Corrective Action Plans

Regarding finding 2023-001, The Financial Aid Director will no longer enter the dates of semesters/sessions in the Banner ERP system. The Registrar will assume responsibility for this task and work in conjunction with directors of Financial Aid and the MBA program to ensure term dates are established when needed and accurately maintained. ECD: Effective immediately. Action Officer: Dr. Lolita Rogers, Registrar.

The College agrees that Enrollment Reporting should be submitted in a timely manner. The College is actively working with the new SIS to ensure the ability to be able to produce the reports.

2023-001 Incorrect Direct Loans Disbursement Amount - Student Financial Aid Cluster Assistance Listing Number 84.007, 84.033, 84.063, 84.268, Grant Period - Year Ended June 30, 2023 Condition Found During our student file testing we noted one student out of forty was disbursed the incorrect Direct Loan amount. Based on the student’s enrollment status and need this student was eligible for $1,750 in Subsidized Loans and $1,000 in Unsubsidized Loans; however, the College awarded the student $1,750 in Subsidized loans and $1,250 in Unsubsidized loans which resulted in an over award of $250 in Unsubsidized Loans. We consider this error in awarding to be an instance of noncompliance of the Eligibility Compliance Requirement. Corrective Action Plan During the audit for the year ending Jun 30, 2023, the financial aid office reviewed the finding and was able to refund the over-award of $250 in Unsub within the student’s loan period. Since the finding our Financial Aid Coordinator completed additional trainings related to the administration of Financial Aid. Within these trainings, successful completion of loan processing training was required. As of May 12, 2023, our Financial Aid Coordinator is a certified Financial Aid Administrator through the National Association of Financial Aid Administrators. Responsible Person for Corrective Action Plan Gregory Putra, Director of Financial Aid & Veterans Affairs Implementation Date of Corrective Action Plan 7/1/2023

Name of Responsible Individual: Brian K. Blackburn, Director of Financial Aid Corrective Action: An automated batch email process has been updated to ensure that all loan disbursement notifications will be sent the same day as the loans are disbursed. In addition to the automation, calendar reminders have been set for all scheduled disbursement days. It will be the duty of the Director to ensure the process is successful and would only fall to the Assistant Director in times that the Director is unavailable. Anticipated Completion Date: November 9, 2023

Name of Responsible Individual: Terri Grice, University Registrar Corrective Action: The Registrar’s Office is continuously cross-training all team members so duties are cross-checked, shared by at least two team members, and completed in a timely manner. The reports used by this office will be reviewed on a frequent basis to ensure information is being reported as it was intended. The team will also meet with other departments on a frequent basis to ensure information is shared in a timely manner and continue to train on the regulations and policies between our institution, Clearinghouse, and NSLDS to ensure accurate reporting of information. Anticipated Completion Date: February 23, 2024

Name of Responsible Individual: Brian K. Blackburn, Director of Financial Aid Corrective Action: The University has implemented a weekly COD maintenance file update that will report any change activity to a student’s COD funds. This process is ensured to take place by ongoing calendar reminders as well as progress checks between the Director and Assistant Director. Anticipated Completion Date: November 6, 2023

FINDING 2023-004 Name of Responsible Individual: Brian K. Blackburn, Director of Financial Aid Corrective Action: The link has been submitted to the Department of Education. Anticipated Completion Date: November 16, 2023

Responsible Individual: Eric Gumm Registrar and Director of the First-Year Program and Academic Development Center Abilene Christian University Finding 2023-001 concerning Enrollment Reporting Agency Name: U.S. Department of Education Program Name: Federal Pell Grant, Federal Direct Student Loans October 13, 2023 Finding Summary: Enrollment Reporting (34 CFR 690.93(b)(2); 34 CFR 682.610; 34 CFR 685.309) Institutions are required to report enrollment information. The University’s processes did not ensure timely and accurate student status reporting to National Student Loan Data System (NSLDS). Out of the population of 1,079 students with student attendance changes required to be reported prior to July 19, 2022 or after February 28, 2023, a sample of 25 students were selected for testing. The University reported the incorrect Program Enrollment Effective Date for 10 students and did not timely report a status change for one student. Corrective Action Plan (CAP): After review, the University acknowledges and understands the findings associated with the reporting date of enrollment changes. ACU's official policy regarding recording the effective date of a status change is to designate the date reflected in the SFAREGS screen in Banner as the official date of determination. This is the date that will be reported to NSLDS for any student status changes. Anticipated Completion Date: Within the Fall semester, the University Registrar’s Office will implement sole use of the dates as shown in our Banner mainframe system’s SFAREGS screen for reporting enrollment statuses. This will afford the consistency of dates needed.

Responsible Individual: Thomas Ratliff Director of Student Financial Services Abilene Christian University Finding 2023-002 concerning Return of Title IV Funds Agency Name: U.S. Department of Education Program Name: Federal Pell Grant, Federal Direct Student Loans, Federal Supplemental Educational Opportunity Grants, Federal Work Study Program, Teacher Education Assistance for College and Higher Education Grants October 13, 2023 Finding Summary: Return of Title IV Funds (34 CFR 668.173(b); 34 CFR 668.22€; 34 CFR 668.22(g) and 34 CFR 668.22(i) note that federal regulations state that the return of Title IV funds must be made in the proper amount and in a timely manner as well as apply the return of Title IV funds to federal programs as required. The University’s processes did not ensure the days in the semester were consistently calculated correctly to calculate the return of Title IV funds correctly. Out of the population of 266 students that withdrew during the year, 25 students were tested. Nine instances were noted in which the total days in the semester were not calculated correctly which resulted in the calculation of an incorrect refund amount. Corrective Action Plan (CAP): After review, the university agrees that the students identified had an incorrect number of days included in their Return of Title IV Aid calculations. There was an error in two of our standard academic calendars used for processing these calculations. The university has since manually reviewed every academic calendar for the 2023-2024 academic year to ensure all academic calendars are completely accurate for each possible enrollment variation. The Director of Student Financial Services reviewed these along with each individual who is responsible for processing Return of Title IV Aid calculations, so as to ensure all parties are in complete agreement about the calendar dates. Anticipated Completion Date: Our new manual confirmation assurance has been implemented for 2023-2024. Calendar reminders have been set for each semester of the coming years to ensure the calendars are reviewed again just before the terms begin, to ensure accuracy at the point that calculations are to start for new enrollment periods. We believe this finding will not be repeated due to our enhanced diligence.

Finding 2023-001 A. Comments on Findings and Recommendations: We agree with the finding and recommendation. B. Actions Taken or Planned: The Institution has reviewed the details of the findings and determined the errors to be due to human error. For student #13, the R2T4 in question was a refund which was returned on June 15, 2023, in the amount of $595 to the 2022-2023 Federal Pell Grant Program funds. The Institution should have recalculated the Federal Pell Grant funds to include in the R2T4 calculation. The Institution used $1,261 as Federal Pell disbursed, when we should have only used $420 (due to the student being less than ½ time). After recalculating the Federal Pell, the Institution should have returned $214 to 2022-2023 Federal Pell Grant program funds. This resulted in an under return of $460 in 2022-2023 Federal Pell program funds. In addition, the Institution used an incorrect number of days in the payment period in the R2T4 calculation, resulting in an incorrect percentage of aid earned. For student #AR1, the R2T4 in question was a refund which was returned on May 31, 2023, in the amount of $9 in 2022-2023 Federal Subsidized Direct Loan Program funds. The $9 was in the amount of R2T4 funds which was due to the student and not required to be returned by the Institution. The Institution did not have authorization from the student to return funds to the Federal Subsidized Direct Loan Program. This resulted in an over return of $9. For student #AR15, the R2T4 in question was a refund which was returned on October 24, 2022, in the amount of $929 to the 2022-2023 Federal Pell Grant Program funds. The Institution should have returned $1,431, which resulted in an under return of $502. The Institution used an incorrect number of days in the payment period in the R2T4 calculation, resulting in an incorrect percentage of aid earned. Subsequent to the audit, the Institution returned $962 to the Federal Pell Grant Program funds on behalf of student #13 and student #AR15. The Institution has planned the following immediate solutions to ensure accuracy for R2T4 calculations. • Share Corrective Action Plan (CAP) with accountable staff. • Create a scheduled hours chart for all programs to address the incorrect number of days being calculated in a payment period. Additionally, the Institution will standardize the usage of the automated calculations within the Institution’s Student Information System (Anthology) to help minimize potential human errors within our processes. • Evaluate and update R2T4 policies and procedures as necessary to incorporate these solutions. • Train staff on R2T4 calculations as well as conduct ongoing training on an annual basis. o This will also incorporate training on the Institution’s R2T4 policies, including covering the requirement that student files should be reviewed for appropriate student authorizations as well as the full-time/part-time status of a student. • Re-train staff on the Institution’s R2T4 peer review process. • Establish target dates to review CAP effectiveness. o The Institution will conduct a monthly review of the CAP’s effectiveness for the first six months after implementation of the CAP and then will conduct periodic reviews of the CAP thereafter.

Department of Education Augustana University respectfully submits the following corrective action plan for the year ended July 31, 2023. Audit period: August 01, 2022 – July 31, 2023 The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. FINDINGS—FINANCIAL STATEMENT AUDIT There were no findings in the current year that require corrective action plan. FINDINGS—FEDERAL AWARD PROGRAMS AUDITS DEPARTMENT OF EDUCATION 2023-001 Title: Student Financial Assistance Cluster – Assistance Listing Nos. 84.007, 84.0033, 84.063, 84.268, 84.379 Recommendation: We recommend the University review its reporting procedures to ensure that students’ statuses are accurately reported to NSLDS as required by regulations. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: We have implemented a secondary compliance check of student withdrawal dates. As the Registrar Assistant is notified of student withdrawals, the ‘Leave Date’ is entered into the Jenzabar/CX system. On a weekly basis, the Assistant Registrar will double check the withdrawal notice with the date in Jenzabar/CX. Performing this double check on a weekly basis should catch any incorrectly entered dates before they are transmitted to NSLDS. If an incorrectly entered date is found, the Assistant Registrar will notify the Director of Financial Aid, who will check NSLDS to further ensure the date has not been incorrectly included in enrollment reporting. Name(s) of the contact person(s) responsible for corrective action: Joni Krueger Planned completion date for corrective action plan: immediately / already implemented If the Department of Education has questions regarding this plan, please call Joni Krueger at 605.274.4121.

Department of Education Carleton College respectfully submits the following corrective action plan for the year ended June 30, 2023. Audit period: July 01, 2022 – June 30, 2023 The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. FINDINGS—FINANCIAL STATEMENT AUDIT There were no findings in the current year that require corrective action plan. FINDINGS—FEDERAL AWARD PROGRAMS AUDITS DEPARTMENT OF EDUCATION 2023-001 Title: Student Financial Assistance Cluster – Assistance Listing Nos. 84.007, 84.0033, 84.063, 84.268 Recommendation: We recommend the Institute review its reporting procedures to ensure that students’ statuses are accurately and timely reported to NSLDS as required by regulations. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: We have developed additional validation steps to confirm that the status of every student who has completed their program and graduated is accurately reflected at both the National Student Clearinghouse and at NSLDS. Name(s) of the contact person(s) responsible for corrective action: Theresa Rodriguez Planned completion date for corrective action plan: 9/30/2023 If the Department of Education has questions regarding this plan, please call Theresa Rodriguez, Registar at 507-222-4290.

The Vice President of Finance corrected the disbursement dates for the students in question in September 2023. Going forward, the Student Financial Aid Office and Business Office will coordinate the drawdown of funds, reporting to COD, and posting to student accounts. The personnel of the College understands that while on the cash advance method to disburse funds, they have three business days from the date the funds are received to post the funds to the student accounts. However, the disbursement date on the student account and in COD still must agree. Anticipated Completion Date: The corrective action was completed in September 2023. Contact Person: Stephanie Dickerson, Registrar/Financial Aid 910-323-5614

Pursuant to federal regulations, Uniform Administrative Requirements Section 200.511, the following are the findings as noted in the Macomb Community College Single Audit Act Compliance report for the year ended June 30, 2023, and corrective actions to be completed. 2023-001 Special Tests and Provisions - Enrollment Reporting Auditor Description of Condition and Effect. We noted that one out student of a testing population of two was not reported timely to NSLDS and did not have the correct status change reported. As a result of this condition, the College was exposed to an increased risk that incorrect and untimely information would be reported to NSLDS. Auditor Recommendation. We recommend that the College consistently apply their enrollment reporting procedures to prevent untimely status change reporting in the future. Corrective Action. This situation occurred because the student graduated during a term in which they were not enrolled. This is connected to our upload to the National Student Clearinghouse which did not mark the student as graduated (G Not Applied) in our degree verify file. There is a known defect in our student information system that causes this issue. We are currently working collaboratively with our information technology department to resolve this defect which will ensure that we capture students in this situation in the future. Responsible Person. Registrar/Director of Enrollment Services Anticipated Completion Date. June 30, 2024

Finding 2023-007 Special Tests and Provisions – Perkins Loan Recordkeeping and Record Retention Federal Agency Name: Department of Education Program Name: Student Financial Aid Cluster CFDA # 84.038 – Federal Perkins Loan Program Finding Summary: We did not maintain all records as required under the program and as a result, subsequent to yearend, were required to buy back specific Perkins Loans that did not have proper documentation maintained. Responsible Individuals: Jillaine Smith, Chief Operating Officer, Erin Drew, Facilitator of Advancement Services and Patty Pietz, Presentation Sisters Accountant. Corrective Action Plan: All loan documentation was provided to Department of Education as part of the liquidation process and any loans that did not have proper documentation were purchased back by the College in September 2023 and the Perkins Liquidation was complete with final reporting requirements completed. Anticipated Completion Date: September 30, 2023

Finding 2023-005 Special Tests and Provisions – Enrollment Reporting Federal Agency Name: Department of Education Program Name: Student Financial Aid Cluster CFDA # 84.268 – Federal Direct Student Loans CFDA # 84.063 – Federal Pell Grant Program Finding Summary: During testing of enrollment reporting, it was noted that 7 of 19 students tested were not reported to NSDLS with changes in effective dates and enrollment statuses; and the certification dates were not within 60 days of the changes and 8 of 19 students tested were reported to NSLDS with incorrect program begin dates. Responsible Individuals: Jillaine Smith, Chief Operating Officer, Erin Drew, Facilitator of Advancement Services and Patty Pietz, Presentation Sisters Accountant. Corrective Action Plan: The errors noted in tested were corrected when we were notified of the errors and additional review was taken to ensure that a final enrollment roster was submitted as required as part of the close audit process. Anticipated Completion Date: September 30, 2023

Finding 2023-004 Cash Management –Reconciliations (Direct Loan) Federal Agency Name: Department of Education Program Name: Student Financial Aid Cluster CFDA # 84.268 – Federal Direct Student Loans Finding Summary: When testing cash management related to reconciliations, the auditors noted 2 of the 12 monthly SAS reconciliations were not completed. Responsible Individuals: Jillaine Smith, Chief Operating Officer, Erin Drew, Facilitator of Advancement Services and Patty Pietz, Presentation Sisters Accountant. Corrective Action Plan: The Student Financial Aid Director completed a final reconciliation after final disbursements were made to students to ensure all aid awards was correctly reflected. Anticipated Completion Date: September 30, 2023

Finding 2023-003 Eligibility – Calculation of the Amount of Pell, Subsidized and Unsubsidized Direct Loan Assistance Awarded Federal Agency Name: Department of Education Program Name: Student Financial Aid Cluster CFDA # 84.033 – Federal Work Study Program CFDA # 84.268 – Federal Direct Student Loans CFDA # 84.007 – Federal Supplemental Educational Opportunity Grants (FSEOG) CFDA # 84.063 – Federal Pell Grant Program Finding Summary: During testing over the eligibility requirements, the following deficiencies were noted: • 2 of 60 students were not awarded the correct amount of Pell. One student was under awarded by $2,773 and one was over awarded by $862. • 7 of 60 students were not awarded the correct amount of subsidized loans. 4 students were under awarded subsidized loans based on being awarded as the wrong academic year in school; and 3 students were over awarded subsidized loans as the student did not have financial need. • 5 of 60 students were not awarded the correct amount of unsubsidized loans. All 5 of the students with errors were under awarded unsubsidized loans based on being awarded as the wrong academic year in school. Responsible Individuals: Jillaine Smith, Chief Operating Officer, Erin Drew, Facilitator of Advancement Services and Patty Pietz, Presentation Sisters Accountant. Corrective Action Plan: The College has reviewed all students impacted by the errors noted above and made corrections to the students as needed. Anticipated Completion Date: September 30, 2023

Finding 2023-006 Reporting – Special Reporting – Fiscal Operations Report and Application to Participate (FISAP). Federal Agency Name: Department of Education Program Name: Student Financial Aid Cluster CFDA # 84.033 – Federal Work Study Program CFDA # 84.007 – Federal Supplemental Educational Opportunity Grants (FSEOG) CFDA # 84.063 – Federal Pell Grant Program CFDA # 84.268 – Federal Direct Student Loans CFDA # 84.038 – Federal Perkins Loan Program Finding Summary: In testing key line items as indicated in the compliance supplement, the auditors noted 2 line items for which amounts reported in the FISAP did not agree to supporting records and documentation that were provided during testing. Lines that were not reported correctly were Part II, Section E Line 22 and Part II, Section D Line 7. Responsible Individuals: Jillaine Smith, Chief Operating Officer, Erin Drew, Facilitator of Advancement Services and Patty Pietz, Presentation Sisters Accountant. Corrective Action Plan: Any errors that were required to be corrected were made for 2022 and resubmitted to the Department of Education prior to the 2023 report being completed. Anticipated Completion Date: September 30, 2023

Department of Education Macalester College respectfully submits the following corrective action plan for the year ended May 31, 2023. Audit period: June 01, 2022 – May 31, 2023 The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. FINDINGS—FINANCIAL STATEMENT AUDIT There were no findings in the current year that require corrective action plan. FINDINGS—FEDERAL AWARD PROGRAMS AUDITS DEPARTMENT OF EDUCATION 2023-001 Title: Student Financial Assistance Cluster – Assistance Listing Nos. 84.038, 84.268, 84.007, 84.063 Recommendation: We recommend the College evaluate the circumstances that delayed reporting disbursements to COD to ensure that it will not happen again. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: We experienced a malfunction in our reporting software and were not aware of the issue until after the reporting deadline. We now have procedures in place whereby we confirm that COD has received the file once we have submitted it. Name(s) of the contact person(s) responsible for corrective action: Jenae Schmidt Planned completion date for corrective action plan: Implemented in November 2022. If the Department of Education has questions regarding this plan, please call Jenae Schmidt at 651-696-6214.

WGU has implemented the appropriate identification of the TPD comment codes with our new aid year configuration and will continue this course of action whenever the new aid year FAFSA is released. The comment code numbering changed in 2024‐ 2025 from 2023‐2024. WGU will review and match the new 2024‐2025 codes with its corresponding 2023‐2024 codes to ensure our system is configured to identify ISIR records that are flagged by FSA requiring further action accordingly. Auditee Contact Person(s) Responsible for Corrective Action: Patti Kohler Vice President, Financial Aid.

The Financial Aid Director recalculated the “need” for each student in question. The Financial Aid Director agreed with the auditor’s calculations. The following corrections were made on August 8, 2023: For the first student, $2,000 of subsidized federal direct loans were reallocated to unsubsidized federal direct loans. For the second student, $382 of subsidized federal direct loans were reallocated to unsubsidized federal direct loans. For the third student, $1,649 of subsidized federal direct loans were reallocated to unsubsidized federal direct loans. For the fourth student, $1,145 of federal work study funds were returned to the Department of Education. The student had already worked for the University and earned the funds in question. He was treated as a regular employee of the University and paid with institutional funds instead of federal work study funds. Anticipated Completion Date: The corrective action was completed on August 8, 2023. Contact Person Shala LaTorraca, Director of Financial Aid 918-335-6260

2023-003 Student Financial Assistance Cluster – Assistance Listing No. Various Recommendation: We recommend the University review their documentation and ensure that there are documented safeguards for identified risks. We also recommend reviewing the changes in the Gramm-Leach-Bliley Act regulations that were required to be implemented as of June 9, 2023. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The IT Executive Director will review the completed risk assessment to identify specific shortcomings, so that safeguards can be documented in relation to those specific risks. Additionally, he will review the updated GBLA regulations and ensure the University is in compliance. Name of the contact person responsible for corrective action: Brandon Ray, Executive Director, Information Technology Planned completion date for corrective action plan: January 31, 2023.

Department of Education 2023-002 Student Financial Assistance Cluster – Assistance Listing No. Various Recommendation: We recommend the University review their internal control procedures over awarding, return of title IV calculations, and professional judgment and implement a formally documented review process. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The University will make the following changes: Awarding: The following are internal controls that the University already has in place to review awards for accuracy. • Financial aid worksheet: As part of the awarding process every award year, a financial aid worksheet is created to verify that the awards input in Colleague are accurate. The worksheet is updated each time there is a change to a student’s financial aid eligibility or status. • COD report monitoring: On a weekly basis, reports are processed to determine if there are any discrepancies between what has been awarded in Colleague and what is being reported/accepted in COD. Any discrepancies found are reviewed and corrected. • Monthly loan/grant reconciliation: The monthly loan/grant reconciliation monitors for any discrepancies between what is shown as disbursed in Colleague and the disbursements that have been accepted by COD. Any discrepancies found are reviewed and corrected. • Over award report: Processed at the beginning of each term, this report details if any students are awarded beyond unmet need and/or cost of attendance. Any discrepancies found are reviewed and corrected. • Enrollment level report: Processed before the start of each term and at the end of the add/drop period, this report evaluates awarded enrollment level against actual enrolled credits. Any discrepancies found are reviewed and corrected. • Disbursement processing rules: There are rules built into the Colleague system to limit disbursement of awards when actual enrollment status does not match awarded status. Any discrepancies found are reviewed and corrected. Beyond the internal controls already in place, the University will implement the following: • Secondary review of awards: For new Financial Aid Counselors, all awards will be reviewed for the first two months to ensure accuracy and commitment to proper training. Additionally, based on current staffing levels, a random selection of 10% of all awarded students will be reviewed to evaluate for awarding accuracy. • Grade level review: After the 10th day of each term, a review will be performed to compare the current class standing of each student to the grade level that was used for awarding. Any discrepancies found will be reviewed and corrected. Return to Title IV (R2T4) Calculations: The Colleague system is used to process R2T4 calculations. This system has been developed to correctly calculate the return formula based on limited information entered by the R2T4 processor. To ensure the correct information is entered, the University will implement a secondary review of all R2T4 calculations. The primary R2T4 processor will enter all required information in the R2T4 calculation screen within Colleague, and then print the screen for review by a secondary member before the return is referred for processing. The primary processor and secondary reviewer will be required to sign off on the printed calculation sheet, verifying the accuracy of the information. The items that will be included as part of the secondary review will be the date of determination, enrollment status, last date of attendance, and institutional charges. Professional Judgment: The University will implement a Professional Judgment Committee. The committee will consist of at least one Financial Aid Counselor and the Director of Financial Aid. The committee will collectively review all the documentation for each case to make a final determination. Name of the contact person responsible for corrective action: Dustin Kummrow, Director of Financial Aid Planned completion date for corrective action plan: November 1, 2023

2023-002 Student Financial Aid Cluster – Assistance Listing No. 84.007, 84.033, 84.063, 84.268 Recommendation: We recommend that the University consider any NSLDS access and documentation requirements necessary to ensure compliance with the stated criteria. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: As part of the University winding down operations, and no longer providing educational services, University management will consider any modifications to the NSLDS access and documentation requirements necessary to ensure compliance with the stated criteria. Name(s) of the contact person(s) responsible for corrective action: Rachel Nielsen, Vice President of Finance and Administration Planned completion date for corrective action plan: July 31, 2024