Corrective Action Plans

Action taken: As of June 2023, the Financial Aid department has a full-time Director, who is responsible for the Return to Title IV (R2T4) determinations. Following the regulations set forth by the Department of Education on R2T4 calculations for schools not required to take attendance, we have reviewed procedures and controls to ensure they are properly designed and implemented to ensure calculations are occurring accurately and timely. Going forward, we will ensure maintenance of proper documentation on students requiring a calculation, including indication of withdrawal date. Potential R2T4 calculations audits are now run multiple times a week, and will continue to be, in order to address timely calculations. The Director plans to continue education in the area of R2T4 calculations to maintain the most accurate and updated information on the topic. Name of Responsible Party: Erin Schaffer, Director of Financial Aid Anticipated completion date: 12/31/2023

CORRECTIVE ACTION PLAN YEAR ENDED JUNE 30, 2023 Finding: Special Tests and Provisions - Gramm-Leach-Bliley Act (GLBA) -Student Information Security - Yosemite Community College District (the "District") did not have a designated individual responsible for implementing and monitoring the institution's information and security program and did not have a written security program in place that addresses the minimum required elements as required under GLBA. Corrective actions taken or planned: The District has started the process of developing a job description for the creation of a position expected to be called the Chief Information Security Officer. The individual hired for this position will be directly responsible for coordinating the information security program, preparing a risk assessment that meets the requirements of 16 CFR 314.4{b), and document a safeguard for each risk identified. Anticipated completion date: June 30, 2024 Contact person responsible: Vice Chancellor of District Administrative Services Columbia

A. The specific findings and plans of action are as follows: Huntington Junior College is committed to addressing the findings of our administration of Title IV programs. We concur with the findings and recommendations of the audit team. B. Actions Taken or Planned. Finding 2023-002 Failure to Meet the Standards for Safeguarding Customer Information. The security of all customer information is very important to Huntington Junior College. We have engaged a new IT firm to establish and maintain proper GLBA requirements. All faculty and staff will be retrained on information security policies and procedures.

A. The specific findings and plans of action are as follows: Huntington Junior College is committed to addressing the findings of our administration of Title IV programs. We concur with the findings and recommendations of the audit team. B. Actions Taken or Planned - Finding 2023-001 Untimely Enrollment Status Reporting. During Spring 2023 the transition to non-profit status created some delays in processing information. Financial Aid officers have been counseled to emphasize the importance of timely enrollment reporting.

Finding 2023-001 – U.S. Department of Education (USDE), Title IV Student Financial Aid Programs We observed the following conditions in connection with our testing of the various U.S. Department of Education, Title IV, Student Financial Assistance Programs: 1. Two (2) out of 16 students tested did not have timely or accurate enrollment reporting to the National Student Loan Data System (NSLDS). 2. One (1) out of 16 students tested did not have a post withdrawal disbursement within the allotted days of the school’s withdrawal date determination. 3. One (1) out of 16 students tested did not have Title IV funds returned within the allotted days of the school’s withdrawal date determination. 4. One (1) out of 16 students received Title IV funding and was not charged for courses taken. The questioned cost is $124. The funds were subsequently returned to the USDE. 5. One (1) out of 16 students received a Pell grant greater than the amount for which the student was eligible. The questioned cost is $862. The funds were subsequently returned to the USDE. 6. Five (5) out of 16 students were selected for refund canceled check testing. There was no documentation provided to test signatures for two (2) of the students selected. All requested documents were subsequently provided. 7. One (1) out of 16 students tested was eligible for a Federal Direct Subsidized loan and was not awarded. 8. One (1) out of 16 students tested had an award letter that stated subsequent Title IV disbursements were available to the student and the subsequent disbursements were not awarded." The University should implement corrective actions to ensure that the above findings are resolved and do not recur in future periods. Corrective Actions – 1. NSLDS reporting is actively reconciled monthly with our third-party financial aid servicer and, as of November 16, 2023, the University confirmed 97.34% reported. The University will continue to actively monitor this reporting to ensure accuracy and timeliness. 2. Student Information System integration with third-party financial aid servicer’s system will allow the University to improve timing of drop notifications to ensure the third-party financial aid servicer is notified timely. The University will continue to monitor and review the process of withdrawal disbursement more thoroughly with the third-party financial aid processor to ensure that they are processed timely. 3. The University will monitor and review the process of returning Title IV funds to ensure that returns are processed timely. 4. The University has implemented a process that cross-checks enrollment with financial aid funding to identify and address situations in which students are inappropriately awarded Title IV funding. 5. The University is working with its third-party financial aid servicer to ensure Pell grants are awarded appropriately and within the amounts eligible. The University will ensure timely enrollment changes are sent to third-party financial aid servicer for any adjustments to aid eligibility. 6. The University has robust controls related to student refunds, and will continue to enforce these controls and retain the necessary documentation. 7. The University is working with its third-party financial aid servicer to ensure Federal Direct Subsidized Loans are awarded in all cases where appropriate. This is a unique situation where the FA software failed to recognize NSLDS information. The third-party financial aid servicer will monitor students closer until the system issue is resolved. 8. The Universiy is working with its third-party financial aid servicer to ensure Title IV disbursements, as outlined in award letters, are ultimately awarded.

Finding 2023-002 Using a Servicer of Financial Institution to Deliver Title IV Credit Balances Views of Responsible Officials The District agrees with the auditor’s findings and recommendations. Corrective Action Plan Under the Title IV cash management regulations, institutions are required to publicly disclose any contract that governs a Tier One or Tier Two Arrangement as well as information about the costs incurred by students who elect to use a financial account offered under one of those arrangements. The District submitted the required disclosure of its Tier One contract with BankMobile Technologies, Inc. to the Department of Education on November 29, 2023. Additional information about student refunds including the District’s contract with BankMobile Technologies, Inc. is currently available to the public at the following link. https://www.tccd.edu/services/paying-for-college/refunds/ Implementation Date Immediate Individual(s) Responsible The Director of Business Services is responsible for disclosures related to student refunds.

The College has returned the ineligible FSEOG to ED. In addition, the College has implemented a system rule in our Financial Aid Management system to prevent additional funds from disbursing after a Return to Title IV is calculated. The College continues to develop its staff and is comfortable with their abilities to prevent such findings in future years.

Review and correct, if necessary, all May and August 2023 graduation records that were returned with the G Not Applied indicator in NSC to ensure that each student’s G status is accurate at the campus and program level in NSC and NSLDS. Anticipated Completion Date November 2023 Run queries to identify Fall 2023 withdrawn students (to date); review the students’ NSC time status to ensure it has been submitted accurately. Anticipated Completion Date November 2023 Add a “Grads Only” file submission to the NSC reporting cycle for all campuses. Anticipated Completion Date on or about January 2024 (or when query is built) Increase the frequency of the Daytona Beach campus and Prescott campus NSC/NSLDS enrollment file submissions to improve the timeliness of reporting. Anticipated Completion Date on or about January 2024 (or when query is built)

Finding Number: 2023-002 Corrective Action: Enrollment reporting is performed by the Office of Student Records. The new university registrar has modified the enrollment reporting process to include audits of all student-related data prior to census day. Any changes in student academic program received after census day will be effective for the next academic semester. Additionally, the registrar created procedural changes to ensure reporting happens for every reporting period with the added redundancy of additional staff. All reporting periods are recorded on the Office of Student Records’ office calendar and in their processing action plan document. Responsible: Karen Jarrell, University Registrar Completion Date: November 1, 2023

Finding Number: 2023-001 Corrective Action: All official and unofficial withdrawals are performed by the Office of Student Records. The new university registrar and deputy director are working collaboratively with the Financial Aid Office to follow defined processes and procedures for both official and unofficial withdrawals. The registrar has developed a new standard operating procedure for processing official and unofficial withdrawals. The registrar has already completed the staff training on the new procedure. The Financial Aid Office is responsible for calculating the return of Title IV funds (R2T4). The financial aid administrator selected the wrong template when performing one of the R2T4 calculations in COD. A new internal control procedure has been implemented to ensure that R2T4 calculations are reviewed for accuracy by a second financial aid administrator before being processed. Responsible: Karen Jarrell, University Registrar, and Elaine Robinson, Director of Financial AidCompletion Date: November 1, 2023

Student Financial Assistance Program Cluster – Department of Education Federal Financial Assistance Listing #84.063 Federal Pell Grant Program (PELL) P063P202209, P063P212209, P063P222209 Finding 2023-003 – Eligibility – Material Weakness Finding Summary: Two instances identified in which the student was eligible to receive Federal Pell assistance but was not awarded the assistance. Responsible Individuals: Lauren Svanda, Director of Financial Aid Corrective Action Plan: Partake in additional training in the awarding of summer PELL. Update procedures on how information is communicated between the Registrar’s Office and Financial Aid to improve awareness of summer reporting and grade change updates. Recondition the reporting process to improve accuracy of delivered information. Anticipated Completion Date: January 1st, 2024

Finding 2023-001 Correc􀆟ve Ac􀆟on Plan This is a response to Finding 2023-001 listed in the Schedule of Findings and Ques􀆟oned Costs for Federal Awards. Unity Environmental University agrees with this finding and has taken the following correc􀆟ve ac􀆟ons to prevent recurrence of such findings. While tes􀆟ng the return of Title IV funds, a nonsta􀆟s􀆟cal sample of 25 students was tested for proper return calcula􀆟ons. During the tes􀆟ng, 1 of 25 calcula􀆟ons were incorrectly calculated. The error did not result in addi􀆟onal funds to be returned. The student in ques􀆟on had a􀆩ended one module of two in the graduate program payment period. When the recalcula􀆟on was performed, the full payment period was used. The student had earned 100% of aid due to comple􀆟ng 60% of the period. The error was not caught by the second reviewer. This occurred during a 􀆟me of low staffing in the financial aid office and a high volume of ac􀆟vity. The calcula􀆟on was corrected but no addi􀆟onal funds needed to be returned as the student s􀆟ll earned 100% of aid due to comple􀆟ng 60% of the module. In an abundance of cau􀆟on, the financial aid staff reviewed R2T4 calcula􀆟ons completed for all graduate students. No addi􀆟onal errors were found. The financial aid staff met to discuss the finding and management emphasized the impact to the student and ins􀆟tu􀆟on when these errors occur. We believe this was an isolated incident and the staff understands the importance of the second reviewer role to avoid such errors. Responsible Person: Sherry Watson Correction Date: 06/27/23

Recommendation: We recommend the College evaluate and enhance the college’s financial aid awarding procedures to prevent future instances of over-awarding. We recommend the College establish a system for ongoing monitoring of financial aid awards to identify and address discrepancies in a timely manner. Regularly review and update policies and procedures to adapt to changes in regulations and best policies. Corrective Action: The college financial aid office will review and update policies and procedures in the Clarendon College Financial Aid Handbook to establish system for ongoing monitoring of financial aid awards in order to identity and address discrepancies and potential over-awards in a timely manner. The system will include monitoring Cost Of Attendance, enrollment status, and unmet need. The policy/procedure will be reviewed and submitted for adoption by the CC Board of Regents for the Clarendon College Financial Aid Handbook by February 2024.

Finding 2023-008 – Student Financial Assistance Cluster – Fraudulent Enrollment Condition City Colleges did not timely report information regarding potential fraudulent student enrollments to the Department of Education’s Office of Inspector General (OIG). City Colleges identified a total of 23 students where the Enrollment and Admissions Departments discovered submission of fraudulent documents to verify residency. City Colleges performed a thorough investigation of student enrollment and verified that no aid was disbursed for these identified fraudulent enrollments Cause City Colleges experienced turnover in the Admissions Department and was training a new employee. The new employee did not have enough training or experience to identify fraudulent documents when the students enrolled with the college and registered for classes. City Colleges was not aware that this issue was required to be reported to the Department of Education. Corrective Action Taken or Planned: The College will review and monitor the Department of Education regulations. The Student Financial Aid will continue to train employees on the regulations and will timely report issues to the Department of Education. Contact Person: Tiffany Morrison, Associate Vice Chancellor – Financial Aid & Scholarship Anticipated Completion Date: In progress

Finding 2023-006– Gramm-Leach Bliley Act—Student Information Security Condition City Colleges did not have a documented policy to address a required safeguard for one of the eight required elements under the Gramm-Leach Bliley Act (GLBA). Specifically, the City Colleges did not conduct a periodic inventory of data, nothing where it’s collected, stored or transmitted. Cause City Colleges does not have a periodic data inventory in place. The policy is under development with an expected completion date of December 2023. Corrective Action Taken or Planned CCC will refresh the current data inventory and instate periodic inventory refresh procedures by December 31, 2023. Contact Person: Zarko Njakara, Interim CIO Anticipated Completion Date: December 31, 2023

Finding 2023-005– Student Financial Assistance Cluster Internal Control over Compliance Condition City Colleges did not have sufficient documentation that internal controls were in place and operating effectively relative to the following areas: • Allowable Activities: For each of the seven campuses, City Colleges did not have sufficient supporting evidence that review controls were performed over the transfer, carryforward, carryback, and administrative cost calculations in the Fiscal Operations Report and Application to Participate (FISAP) for award year July 1, 2021 through June 30, 2022 submitted during fiscal year 2023. • Reporting: For each of the seven campuses, City Colleges did not have sufficient supporting evidence that secondary review controls were performed over FISAP data for award year July 1, 2021 through June 30, 2022 submitted during fiscal year 2023. Cause City Colleges did not formally document the additional reviews and approvals over the department’s review of the FISAP. Corrective Action Taken or Planned Financial Aid will develop and document a review/approval process that will detail accurate reporting, secondary reviews, and review/approval of FISAP submissions and completions. Contact Person: Tiffany Morrison, Associate Vice Chancellor, Financial Aid Anticipated Completion Date: December 31, 2023

Finding 2023-004 – Cash Management – Excess Cash Condition During our cash management testing, we identified the following instances of excess cash: • Kennedy King College had excess cash for the Pell Grant Program ranging from $34,408 to $175,609 during the period of November 14, 2022 through January 31, 2023. In these situations, the excess cash exceeded one percent of total prior year drawdowns and amounts were not returned within a seven-day period. • Kennedy King College had excess cash for the Direct Loan Program ranging from $1,349 to $4,318 during the period of November 29, 2022 through December 13, 2022, from $1,508 to $3,948 during the period of January 6, 2023 through January 16, 2023 and from $3,207 to $5,137 during the period of June 15, 2023 through June 29, 2023. In these situations, the excess cash did not exceed one percent of total prior year drawdowns, however, amounts were not returned within a seven-day period. • Truman College had excess cash for the Pell Grant Program ranging from $164,625 to $262,034 during the period of November 14, 2022 through January 31, 2023. In these situations, the excess cash exceeded one percent of total prior year drawdowns and amounts were not returned within a seven-day period. • Truman College had excess cash for the Direct Loan Program ranging from $2,731 to$8,669 during the period of January 20, 2023 through February 16, 2023 and from $752 to $10,028 during the period of April 28, 2023 through June 29, 2023. In these situations, the excess cash did not exceed one percent of total prior year drawdowns; however, amounts were not returned within a seven-day period. Cause The College drew down funds available in the G5 system as opposed to drawing down expected student disbursement amounts. Corrective Action Taken or Planned District Office Financial Aid will develop and implement better controls and procedures for monitoring the timing of the draw downs and student disbursements as well as controls to monitor the return of excess cash, if any, within the 7-day period. During the middle of a semester, timely reconciliations will be prepared, reviewed and approved prior to the next draw down to ensure the acceptable amount is drawn down and disbursed timely to the students. Contact Person: Tiffany Morrison, Associate Vice Chancellor, Financial Aid Anticipated Completion Date: December 31, 2023

Finding 2023-003 – Common Origination and Disbursement (COD) Reporting Condition For ten out of forty students tested (25%), the College did not report certain disbursements of financial aid to COD within the require fifteen days from the date of disbursement. In all instances, the disbursements were reported one day late. Cause The financial aid office inadvertently miscalculated the reporting date. Corrective Action Taken or Planned Financial Aid will add additional monitoring controls of COD files to ensure timely reporting. Contact Person: Tiffany Morrison, Associate Vice Chancellor, Financial Aid Anticipated Completion Date: December 31, 2023

Finding 2023-002 – Short-Term Program Completion and Placement Rates Condition The College did not achieve the required 70% completion rate for a short-term program. The College cannot demonstrate compliance with the gainful employment placement rate calculation for a short-term program. Cause The financial aid office did not follow-up on the gainful employment of students. Corrective Action Taken or Planned The Financial Aid Office will work with campus leadership and staff to ensure an accurate reporting process is in place to track gainful employment and completion. Documentation will be required by campus leadership to show communication efforts for students. Contact Person: Tiffany Morrison, Associate Vice Chancellor, Financial Aid Anticipated Completion Date: December 31, 2023

Finding 2023-001 – Enrollment Reporting Condition For four out of sixty students tested (7%) who withdrew from City Colleges, the students’ withdrawal date reported to the National Student Loan Data System (NSLDS) for campus level and program level did not match the institution’s records. Cause The financial aid office does not have an effective system in place to ensure all official student status changes are reported to the lender accurately. Corrective Action Taken or Planned City Colleges sends enrollment files of all students to the National Student Clearinghouse monthly, who then reports CCC enrollment data to NSLDS. City Colleges (Records, Financial Aid, Decision Support and the Office of Information Technology) continues to meet bi-weekly to review and update the enrollment reporting logic to ensure the dates for student enrollment actions align at the campus level and the program level. Contact Person: Laura Clark, Associate Vice Chancellor, Academic Systems and Tiffany Morrison, Associate Vice Chancellor, Financial Aid. Anticipated Completion Date: May 1, 2024

The School returned the $2,585.50 in question to the Department of Education on September 6, 2023. Communication will be improved between the various offices on campus. Policies and procedures are being reviewed and updated, as needed, for the students participating in on-line courses. Anticipated Completion Date: The corrective action was completed on September 6, 2023. Contact Person Valorie Quesenberry, Financial Aid Coordinator 513-763-6659

The credit balances were returned to the students in question before the end of the academic year. The financial aid office will follow-up with the cashier to ensure that, in the absence of a signed authorization to hold credit balances authorization, the credit balance refunds requested are processed timely. Anticipated Completion Date: The corrective action was completed in May 2023. Contact Person Valorie Quesenberry, Financial Aid Coordinator 513-763-6659

Management agrees with the auditors’ finding. Federal Pell Grant funds are entitlement funds and cannot be returned. The student in question also worked the hours in which Federal Work Study funds were awarded. Going forward, the School has made changes to the provisions of the institutional scholarship to avoid overawards. All state and federal aid and endowed scholarships are applied first and then the scholarship covers the remaining tuition cost. The corrective action was completed in September 2023. Contact Person Valorie Quesenberry, Financial Aid Coordinator 513-763-6659

Federal Direct Loan exit interview information was sent to the student in question on October 27, 2023. Procedures will be improved to ensure Federal Direct Loan exit interviews are completed or information is sent to students when they drop below a half-time enrollment status at the School. Anticipated Completion Date: The corrective action was completed on October 27, 2023 Contact Person Valorie Quesenberry, Financial Aid Coordinator 513-763-6659

Regarding finding 2023-002, Due to costs associated with full and immediate implementation, The College use a phased approach and will continue to make progress of meeting the federal standards related to the GLBA security program. The college expects to at minimum 80% in compliance by the end of FY24 and in full compliance by the end of FY25. The college will prioritize key elements such as reviewing access controls, implementing multi-factor authentication for the campus, disposing of student information securely, performing annual penetration testing, and encrypting all the institution's information. ECD: June 30, 2026. Action Officer: Mr. Scott Merritt, Director of Information and Technology & CIO.