Corrective Action Plans

The Child and Family Services Agency (CFSA) concurs with this finding as stated. The corrective action is already completed. Formal correspondence protocols are in place as of April 1, 2025. Contact: James Murphy, Business Services Administrator Estimated Completion Date: Completed See Corrective Action Plan for chart/table

The Child and Family Services Agency (CFSA) concurs with the findings. The finding involved a recurring formula error in the workbook CFSA uses to calculate its lapsing quarter family-based rate adjustment. The issue stemmed from the pandemic-era stimulus funding that increased the District’s FMAP percentage from the standard 70% to 76.2%, which CFSA accommodated in its family-based rate adjustment claiming tools with manual entries. Corrective action is outlined below, but in the meantime the District has returned to the standard 70% FMAP, which precludes recurrence. To address Condition 1 going forward, expenditures occurring within the current fiscal year will be reflected on the SEFA for the Foster Care grant and be consistent with claimed expenditures reported on the CB 496. The CFSA Agency Fiscal Officer and the CFSA Accounting Supervisor will develop a written procedure to prevent expenditures from being charged to other periods. The principal corrective action for Condition 2 will be to update the entire suite of financial tools that undergird the family-based rate adjustment claims. The updates will feature formula “fail safes” that will require validation of the various statistics that inform the claims. CFSA will make an adjusting entry for the entirety of the questioned costs in the next federal claim, to be submitted on or before August 15, 2025. Contact: James Murphy, Business Services Administrator Estimated Completion Date: September 30, 2025 See Corrective Action Plan for chart/table

The Child and Family Services Agency (CFSA) concurs with the findings. The licensure issue involved a provider who was in process of permanently closing her home as a foster care provider (and the existing license expired in the meantime), and the other item involved a brief lapse in the child protection register check. Corrective action will involve improved automation within the claiming process. CFSA also acknowledges that the third bullet regarding the legibility of the background criminal check document for the “other adult in the home” is an internal control issue for which there are no questioned costs. Corrective action will occur within STAAND implementation as key system edits in the foster care maintenance claim report will account for lapsing/expiring (according to District standards) licensure documentation. Payments to providers that do not meet title IV-E requirements across all axes will be left out of the IV-E foster care maintenance claim. Contact: James Murphy, Business Services Administrator Estimated Completion Date: December 31, 2025 See Corrective Action Plan for chart/table

The University of the District of Columbia (UDC) agrees with the conditions and recommendations of this finding. Action plan steps include the following: • The Office of the Registrar will continue to use National Student Clearinghouse third party reporting tool to report enrollment data to NSLDS. • The Office of the Registrar continue to utilize the "Submission schedule tool" to keep us compliant with the timeframe required for submission of the reports. • Students who have been reported during the first week of courses as "Never Attended - NA" will be dropped from there courses for the term no more than 1 week after the end of attendance verification. • The Enrollment Time Status (Full Time, Part Time, etc.) for student who are enrolled in Summer courses will be updated effective immediately. Contact: Nakia Pugh, Associate Registrar Estimated Completion Date: June 2, 2025 See Corrective Action Plan for chart/table

The University of the District of Columbia (UDC) agrees with the conditions and recommendations of this finding. Action plan steps include the following: • Correcting the Issue - R2T4 Funds have been returned in COD as of 06/03/25 for sample selection #15 of the R2T4 sample. • Reporting the Downward Adjustment to update COD - R2T4 Funds have been returned in COD as of 06/03/25 for sample selection #15. • Review all official and unofficial R2T4s - We will now pivot to ensure that all R2T4 files are reviewed as opposed to only a random selection. Also, we will now begin to send email notifications to both loan and Pell reporting individuals. Additionally, calendars for all involved staff members will be updated to reflect the regulatory requirements for returning Title IV funds. Wayne Montgomery, Director of Financial Aid Contact: Katrina Johnson, Compliance Officer Estimated Completion Date: June 3, 2025 See Corrective Action Plan for chart/table

The University of the District of Columbia (UDC) agrees with the conditions and recommendations of this finding. Action plan steps include the following: • The Bursar or designee shall run a report daily of all Title IV disbursements that occurred on the prior business day. • The Bursar or designee will run the SA Registration Review report for the terms shown on the disbursement report above and select students who had a Title IV disbursement based upon the report above. • The students with the disbursements shall be reviewed in addition to any other student shown having a Title IV Credit balance to determine if a non-refunded Title IV credit balance exist. • Where a non-refunded Title IV credit balance exist, the student shall be included in the list of refunds named Refund Review Report dd/mm/yyyy to be processed following the institution refund process for Title IV Credit Balances. • At the end of the day, the Bursar or designee shall generate a report showing the refunds entered in the SIS for that day and confirm all previously identified Title IV refunds credit balance refunds were completed and attach said report to the refund review report and save in a designated folder. • The Bursar or designee will complete the batch release process daily to allow refund entered on student records to be transmitted to AP following institutional process. • On the AP check run date, the Bursar or designee shall review the check run notification from AP to confirm all refunds entered in SIS since last check run date have been processed successfully. Contact: Stephen Toppin, Bursar Estimated Completion Date: June 8, 2025 See Corrective Action Plan for chart/table

Finding 2024-046 Temporary Assistance for Needy Families, ALN 93.558 - Inappropriate TANF- Funded Emergency Foster Care Assistance Management Views MDHHS agrees with the finding. Planned Corrective Action MDHHS redetermined the Foster Care Title IV-E (Title IV-E) program eligibility after the birth certificate was identified and the youth was determined to be Title IV-E eligible. MDHHS will reclassify the funds to the appropriate funding source, allowing the department to claim Title IV-E for the eligible placement. For those cases in which Title IV-E funding is denied initially based on lack of a birth certificate or other documentation of citizenship, the Child Welfare Funding Specialists will continue to monitor the case for updated documentation in order to complete a redetermination of funding. Child Welfare Funding Specialists will be reminded to monitor cases for updated documentation during a Child Welfare Funding conference call in June 2025. Anticipated Completion Date June 30, 2025 Responsible Individual(s) Nancy Berger, MDHHS

The instances identified in this finding represent individuals who, in several cases, were processed in the same batches ( e.g., COD date 9/28/23, disbursement date on ledger 10/3/23, and COD date 11/3/23, disbursement date 11/8/23). CMN recognizes the importance of disbursing funds to student accounts on the date that funds are stated to be disbursed through COD. While there have been instances of funds not being available in COD in a timely manner, the financial aid coordinator and bursar will work together to ensure these disbursements are completed on the same date in order to remain compliant with stated CMN policy.

The College has identified that the dates of Return of Title IV Calculations and amounts (in one case) were out of compliance. The return calculations for all three students identified through this audit have been completed and corrected to reflect the correct return amounts, if appropriate. Student 1: After changing from an attendance-taking institution to a non-attendance taking institution, this student was identified during the audit as a student who may not have completed the term due to all F/NP grades. Calculation was completed and a return was made based on the midpoint date of the spring term. Student 2: After changing from an attendance-taking institution to a non-attendance taking institution, this student was identified during the audit as a student who may not have completed the term due to all F /NP grades. Calculation was completed and a return was made based on the midpoint date of the spring term. Student 3: Student officially withdrew but withdrawal was not processed until the end of the term. Since the withdrawal was not processed in a timely manner, the enrollment status (as noted in fmding 2024-001) and subsequent R2T4 calculation was delayed. Calculation was completed and a return was made based on the date indicated in the official withdrawal documents. Due to delayed calculations on these three students, CMN will continue to work with fmancial aid staff and the registrar's office to streamline communication on withdrawals and students who complete the term with all F/NP grades, as indicated in CMN policy. CMN has already worked with Anthology (student information system)'to provide electronic triggers to the fmancial aid office when a student status changes from active to drop/withdrawal. Additionally, Enrollment Management notifies all faculty by email at the beginning of the term and again prior to fmal grades being submitted that electronic notification must be sent by the faculty to financial aid in order to alert the fmancial aid office of the date oflast academic engagement for students who earn an For NP grade. For the current audit period, the Director of Enrollment Management and the Financial Aid Coordinator work together to review a final grade report for all students and identify those who need R2T4 calculations based on that review. Both the director and coordinator sign the working documents to indicate that it has been reviewed by both parties. We will continue with this process and will refme as necessary, but we anticipate that this will resolve the issue of calculations not having been performed on students with all F /NP grades at the end of the term.

The College has identified that the dates of enrollment submissions and status changes for the two students identified in the audit were out of compliance (102 days and 69 days). The statuses of both students are correct with NSLDS. Student 1: Student officially withdrew but withdrawal was not processed until the end of the term. Since the withdrawal was not processed in a timely manner, the enollment status and subsequent R2T4 calculation (as noted in finding 2024-002) was delayed. Student 2: Student graduated, and status was updated with NSLDS at 69 days. Due to delayed communication and delayed reporting to NSLDS, CMN will revise institutional policy to clearly define the process and timeline for enrollment status changes. Financial aid staff will seek additional training in enrollment reporting through FSA and/or NSFAA. To further monitor compliance, CMN has already worked with Anthology (student information system) to provide electronic triggers to the financial aid office when a student status changes from active to drop/withdrawal. This electronic, automatic process will provide an additional layer of notification to the financial aid office when a student status change requires further attention.

2024-002 – Special Tests and Provisions - Enrollment Reporting – Material Weakness in Internal Controls over Compliance Student Financial Assistance Cluster Department of Education Federal Assistance Listing Number: 84.063, 84.268 Federal Program Name: Federal Pell Grant Program, Federal Direct Student Loans Federal Award Number: P063P230357, P268K230357 Award Year: 2023-24 Criteria: The National Student Loan Data System (NSLDS) is the Department of Education’s (ED) centralized database for students’ enrollment information under the Pell Grant and the Direct Loan and Federal Family Education Loan programs. Uniform guidance requires institutions to have internal controls in place to ensure attendance changes for students are reported to NSLDS within at least 60 days of when the student attendance change occurs. It is the College’s responsibility to update students' enrollment information timely and accurately as outlined in 34 CFR § 685.309. Condition/context: The auditors selected a sample of 34 students out of a population of 1,454 who had received Federal aid and had withdrawn or graduated from the College during the 2023-2024 fiscal year. The auditors compared the withdrawal or graduation date per the College’s records to NSLDS. The auditors noted eight students were not reported to NSLDS within the 60-day requirement. In addition, the auditors identified ten students who graduated but were not reported as graduated to NSLDS. Corrective Action: LCC reports enrollment to the National Student Clearinghouse: in the second, sixth and the tenth week of each standard term. There is an error report that the Clearinghouse returns with discrepancies in enrollment status which we respond to and correct within five business days. Once all errors are resolved and the report is accepted the NSC will post the data and report to NSLDS. Lane is an open access institution and therefore does not have a formal withdrawal policy. Two weeks after the end of each term, Lane sends the enrollment report and the “degree verify” extract to NSC. We are in the process of reviewing our NSC reporting strategies and including additional staff who will be supporting the process. We are reviewing NSC reporting times to ensure that we are reporting often enough to meet the required 60 day timeline for NSLDS. We are considering moving the enrollment and degree verify extract to a 30 day reporting period to meet the 60 day timeline. Phase 1: Issue an off cycle report to the NSC by June 6th, which is our next anticipated enrollment reporting cycle (week ten). We will send both the enrollment report and the “degree verify” extract to catch any updates to graduation information that may have changed since our last end of term report. Phase 2: Review updates to NSC processes that were issued through Banner and Ellucian and revise the “degree verify” process to capture regular graduation or withdrawal updates outside our standard reporting window. Unless it is discovered that the 30 day cycle does not meet the requirements of the reporting cycle, we will update our processes to - at a minimum - report every 30 days or in alignment with the weeks two, six and ten current enrollment report to the NSC. Additionally, the students noted in the finding will be reviewed to address any potential anomalies with reporting and to identify the cause of why these were not updated. This will be another consideration during the assessment for any updates to our reporting cycles. Following spring term, we will report graduated and withdrawn students, as is our current practice and after student degree awarding is complete. Name of Contact Person Responsible for Corrective Action: Dawn Whiting Anticipated Completion Date for the Corrective Action: A review process of 90 days should result in refined practices and an implementation of those practices to meet required reporting. All reporting changes will be finalized and followed by Aug 21, 2025.

The finding from Section III – 2024-006 General Ledger System Condition: The District did not track the federal expenditures within the general ledger system, or if they were, the business office was unaware of the process and was not using the correct expenditures to claim as eligible expenditures. Views of Responsible Officials and Planned Corrective Actions: Southern Fulton School District has hired a Certified Public Accountant (CPA) as the Chief Financial Officer (CFO) as of 4/1/2025 who will be responsible for ensuring that the general ledger system is utilized to track all federal expenditures.

The finding from Section III – 2024-005 Reporting Requirements Condition: The District did not file the Title 1, Title 2, and Title 4 Reconciliation of Cash on Hand Quarterly Reports for March 2024 and June 2024.Additionally, the Final Expenditure Reports for Title 1, Title 2, and Title 4 were not filed by the required date. Views of Responsible Officials and Planned Corrective Actions: Southern Fulton School District has hired a Certified Public Accountant (CPA) as the Chief Financial Officer (CFO) as of 4/1/2025 who will be responsible for ensuring all Title reports are filed timely and by the deadlines.

DEPARTMENT OF TRANSITIONAL ASSISTANCE 2024-026 Temporary Assistance for Needy Families (TANF) - Assistance Listing No. 93.558 Recommendation: We recommend the Department evaluate its procedures and internal controls over Child Support Non-Cooperation to ensure that sanctions are applied timely. Action taken in response to finding: The Department will utilize existing training opportunities, including but not limited to new hire training, monthly supervisor webinars and ad hoc guest training from DOR to address this topic as needed. Further, the Department is working on building out a quality control program on sampling of TAFDC cases in the Quality Management organization. When built out, this program would include a sample review of child support non-cooperative cases to ensure sanctions are applied timely and appropriately. In the interim, ad hoc targeted reviews on this topic will be performed annually at minimum as a compensating control for risk mitigation. Reviews will be performed on a sample basis. Name(s) of the contact person(s) responsible for corrective action: Megan Nicholls, Associate Commissioner of Family and Economic Assistance - Training Lily Kuo, Director of Internal Controls – Ad hoc Targeted Reviews Planned completion date for corrective action plan: September 30, 2025 and forward – Facilitate training March 30, 2026 and forward – Perform ad hoc targeted reviews

Finding 2024-002 - Special Tests and Provisions - Federal Direct Loan Program Student Notification – Significant Deficiency Name of Federal Agency: U.S. Department of Education Federal Program Name: Federal Direct Student Loans Assistance Listing Number: 84.268 Federal Award Identification Number and Year: P268K243382 2024 Name of Pass-through Entity: N/A Planned Corrective Action: The failure to timely send out the required notification of Federal Direct Student Loan Program proceeds credited to one student’s account, as noted in the auditor’s findings, was an administrative oversight. In May 2025, the Institute reviewed and revised its current procedures to ensure that all required notifications are made. Under the revised procedures, an employee independent from the student loan proceed crediting notification process is to review that notifications are sent out within prescribed time frames in accordance with U.S. Department of Education regulations to all students receiving and being credited with Federal Direct Loan Program amounts and that copies of the notifications are maintained in each applicable student’s file.

Finding 2024-001 – Special Tests and Provisions – Exit Counseling – Significant Deficiency Name of Federal Agency: U.S. Department of Education Federal Program Name: Federal Direct Student Loans Assistance Listing Number: 84.268 Federal Award Identification Number and Year: P268K243382 2024 Name of Pass-through Entity: N/A Planned Corrective Action: The failure to document the exit conference of one student borrower in the Federal Direct Loans Program, as noted in the auditor’s findings, was an administrative oversight. In May 2025, the Institute reviewed and revised its current procedures to ensure that all exit conferences are documented. Under the revised procedures, an employee independent from the exit conference process is to review that any student that has not enrolled in a new semester or that is enrolled at less than half time status has received proper exit conferencing and that the exit conferencing has been properly documented.

Finding NO. 2024-0006 – Reporting View of the University of Guam and Correction Action Plan: An agreed upon timeline for generating data will be established for use in the annual FISAP. The Admissions and Records Office will generate the school enrollment for the relevant academic year. The data snapshot will be taken immediately after the end of the summer semester. For the enrollment data for AY24-25, the snapshot will be taken during the first week of September 2025 with a similar timeline for subsequent years. Once that data snapshot is generated, the Office of Information Technology will generate a report of collected tuition and fees corresponding to the snapshot data from Admissions and Records. In testing, this was found to be the most accurate process in generating the required data for the FISAP. Name of Contact Person: Mark Duarte, Director, Financial Aid and Triton One Stop Office Proposed Completion date: Next Reporting Period

Finding NO. 2024-005 Special Tests and Provisions – Enrollment Reporting View of the University of Guam and Corrective Action Plan: The University of Guam has signed a service agreement with the National Student Clearinghouse (NSC) to assist the University with enrollment reporting. The Admissions and Records Office (A&R) will submit an enrollment report to the NSC at least four times per semester. A first of term report, and three other subsequent reports within the semester. This report will be sent to the National Student Loan Database System (NSLDS) in fulfillment of the federal regulations requirement for enrollment reporting. Name of Contact Person: Mark Duarte, Director, Financial Aid and Triton One Stop Office Proposed Completion date: Next Reporting Period

Finding NO. 2024-003 Cash Management View of the University of Guam and Corrective Action Plan: The Financial Aid Office (FAO) will conduct both internal and external monthly reconciliations to ensure the accuracy of financial aid disbursements and compliance with federal regulations. Internally, the FAO and the Business Office will reconcile actual disbursements and adjustments against drawdowns, drawdown adjustments, refunds of cash, and returns weekly or bi-weekly, following each transmittal to the Business Office. Any discrepancies will be documented and resolved promptly. Externally, the FAO will reconcile with the COD system by the 10th of each month, comparing all disbursements, adjustments, and refunds to the balances reported in COD. A copy of the completed monthly reconciliation will be forwarded to Accounts Receivable as official documentation. Name of Contact Person: Mark Duarte, Director, Financial Aid and Triton One Stop Office Proposed Completion date: Ongoing

Finding NO. 2024-002 Special Tests and Provisions – Disbursements to or on Behalf of Students (Credit Balances) View of the University of Guam and Corrective Action Plan: To comply with federal regulations regarding the timely disbursement of Title IV credit balances, the University’s Business Office established a payment log in October 2024 to monitor and document all related transactions. Furthermore, to ensure ongoing compliance, the University will create a Standard Operating Procedure to be distributed among the Business Office staff. Name of Contact Person: Abigail Martin, Comptroller Proposed Completion date: September 30, 2025

Action taken in response to finding: Admissions training manuals have been updated to ensure that the date the student first indicated a desire to withdraw from a course is used as the date of withdrawal rather than the date that the withdrawal was processed in Colleague. Admissions staff members have been trained on the updated procedure for processing student course withdrawals. The Office of Institutional Research has reviewed and updated the procedures used to generate reports sent to National Student Clearinghouse. IR staff members will ensure that the last date of attendance is reported for student course withdrawals. The office of Institutional Research has contacted National Student Clearinghouse for guidance on the enrollment reports needed to ensure that student enrollment is reported to NSLDS accurately and timely. An additional enrollment report will now be sent to National Student Clearinghouse for reporting graduated students. This will ensure that students that have graduated are reported as no longer enrolled within the required reporting timeframe.

Action taken in response to finding: As a result of the 2023 audit, which concluded in May of 2024, adjustments were made to reflect a five day fall break for Fall 2024. R2T4 calculations for Fall 2024 have been reviewed and the use of a five-day break for the term has been verified. The Fall 2025 term has already been built in Colleague to reflect a five day fall break. The Fall 2023 term was built in Colleague by the previous Director of Financial Aid. The current Director of Financial Aid has recognized a five-day break when building the fall terms in Colleague and will continue this practice for future terms. In following our recently updated R2T4 process, all Financial Aid staff members have been trained and are able to perform R2T4 calculations. R2T4 calculations for the 2024-2025 academic year have been performed by Financial Aid staff and have been reviewed for accuracy and approved by the Director of Financial Aid.

Finding #2024-001 – Significant Deficiency and Other Noncompliance. Applicable federal program: U. S. Department of Education, Student Financial Assistance Programs Cluster, Assistance Listing #84.063, Federal Pell Grant Program, Assistance Listing #84.268, Federal Direct Student Loans, Contracts #003556 and G03556, Contract years: 05/05/21 – 12/31/26. Recommendation: Emphasize the importance of accurately reporting enrollment status. Planned corrective action: Management agrees with audit finding #2024-001. The Financial Aid Coordinator is responsible for reporting enrollment status changes, certifying enrollment every 60 days, and responding to NSLDS Roster files within 15 days, all through the NSLDSFAP website. To enhance the accuracy of these enrollment reports, the Institute is implementing a new double-check process. Henceforth, the Financial Aid Coordinator will print all enrollment status changes or enrollment report rosters prior to making any online updates or certifications. These printed reports will then be given to the Director of Operations for verification. Only after this verification will the Financial Aid Coordinator proceed with the necessary changes or certifications on the NSLDSFAP website. All printed reports will be retained by the Financial Aid Coordinator for documentation. Responsible officer: Cody Lopasky, President. Estimated completion date: June 1, 2025.

At the time that the last FISAP was completed, the Financial Aid office was severely understaffed. As a result, an oversight occurred in reporting dependent undergraduate students with Baccalaureate degrees. In thi instance, the correct information was retrieved, however it was reported incorrectly. Staffing in the Financial Aid office has been addressed by hiring an Advisor and Assistant Director. Moving forward, the Assitant Dean will continue to complete the FISAP. However, prior to submission, the application will be reviewed by both Assistant Directors of Financial Aid. Contact person(s) responsible for corrective action: Yvette McGhee, Assistant Dean of Financial Aid. Anticipated completion date: Immediate

2024-004 – Disbursing Funds (Significant Deficiency) Department of Education, SFA Cluster, Special Tests and Provisions Criteria: Except for paying a student under the Federal Work Study program or unless 34 CFR 685.303(d)(4)(i) applies, an institution must disburse during the current payment period the amount of Title IV, HEA program funds that a student enrolled at the institution is eligible to receive for that payment period. (34 CFR 668.164 (b)(1). Condition: From a population of 679 students that received the Pell grant, we tested 24 students and noted that two students did not receive the Pell awards for which they were eligible, and one student received an incorrect Pell award. Cause: Controls to ensure accurate disbursements to students are not functioning properly. Effect: Two students did not receive Pell awards they were eligible for during the payment period and one student received more Pell funds than they were entitled to. Recommendation: We recommend that procedures are put in place to ensure timely and accurate payment of Title VI awards. Action Taken: Shortages in staffing did not allow for double checking student enrollment post census. To correct this situation, we have added an additional counselor. We are working with a consultant to automate manual processes to free up more counselor time. Responsible Party and contact information: Daisy Tabachow, Director of Financial Aid. Expected Date of Correction: Beginning with the summer 2025 trimester and ending at the end of the fiscal year.