Corrective Action Plans

Name of Responsible Individual: Dylan Nowakowski, Assistant Director of Financial Aid Corrective Action: There is no documentation available to indicate that a professional judgement was completed at the time of the incident cited. Wheeling did not have access to any documentation such as log notes, documents, or contact records of any kind. The DPT program budgets differ in amount for first- and second-year attendance. It is known that at this time, the first-year budget was not available, and some student budgets were not separated and entered correctly for first- and second-year cost of attendance. A Financial Aid Office policy has been established to ensure that proper documentation and records maintenance is achieved. Staff enter detailed log notes regarding student contact and results of those contacts. A Budget Adjustment form has been created for students to present to the office if they request a cost of attendance and budget increase. These forms are scanned into the individual student file and is easily obtained for future use when and if necessary. Each DPT budget year has been incorporated into a spread sheet format. Any change to a budget item is input into the sheet and the system will auto calculate a new or different budget amount. These new numbers and the updated COA (cost of attendance) are inserted into the colleague system and is a permanent, easily retrievable record. Anticipated Completion Date: July 2023.

In order to address this audit finding, CMN financial aid staff plans to seek continual improvement in the areas relating to Return of Title IV funds calculations. Through both Federal Student Aid and National Association of Financial Aid Administrators (NASFAA), staff will complete trainings to understand calculation and timing of returns. It should also be noted that in the current award year, CMN has moved to a model where attendance taking is not required, so staff is working with faculty and students to ensure timely notification of withdrawal and reviewing final grades at the end of the term in order to ensure all students needing a R2T4 calculation have one performed.

In order to address this audit finding, CMN financial aid staff plans to seek continual improvement in the areas relating to Pell calculations. Through both Federal Student Aid and National Association of Financial Aid Administrators (NASFAA), staff will complete trainings to understand all aspects of calculating awards, as well as staying up to date on regulatory changes through our student information system. In addition to more training in this area, priority will be placed on rechecking and auditing Pell awards so that they are reviewed during the award year. Staff has already begun reviewing fall 2023 Pell awards for accuracy and will continue to review awards as terms move forward.

Special Tests and Provisions: Return of Title IV funds for withdrawn students (Repeat finding 2021-004, 2020-002, 2019-003, 2018-005, 2017-004, 2016-003, 2015-004, 2014-011) Name of contact person responsible for corrective action plan: Rhett R. Vertrees, Assistant Chief Financial Officer 2601 Enterprise Road, Reno NV 89512-1666 Phone: (775)784-3409, Fax: (775)784-1127 Email: rvertrees@nshe.nevada.edu Responses CSN agrees with the findings. • Detailed corrective action taken, including what will be done to avoid the identified issues in the future, and when these measures will be in place; CSN has started to select additional team members to cross train with seasoned R2T4 team members on the processing of R2T4 files. This will ensure that files are processed in a timely manner and meet compliance requirements. Additionally, training opportunities will be assessed and offered to the team members who are processing R2T4 records on an ongoing basis. Additionally, CSN is currently assessing a potential 3rd party vendor to assist with the processing of R2T4s as needed on an ongoing basis. • How compliance and performance will be measured and documented for future audit, management and performance review. Cross training and workshop opportunities will be provided to ensure knowledge and compliance for the R2T4 team and any staff member assisting with processing of R2T4 records. Queries will be utilized to track R2T4 files to ensure timely processing. • Who will be responsible and may be held accountable in the future if repeat or similar observations are noted. The Assistant Director of Financial Aid will be responsible and may be held accountable.

Internal Control over Compliance (Repeat Finding 2022-001, 2021-003, 2020-001, 2019-002, 2018-003, 2017-002, 2015-002, 2014-008) Name of contact person responsible for corrective action plan: Rhett R. Vertrees, Assistant Chief Financial Officer 2601 Enterprise Road, Reno NV 89512-1666 Phone: (775)784-3409, Fax: (775)784-1127 Email: rvertrees@nshe.nevada.edu Responses UNR agrees with the findings • Detailed corrective action taken, including what will be done to avoid the identified issues in the future, and when these measures will be in place; The technical staff can only have the PeopleSoft Administrator (PSA) role in either development or production, but not both. There is an approval process in place to ensure that access is removed from either development or production when a PSA needs to be moved across to the other environment. This process became effective March 1, 2023. There is a quarterly security review of the PeopleSoft Administrator role in PeopleSoft. The first quarterly review was performed in FY16 Q1 and has been performed each quarter since. The reviews are documented and approved. There is a quarterly security review of the PeopleSoft Administrator activities in PeopleSoft. The first quarterly review was performed in FY22 Q4 and has been performed each quarter since. The reviews are documented and approved. There is a quarterly security review of the PeopleSoft Oracle database and user access. The first quarterly review was performed in FY20 Q2 and has been performed each quarter since. The reviews are documented and approved. • How compliance and performance will be measured and documented for future audit, management and performance review. Compliance and performance can be measured by the documented quarterly reviews. • Who will be responsible and may be held accountable in the future if repeat or similar observations are noted. The PeopleSoft Manager will be responsible for ensuring the corrective actions plans are implemented and followed. The Vice President of Information Technology will be accountable for the department’s compliance. UNLV agrees with the finding. • Detailed corrective action taken, including what will be done to avoid the identified issues in the future, and when these measures will be in place; UNLV understands the importance of adequate segregation of duties within the PeopleSoft environments and applications. The PeopleSoft Administrator (PSA) position that is the subject of the finding is responsible for the installation, configuration, upgrades, and troubleshooting of all the application environments. The PeopleSoft Administrators are not programmers/developers, and their access to the production environments is periodically required to perform the needed activities required to provide timely support of the application within the scope of their job duties. UNLV has implemented the following controls to mitigate the risks associated with the elevated access required for the administrators to perform their required support activities. 1. UNLV has removed all persistent assignment of the PeopleSoft Administrator role from all PSAs in all environments. 2. The PeopleSoft Administrator role is temporarily assigned only when elevated actions are required. All assignments are of a limited duration and include a justification detailing the need and actions to be performed. All assignments trigger the follow actions: a. An immediate notification to the Director of Business Continuity & Resiliency and the Interim Senior Associate Vice Provost for Digital Strategy and Transformation. b. Removal is automatic but can be initiated by PSA if work is completed sooner than expected. c. All details around the assignment are captured in a tracking table. d. A review of all assignments and activities is performed monthly. 3. UNLV will continue to review access, activities, and assigned privileges monthly for the PeopleSoft Administrators. 4. UNLV will continue researching and implementing other control methods that may strengthen the segregation of duties or the monitoring capabilities that are available. • How compliance and performance will be measured and documented for future audit, management and performance review. The PeopleSoft Administrator role is no longer persistently assigned to the PSA position. It is only assigned upon request with the knowledge and approval of approving authorities. UNLV performs monthly reviews of the access and activities to determine if the PeopleSoft Administrators' activities align with the necessary support. Additionally, UNLV will continue to research other control methods that will address the segregation of duties while providing appropriate service and support. • Who will be responsible and may be held accountable in the future if repeat or similar observations are noted. The Director of Business Continuity & Resiliency will be responsible for performing the activity reviews and access needs of the PeopleSoft Administrators. The Director will complete the reviews and is also accountable if repeat or similar observations are noted. The Chief Information Security Officer will verify that reviews are conducted on a monthly basis per audit practices. SCS agrees with the findings • Detailed corrective action taken, including what will be done to avoid the identified issues in the future, and when these measures will be in place; In addition to the compensating controls (a) to (d), that have been operating since prior to FY23 the segregation of PeopleSoft Administrators (PSA) is enforced through a “locked account” process. Only two employees have PSA access in both the Production and Development environment. Each employee can only have access to the Production or Development environment at any one time, i.e., the PSA account in the other environment remains locked. A JIRA ticket must be opened for an account to be unlocked. The request is approved by management and the account is unlocked by a member of the IT Security Team. The controls listed below should also mitigate the segregation of duties risk and support a review of “user activities” in the absence of an appropriate user activities audit log function. (a) STAT for PeopleSoft – Code control and internal modification tracking provides visibility over PSA activities that are processed via this tool. These object changes are reviewed and approved by the Director of Information and Application Services. (b) JIRA ‐ Change control management and project tracking software. Change requests and projects related to the PeopleSoft shared instance are tracked and approved. This would include user access modifications and system updates for example. (c) Security e‐mail alerts – The SCS security team are alerted via automated e‐mails when key events are triggered. For example, an elevated role is assigned to a user. (d) User Access Reviews – On an annual basis an independent user access review is performed incorporating SCS/SA privileged users and all shared instance security coordinators. • How compliance and performance will be measured and documented for future audit, management and performance review. The PeopleSoft Administrators will have persistent unlocked access to either the Production or Development environments only. Their corresponding account in the other environment will remain locked. In the event that access is needed to the locked environment, a ticket will be created requesting access which will document the rationale and approvals. In addition, PSA activities are monitored via the change control process through STAT for PeopleSoft. Object changes within the Production environment for example, are approved along with the associated workflows. • Who will be responsible and may be held accountable in the future if repeat or similar observations are noted. The SCS Director of Information and Application Services, and SCS Security Group are responsible for locking/unlocking PSA accounts. The SCS Security Group monitor PeopleSoft e-mail alerts. The IT Audit Manager is performing annual SCS/SA privileged user access reviews.

NCC conducted staff training to reinforce requirements for the return of funds within 240 days for all federal award checks returned uncashed. Effective November 2023, we implemented an automated process to assist with identifying federal funds that need to be returned.

The attendance process has been moved to the Registrar’s Office and registration status codes for unofficial withdrawals have been created in order for the system to find those students when submitting monthly enrollment reporting to clearinghouse, which is then sent to NSLDS.

Contact person(s) responsible for corrective action - Amy Cavelier and Robert Wagstaff, Registrar’s Office Anticipated completion date – Complete Corrective Action The Registrar’s office will ensure proper controls and processes are in place to ensure program-level effective date information is properly and timely submitted to the NSLDS. Timeframe: June through August 2023 Responsible Parties: Amy Cavelier and Robert Wagstaff Registrar management and staff worked with the College’s Student Information Systems and IT departments to verify when and how the conflicting program-level effective dates were entered. It appeared that the data originating from Jenzabar was correct. Discrepancies were created during the NSC error cleaning process, and data including those discrepancies were reported to the NSC and subsequently the NSLDS. Registrar’s Office management and staff worked with the NSLDS to obtain final student data reports which were compared to the monthly student data files originally submitted to the NSC, prior to error correction, to identify the discrepancies and the cause of the data errors. The College transitioned the enrollment reporting responsibility to another member of the Registrar’s Office. This transition included formal training on the Jenzabar student information system, with a particular focus on NSLDS data reporting, as well as the NSC and NSLDS data submission processes.

Management's Views and Corrective Action Plan Finding 2023-002 - Non-Compliance with Financial Need Requirements for Subsidized Direct Loans in Non-Standard Semesters Grantor: U.S. Department of Education Program: Student Financial Assistance Cluster Assistance Listing#: 84.268 Award Titles: Federal Direct Student Loan Program Program Award Years: 7/2022 - 6/2024 Management agrees with the finding and proposes the following corrective action plan: Corrective Action Plan: When a student attends a standard semester (Fall and Winter), PeopleSoft uses the Prorated Estimated Family Contribution (EFC) Methodology to determine the subsidized loan eligibility based on their EFC. When a student attends a non-standard term (Spring), PeopleSoft uses the Automatic Zero EFC Methodology and offers subsidized loans to all students rather than the subsidized loan eligibility based on their EFC. Tammie Fonoimoana, Financial Aid & Scholarships Senior Manager, will work to update the PeopleSoft system to use the Prorated EFC Methodology for calculating subsidized loan eligibility for both standard and non-standard terms. In addition, Tammie Fonoimoana, Financial Aid & Scholarships Senior Manager, who is responsible for packaging and awarding of Financial Aid at Brigham Young University- Hawaii will continue to provide training to the staff who administer Title IV aid to ensure they are aware of the changes in packaging and awarding subsidized loans for the non-standard term (Spring). Also, Tammie Fonoimoana will oversee the implementation of controls wherein the University will implement preventative mechanisms to verify financial aid packages are calculated correctly. Timing: Tammie Fonoimoana, Financial Aid & Scholarships Senior Manager, will be responsible for overseeing that the items as noted in the corrective action plan section above will be implemented by July 1, 2024. Signed and Acknowledged, Tammie Fonoimoana, Senior Manager BYU-Hawaii Financial Aid & Scholarships Tammie.fonoimoana@byuh.edu 808-675-4737

Management's Views and Corrective Action Plan Finding 2023-001 - Non-Compliance with Timely and Accurate Student Enrollment Change Submissions to the National Student Loan Data System (Significant Deficiency) Grantor: U.S. Department of Education Program: Student Financial Assistance Cluster Assistance Listing#: 84.268, 84.063 Award Titles: Federal Direct Student Loan Program, Federal Pell Grant Program A ward Years: 7 /2022 - 6/2024 Management agrees with the finding and proposes the following corrective action plan: Corrective Action Plan: The prior year's corrective action plan was successful in addressing two of three issues identified in previous audits in enrollment reporting. These additional steps will be taken to address the remaining issue noted during the 2023 audit, which resulted in a repeat finding of 2022-001. When a student returns from a leave of absence, PeopleSoft updates the students' program begin date for the student's return date rather than the original program begin date. Daryl Whitford, Registrar, will continue reviewing program begin dates for students returning from a leave of absence to ensure the proper program begin date is reported to NSLDS. In addition, we will review if any PeopleSoft enhancements can be made to provide additional comfort that the program begin elates are accurate in these circumstances. Daryl Whitdord, Registrar, who is responsible for enrollment reporting at Brigham Young University Hawaii will continue to provide training to staff who participate in enrollment reporting to ensure that they are aware of the campus and program enrollment changes to be reported, the details to be reported for each change, and the importance of submitting changes timely. Also, Daryl Whitford, Registrar, will oversee the implementation of a control wherein the University will review program begin dates for students returning from leave of absence to ensure the proper program begin date is reported to NSLDS. Timing: Daryl Whitford, Registrar, will be responsible for overseeing that the items as noted in the corrective action plan section above will be implemented by September 1, 2024. Signed and Acknowledged, Daryl Whitford, Registrar BYU-Hawaii daryl.whitford@byuh.edu 808-675-3730

Action taken in response to finding: will include Institutional Research compiling the data and then sending to Financial Aid/Admissions for review of the enrollment files. The Financial Aid/Admissions department will test a sample of the student enrollment data that it is correct. The Department will maintain evidence of the review and confirm back to Institutional Research the review has been completed. Institutional Research can then submit the enrollment files to the National Student Clearinghouse.

Action taken in response to finding: Adjustments have been made to reflect the full spring break period in our return of funds process. The number of days campus is considered to be closed for spring break has been updated to nine days for Spring 2024. Spring terms in the future will be set up in Colleague with the day following the last day of classes prior to spring break as the first day of spring break and the day prior to the first day of classes after spring break as the last day of spring break. For 2023-2024 and 2024-2025, this equates to a nine-day spring break. All R2T4 calculations for Spring 2024 have been reviewed and recalculated using a nine-day spring break rather than a seven-day spring break. In communicating with Ellucian regarding the processing of R2T4, we discovered a report that we can run in Colleague to identify students that have withdrawn from all courses and will not complete any courses for the semester. This will be used instead of the report made in house, previously utilized for this process. A financial aid staff member will run the report and perform the R2T4 calculations in Colleague. Then the staff member that performed the calculations will run the Return of Funds Detail Report in Colleague, indicate on that report that they performed the calculations, and send the report to the Director of Financial Aid. The Director will review the Return of Funds Detail Report and the calculations. The Director will sign off on the Return of Funds Detail Report approving the calculations. The report will then be saved in the Return of Funds folder in the Financial Aid Files. All Financial Aid staff members will be trained and have the ability to perform R2T4 calculations to ensure that the calculations can be performed regularly prior to each student refund date during the term. All R2T4 calculations for the 2023-2024 school year have been reviewed for accuracy. Calculations performed for the fall 2023 semester have been reviewed by the Director of Financial Aid for accuracy. Due to short staffing in the Financial Aid Office in the spring semester, and remaining staff not being trained on the R2T4 process, calculations for the Spring 2024 semester were performed by the Director of Financial Aid. To ensure the accuracy of the calculations, the calculations were checked using the R2T4 calculation tool in COD (Common Origination Disbursement).

Finding: The Department of Children, Youth, and Families did not have adequate internal controls over reporting requirements for the Foster Care program. Questioned Costs: Assistance Listing # 93.658 93.658 COVID-19 Amount $0 Status: Corrective action complete Corrective Action: The Department partially concurs with the finding. The Department acknowledges that errors were made in the crosswalks and quarterly reports submitted during the audit period. To address the auditor’s specific finding, the Department has: • Reviewed and updated all electronic versions of the quarterly crosswalks for accuracy. • Submitted corrections for the federal fiscal year 2023 Quarter 3 report. The conditions noted in this finding were previously reported in finding 2022-051. Completion Date: February 2024 Agency Contact: Stefanie Niemela Audit Liaison PO Box 40970 Olympia, WA 98504-0970 (360) 725-4402 stefanie.niemela@dcyf.wa.gov

Finding: The Department of Children, Youth, and Families did not have adequate internal controls to ensure group care facility employees and adults residing in prospective caregivers’ households had cleared background checks before having unsupervised access to children. Questioned Costs: Assistance Listing # 93.658 93.658 COVID-19 Amount $0 Status: Corrective action complete Corrective Action: The Department partially concurs with the finding. The auditors identified two exceptions where fingerprint checks for two family foster home adults were completed two days later than the required timeline of 15 calendar days. The delay was due to the misspelling of one applicant’s last name in the system. Upon correction, the applicants subsequently completed the fingerprint checks and were determined eligible. As stated in the finding’s Cause of Condition, the Department developed a corrective action plan to address the internal control deficiencies in response to the prior year’s finding which had not been fully implemented within the current audit period. The Department is confident that all staff who work with children and youth have cleared background checks. As of April 1, 2023, the Department implemented a new process for processing background checks for group care facilities to strengthen internal controls, documentation, and clarification on the “effective date.” The updated process is outlined below: • A new form was created with clear instructions for the group care facilities to provide the applicant/employee information, including the background check confirmation code, directly to the Department’s Background Check Unit (BCU). • The BCU works with the applicant/employee through the fingerprint background check process. • The results are sent directly to the BCU, at which time they complete a child abuse/neglect history check and if needed a suitability assessment. The BCU documents the results in FamLink with the date the background check is completed. • The BCU emails the results to the group care facility and the Department’s Licensing Division (LD) group. If the applicant/employee is cleared and is not a renewal, LD staff adds the applicant/employee to the group care facility in FamLink with the clearance information attached. The conditions noted in this finding were previously reported in finding 2022-050. Completion Date: April 2023 Agency Contact: Stefanie Niemela Audit Liaison PO Box 40970 Olympia, WA 98504-0970 (360) 725-4402 stefanie.niemela@dcyf.wa.gov

Finding: The Department of Children, Youth, and Families did not have adequate internal controls to ensure monthly foster care maintenance payments to children’s caregivers were adequate and accurate for the Foster Care program. Questioned Costs: Assistance Listing # 93.658 93.658 COVID-19 Amount $0 Status: Corrective action in progress Corrective Action: The Department is committed to strengthening internal controls and complying with grant requirements. As stated in the finding’s Cause of Condition, the Department utilizes FamLink as the case management system for the Foster Care program which, due to system limitations, did not have the reporting capabilities to track rate setting reviews during the audit period. To assist with tracking rate setting requirements, the Department: • Created a new report in FamLink to assist rate assessors in identifying six-month reviews that have not been performed timely. • Implemented monthly tracking by supervisors to assist with internal controls and compliance. In response to the auditor’s recommendations and to assist in compliance, the Department has submitted a request to the technical team for an update to the report to also show when the next rate assessment is due. Completion Date: Estimated June 2024 Agency Contact: Stefanie Niemela Audit Liaison PO Box 40970 Olympia, WA 98504-0970 (360) 725-4402 stefanie.niemela@dcyf.wa.gov

Finding: The Department of Children, Youth, and Families did not have adequate internal controls to ensure payments to providers for travel and family visits were allowable and adequately supported for the Foster Care program. Questioned Costs: Assistance Listing # 93.658 93.658 COVID-19 Amount $0 Status: Corrective action complete Corrective Action: The Department is committed to strengthening internal controls and complying with grant requirements. As stated in the finding’s Cause of Condition, the Department was unable to fully implement the prior corrective action plan during the audit period. In April 2023, the Fiscal Integrity Unit collaborated with other divisions to implement the following internal controls: • Utilized algorithms in the Sprout system to identify reimbursement requests outside of a reasonable amount. • Required providers to submit additional documentation or explanation for those identified amounts. • Implemented a re-run process for prior billing periods to eliminate potential double billings by providers. • Trained headquarters and field office accounting staff to utilize the new algorithms and review additional documentation prior to processing payments. • Required program staff review and approval of all vendor invoices prior to release of payment for the Eastern Washington regions. In January 2024, the Fiscal Integrity Unit identified and implemented regional program approvals for Western Washington providers. The Contracts office has also taken the following actions: • In August 2023, filled one vacant staff position dedicated to reviewing child welfare contracts to include family time visit payments. • In November 2023, developed compliance audit plans for child welfare contracts and began fiscal monitoring of family time visit payments. • In December 2023, filled an additional vacant staff position dedicated to reviewing child welfare contracts. The conditions noted in this finding were previously reported in findings 2022-048 and 2021-040. Completion Date: January 2024 Agency Contact: Stefanie Niemela Audit Liaison PO Box 40970 Olympia, WA 98504-0970 (360) 725-4402 stefanie.niemela@dcyf.wa.gov

Management Views and Corrective Action Plan Year Ending December 31, 2023 Finding 2023-002 - Untimely Return of Title IV Requirements Grantor: U.S. Department of Education Program: Student Financial Assistance Cluster Assistance Listing#: 84.268, 84.063 Award Titles: Federal Direct Student Loan Program, Federal Pell Grant Program Award Years: 7/2022 – 6/2024 Management agrees with the finding and proposes the following corrective action plan: Corrective Action Plan The College hired two new financial aid employees during the Fall 2023 semester. These employees will be responsible for monitoring student withdrawals and performing return of title IV fund calculations on a weekly basis to ensure all refunds transactions are processed timely and accurately. Additional training will be provided by Riley Niemand, Financial Aid Manager to ensure compliance with R2T4 regulations. Timing Riley Niemand is currently training these new employees on the return of title IV fund process. This training will be completed by September 1, 2024. Sincerely, S. Christopher Reitz Director of Financial Services and Controller creitz@ensign.edu 801-524-8109

Management Views and Corrective Action Plan Year Ending December 31, 2023 Finding 2023-001 - Inappropriate Amounts Included in Loan Notification Letters (Significant Deficiency) Grantor: U.S. Department of Education Program: Student Financial Assistance Cluster Assistance Listing #: 84.268 Award Title: Federal Direct Loan Program Award Years: 7/2022 – 6/2024 Management agrees with the finding and proposes the following corrective action plan: Corrective Action Plan The first instance where disbursement dates and amounts were not included in the communication because the system incorrectly captured the student’s name rather than the date and amount of disbursements was caused by a system update. When PeopleSoft system updates are installed, they sometimes affect the data tables where our notification letters pull from. In this instance an update changed a table referenced in the query used to compile loan notification letters. The letter for this student was sent out before the query could be updated to correct for this change. Because of this issue, management has decided to have all loan notification letters compiled manually, effective January 2024, until a consultant can be brought in to help address the issue. Once the system configuration is corrected, we will return to using automated letters, but will continue to review a sample of loan notification letters each semester as an additional control. The second instance where loan disbursement letters were not sent due to the system not being updated to reflect the new academic was the result of a training issue. During 2023, the College made system changes to address prior year audit findings. These changes were made during the 2022-23 academic year and when the 2023-24 academic year started the system settings were not updated. The financial aid staff responsible for setting up the new academic year in the system will receive additional system setup training to ensure this type of issue does not happen in future academic years. Timing Starting in May 2024, Riley Niemand, Financial Aid Manager will work with a consultant to correct the automated loan notification letter process and to implement a process to review loan notification letters after a system update. This process will be completed by August 31, 2024. In May 2024, Chris Reitz, Controller, will also implement a financial aid review process to ensure loan notifications are completely, accurately, and timely sent to the student and/or parent each semester. System setup training to individuals involved in the process of setting up the new academic year in the system will be completed by Chris Reitz and Riley Niemand in May 2024. Sincerely, S. Christopher Reitz Director of Financial Services and Controller creitz@ensign.edu 801-524-8109

Corrective Action The Office of the Registrar is aware that two separate reports need to be extracted from the Student Information System (SIS) to capture both withdrawal and graduation dates, so both are being reported in a timely manner. National Student Clearinghouse reporting date parameters are also being updated so the last date of attendance is pulled into the fields needing to be reported to NSLDS as the Effective Date. Enrollment reporting will be reviewed and submitted at the start of each term, subsequently within the term, and at the end of the term to ensure reporting timelines are met and that the withdrawal date and effective date match for reporting purposes. Timeline for Implementation of Corrective Action Plan: This corrective action plan was implemented in April 2024. Contact Person: Waqas Mirza, Registrar, waqas.mirza@urbancollege.edu

Corrective Action The Office of the Registrar is aware that two separate reports need to be extracted from the Student Information System (SIS) to capture both withdrawal and graduation dates, so both are being reported in a timely manner. National Student Clearinghouse reporting date parameters are also being updated so the last date of attendance is pulled into the fields needing to be reported to NSLDS as the Effective Date. Enrollment reporting will be reviewed and submitted at the start of each term, subsequently within the term, and at the end of the term to ensure reporting timelines are met and that the withdrawal date and effective date match for reporting purposes. Timeline for Implementation of Corrective Action Plan: This corrective action plan was implemented in April 2024. Contact Person: Waqas Mirza, Registrar, waqas.mirza@urbancollege.edu

Corrective Action The Office of the Registrar is aware that two separate reports need to be extracted from the Student Information System (SIS) to capture both withdrawal and graduation dates, so both are being reported in a timely manner. National Student Clearinghouse reporting date parameters are also being updated so the last date of attendance is pulled into the fields needing to be reported to NSLDS as the Effective Date. Enrollment reporting will be reviewed and submitted at the start of each term, subsequently within the term, and at the end of the term to ensure reporting timelines are met and that the withdrawal date and effective date match for reporting purposes. Timeline for Implementation of Corrective Action Plan: This corrective action plan was implemented in April 2024. Contact Person: Waqas Mirza, Registrar, waqas.mirza@urbancollege.edu

Corrective Action The Office of the Registrar is aware that two separate reports need to be extracted from the Student Information System (SIS) to capture both withdrawal and graduation dates, so both are being reported in a timely manner. National Student Clearinghouse reporting date parameters are also being updated so the last date of attendance is pulled into the fields needing to be reported to the National Student Loan Data System (NSLDS) as the Effective Date. Enrollment reporting will be reviewed and submitted at the start of each term, subsequently within the term, and at the end of the term to ensure reporting timelines are met and that the withdrawal date and effective date match for reporting purposes. Timeline for Implementation of Corrective Action Plan: This corrective action plan was implemented in April 2024. Contact Person: Waqas Mirza, Registrar, waqas.mirza@urbancollege.edu

Corrective Action Urban College of Boston (UCB) has contracted with Global Financial Aid Services (Global FAS) effective for the 2023/2024 Award Year. As part of the Global FAS process, any unearned Return to Title IV funding is processed through a negative disbursement check register. The Business Office will receive the calculated unearned portion of Title IV funding and post as a negative disbursement onto the student’s ledger/billing. The negative disbursement is auto processed through Global FAS back to COD. The Director of Financial Aid and Manager of the Business Office will review monthly to ensure all returns have been completed. Timeline for Implementation of Corrective Action Plan: This corrective action plan will be implemented by May 2024. Contact Person: Stacy Broadus, Director of Financial Aid, stacy.broadus@urbancollege.edu

Corrective Action Plan: Urban College of Boston (UCB) has contracted with Global Financial Aid Services (Global FAS) effective for the 2023/2024 Award Year. In addition, Urban College has hired a new Director of Financial Aid who started on January 1, 2024 who is familiar with the rules around calculating R2T4s. Going forward, Global FAS will be processing all Exits and Return to Title IV (R2T4) calculations as of the Fall semester of the 2023/2024 award year. The Director of Financial Aid at UCB has confirmed with Global FAS that our school profile is accurately, and the number of days being used in the R2T4 calculation is accurate based on the current Academic Calendar. Timeline for Implementation of Corrective Action Plan: The corrective action plan has been implemented as of September 2023. Contact Person: Stacy Broadus, Director of Financial Aid, stacy.broadus@urbancollege.edu

Corrective Action Plan: The Business Office will review uncashed checks every 30 days as part of the ledger/billing reconciliation process to ensure these are addressed prior to the 240-day regulation. This process is being updated in the Business Office Cash Management operating procedure. The Business Office and the Director of Financial Aid will review monthly any uncashed checks to ensure that UCB is meeting the required timeline. Timeline for Implementation of Corrective Action Plan: This corrective action plan will be implemented by May 2024. Contact Person: Karen Lucas, Manager of Business Office, karen.lucas@urbancollege.edu