staff to discuss inaccurate information entry and the policy associated with the findings. The County will continue Second Party Reviews and conduct trainings based on findings Section IV- State Award Findings and Questioned Costs Finding: 2024-006 Untimely Review of SSI Terminations The County met with all Adult Medicaid Staff to discuss the untimely review of SSI terminations and the policy associated with the findings. The County will continue Second Party Reviews and conduct trainings based on findings. Meeting held 10/28/24

Name of Contact Person: Nia Broadway, Medicaid Manager Corrective Action: Proposed Completion Date: Name of Contact Person: Nia Broadway, Medicaid Manager Corrective Action: Proposed Completion Date: Name of Contact Person: Nia Broadway, Medicaid Manager Corrective Action: Proposed Completion Date: Inaccurate Resources Entry The County met with all Adult Medicaid Staff to discuss inaccurate resource entry and the policy associated with the findings. The County will continue Second Party Reviews and conduct trainings based on findings. Meeting held 10/28 through 10/29/24 Finding: 2024-004 Corrective Actions for findings 2024-002, 2024-003, 2024-004, 2024-005, and 2024-006 also apply to the State Award findings. Finding: 2024-005 Inaccurate Information Entry The County met with All MAGI and Adult Medicaid Staff to discuss inaccurate information entry and the policy associated with the findings. The County will continue Second Party Reviews and conduct trainings based on findings Section IV- State Award Findings and Questioned Costs Finding: 2024-006 Untimely Review of SSI Terminations The County met with all Adult Medicaid Staff to discuss the untimely review of SSI terminations and the policy associated with the findings. The County will continue Second Party Reviews and conduct trainings based on findings. Meeting held 10/28/24

Name of Contact Person: Nia Broadway, Medicaid Manager Corrective Action: Proposed Completion Date: Name of Contact Person: Nia Broadway, Medicaid Manager Corrective Action: Proposed Completion Date: Finding: 2024-003 IV-D Non-Cooperation The County met with All MAGI Medicaid Staff to discuss the noncooperation with child support procedures and the policy associated with the findings. The County will continue Second Party Reviews and conduct trainings based on findings. Meeting held 10/29/24 Section III - Federal Award Findings and Questioned Costs Corrective Action Plan Meeting held 10/28/24 Inadequate Request for Information The County met with all Adult Medicaid Staff to discuss inadequate request for information and the policy associated with the findings. The County will continue Second Party Reviews and conduct trainings based on findings. Reconciliation of Records and Reporting Holly Martinez-Borja, Finance Director The County has made great efforts to achieve the timely completion of the annual audit and issuance of the financial statements. The County will ensure the appropriate year-end accounting adjustments to be properly recorded. The County has hired an experienced Finance Officer with 20 years of experience. An Assistant Finance Officer position has been added to the department to assist with the daily operations to increase capacity within the department. Board policies and procedures are implemented to increase oversight and accountability. For the Year Ended June 30, 2024 Section II - Financial Statement Findings Finding: 2024-001 Imminently.

Name of Contact Person: Nia Broadway, Medicaid Manager Corrective Action: Proposed Completion Date: Name of Contact Person: Nia Broadway, Medicaid Manager Corrective Action: Proposed Completion Date: Finding: 2024-003 IV-D Non-Cooperation The County met with All MAGI Medicaid Staff to discuss the noncooperation with child support procedures and the policy associated with the findings. The County will continue Second Party Reviews and conduct trainings based on findings. Meeting held 10/29/24 Section III - Federal Award Findings and Questioned Costs Corrective Action Plan Meeting held 10/28/24 Inadequate Request for Information The County met with all Adult Medicaid Staff to discuss inadequate request for information and the policy associated with the findings. The County will continue Second Party Reviews and conduct trainings based on findings. Reconciliation of Records and Reporting Holly Martinez-Borja, Finance Director The County has made great efforts to achieve the timely completion of the annual audit and issuance of the financial statements. The County will ensure the appropriate year-end accounting adjustments to be properly recorded. The County has hired an experienced Finance Officer with 20 years of experience. An Assistant Finance Officer position has been added to the department to assist with the daily operations to increase capacity within the department. Board policies and procedures are implemented to increase oversight and accountability. For the Year Ended June 30, 2024 Section II - Financial Statement Findings Finding: 2024-001 Imminently.

2024-002 – Return of Title IV Calculation. Auditor Description of Condition and Effect. A break of at least five consecutive days was not excluded from the reported enrollment period for the Winter 2024 semester, which resulted in the calculation being incorrect for all students who had returns in the Winter 2024 semester. As a result of this condition, Return of Title IV calculations were incorrect for five students for the Winter 2024 semester, resulting in $66.52 in excess funds returned to the U.S. Department of Education. It is our understanding that on August 14, 2024, the College repaid the five students affected by this calculation error. Auditor Recommendation. We recommend that the College implement a review process to ensure the number of enrollment days used in the Return of Title IV calculations is accurate and that the R2T4 calculation is reviewed by a second individual. Corrective Action. Upon discovery of the Return of Title IV Calculation error, the College went through and made corrections to all student accounts affected. To prevent a similar problem from arising in the future, the College has developed a review process where the Director of Financial Aid will review break day regulations in the FSA handbook and verify that the Ellucian Colleague annual set-up has accurate break days. The Director of Financial Aid will also verify accuracy as calculations are processed for students. Responsible Party. Jean Zimmerman, Director of Financial Aid. Anticipated Completion Date. August 14, 2024.

2024-001 – Timeliness of Status Change Reporting. Auditor Description of Condition and Effect. During our testing of thirteen students with status changes, we noted six instances of late reporting of a student's status changes. Three of these instances were winter term graduates whose status change was reported one day late. The other three of these instances were winter term graduates whose status changes had not been reported as of the date of our audit fieldwork, due to a technical glitch in the College's reporting system. Therefore, the NSLDS system is not updated with the student information timely which could lead to a student's grace period being shortened. Auditor Recommendation. We recommend that the College review its reporting procedures to ensure that students' status changes are accurately and timely reported to NSLDS as required by regulators. Corrective Action. The Director of Financial Aid will review the reporting procedures to ensure that students' status changes are accurately and timely reported to NSLDS. The Director of Financial Aid will check NSLDS to ensure timely reporting. Responsible Party. Jean Zimmerman, Director of Financial Aid, and Amy Young, Registrar. Anticipated Completion Date. First Fall 2024 NSC reporting.

Name of Contact Person:Jonathan Scott, Chief Financial Officer, Business and Financial Services. Corrective Action Plan: Management will implement controls and procedures to ensure that staff responsible for overseeing compliance with Title I requirements understands the 12% administrative expenditure limit. In addition, the Title I budget will be monitored by Title I staff during the year to ensure that the 12% administrative requirement is not exceeded. Proposed Completion Date: Immediately

Mortgage Insurance Nursing Homes, Intermediate Care Facilities, Board and Care Homes, and Assisted Living Facilities -Assistance Listing No. 14.129 - Significant Deficiency in Internal Control over Compliance Recommendation: CLA recommends the organization develops and enforces a policy requiring the approval of all invoices before payment. Explanation of disagreement with audit finding: Management is in agreement with the finding. Action taken in response to finding: Starting in April 2024, Webster began implementing Silverstone Living's invoice approval policy. The authorized signers for invoices are the Executive Director, the CFO, and the department heads. Name of the contact person responsible for corrective action: Janet Langlois, CFO Planned completion date for corrective action plan: April 30, 2024.

Section 8 Project-Based Cluster – Assistance Listing No. 14.195 / 14.856 Recommendation: The Commission should implement processes to ensure that claims for assistance are properly terminated. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Pratum will ensure that move-outs are processed promptly to prevent assistance payments from being requested for vacant units. The Regional Property Manager will oversee the completion and review of end-of-month checklists to confirm that all monthly tasks have been addressed, thereby minimizing the likelihood of this exception occuring in the future. Effective immediately, HOC’s PM Compliance Manager will ensure that move-outs are processed in a timely manner and will review monthly reports to confirm that esident terminations are handled accurately. For both HOC and Pratum, the HOC team will incorporate any open move-out and move-in actions into the monthly review of past-due certifications as part of the report. Name(s) of the contact person(s) responsible for corrective action: Carmen McLaurin, Vice President of Operation with Pratum, Darcel Cox, Vice President of Compliance with HOC and Ali Ozair, Vice President of Property Management with HOC. Planned completion date for corrective action plan: Pratum and HOC have immediately implemented the corrective actions as outlined above. Both discrepancies have been resolved. The HOC team will include open move-in and move-out actions within the report effective November 2024. If the U.S. Department of Housing and Urban Development has questions regarding this schedule, please call Timothy Goetzinger, Senior Vice President, Finance / Chief Financial Officer at (301) 949-4690.

Section 8 Project-Based Cluster – Assistance Listing No. 14.195 / 14.856 Recommendation: The Commission should implement processes to ensure that fatal errors occurring during PIC/TRACS submissions are corrected in a timely manner Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Previously,Pratum was responsible for completing the certifications and the HOC team was responsible for transmitting the certifications through TRACS. Effective October 1 2024, Pratum assumed responsibility of ensuring that all certifications are transmitted to TRACS in alignment with the HAP reported date. The Regional Property Manager will conduct monthly reviews of HAP and TRACS submissions to ensure accuracy. HRD staff will provide weekly internal staff training to correct PIC errors and procure additional training from a third party consulting company.. Name(s) of the contact person(s) responsible for corrective action: Carmen McLaurin, Vice President of Operation with Pratum, Darcel Cox, Vice President of Compliance with HOC and Lynn Hayes, Vice President of Housing Resources. Planned completion date for corrective action plan: Pratum immediately implemented the corrective actions as outlined above and will commit to correcting all specific discrepancies by March 31, 2025. The HRD team has corrected the errors and will attempt to secure training from a consultant company no later than March 31, 2024.

Housing Voucher Cluster – Assistance Listing No. 14.871 / 14.879 Recommendation: We recommend the Commission implement processes to ensure that all proper documentation is being maintained during the recertification process for every tenant. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Effective September 2024, the HOC compliance team significantly enhanced the quality control review process to proactively identify SEMAP findings and eligibility discrepancies before the end of each fiscal year. Staff anticipates that this proactive approach will facilitate early identification of training needs on a more frequent basis, ensuring compliance standards are met while also improving overall program effectiveness. Additionally, HRD staff will identify and address systemic findings during monthly staff meetings. To further support these efforts, HOC enlisted a third-party consulting firm to provide training to new and existing staff in October 2024. Staff were trained on eligibility, portability and SEMAP requirements. Additional HOTMA training is scheduled on 11/6/24 - 11/7/24. Moreover, HOC will continue to procure recurring training based on systemic quality control findings prior to the end of the fiscal year. This comprehensive approach will ensure that staff are well-equipped to address any challenges and enhance overall compliance and effectiveness. Name(s) of the contact person(s) responsible for corrective action: Lynn Hayes, Vice President of Housing Resources Division and Darcel Cox, Vice President of Compliance. Planned completion date for corrective action plan: Staff training commenced October 2024 and will continue throughout the fiscal year.

November 18, 2024 Response to Finding 2024-002 Special Tests and Provisions - Enrollment Reporting Significant Deficiency in Internal Control over Compliance Otis College of Art and Design agrees with the finding. Responsible Office and Individual The Executive Director of Financial Aid and The One Stop, Michaela Matsumoto (mmatsumoto@otis.edu) and Registrar Nicole Raef (nraef@otis.edu) are the responsible individuals for implementation of the corrective action plan. Corrective Action Plan Upon review of the finding, Financial Aid administration met with the Registrar's staff to create a new procedure whereby immediate reporting of withdrawals are made directly to NSLDS in addition to the regularly scheduled monthly reports to NSLDS through the National Student Clearinghouse (NSC). This immediate reporting should elimnate any timing issues with the monthly reports through NSC. In addition, a joint effort to streamline the routing of withdrawal forms to the appropriate departments for faster processing is underway. This is reprocessing of the withdrawal forms will be implemented in the next 120 days.

November 18, 2024 Finding 2024-001 Special Tests and Provisions - Return of Title IV: Significant Deficiency in Internal Control over Compliance Otis College of Art and Design agrees with the Return of Title IV calculation finding. This error was noticed by new financial aid staff/administration hired in late spring of 2024 after the prior administration had completed all return of Title IV calculations except for the unofficial withdrawals. The new staff noticed the error and made the adjustment going forward starting with the unofficial withdrawals for spring 2024. This error only affected the days of Spring Break. No other semesters had an error in dates used in the Return of the Title IV calculations. Responsible Office and Individual The Executive Director of Financial Aid and The One Stop, Michaela Matsumoto (mmatsumoto@otis.edu) and Registrar Nicole Raef (nraef@otis.edu) are the responsible individuals for implementation of the corrective action plan. Corrective Action Plan Financial Aid Management met with the Registrar's Office to ensure all future semester set up dates are correct and have been reviewed. This improvement of processes to ensure a double check of the Return of Title IV calendar setup has been implemented for 2025-2026.

Finding 2024-001, Significant Deficiency and Non-Material Non-Compliance - Eligibility: During the Medicaid control testing, eleven cases were identified that required subsequent corrections in NCFAST; however, these corrections were not completed within the 20-day requirement following the case worker’s audit, as mandated by DHHS policy. Corrective Action Plan: Case Corrections Goal: To ensure Medicaid error findings identified by internal and external audits are timely and accurately corrected for compliance, oversight will be provided by Medicaid Leadership and applicable staff. Plan: The county’s Medicaid Audit Submission tool has been revised to include a case correction due date for eligibility, procedural, and internal control findings. The revision ensures compliance with timely and accurate case corrections. Case corrections must be initiated within five business days of the case audit date. When policy allows, case corrections should be completed within 20 days of the case audit. Performance Improvement Strategies: 1. Program managers, supervisors, applicable lead staff, and trainers, will be provided access and training on the audit tool to monitor the compliance of timely and accurate case corrections. 2. Audit reports will be stored on the county’s OneDrive in the Medicaid Division folder. 3. Supervisors will begin to follow up no later than the 6th business day from the date of audit to ensure case corrections have been completed or initiated, at minimum, by the eligibility specialist. Supervisors will follow up throughout the case correction process to ensure corrections are complete and accurate. 4. Each month, for the prior month, each program manager will select a total of ten audit findings from the Medicaid Audit Finding spreadsheet to ensure their assigned supervisors are compliant with the case correction procedure. These compliance reviews will be conducted and saved to the Medicaid Division folder by the last day of the month. Program managers will take further corrective measures if noncompliance is discovered, by first reporting the continued deficiencies to the Medicaid Division Director. Responsible Parties: Medicaid Program Mangers, Jennifer Hurdle and Alison Westbrook Timeframes: A Medicaid Division meeting will be held no later than November 30, 2024, with all program managers, supervisors, lead staff, and trainers to discuss roles and responsibilities, receive the required training, and the state’s requirement of compliance with monthly audits, case corrections, and corrective actions to mitigate risks from recurring. Agenda and sign-in sheet are required and due to D. Hill no later than December 5, 2024. Finding 2024-001, Significant Deficiency and Non-Material Non-Compliance - Eligibility: During the eligibility compliance testing, it was identified that a Register of Deeds (ROD) check had not been performed at the time of recertification for one case. Although this was an oversight, it did not impact the eligibility determination for the case. The ROD results were subsequently reviewed during the audit process, confirming that the beneficiary was appropriately eligible to receive benefits. This error was classified as a procedural and documentation issue related to the completion of the ROD check. Corrective Action Plan: Register of Deeds Goal: To ensure Register of Deeds (ROD) is inquired and the results are uploaded to the County’s document imaging system when policy requires. Plan: Medicaid programs that have a resource limit require inquiries to be made to the local ROD in the applicant's county of residence to assist with identifying countable and non-countable assets such as real property when determining Medicaid eligibility at application and redetermination. Performance Improvement Strategies: 1. Adult Medicaid - program manager, supervisors, applicable lead staff, and trainers, will develop a required documentation template for all Adult Medicaid staff to use when completing applications and recertifications. The template will be used for all programs under the Adult Medicaid umbrella without exception. The template will include a subsection for resources, highlighting the date ROD checks were conducted and uploaded into NC FAST, if applicable. ROD verification of real property and verification of no real property should be uploaded to the attachments folder within the administrative tab on the Income Support Case. 2. The documentation template will be included in the note section on the beneficiary’s person page or the head of household’s (HOH) person page, if the applicant is not the HOH. 3. The required template will be added to the audit tool to ensurecompliance. 4. Supervisors are required to provide compliance when conducting monthly second party reviews by ensuring the required template, documentation, and uploaded ROD verification is present and correct. 5. Supervisors will take further corrective measures if noncompliance is discovered by first reporting the continued deficiencies to the Medicaid Division Director and Adult Medicaid Program Manager. Responsible Parties: Adult Medicaid Program Manager, Supervisors, Lead Staff, and Trainers Timeframes: A Medicaid Division meeting will be held no later than November 30, 2024, with the Adult Medicaid program managers, supervisors, lead staff, trainers, and other applicable staff to introduce and provide training on the mandatory template. The template will be effective December 1, 2024, with supervisor compliance beginning January 1, 2025, for dates of applications beginning December 1, 2024, and redeterminations initiated beginning December 1, 2024. Agenda and sign-in sheet are required and due to D. Hill no later than December 5, 2024.

Recommendation: We recommend the University review their current policies and procedures around credit balances and ensure the processes in place are sufficient to ensure student credit balances due to federal funds are refunded within 14 days. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Continue reviewing student credit balances on a weekly basis ensuring Title IV refund checks are processed within the 14 calendar days. Additionally, the Finace team will review current procedure and draft a formal policy and procedure for Student Credit Balances. Name(s) of the contact person(s) responsible for corrective action: Michael Werner- VP of Finance Planned completion date for corrective action plan: End of Calendar year 2024

Recommendation: We recommend that the University implement a formal review process as it relates to withdrawn students to ensure R2T4 calculations are being performed accurately and timely. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: ACU has created 1 additional financial aid advisor position. This position will assist the financial aid team. The Financial aid office will review the withdrawn requests sent to the financial aid inbox on a weekly basis. The withdrawn report will be worked at the end of every week to ensure all withdrawn students have been reviewed to date and all R2T4 calculations have been completed. The Director of Financial Aid will create formal training processes and will conduct training with the financial aid advisors. The Director of Financial Aid will conduct periodic reviews to ensure ongoing compliance with Title IV regulations. Name(s) of the contact person(s) responsible for corrective action: Angel Faast- Director of Financial Aid Planned completion date for corrective action plan: 01/31/2025

Recommendation: We recommend the University review its reporting procedures to ensure that students’ statuses are accurately and timely reported to NSLDS as required by regulations. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The AVP of Institutional Effectiveness will create a secure digital tracking spreadsheet that will contain file submission tracking and error resolution tracking. A digital signature protocol will be implemented that will require a sign off on submission from ADIR and AVP will verify and sign off within 48 hours of submission. A weekly check-in will be conducted on Monday that will review weekly reports, upcoming submissions, error resolution status updates and documentation for meeting outcomes. Tracking deadlines will be implemented for error resolution. ADIR must acknowledge NSC error notifications within 1 business day and error resolution must begin within 2 business days. The first attempt must be completed within 5 business days and secondary error notifications must be addressed within 3 business days. AVP IE will conduct a monthly audit and a quarterly assessment to ensure ongoing compliance with Title IV regulations. Name(s) of the contact person(s) responsible for corrective action: Jeff Phillips-AVP of Institutional Effectiveness Planned completion date for corrective action plan: End of Calendar year 2024

Condition: The University did not return Title IV funds within 45 days of the date of determination of withdrawal for four students. Views of Responsible Officials and Planned Corrective Action: Beginning in the Fall 2024 semester, Student Account Services and University Billing (SASUB) implemented a dedicated R2T4 SharePoint site to enhance the tracking and management of withdrawn students as identified. The site includes dynamic lists that log students requiring a return of Title IV funds as they are identified. Each entry records the student’s date of determination, and the corresponding 45-day return deadline. This centralized platform allows authorized users to easily view pending returns, associated deadlines, and the completion dates for each case. The system improves the accuracy of Title IV fund return tracking, enhances accountability, and fosters greater transparency and communication among university stakeholders. Key personnel and leadership from SASUB and the Office of Scholarships and Financial Aid have access to the SharePoint site and conduct regular reviews to ensure compliance and operational efficiency. Contact person responsible for corrective action: Director of Student Account Services and University Billing Anticipated Completion Date: 8/26/2024

Incorrect Return of Title IV Funds Calculations Planned Corrective Action: The Student Financial Services Office will train additional staff on R2T4 procedures and then conduct secondary reviews to validate the correctness of the R2T4 calculations and return amounts. Person Responsible for Corrective Action Plan: Bryan Taylor, Associate Director of SFS Processing Anticipated Date of Completion: July 1, 2025

The disbursement process of such refunds was transferred to a new team within the Finance/Treasury branch. The team size was increased from 2 to 4 members. Members added to this team have relevant previous experience in student accounts. The additional resources as well as their experience and knowledge should ensure that funds are returned in a timely manner that complies with program requirements.

FINDINGS — FEDERAL AWARD PROGRAMS AUDITS DEPARTMENT OF EDUCATION 2024-001 Student Financial Aid – CFDA No. 84.007, 84.268, 84.063, 84.033 Recommendation: 1) We recommend the College reevaluate its procedures and review policies surrounding reporting status changes to NSLDS to ensure the enrollment effective date reported to NSLDS is aligning with the College’s last date of attendance. 2) We recommend the College reevaluate its procedures and review policies surrounding reporting program enrollment effective dates to NSLDS. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Corrective Action Response Regarding Graduation Date Discrepancy 1. Immediate Correction of Records: • Verified and corrected all affected student records to reflect accurate graduation dates. • Graduation dates for graduates from Fall 2023 to Summer 2024 will be updated. This action ensures alignment between the student information system, official transcripts, and graduation rosters. 2. Process and Policy Updates: • Internal policies will be revised to provide clear guidance on assigning and verifying graduation dates. Corrective Action Response Regarding Enrollment Transmission Reporting Timeline Beyond the 60-Day Requirement 1. Policy and Procedure Enhancements: • Updated internal policies to require enrollment data transmission at least every 20 days, well ahead of the 60-day federal requirement to ensure receipt by the National Student Loan Data System (NSLDS) in a timely manner. • Staff will periodically request a transmission audit from the Clearinghouse verifying that the institution’s enrollment data has been forwarded to the National Student Loan Data System (NSLDS). Name of the contact person responsible for corrective action: Dayne Chance, Director of Financial Aid at 908-709-7089 If the Department of Education has questions regarding this plan, please contact the appropriate individual outlined above.

Finding 2024-001 – Special Tests and Provisions – Enrollment Reporting (Noncompliance and Significant Deficiency) Identification of the Federal Program - Student Financial Aid Cluster - Assistance Listing Nos. 84.007, 84.033, 84.038, 84.063, and 84.268 Criteria - Institutions are required to report enrollment information under the Pell grant and the Direct loan program via the National Student Loan Data System (NSLDS). The administration of the Title IV programs depends heavily on the accuracy and timeliness of the enrollment information reported by institutions. Institutions must review, update, and verify student enrollment statuses, program information, and effective dates reported to NSLDS. Institutions are responsible for accurate reporting. According to 34 CFR 685.309(2), the University is required to notify the Department of Education via the NSLDS if a “student has ceased to be enrolled on at least a half-time basis for the period for which the loan was intended”. Changes to status are required to be reported within 30 days of becoming aware of the status change, or with the next schedule transmission of statuses if the scheduled transmission is within 60 days. Condition - A sample of 40 students were selected from the population of all students who received federal student financial aid during the year ended May 31, 2024. We obtained the student records and tested compliance with federal regulations for the specific loans and grants. For 13 out of the 40 students selected for Enrollment Reporting testing, the status change to withdrawn was not reported within the 60 day reporting window after the status change was effective. For 7 out of the 40 students selected for Enrollment Reporting testing, the status change was not reported to NSLDS. Cause - The University’s processes of internal controls for reporting enrollment information and to timely report student status changes to NSLDS were not adequate. Effect - Enrollment reporting to NSLDS did not include accurate information. Identification of Repeat Finding – Repeat finding of prior year finding 2023-001. Student status changes were not reported to NSLDS within the required timeframe. Recommendation - We recommend the University revise its processes for reporting student status changes to NSLDS. The University should implement a process to review, update, and verify student enrollment statuses that appear on the Enrollment Reporting roster files. We also recommend that management implement controls to ensure reported changes are timely and correctly reported to the NSLDS. Views of Responsible Officials - Management agrees with the finding. Out of the 20 exceptions included in this finding, 16 were properly and timely reported by the University to the third-party service provider. The University is currently working with their third-party service provider to identify the root cause of the untimely reporting. Corrective Action Plan for Finding 2024-001 - The University provided additional training and monitoring to the employees involved in this process. Furthermore, the University engaged a former employee on a contractual basis to assist with the reporting process. The contract employee has significant experience in reporting information to the University’s third-party agent, National Student Clearinghouse (NSC), and to the National Student Loan Data System (NSLDS). The University is actively working with the Audit Resources team at NSC to revise our reporting processes and develop a reporting schedule that will more closely align with the University's calendar and eliminate the root cause of the data errors.

Finding 2024-003 Lack of Internal Control over Activities Allowed or Unallowed and Allowable Costs/Cost Principles Name of Contact Person: Ralph Watkins, Superintendent Corrective Action Plan: All payroll reports will be reviewed for correct coding to district grants. Proposed Completion Date: June 30, 2025