Corrective Action Plans

Auditor Description of Condition and Effect. Instead of earning additional aid due to the Return of Title IV calculation error, one of the twenty one students who were affected saw a reduction due to a transposition/rounding error that was missed in the original calculation. As a result of this condition, input errors for the Return of Title IV calculations can make it through the process without being discovered. It is our understanding that on July 26, 2023, the College corrected the transposition/rounding error that impacted the students Return of Title IV calculation. Auditor Recommendation. Management has already taken appropriate corrective action by updating the returns for the student impacted by the input error. However, we recommend that the College implement a review process to ensure that the R2T4 calculation is being reviewed by a second individual. Corrective Action. The College has performed the necessary steps to correct the error and will amend the calculation process to ensure that a second individual is reviewing the work performed. Responsible Person. Katie Malone, Director of Student Aid Anticipated Completion Date. June 30, 2024

Auditor Description of Condition and Effect. For the Winter 2023 semester, a break of 5 days (excluding weekends) was being subtracted instead of 9 days (including weekends) from the total days in the term, which resulted in the calculation being incorrect for all students who had returns in the Winter 2023 semester. As a result of this condition, Return of Title IV calculations were incorrect for 21 students for the Winter 2023 semester, resulting in $4,265 in excess funds returned to the U.S. Department of Education. It is our understanding that on July 26, 2023, the College repaid the 21 students affected by this calculation error. Auditor Recommendation. Management has already taken appropriate corrective action by updating the returns for the 21 students impacted by the calculation error in the Winter 2023 Semester. However, we recommend that the College implement a review process to ensure that the R2T4 calculation is being reviewed by a second individual. Corrective Action. The College has performed the necessary steps to correct the error and will amend the calculation process to ensure that a second individual is reviewing the work performed. Responsible Person. Katie Malone, Director of Student Aid Anticipated Completion Date. June 30, 2024

The University will further evaluate policies and procedures in place for student status change reporting. This will include response procedures when third party servicers experience unusual events that might cause our reporting to be delayed to the National Student Loan Data System (NSLDS). The University will fund an additional position resource for the Registrar’s office to manage this reporting. In addition, we will provide requisite and ongoing training for sustained compliance with applicable procedures.

Corrective Action Plan Recommendation 1: The University Registrar will review the NSC Reject Detail Report every 45 days and will use the NSC error description resources to resolve any errors noted. For files rejected due to a discrepancy with a student’s SSN, the University Registrar will attempt to verify the students’ SSN via the Social Security Administration’s verification site (https://www.ssa.gov/employer/ssnv.htm). If the SSN cannot be verified using the link above, the University Registrar will provide the NSC Reject Detail Report to USA’s Office of Financial Aid to verify the students’ SSN. If the SSN is unable to be verified by Financial Aid, the Registrar’s Office will send an email to the student’s university email account notifying them that there is an issue with the SSN reported for them to NSC. The notification will encourage students to provide documentation to the Registrar’s Office to verify their SSN. Students will be given the option to provide their documentation directly to NSC if they prefer that option. After the student provides documentation of their SSN, we will notify NSC to have the student’s records corrected and updated to the NSLDS. Recommendation 2: The University Registrar's Office will submit student status enrollment changes every 30 days based on the date the enrollment file was submitted. Anticipated Completion Date 11/27/2023 Name of Contact Person for Corrective Action Ashley Suggs, University Registrar

Finding 2023-002 Cash Management Internal Controls (Significant Deficiency) Responsible Persons: Debbie Rapier, Chief Financial Officer Corrective Action Plan: All monthly billing information for the FPP and MST programs is sent by the Director of Revenue Cycle to the FPP/MST supervisor for review and comparison. The Outpatient Services Manager then prepares the monthly invoice. The invoice is forwarded to finance and reviewed by the Chief Financial Officer or Accounting Manager, in the absence of the CFO. Once approved, it is submitted to the Department of Community Based Services for payment. Once payment is received, it is compared against the receivable for accuracy. Anticipated Completion Date: Throughout fiscal year ending and beyond June 30, 2024

U.S. Department of Education 2023-001 NSLDS Enrollment Reporting Student Financial Aid Cluster – Assistance Listing No. 84.063, 84.268 Condition: During testing of enrollment status reporting, we noted that the incorrect enrollment status, effective date, and program begin date was reported to NSLDS. Recommendation: The College should evaluate their procedures and policies related to reporting status changes to NSLDS and enhance as deemed necessary to ensure that accurate information is reported to NSLDS. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Cause-Enrollment Status Reporting: Montgomery College utilizes the National Student Clearinghouse (NSC) as a third-party provider in order to submit student information to the NSLDS. Student enrollment status corrections were uploaded to NSC timely, however, monitoring of the upload through success was inconsistent, resulting in error reports preventing the accurate and timely update to the enrollment statuses. No review was completed to ensure the upload was completed in NSLDS. Cause for Effective Date Reporting - Inaccurate Student withdrawal effective dates were not identified timely due to delays in the review of student withdrawal status. Cause for Program Start Date Reporting - Inaccurate Student program begin dates were due to a programming issue with the file transmission software. Program start date was updating each semester to the latest semester start date. There was insufficient review to identify the problem and recommend a solution to resolve. The following actions have been implemented to resolve the deficiencies: Review of error reports by an employee not responsible for correcting the errors to ensure completeness and timeliness of the corrections submitted. Use of internal weekly reports to identify students who dropped below half time status or withdrew entirely from a semester. Use of the NSC online error reporting tool to correct errors monthly. Errors are corrected using this tool within eight days of receipt of the error report, which provides the NSC two days to resubmit the information and meet the ten-day resolution requirement. Utilize the Enrollment Reporting Summary Report (SCHER1) to ensure completeness and timeliness of error correction submissions. The Dept of Enrollment Services has coordinated with the Office of Information Technology to adjust the programming on the file transmission to NSC to ensure accuracy and minimize discrepancies. Manually submit corrections directly to NSLDS on an as-needed basis. Name(s) of the contact person(s) responsible for corrective action: Director of Enrollment Services- Earnest Cartledge Planned completion date for corrective action plan: December 2023

2023-002: Special Tests and Provisions – NSLDS Program-Level Reporting Student Financial Aid Cluster – Assistance Listing No. 84.063, 84.268 Condition: The associate degree programs were not reported as two years per the recommendation in the NSLDS enrollment reporting guide. Recommendation: We recommend the College report associate degree program length to NSLDS at two years. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Currently investigating ERP system configuration changes necessary to report associate degree program length to NSLDS at two years. Name(s) of the contact person(s) responsible for corrective action: Nanci A. Beier, Registrar Planned completion date for corrective action plan: Spring 2024

2023-001: Gramm-Leach-Bliley Act Student Financial Aid Cluster – Assistance Listing No. 84.063, 84.268, 84.007, 84.033 Condition: Certain elements of the College’s information security program were not maintained in written form. Recommendation: We recommend the College ensure its written information security program addresses the required minimum elements as outlined in 16 CFR 314.4. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Prior to the conclusion of our audit the College documented in writing the required minimum elements. Name(s) of the contact person(s) responsible for corrective action: Dr. Richard C. Kralevich, Vice President, Information and Instructional Technology Planned completion date for corrective action plan: Completed

Finding No. 2023-001: SFA – Direct Loan Disbursement Notification Reporting Contact person for corrective action: Dr. LaMario Primas – Associate Vice President of Student Financial Services/ Interim Director of Financial Aid & Scholarships Corrective Action Plan: Morehouse College plan to implement the following to address finding No. 2023-001 • Effective Spring 2024 of the 2023-2024 academic year, the Office of Financial Aid & Scholarships department will implement the following mechanisms to ensure that all disbursement notifications are sent to students no earlier than 30 days before, and no later than 30 days after crediting the student’s account with Direct Loan as required. o Automic Auto Scheduling: ▪ Automic will be configured to execute batch communications to all required students. This process will be scheduled to run multiple times throughout the 30-day before and after window to ensure compliance.

2023-005 – Student Financial Aid Cluster – (a) Federal Supplemental Educational Opportunity Grant (b) Federal Work Study Grant (c) Federal Perkins Loan Program (d) Federal Pell Grant Program (e) Federal Direct Loan Program, Assistance Listing No. (a) 84.007 (b) 84.033 (c) 84.038 (d) 84.063 (e) 84.268 - Year Ended June 30, 2023 Condition Found The College did not report actual loan disbursement dates to the Common Origination and Disbursement (COD) system for 2 of the 40 students in the sample (5%). We consider this condition to be an instance of noncompliance in internal control over compliance relating to the Eligibility compliance requirement. Corrective Action Plan We have updated our process for reporting actual loan disbursement dates and validated that our future loan disbursement dates are accurate. Responsible Person for Corrective Action Plan Jeremy Hurse – Director of Student Financial Services Deborah Beck – Associate Director of Student Financial Services Implementation Date of Corrective Action Plan 7/1/2023

2023-004 – Student Financial Aid Cluster – (a) Federal Supplemental Educational Opportunity Grant (b) Federal Work Study Grant (c) Federal Perkins Loan Program (d) Federal Pell Grant Program (e) Federal Direct Loan Program, Assistance Listing No. (a) 84.007 (b) 84.033 (c) 84.038 (d) 84.063 (e) 84.268 - Year Ended June 30, 2023 Condition Found For 2 of the 40 student files (5%) we examined, we noted the students were not properly awarded Direct loans. We consider this condition to be an instance of noncompliance relating to the Eligibility compliance requirement and is a repeat finding shown in Section IV of this report as prior year finding 2022-003. Corrective Action Plan We have updated our process to initially evaluate all loans at the beginning of each semester, then again mid-semester, and finally a third time at the end of each semester for the academic year. Responsible Person for Corrective Action Plan Jeremy Hurse – Director of Student Financial Services Deborah Beck – Associate Director of Student Financial Services Implementation Date of Corrective Action Plan 10/11/2023

2023-003 – Student Financial Aid Cluster – (a) Federal Pell Grant (b) Federal Supplemental Educational Opportunity Grant (c) Federal Work Study Grant (d) Federal Perkins Loan Program (e) Federal Direct Student Loans, Assistance Listing No. (a) 84.063 (b) 84.007 (c) 84.033 (d) 84.038 (e) 84.268 - Year Ended June 30, 2023 Condition Found The College did not accurately complete refund calculations for 2 out of 17 students (11.7%) tested. We consider this finding to be a significant deficiency in relation to the Special Tests and Provisions compliance requirement. Corrective Action Plan We have updated our process to do a comprehensive double check of all refund calculations at the end of each semester. Responsible Person for Corrective Action Plan Jeremy Hurse – Director of Student Financial Services Deborah Beck – Associate Director of Student Financial Services Implementation Date of Corrective Action Plan 10/11/23

2023-002 – Student Financial Aid Cluster – (a) Federal Pell Grant (b) Federal Supplemental Educational Opportunity Grant (c) Federal Work Study Grant (d) Federal Perkins Loan Program (e) Federal Direct Student Loans (f) Teacher education Assistance for College and Higher Education ALN No. (a) 84.063 (b) 84.007 (c) 84.033 (d) 84.038 (e) 84.268 (f) 84.379 – Year Ended June 30, 2023 Condition Found The College did not report graduate status changes within 60 days for ten out of twenty students (50%) tested. We consider this condition to be a material weakness of internal control over compliance relating to the Special Tests and Provisions compliance requirement. Corrective Action Plan The Registrar has updated its process to report the graduate status within 30 days of the end of each semester. Student Financial Services has set up an additional process to follow up with the Registrar at the end of each semester to ensure it has been completed. Responsible Person for Corrective Action Plan Fred Miller – Registrar Jeremy Hurse – Director of Student Financial Services Deborah Beck – Associate Director of Student Financial Services Implementation Date of Corrective Action Plan 10/11/2023

Special Test – Student Financial Aid Cluster Assistance Listing Nos. 84.007, 84.003, 84.063, 84.268 Recommendation: Recommend the design of controls to ensure an adequate documentation of control and review of student records to determine they are appropriately reflecting the proper status. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Moraine Park Technical College’s review of student record confirmed the record had the correct enrollment date in Financial Aid reported. Financial Aid reviewed and determined no Return to Title IV of financial aid was required. The student record in the National Student Loan Data System (NSLDS) was reviewed and updated to the correct enrollment date. The College has meetings planned with our ERP (Enterprise Resource Planning) vendor to determine possibility of automation of this manual process. Name(s) of the contact person(s) responsible for corrective action: Lynn Marquardt, Registrar and Enrollment Services Manager Planned completion date for corrective action plan: June 2024

Recommendation: We recommend the college implement procedures to strictly comply with the requirements of 34 CFR 690.83 and 34 CFR 685.309 as it relates to reporting enrollment information to the Department of Education. We further recommend the College follow the guidance provided in the NSLDS Enrollment Reporting Guide and stay abreast of new guidance as published by the Department of Education. Corrective Action Taken: The College will be taking extra measures to periodically review enrollment batches that are sent to the Clearinghouse, ensuring that they are being updated into NSLDS alongside any error reports that may be coming back from the Clearinghouse. This will help prevent any unknown or missed student enrollment report from the Clearinghouse to NSLDS. Anticipated Completion Date: Fall semester 2023 and ongoing

Lamar State College Orange Response and Corrective Action Plan to FY 23 Federal Financial Aid Audit Finding 2023-001 Enrollment Reporting Views of Responsible Officials The College agrees with the auditor's findings and recommendations. Corrective Action Plan The College has identified three issues that delayed identification and reporting of changes in student enrollment status for reporting on the NSLDS component. In response, the college will implement the following corrective actions: 1.The Registrar will review the error resolution reports provided by National Student Clearinghouse (NSC) to ensure the correct enrollment information is being reported to NSLDS within 60 days of the determination date. Implementation Date Immediate 2.An advisor drop code will be implemented effective Spring 2024. This code will trigger an email to the Records Office, and at that point the Records Office will determine the student's enrollment status and update to withdrawn in Banner when it is determined the student has withdrawn from the semester. This will ensure the correct enrollment status is reported to NSLDS within 60 days of the determination date. Implementation Date 1/16/2024 3. LSCO will ensure a subsequent term report is submitted any time a late award is processed. This will ensure the correct enrollment status is reported to NSLDS within 60 days of the determination date. Implementation Date Immediate Individual Responsible Summer Rather, Registrar

Audit for the 2022-2023 academic year. Enrollment Reporting Finding Compliance Requirement: Special Test and Provisions - Enrollment Reporting Criteria: The College is required to send changes in attendance levels, graduated, withdrew, dropped out, or enrolled changes to the NSLDS within 60 days of the change. Cause: The College had not reported changes for graduated students to the NSLDS as required with the time period to be in compliance with enrollment reporting requirements. Context: Of the nine students selected for testing in the annual audit, the college did not send changes related to four students whose status changed after graduation on May 8th, 2023 to the NSLDS system. Later the status was updated however, was outside of the 60 day requirement. Corrective Action Plan from College: Documentation of Graduation enrollment dates missing. This is submitted to Derrick Everhart, Director of Financial Aid by the College Registrar Brooke Millsaps. Update regarding processing of NSC Grad Only file for May 2023 Warren Wilson College has made multiple efforts to submit a May 2023 Grad Only file to the National Stud Clearinghouse but has been unable to due to our software not recognizing or pulling the files of the students who are documented as May 2023 graduates. We submitted an end-of-term file to the NSC which was certified on June 6, 2023. As of August 17, 2023, we have taken the following steps to try and remedy this: • Applied a script/patch provided by our software company (Jenzabar). This script failed to resolve the issue. • Manually edited all graduating student records for the NSC grad only file report. This manual input of information did not result in our ability to process a grad only file. • Consultation with IT Department and software consultants to determine what we can do to process and report this grad only file. Action Steps: Moving forward, if an enrollment file cannot be uploaded to National Student Clearing House for any reason by the College Registrar within the 60-day requirement, the Registrar will communicate with the Director of Financial Aid. A file with updated enrollment reporting of student records will be created from the Colleges reporting system. Those records will then be manually entered into the NSLDS system by the Director of Financial Aid to main­tain compliance with enrollment reporting requirements. Management Response: The Director of Financial Aid concurs with this finding and noted while the College out of compliance with the reporting timeframe, the College did make a substantial effort to complete the requirements and follow up with NSLDS and NSC to correct the students enrollment. Contact College personnel for corrective action. Derrick Everhart, Director of Financial Aid deverhart@warren-wilson.edu Brooke Milsaps, College Registrar bmillsaps@warren-wilson.edu

Management Response: Management agrees with this finding. To prevent this situation from occurring in the future, staff members will create a new academic record in our Student Information System (Jenzabar) for a student who graduates and enrolls in a subsequent semester. The new academic record will reflect the student’s non-degree status. A new academic record will prevent reporting conflicts between the student’s graduation status and subsequent non-degree enrollment status and therefore, will assist the college in reporting within the 60-day timeline. When a student changes enrollment statuses between regular monthly reports, staff members will continue to exercise the option to use the National Student Clearinghouse ad-hoc enrollment reporting so that the National Student Loan Database System receives timely enrollment updates. Contact Person: Betsy Henkel, Director of Financial Aid (henkelb@beloit.edu) Anticipated Completion Date: December 1, 2023

Condition: Expenditure reports were not filed in a timely manner. Recommendation: We recommend that steps are taken, including oversight by a second employee, to ensure that all quarterly expenditure reports are filed by the due dates. Management Response: Management will take the necessary steps to file all quarterly expenditure reports on time in the future. Anticipated Date of Completion: June 30, 2024

The Financial Aid Office and the Registrar's Office will work closely together to resolve the NSLDS reporting discrepancies. Based on the review information from last year's similar finding (2022), it was determined after the fact that Webster University had both repeated the enrollment information correctly and in a timely manner to the Clearinghouse, however, the Clearinghouse frequently reported glitches and outages that prevented reporting to NSLDS in a timely manner. The Clearinghouse continues to have system issues that delay reporting. Because the Clearinghouse is not able to consistently report accurate enrollment until their system challenges are resolved, the Financial Aid Registrar's Offices, with the assistance of IT and Enrollment Technology, will develop a mechanism going forward to establish more internal checks to compare against NSLDS data. One of these measures would include a monthly enrollment reporting audit to ensure timely and accurate enrollment information is provided to NSLDS.

2023-001 – Cost of Attendance Calculation. Auditor Description of Condition and Effect. Two students out of the 40 tested had an incorrect COA recorded in PowerFAIDS. The error was isolated to the population of students enrolled half-time at the College. The College determined that they did not properly update COA for the year. Subsequent to initial testing, the College adjusted the COA for the half-time students whose COA was not updated for the year. This condition did not result in any students being awarded an incorrect amount of Pell. As a result of this condition, the College was exposed to an increased risk that incorrect information would be used to determine students' Pell Grant award amounts. Auditor Recommendation. We recommend the College implement procedures to ensure the COA used to calculate each student's Pell Grant is updated for each academic year and reviewed by an independent official. Corrective Action. The College will evaluate and implement controls that will ensure Pell Grant Budget Cost of Attendance requirements are met. The Financial Aid Office will determine Cost of Attendance budget component amounts and School Administration will approve these amounts prior to the financial aid system and school website being updated accordingly each academic year. Responsible Party. Financial Aid Office and School Administration. Anticipated Completion Date. September 27, 2023

Condition: The University had one of the minimum safeguards written down within its information security program during the fiscal year. Planned Corrective Action: The University does have information security controls in place. While we have implemented these controls and safeguards, we acknowledge they are not documented in our formal policies. Our corrective action is to have these controls formalized and documented in the coming year. Contact person responsible for corrective action: Linda L Height, VP Finance Anticipated Completion Date: June 30, 2024

Condition: The University did not report certain students' status to NSLDS in a timely manner during the fiscal year Planned Corrective Action: The University Team will review status updates for all students that continue enrollment from one semester to another (May to Summer) to be sure their previous and new status both appear in NSLDS. All the students that were identified had continued with a new degree program in the summer, so the corrective action plan we are implementing will catch any issue before their new enrollment information is updated to NSLDS. Contact person responsible for corrective action: Noreen Ferguson, Registrar Anticipated Completion Date: December 31, 2023

Name of Contact Person Responsible for the Corrective Action Plan: Beth Young Corrective Action Plan: The College administration has met and is in the process of implementing controls and procedures to ensure that all Title IV funds are properly monitored and reviewed. Anticipated Completion Date: Fiscal year 2024.

Finding Reference Number: 2023-001 Initial Fiscal Year: 2023 Summary of Finding: Material Weakness: Gramm-Leach-Bliley Act (GLBA) (U.S. Department of Education, William D. Ford Direct Loan Program, ALN #84.268) Entity’s Corrective Action Plan Due to turnover within the IT Department, GLBA requirements were not communicated well to incoming staff or to the organization. Once GLBA requirements were discovered, a plan was developed to begin implementing GLBA controls and revise our security plan. The plan to bring the organization into GLBA compliance was developed for the 2023-2024 school year and was not in effect before this audit. The IT Department, and key stakeholders within the organization, are working to ensure GLBA compliance within the next year.. Anticipated Completion Date: September 21, 2023 Name and Title of Responsible Person: Luke Edwards, Director of IT.