Corrective Action Plans

Contact Person: Traci Veyl, Associate VP of Student Financial Services Corrective Action: The College acknowledges the findings. Corrective action has occurred. The Financial Aid Office has updated policies and procedures to include a new report of all federal student aid to be sent to the Finance Office after any disbursements or adjustments of student aid. This report will include Direct Loans, Pell and SEOG. Anticipated Completion Date: March 11, 2024

San Francisco AAP FY 2022/2023 Corrective Action Plan The Adoption Assistance Program (AAP) was selected as a major program in the City's FY 2022/23 single audit. The Auditor tested AAP's compliance with eligibility requirements. The audit sample consisted of 55 on-going active cases, and 5 intake samples for the Fiscal year 2022-2023 from a random sampling. Findings The Auditor tested a statistically valid sample of 60 participants selected from a population of 1,087 cases receiving benefits under the AAP program for the period of July 1, 2022 through June 30, 2023, the Period under review (PUR). The Auditor noted 7 case findings needing improvement. All case findings were from the on-going active case samples. All of the intake cases sampled were correct with no error. There were no findings found to have any dollar amount errors. The auditor identified the following issues: renewal checklists were not submitted with physical files on a consistent basis. It could not be verified that Supervisor reviews were done consistently on all reassessments as the checklists used by the caseworkers, were not consistently found in the case files. Response to findings The Family & Children’s Services Foster Care Eligibility (FCE) unit recognizes the need for improvements through the Auditor’s findings. Inconsistencies were in large part due to the circumstances of the COVID-19 Pandemic. We have changed our previous business practices to improve deficiencies and maintain program integrity. Root Causes - COVID-19 pandemic The pandemic’s restrictions significantly altered FCE’s traditional in-office schedules and business processes, prompting a significant shift towards remote work arrangements and digital transformation. FCE adapted quickly to these operations changes while trying to maintain employee safety. This transition necessitated the need for flexible working hours, increased reliance on virtual communication, implementation of new technologies, and business processes to streamline workflows. - Physical files o FCE, during the PUR of this audit, used physical case files. Digital case files offer many advantages that FCE wasn’t able to access, such as easier accessibility, improved organization capabilities through search functions, greater security measures to protect sensitive data from unauthorized access or loss, and better oversight capabilities. Overall, transitioning from physical case files to digital files will result in having files easily accessible and will increase effectiveness and efficiency. - Staffing issues During the PUR, there were a variety of staffing issues that included leaves, promotions, and shortages. These staffing changes significantly impacted the administration of FCE program benefits. Corrective Actions - Future Staff training o We have recognized the need to develop refresher training for staff that will provide a thorough understanding of our AAP business processes. These trainings will ensure that AAP case reassessments are processed uniformly across the program. By investing in the development of these refresher staff trainings, we aim to equip our staff with the knowledge and skills necessary to perform their roles effectively and contribute positively towards achieving our organizational goals. o Time frame to implement trainings will be no later than 6/1/2024 with completion by 10/2024. - Digital Files o FCE recognizes the need to move from physical case files to digital case files. The COVID-19 pandemic provided the catalyst to speed up the transition to digital files. With the change to digital imaged files, future case reviews and tasks completed by workers and supervisors can, and will, be done more efficiently and will provide the necessary oversight.  Imaging case files conversion project was created in 4/2023.  FCE is currently at 70% percent converted to digital case files since the implementation of CalSAWS (11/1/2023).  FCE plans to convert to 100% digital files by the end of June 30, 2024. - Systematic Reporting o Reports generated from CalSAWS and case tasking will help improve our program’s overall efficiency.  Effective 11/2023, implementation of new task reports generated from CalSAWS will aid staff with reminders of tasks and will improve overall case review.  CalSAWS provides unit Supervisors with reports of overdue, pending and future case actions needed, including AAP reassessments.  By June 30, 2024, FCE will provide unit Supervisors and staff with additional tools to support them with their case tracking and reporting. This includes developing detailed reports accessible through our eligibility system CalSAWS. The AAP Corrective Action plan will be administered by FCE Program Specialist Justin Hyun and overseen by Program Manager, Juliet Halverson.

Under Awarding of Pell Based on Enrollment Status Planned Corrective Action: Crossover PELL only occurs with the College's online population of students and while there are systems currently in place to check for this, it does not always get caught. There is a plan in place to begin a better tracking system within the Financial Aid Office to track who should have crossover PELL so that it can be certain it is not missed. The Financial Aid Office will also request a list of all summer school students from the Academic Office to confirm summer attendance and funding eligibility. Person Responsible for Corrective Action Plan: Lyndsi Romero, Director of Financial Aid Anticipated Date of Completion: 12/31/2024

Inaccurate and Untimely Return of Title IV (R2T4) Funds Planned Corrective Action: After the completion of the 2021-22 audit, the Student Finance Clerk began completing R2T4's internally. These are done prior to 3rd party financial aid servicer completing the R2T4's so that the Institution can either sign off on what was done as the R2T4's are the same, or the Institution can instruct the 3rd party servicer to adjust. The Student Finance Clerk has also begun tracking all steps of the withdraw process internally to make sure R2T4's are completed in a timely manner. Person Responsible for Corrective Action Plan: Lyndsi Romero, Director of Financial Aid Anticipated Date of Completion: 6/30/2024

Finding 2023-001 Condition The College did not notify the National Student Loan Data System (NSLDS) in a timely manner for 24 students with status changes in our sample of 25 students. The sample was not a statistically valid sample. Corrective Action Plan Corrective Action Planned: The College has updated its policies and procedures to ensure notifications to the National Student Loan Data System are performed timely. In addition, all members of the responsible team will undergo formalized training to ensure their knowledge and proficiency regarding all applicable rules and regulations are kept up to date. Name(s) of Contact Person(s) Responsible for Corrective Action: Jeremy Sivillo, Institutional Registrar Kevin A. Thomas, D.O., Assistant Dean of Institutional Enrollment Management Anticipated Completion Date: Policies and procedure update implementation has been completed. Training for existing staff is to be completed by April 30, 2024. Training material development for new employees will be completed by May 31, 2024

Corrective Action Plan The Student Financial Services department has undergone major process improvements over the previous fifteen months. The processes and procedures for the calculation and Return of Title IV funds have been reviewed and staff in charge of these functions have been trained. Training materials have been recorded and are easily accessible to personnel as needed. All Title IV calculations are reviewed prior to being processed and a schedule has been implemented to ensure that funds are returned in a timely manner. In addition, the department’s staffing levels have improved. Timeline for Implementation of Corrective Action Plan The corrective action plan was implemented as of October 1, 2023. Contact Person Samantha Plourd, Dean of Enrollment, Retention & Completion

Corrective Action Plan The Student Financial Services department has undergone major process improvements over the previous fifteen months. The department now has a data dictionary that houses recorded trainings and written procedures on various processes that occur regularly, including the reporting of rejected COD items. In addition, the department’s staffing levels have improved, and cross-training has been implemented to ensure COD reporting is conducted within the 15-day requirement. Timeline for Implementation of Corrective Action Plan The corrective action plan was implemented as of October 1, 2023. Contact Person Samantha Plourd, Dean of Enrollment, Retention & Completion

FINDING 2023-005: INACCURATE ENROLLMENT STATUS REPORTING A. COMMENTS ON FINDING AND RECOMMENDATION(S): PIMS AGREES WITH THE FINDINGS OF THE AUDITORS THAT STUDENT A AND STUDENTS LISTED AS B WERE NOT PROPERLY REPORTED. B. ACTIONS TAKEN OR PLANNED: PIMS HAS FOUND THAT UPDATES NEED TO BE VERIFIED AND MADE DIRECTLY IN NSLDS. PIMS HAS RELIED MOSTLY ON FAME OUT THIRD-PARTY SERVICER TO COMPLETE THE MAJORITY OF ENROLLMENT REPORTING, GOING FORWARD ALL REPORTING WILL BE EITHER DONE DIRECTLY TO NSLDS OR REVIEWED AFTER THE INFORMATION IS RELAYED THROUGH FAME'S ENROLLMENT REPORTING SYSTEM (SSCR)

FINDING 2023-004: INCORRECT REFUND CALCULATIONS A. COMMENTS ON FINDING AND RECOMMENDATION(S): PIMS AGREES WITH THE FINDINGS OF THE AUDITORS THAT STUDENT B3 AND B 1 WERE INCORRECTLY REFUNDED DUE TO MISSING OR INCORRECT INFORMATION ON THE R2T4. PIMS WILL REFUND THE $352 OWED TO THE DOE. B. ACTIONS TAKEN OR PLANNED: PIMS FA OFFICE HAS MOVED TO COMPLETING THE R2T4 ONLINE TO HELP ELIMINATE CALCULATION ERRORS. ALL R2T4'S ARE THEN REVIEWED BY FA MANAGER TO ENSURE ALL FIGURES ARE ENTERED CORRECTLY AND AUTO CALCULATING CORRECTLY.

FINDING 2023-003: LATE REFUND A. COMMENTS ON FINDING AND RECOMMENDATION(S): PIMS AGREES WITH THE FINDINGS OF THE AUDITORS THAT STUDENT B1 WAS REFUNDED WITHIN THE FEDERAL GUIDELINE TIME ALLOTMENT. B. ACTIONS TAKEN OR PLANNED: THE INSTITUTE HAS IMPROVED THE WITHDRAWAL PROCESS AND PROCEDURES UNDER NEW MANAGEMENT ALONG WITH WORKING MORE CLOSELY WITH THE ENROLLMENT OFFICE TO WATCH FOR STUDENTS THAT DO NOT BEGIN A NEW TERM.

FINDING 2023-002: OVERAWARDED FEDERAL DIRECT SUBSIDIZED LOAN A. COMMENTS ON FINDING AND RECOMMENDATION(S): PIMS AGREES WITH THE FINDINGS OF THE AUDITORS THAT STUDENT B2 WAS NOT PROPERLY PRORATED WHEN FEDERAL DIRECT LOANS WERE CALCULATED. B. ACTIONS TAKEN OR PLANNED: MOSTLY ALL STUDENTS THAT ATTEND PIMS NEED TO BE PRORATED FOR THEIR LAST ACADEMIC YEAR. THIS STUDENT SHOULD HAVE BEEN PRORATED, PIMS WILL RETURN THE $2,709 THE STUDENT IS INELIGIBLE FOR. FA MANAGEMENT HAS BEGUN CONDUCTING QUARTERLY FILE REVIEWS WHERE END PROCESSING AND STUDENT PRORATION CALCULATIONS CAN CONTINUE TO BE MONITORED FOR COMPLIANCE.

FINDING 2023-001: INCORRECT PELL GRANTS A. COMMENTS ON FINDING AND RECOMMENDATION(S): PIMS AGREES WITH THE FINDINGS OF THE AUDITORS THAT STUDENT A1 RECEIVED THE INCORRECT AMOUNT OF PELL AND STUDENT B1 WAS INCORRECTLY ADJUSTED DURING THE R2T4 PROCESS. B. ACTIONS TAKEN OR PLANNED: PIMS HAS FOUND THAT AN EXTRA LAYER OF REVIEW ON EACH PELL DISBURSEMENT ROSTER FROM FAME WILL ELIMINATE INCORRECT PAYMENTS. PIMS REPORTS THE NUMBER OF CREDITS AND ENROLLMENT STATUS TO FAME THEN FAME REQUESTS THE FUNDS BASED ON THIS INFORMATION THAT PIMS ELECTRONICALLY TRANSMITS. IN MOST CASES THE PAYMENT AND THE ENROLLMENT STATUS MATCH BUT FOR STUDENT A1 THAT IS NOT THE CASE. GOING FORWARD, AT THE TIME THE ROSTER IS PRODUCED THE FA OFFICE WILL VERIFY EACH PAYMENT BEFORE THE ROSTER GOES TO THE BUSINESS OFFICE. PIMS WILL ALSO RETURN THE $811 OF 21/22 PELL THAT STUDENT A1 WAS INELLIGIBLE FOR. PELL ADJUSTMENTS DURING THE R2T4 PROCESS WILL BE LOOKED AT BY BOTH THE FA PROCESSOR AND SUPERVISOR. AS WITH THE PELL MATCHING THE STUDENTS' ENROLLMENT WHILE ATTENDING THE INSTITUTE'S FA OFFICE UNDERSTANDS THAT THE SAME CONCEPT IS APPLIED WHEN A STUDENT WITHDRAWAL AND A PELL RE-CALCULATION IS REQUIRED. PIMS WILL RE-REQUEST ON BEHALF OF STUDENT B1 $431 IN PELL GRANT FUNDS.

Finding 2023-001 To whom it may concern, UNIVERSITY of INDIANAPOLIS,,, UNIVERSITY OF INDIANAPOLIS'S RESPONSE TO AUDIT FINDING February 15, 2024 Management acknowledges the error in the Federal Work Study calculation. A refund was processed to the GS site on February 15th , 2024, in the amount of $90,184. Management further notes that it has removed the waiver from its calculation files. This corrective action will be monitored by the University's Controller and will be fully implemented during the 2023-2024 fiscal year. Jodi Purtee, AVP & Controller

Corrective Action Plan for Current Year Findings June 30, 2023 Finding 2023-001: Reporting – Special Reporting Student Financial Assistance Cluster U.S Department of Education Award Period: July 1, 2022 – June 30, 2023 Responsible Person: Wilbert Casaine, Executive Director of Student Financial Aid, 609-771-2211 Corrective Action Plan: For the fiscal year ending June 30, 2023, the supporting documentation for the FISAP did not tie to the report that was submitted through COD. The two sections reported zero (0) students were erroneously skipped, thus no data was entered, even though the support document had students listed there, for the following lines in Part II, Section F: Line 29 Column C per the FISAP noted 0 students, and 8 students in the underlying support. Line 29 Column E, per the FISAP noted 0, and 16 students in the underlying support. One section where 12 students were reported but the support document had 11 was due to the excel support spreadsheet formula error that counted an additional column causing data entry error for the following line: Line 34, Column E, per the FISAP, noted 12 students, and 11 in the underlying support. After the original FISAP submission, the data errors were discovered. The FISAP was reopened and the data was corrected. In completing the annual FISAP, the College will conduct a more thorough multi-level review of entries and support documents before submitting the report to the DOE. The College implemented the corrective action on October 18, 2023 retroactive to July 1, 2023 and was able to resubmit the FISAP. The College implemented the corrective action on October 18, 2023 retroactive to July 1, 2023. Anticipated Completion Date: Completed

The Office of the Registrar has identified the errors in the National Student Clearinghouse reporting. They have worked internally with our IT department to pinpoint the errors resulting in delays in submission to the National Student Loan Database Systems (NSLDS) via the National Clearinghouse. The Office of the Registrar is presently completing data review and clean-up. Once this is completed The Office of the Registrar will submit overdue files to the National Clearinghouse in conjunction with the Senior Director of Information Technology to ensure all technical requirements are met. These updates and alignments should bring late reporting to zero. The goal is to have no findings in 2025. Name of Contact Person Responsible for Corrective Action: Debbie Blake, Registrar and Emily Perl, Associate Vice President for Student Success. Anticipated Completion Date: 06/01/2024

II. FEDERAL FINDINGS AND QUESTIONED COSTS 2023-001 Special Tests and Provisions Management's Response: We concur. View of Responsible Officials and Corrective Action Plan The District reviewed past practices and implemented revised procedures to ensure accurate student enrollment information is reported to the National Student Loan Data System. Additionally, the District consulted with the National Student Clearinghouse and prior semesters’ enrollment information was revised and resubmitted. Name of responsible individual: John Cooney Implementation Date: October 26, 2023

Finding Number: 2023-003 Condition: The notifications related to the direct loan borrowers did not include information on the right to cancel or instructions on how to cancel the loans. Planned Corrective Action: Missing notifications to students was a result of a coding error in the automated process that was resolved on September 5, 2023. Notifications to parents didn’t begin until the Summer 2023, with an automated procedure being implemented in the Fall 2023 semester. Contact person responsible for corrective action: Kent McGowan, Assistant Director, Office of Financial Aid Anticipated Completion Date: 01/01/2024

Finding Number: 2023-002 Condition: The University used inaccurate or incomplete data in the return of Title IV calculations. Planned Corrective Action: The failure to return funds in a timely fashion is primarily a result of university withdrawal policy not aligning with the timelines required by the regulations. To that end, the university is revising its policies and procedures, specifically as they relate to “medical withdrawals” and for programs where attendance is required. As of June 2023, the University now has reports that identify all the affected students in a timely fashion. Additional resources have been allocated to assure that there is consistency and timeliness in the review of enrollment data specifically as it relates to determining attendance in dropped courses, and students who rescind their intent to withdraw, or enroll in or attend subsequent modules. Contact person responsible for corrective action: Steve Shablin - University Registrar, Matthew Lyth - Financial Aid Officer Anticipated Completion Date: 05/10/2024

Finding Number: 2023-001 Condition: The University did not report the status changes of certain students to the NSLDS in an accurate and timely manner during the fiscal year. Planned Corrective Action: The University is submitting the data to NSLDS via the Clearinghouse in the required timeline. Certain status changes took place after the standard reporting cycle and were not picked up in this process. New processes have been established to identify and report these status changes to NSLDS that take place after the standard reporting cycle. Contact person responsible for corrective action: Becky Keogh, Senior Associate Registrar Anticipated Completion Date: 05/10/2024

Corrective Action Plan For the Year Ended May 31, 2023 Finding 2023-001 Assistance Listing Number(s), Federal Agency and Program Name: 84.063, 84.007, 84.033, and 84.268; United States Department of Education (DOE), Student financial assistance cluster. Finding Type: Noncompliance and material weakness in internal control over compliance relating to special tests. Criteria: The Institute is responsible for designing, implementing, and maintaining internal control over compliance for special tests and provisions and for accurately and timely reporting significant data elements under the Campus- Level and Program-Level records within the National Student Loan Data System (NSLDS) that DOE considers high risk. Statement of Condition: Management implemented controls that specifically addressed the circumstances surrounding prior year finding 2022-001. Management's review of the enrollment reporting did not detect other errors on certain student data elements or timely reporting. Certain student records within the NSLDS were identified with inaccurate data elements and not timely reported. Questioned Costs: Questioned costs could not be determined. Context: 10 students were identified with inaccurate data elements and not timely reported out of a total of 25 students tested. Cause: The Institute’s internal control over compliance did not detect and correct the errors. The preparer incorrectly input the student's effective date and status into NSLDS resulting in inaccuracies in significant Campus- Level and Program-Level enrollment data elements that DOE considers high risk. Effect: The Institute incorrectly reported certain Campus-Level and Program-Level records in NSLDS which is information that DOE considers high risk and the Institute’s internal controls over compliance did not detect and correct the errors. Recommendation: We recommend management review policies and procedures surrounding enrollment reporting submissions to ensure the accuracy of data elements reported to DOE. A review performed by an appropriate individual separate from the preparer prior to the submission of the enrollment reports to NSLDS may improve the accuracy of enrollment reporting. Status: Completed February 2024 Corrective Action: Management agrees with the finding. Through internal investigation, it was determined that there was a procedural issue with the manual entry of two date fields which both need to be the same when submitted to National Student Clearinghouse (NSC). Human error during these manual checks caused one data field to be correct, and the other incorrect. This error has been fixed so that both fields will always be the same and accurate. We have also updated our enrollment reporting procedures to have the registrar log into NSLDS monthly to confirm that the prior month NSC status changes are properly recorded in NSLDS. Contact Jean Weimer Registrar 414-847-3272 jeanweimer@miad.edu Submitted Feb 23, 2024

Finding: Management's review of the enrollment reporting did not detect errors on certain student data elements. Certain student records within the NSLDS were identified with inaccurate data elements. The College is responsible for designing, implementing, and maintaining internal control over compliance for special tests and provisions and for accurately reporting significant data elements under the Campus-Level and Program-Level records within the National Student Loan Data System (NSLDS) that the Department of Education (ED) considers high risk. The College's internal control over compliance for special tests are not operating effectively. The preparer did not update the student's status into NSLDS resulting in inaccuracies in significant Campus-Level and Program-Level enrollment date elements that ED considers high risk. Additionally, student with status changes were incorrectly reported as withdrawn but upon review of internal documentation, those same students graduated. We recommend management review and enhance its review policies and procedures surrounding enrollment reporting submissions to ensure the accuracy of data elements reported to ED. A review performed by an appropriate individual separate from the prepared prior to the submission of the enrollment reports to NSLDS may improve the accuracy of enrollment reporting. We also recommend management review all students reported to NSLDS to verify they are accurately reported. Corrective Action: Management agrees and has implemented necessary procedures/controls to ensure the College is in compliance with enrollment requirements.

Finding number: 2023-002 Federal agency: U.S. Department of Education Programs: Student Financial Assistance Clusters AL #’s: 84.268 Award year: 2023 Corrective Action Plan: The College will be looking at making some business process changes to review files submitted to NSC(National Student Clearing House) and NSLDS (National Student Loan Data Service) on a monthly basis and perform monthly reconciliation between responsible offices to ensure students are accurately reported to ED/NSLDS. This new implementation will allow the College/Office to better verify each student’s enrollment status visibility of reporting issues in the future. Timeline for Implementation of Corrective Action Plan: This new procedure was implemented starting with the Fall 2023 semester and beyond. Contact Person Alex Jean-Jacques Director of Financial Aid of Operations

Condition: The College did not have a control in place to ensure all returns of Title IV refunds were reviewed. As a result, certain student Title IV refund calculations were not correctly calculated and returned.. Planned Corrective Action: • GRCC updated its R2T4 procedure document to highlight the steps needed to be taken so that bookstore charges are handled correctly in the R2T4 calculation. • GRCC provided updated training to the current employees who handle the R2T4 process. • GRCC reviewed all of the R2T4s in which students had bookstore charges. The results were as follows: oTotal number of students: -Fall -- 103 students reviewed; 61 corrections made -Winter -- 83 students reviewed; 5 corrections made o Total amount of adjustments: -Fall = $13,372 -Winter = $1,362 • GRCC reviewed all unofficial withdrawals during fiscal year 2023 adn matched them with R2T4's where required. Once correction was made for $558. This is the same error noted in teh finding. • During the 2023-2024 year (fiscal year 2024), GRCC is performing a 100% review of the R2T4s that have bookstore charges. While performing the review of the bookstore charges, we are reviewing the entire R2T4, not only whether bookstore charges are correctly included. By doing so, we can ensure that the entire process is performed accurately. • Additionally, GRCC will be conducting R2T4 training each semester by way of ensuring that staff who perform the calculations understand the process and the specific steps needed to complete the calculations. Contact person responsible for corrective action: David DeBoer, Executive Director of Financial Aid Anticipated Completion Date: 12/02/2023

Finding 2023-001- Enrollment Reporting Recommendation: It is recommended that the University review policies and procedures in place to resolve reporting issues in a timely manner to facilitate compliance with Title IV regulations. Action Taken: Each error was corrected within the system. Going forward, the reports submitted to NSLDS will be closely reviewed to ensure effective dates for student changes are appropriately reported. In addition, the registrar has updated their process notes which are used each time they pull the report. Responsible Individual for Corrective Action: Registrar - Joanna Raudenbush Anticipated Completion Date: December 31, 2023

2023-001: Student Financial Aid Cluster - Return to Title V Recommendation: We recommend that the Colleges improve the existing procedures and controls to ensure compliance with the aforementioned criteria. We also recommend an additional level of review is added in the process to ensure completed Return to Title IV calculations are properly completed. Action taken in response to finding: The Financial Aid office is implementing the following steps to ensure all Return to Title IV calculations are properly completed: To improve our process, a Return of Funds Calculation report is in place to assist with monitoring the return of unearned aid the Department of Education within 45 days of determination. An additional staff member has been assigned to the Return of Title IV program. We now have two staff members processing Return to Title IV calculations and each will be required to complete R2T4 training on an annual basis. The first staff member is assigned with the review of Return to Title IV calculations, while the second will conduct a secondary review for any miscalculation or data entry error. Thus, each Return to Title IV calculation will be checked by two staff members for accuracy. We will have an additional staff member help with the return of funds to COD to meet the 45-day rule; this will be on the accounting side. Our final step includes management review of Return to Title IV calculations. These added redundancy review will confirm Return to Title IV calculations are accurate. Our Return to Title IV procedures have been updated to reflect these changes. Name of the contact person responsible for corrective action: Chau Dao, Director of Financial Aid & Basic Needs Planned completion date for corrective action plan: June 2024