Corrective Action Plans

Corrective Action Plan Urban College of Boston (UCB) has contracted with Global Financial Aid Services (Global FAS) effective for the 2023/2024 Award Year. Global FAS provides UCB with a monthly reconciliation report through our shared Secured File Transfer Protocol site (SFTP)and notifies us when one is ready to be reviewed. Once the file is received, the Business Office will conduct a secondary reconciliation using the Global FAS report. The Business Office will review the students ledger/billing and compare information with COD to ensure all disbursement information matches according to regulation. The Director of Financial Aid will also conduct a quarterly internal review of Global FAS reports against COD reporting. 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 Urban College of Boston (UCB) has contracted with Global Financial Aid Services (Global FAS) effective for the 2023/2024 Award Year. Global FAS provides UCB with a daily check register report of all student disbursements. Through the Disbursement process, UCB must first process all check registers, reconcile student billing, and identify and process student credit balances before funds can be drawn down from the Common Origination and Disbursement System (COD). The UCB Business Office commits to processing check registers within 7 business days and providing the Cash Monitoring report to Global FAS so funds can be released and deposited into the Federal Funds Account. This will ensure student refunds are processed within the 14-day federal regulation. 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

Finding: 2023-071 - UAS had twenty-two stale Title IV checks greater than 240 days. Questioned Costs: None Assistance Listing Number: 84.007, 84.038, 84.063, 84.268, 84.379 Assistance Listing Title: Student Financial Assistance Cluster Views of Responsible Officials (state whether your agency agrees or disagrees with the finding; if you disagree, briefly explain why): Agree Corrective Action (corrective action planned): The UAS Bursar’s office, the Financial Aid Office are working with the Budget, Grants and Contract Office to send funds back to the Department of Education for the stale dated Title IV checks. A quarterly review will be performed to ensure future compliance. Completion Date (list anticipated completion date): November 2023 Agency Contact (name of person responsible for corrective action): Jonathan Lasinski, Vice Chancellor for Administrative Services, 907-796-6497

When the district bookkeeper submits the reports to ISBE, she will notify the superintendent that they are ready for her review and final aubmittal to avoid any delay and late filings. See full Corrective Action Plan on district letteread.

Finding 2023-001 - Return of Title IV Funds Management Response: Management concurs with the finding Views of Responsible Officials and Corrective Action Plan: Point Park University uses PowerFAIDS software to complete the Federal Return of Title IV calculation. The University reviewed the Return of Title IV process within PowerFAIDS and found that the days completed were not properly updated to exclude the days of the University's spring break from the numerator of the calculation. This resulted in an incorrect amount being returned. The University is in the process of returning the underpayment of $454 for the 2022-2023 academic year. The University is implementing an additional procedure to review each Return of Title IV calculation from PowerFAIDS prior to the issuance of the refund. A spreadsheet has been created to independently check each calculation based upon withdrawal dates, number of days in the semester, number of davs completed and factoring in break days as applicable. Anticipated Completion Date: April 30, 2024 Name of Responsible Person: George Santucci, Director of Financial Aid (412) 392-3498 gsantucci@pointpark.edu

Finding 2023-002 - Enrollment Reporting Management Response: Management concurs with the finding Views of Responsible Officials and Corrective Action Plan: Point Park University uses the National Student Clearinghouse (NSC) to transmit enrollment information to the National Student Loan Data System (NSLDS). The University has verified that the student status changes were correctly submitted to the NSC, however the campus and program level information was not properly reflected in NSLDS and did not appear on the error report. The University's Financial Aid Office in conjunction with Registrar's office will implement a 45-day report to verify that all student enrollment status changes are properly reported to NSLDS via the NSC. The discovery of any status changes did not reach NSLDS will be manually reported directly on the NSLDS platform. Anticipated Completion Date: May 31, 2024 Name of Responsible Person: George Santucci, Director of Financial Aid (412) 392-3498 gsantucci@pointpark.edu

Corrective Action The Foundation will ensure that policies and procedures are in place to both verify the correct program level effective dates and enrollment statuses are reported timely and are also reviewed by a second person to ensure the accuracy of the data as well as the timeliness of reporting the data. The initial reporting and the subsequent reviews will be documented with names of staff and dates of work/reviews.

THE COLLEGE HAS PROVIDED TRAINING TO EMPLOYEES AND IMPLEMENTED REVIEW PROCEDURES TO ENSURE ACCURACY OF REPORTING STUDENT STATUS FOR THE NEXT FISCAL YEAR.

I will ensure the Financial Aid Office works closely with the Accounts Payables department to monitor that all Title IV refund checks have been cashed after 30 days of issuance of the refund. If a check has not been cashed a new check will be reissued immediately. If, after 30 days of the reissuance, the check has not been cashed then the funds will be returned to the Department of Education within the mandated 45-day period.

We recently completed the transition and onboarding of departmental staff which would allow the University to fully enact its plan to ensure both the financial aid and the Registrar's office will perform prompt review of processing University withdrawals. The Registrar's office will develop process and procedures documentation as an internal control measuring tool to ensure that Administrative Withdrawals (AW) and Withdrawals for lack of attendance (WA) that affect student emollment are identified immediately. Staff in the Financial Aid and the Registrar's office will actively take part in training workshops and webinars provided by the Depatiment of Education and NASF AA for continuing education to stay abreast of new developments and best practices in the industry.

CORRECTIVE ACTION PLAN Federal Award Findings and Questioned Costs Finding 2023-001 Student Financial Aid Cluster: Assistance Listing #84.007 Federal Supplemental Educational Opportunity Grants Assistance Listing #84.033 Federal Work-Study Program Assistance Listing #84.063 Federal Pell Grant Program Assistance Listing #84.268 Federal Direct Student Loans Assistance Listing #93.364 Nursing Student Loans Federal agency – U.S. Department of Education Grant Period – Year ended August 31, 2023 Compliance Requirement: Special Tests and Provisions Criteria: The Gramm-Leach-Bliley Act (Public Law 106-102) (GLBA) requires the College, on an annual basis, to identify reasonably foreseeable internal and external risks to the security, confidentiality, and integrity of customer (student) information that could result in the unauthorized disclosure, misuse, alteration, destruction, or other compromise of such information, and assess the sufficiency of any safeguards in place to control these risks. At a minimum, the GLBA risk assessment should include consideration of risk in each relevant area of operations, including: Employee training and management. Information systems, including network and software design, as well as information processing, storage, transmission, and disposal. Detecting, preventing, and responding to attacks, intrusions, or other system failures. Condition: During our testing, we noted the following: While the IT Systems Team is the assigned resource for information security matters, the College communicated that it does not have a single qualified individual designated with the responsibility for implementing and enforcing the College’s information security program. An annual IT risk assessment was not performed. A vendor management program is not in place. Mobile device management is not in place. Backup media is not encrypted. A full set of policies and procedures is not in place. Cause: The expected documentation supporting the required controls to adequately confirm compliance with GLBA safeguards was not complete. Effect: Without demonstrable, documented controls supporting compliance with the GLBA standards for safeguarding the protected data, compliance with the law and the requirements in the federal PPA may not be assured. Context: Inquiry and observation of the information received from the College related to compliance with GLBA. Recommendation: The College should review the GLBA safeguarding rules and as soon as practical implement and document the controls necessary for compliance with the rule, focusing on the completion of a documented, thorough, and standardized risk assessment and management reporting framework. The College should perform comprehensive risk assessments on a regular basis, which is suggested to be at least annually, and at any significant change in infrastructure or business process. Contact Person Responsible for Corrective Action Plan: Donna Rocap, Associate Vice President of Administration Corrective Action Plan: The College agrees with the findings and is in process of developing a corrective action plan to address. In addition, the College has made it a top priority to hire both a Chief Information Officer and a Chief Information Security Officer but has experienced difficulty getting a qualified pool of candidates. Timing of Planned Corrective Action: The College expects to resolve this finding during its August 31, 2024 fiscal year.

Institutional Comments on Findings and Recommendations: The institution agrees with the auditor on this finding in that there were (3) three cases where the enrollment status was not reported correctly. Although as was observed by the auditor, the enrollment status for the three students in question were corrected in the next enrollment report that was submitted. During the audit period, the institution was unable to update, submit or complete in a timely manner Enrollment reports for the period of July through December 2022. This was mainly due to problems with the implementation of a new format for enrollment reporting through the NSLDS Modernized Website. The institution has on file, multiple inquiries to the NSLDS Customer Support Center in relation to this issue. The Department of Education also posted various Electronic Announcements updating and giving continued guidance to institutions on this issue. The auditors were provided with copies of all of ED’s posting and updates as related to this issue. Nevertheless, during the subsequent months from January 2023 to June 2023 covered in this audit period, the institution was able to complete and report the current enrollment status of students to the NSLDS platform. Actions Taken or Planned: The matter as related to this finding has already been discussed with the Registrar who is responsible for the completion and submission of the Enrollment Reports to the Department of Education To continue to improve on the reporting to student’s enrollment status, the institution would continue to submit its Enrollment Reports monthly instead of every two months as schedule. Status of Corrective Actions on Prior Findings: The issue as related to this finding occurred in the past audit.

Institutional Comments on Findings and Recommendations: Compliance Requirements – Applicable After a Student Begins Attendance: The institution agrees with the auditors on this finding in which there were two (2) cases where the auditors noted that the institution failed to determine that the students withdrew within fourteen (14) days after the student’s last day of attendance. In one (1) of the two (2) cases the Date of Determination was twenty-two (22) days after the Last Day of Attendance and in the second case, the Date of Determination was Three (3) days after the Last Day of Attendance. All funds due to the Department, (for the first case $682.00 of Unsub. Direct Loan funds and in the second case $974.22 of Federal Pell Grant funds), were returned within the forty-five (45) days required timeframe as of the Date of Determination of each case. This process was evidenced to the auditors for their records. Actions Taken or Planned: The institution is fully aware of the Return of Title IV funds (R2T4) reporting requirements and deadlines. The issue related to this finding was identified as a lack in some Faculty notifying student absences within the fourteen (14) day timeframe to process an R2T4 in a timely manner as required. Although this issue was already discussed with them by the Dean of Academic Affairs, an additional follow up meeting would be held to remind them of the importance in monitoring student attendance and notifying student absences to the Registrar office within the required timeframes to fully comply with the R2T4 reporting requirements. Status of Corrective Actions on Prior Findings: The issue as related to this finding occurred in the past audit.

Management concurs with this finding. The College will adhere to its policies, procedures, processes, and federal guidelines as it relates to disbursing loans within aggregate loan limits. Responsible Administrators: Director of Financial Aid Effective: Immediately and ongoing

Management concurs with this finding. The College will adhere to its policies, procedures, processes, and federal guidelines as it relates to competing and submitting the audit. The College has a new CFO and Controller. These measures will ensure stability and a timely audit. Responsible Administrators: Director of Financial Aid & Chief Financial Officer Effective immediately and ongoing

Management concurs with this finding. The College will adhere to its policies, procedures, processes, and federal guidelines as it relates to calculating and awarding Pell. The College will return any ineligible funds accordingly. Responsible Administrators: Director of Financial Aid & Chief Financial Officer Effective: Immediately and ongoing

Management concurs with this finding. The College will adhere to its policies, procedures, processes, and federal guidelines as it relates to over awarding students. The College will return any ineligible funds accordingly. Responsible Administrators: Director of Financial Aid & Chief Financial Officer Effective: Immediately and ongoing

Management concurs with this finding. The College will review and adhere to its practices, policies, and procedures along with federal guidelines as it relates to students meeting satisfactory academic progress. The College has an SAP appeal committee in place to enforce and abide by the College's policy. The College will return any ineligible funds accordingly. Responsible Administrators: Director of Financial Aid Effective: Immediately and ongoing

Management concurs with this finding. The College will review and adhere to its practices, policies, and procedures along with federal guidelines as it relates to disbursing and administering federal aid. The College will return any ineligible funds accordingly. Responsible Administrators: Director of Financial Aid, Chief Financial Officer & V.P. of Academic Affairs Effective: Immediately and ongoing

Management concurs with this finding. The College will set policies, procedures and practices in place and adhere to ensure that changes in students’ enrollment are reported accurately and timely as defined in the Federal guidelines. Responsible Administrators: Director of Financial Aid & Registrar Effective: Immediately and ongoing

Management concurs with this finding. The College will review and adhere to its practices, policies, and procedures along with federal regulations as it relates to resolving credit balances. The College will resolve credit balances timely and within the 14-day period as defined in the Federal guidelines. Responsible Administrators: Director of Financial Aid & Chief Financial Officer Effective: Immediately and ongoing

Management concurs with this finding. The College will ensure the accuracy of the data that is input into the COD system and the College will work to apply funds appropriately to students' accounts. The College will review and adhere to its practices, policies, and procedures along with federal guidelines as it relates to managing the COD system. Responsible Administrators: Director of Financial Aid & Chief Financial Officer Effective: Immediately and ongoing

Management concurs with this finding. The College will keep accurate attendance and participation records. The College will calculate R2T4s accurately and will return the funds in a timely manner. The College will review and adhere to its practices, policies, and procedures along with federal guidelines as it relates to R2T4 regulations. The College will return any ineligible funds accordingly. Responsible Administrators: Director of Financial Aid & Chief Financial Officer Effective: Immediately and ongoing

During November 2023, the Enrollment Reporting Manual was revised. This guide states that the assistant registrar will draw a sample from the of the population to review the data submitted to NSLDS. A retraining session will be coordinated for the assistant registrar, to review the NSLDS certification process. This activity will be aligned to the recent updates of the electronic platform.

A user guide will be established describing the steps to assembly the academic year in Banner system. This document will detail all the validation tables, processed at the registrar’s office, that impact the financial aid office procedures. Each associate registrar will have access to this guide. The institutional registrar will be in charge of disseminating this guide across all campuses and locations. The Registrar office will notify Financial Aid, once they validate the table assembly is completed in Banner.