Corrective Action Plans

Aggregate Loan Limits Planned Corrective Action: ·The financial aid leadership team (Director and Associate Director) will review the current awarding loan processes to determine where the deficiencies are to ensure this issue does not reoccur next year. ·The financial aid leadership team will review the setup to configure automation and minimize manual processes to catch student approach loan limits ·The financial aid team will review NSLDS when students are flagged for approaching loan limits to verify remaining eligibility. Person Responsible for Corrective Action Plan: Kary Tejeda-Executive Director of Financial Aid and Veteran Services, Elisa Fisher-Associate Director of Financial Aid Operations and Dr. Anthony Turner-Vice President of Enrollment and Marketing Anticipated Date of Completion: March 15, 2024

Inaccurate and Untimely Return of Title IV Funds (R2T4) Planned Corrective Action: The oversight of R2T4 will be performed by the Financial Aid team. Going forward all Return of Title IV will be processed in PowerFAIDS enabling the calculation to be completed and the funds adjusted at the same time. This should eliminate the late return of funds. Person Responsible for Corrective Action Plan: Kary Tejeda, Executive Director of Financial Aid and Veteran Services, Julie Hodge-Assistant Director of Compliance Anticipated Date of Completion: January 15, 2024

Views of Responsible Officials and Planned Corrective Actions – The University moved from an on-premise solution to a cloud environment in fiscal year 2022. This upgrade included a new reporting tool. The reports used to identify and send disbursement notifications were not working as expected, therefore notifications were not sent out in a timely manner. The Director of Financial Aid has created a process to ensure all students and parents receiving loan funds are being notified about their right to cancel their loans. This process will be run immediately after loans have been transmitted to a student's account. The letters will be emailed to the student and parent email address.

Views of Responsible Officials and Planned Corrective Actions - The Student Financial Services Office is notified by the Registrar's Office when a student has completed the withdrawal process. Once that notification has been received, the Director of Financial Aid will complete the return of Title IV funds worksheet on the Common Origination and Disbursement (COD) website and update Colleague accordingly. A letter will be sent to the student notifying them of the modification to their financial aid award. To ensure all withdrawn students receiving federal financial aid have been processed, the Argos Withdrawn Student report will be run monthly. Each student will be reviewed to see if federal financial aid was awarded and disbursed for the term in which they withdrew. If there is a student that still needs to be processed, the Director of Financial Aid will complete those steps immediately.

Views of Responsible Officials and Planned Corrective Actions – The Registrar's Office reports student enrollment status to the National Student Clearinghouse according to the predetermined reporting schedule based on our census dates. The University opened a case with the Clearinghouse's audit resource department to gather information on what may have led to reporting delays. The Clearinghouse has indicated there was an NSLDS outage between July 2022 and March 2023 which could have resulted in several delays, such as those noted in the audit. If future NSLDS outages are anticipated or known, the Registrar's Office will adjust our reporting practices accordingly. The Registrar's Office has created and made available a procedural guide to running and submitting reports to make sure program length and other data submitted is accurate.

Name of Responsible Individual: Jason Byrd, University Registrar Liberty acknowledges that there was one instance in which a student’s enrollment status was not reported within compliance timeframes. Additionally, Liberty recognizes that there were multiple months in the year in which there were repeat errors found in the SSCR error file. Corrective Action: Liberty University continues to work to ensure the enrollment reporting process is handled compliantly and within allowable timeframes. There were multiple errors that were proactively addressed with National Student Clearinghouse (NSC) as Liberty was unable to resolve them internally. This was one of the contributing factors in having multiple months of repeat errors as NSC did not resolve. We will continue to work with NSC to resolve timing issue that result in errors outside of compliance timeframes. Additionally, the Registrar’s Office will work with ADS Academics to review the standard report used through Ellucian’s Banner to report student enrollment status to NSC. The goal of this review will be to better identify the source of errors and reduce error count for future submissions. Finally, over the last year, Liberty’s Financial Aid Office has hired an employee whose primary focus will be to provide an additional Quality Control (QC) process for enrollment reporting. This employee will work collaboratively with the Registrar’s Office to ensure roster errors and student enrollment level changes are resolved and reported within the permissible timeframes. While this position has been filled, we have been limited by the U.S. Department of Education’s National Student Loan Data System (NSLDS), as they transitioned to a new system and reporting used for this QC process was not released until July of 2023 and was not functional until September 2023 due to run-time errors that went unresolved. Liberty reached out to the U.S. Department of Education on multiple occasions (Case# 220920-00436 and Case# 230718-000084) in order to obtain a working report. Anticipated Completion Date: March 2024

Finding 2023-002 Recommendation: We recommend that management consider applicable regulation guidelines and ensure that background functions are appropriately functioning for all applicable fund codes, particularly around mergers with other institutions. View of Responsible Officials and Planned Corrective Actions: The EFT or “Loan Notice” email runs through an integration maintained by the University’s Information Technology department that generates a Loan Notice email based on a student having a disbursement under a specific federal loan fund code in Banner, the University’s financial aid software. Following the merger of the University of the Sciences with the University, the University of the Sciences had a Temporary Provisional Program Participation Agreement in effect through December 30, 2022. As a result, the University disbursed federal loans for the University of the Sciences campus for this period utilizing a different federal loan fund code within Banner. The Financial Aid Office was unaware that the integration utilized fund codes to generate the Loan Notice email and as a result the integration was not updated to include the additional fund code being utilized. Therefore, students that received loan disbursements under this fund code for the summer 2022 and fall 2022 terms did not receive Loan Notice email. These students were sent general communications in the summer and fall about the timing of loan disbursements for each term, but these did not meet the federal requirements. During the spring 2023 term, all student loan disbursements were included under the same federal loan fund code and all students received the Loan Notice email. During the upcoming merger with Pennsylvania College of Health Sciences, federal loans for the Lancaster campus will be processed in the legacy financial aid system under the existing procedures for the spring 2024 and summer 2024 terms during the period in which the Temporary Provisional Program Participation Agreement is in effect. Federal loans will be processed as one institution, under the University’s federal OPEID, utilizing a single federal loan fund code, beginning in the fall 2024 term. In the future, anytime there is a change federal loan fund codes being utilized the University will review the background functions to ensure they are operating appropriately. Individual Responsible for Corrective Action: Elizabeth Rihl Lewinsky, Assistant Vice President for Financial Aid, 610-660-1346, lewinsky@sju.edu Anticipated Completion Date for Corrective Action: The planned Corrective Actions will be immediately implemented

Department of Education Bucknell University 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—FEDERAL AWARD PROGRAMS AUDITS Department of Education 2023-001 Federal Pell Grant Program – Assistance Listing No. 84.063 Federal Direct Student Loans – Assistance Listing No. 84.268 Recommendation: We recommend the University review procedures around sending correct information to the NSLDS. In addition, we recommend the University develop a process to help better oversee the submissions completed by the third-party servicer. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Bucknell is currently reviewing its existing process of reporting student enrollment data to the NSLDS. The University through its Registrar and Financial Aid Office will update current procedures to include a more thorough verification of third-party servicer submissions to the NSLDS. Name(s) of the contact person(s) responsible for corrective action: Tim Kracker, University Registrar and Erin Wolfe, Director, Financial Aid Planned completion date for corrective action plan: December 2023 If the Department of Education has questions regarding this plan, please call Elizabeth D. Stewart, Associate Vice President, Treasurer & Controller at 570-577-3108.

Corrective Action Plan: Upon suggestion of the Office of Registrar the University of Dallas will begin dual reporting to both the National Student Loan Clearinghouse (NSLC) and the National Student Loan Data System (NSLDS) every thirty days. The Office of Registrar will work with Information Technology to set-up and run the SFRSSCR from the Banner system as well as run the same reports for the NSLC on the same day and approximate time to ensure that timely reporting is completed for the University of Dallas. The Office of Financial Aid will in turn run the appropriate reports to ensure that such reporting is successful. The Financial Aid Office will request access for the Office of Registrar personnel to submit such reports to the NSLDS or, if necessary, perform this task on behalf of the Office of Registrar. The Office of Financial Aid will work with the Student Registrar to ensure such reporting is accurate by reviewing such data points as Enrollment Effective Date, Enrollment Status, Term Begin Date, Term End Date and Award Completion Date. Implementation: The responsible parties include the Office of Registrar, the Office of Financial Aid along with the staff of Information Technology at the University of Dallas. Anticipated date of implementation of February 2024, pending updates to the SAIG and Electronic Services for the Department of Education and schema updates from the Department of Education with full utilization by close of the Spring 2024 term.

Corrective Action Plan: While the student was not initially identified, the record was corrected within the appropriate term and the student received the full proceeds of their aid eligibility. The Office of Financial Aid will be notified of grade changes on a weekly basis, if applicable, by the Office of the Registrar who is responsible for documenting and recording corrections to grading. The Office of Financial Aid will recalculate, if appropriate, the student Satisfactory Academic Progress status and make any necessary awarding and disbursement updates to the student’s record. Implementation: The responsible parties include the Office of Financial Aid and the Office of the Registrar with initial submissions within the month of November 2023 and continuing forward until such further efficiencies have been identified.

Condition: The College did not submit accurate and timely notification to the National Student Loan Data System (NSLDS) of student status changes and program-level enrollment data. Corrective Action: Because of the breach at the Clearinghouse, the College intentionally delayed its submission to the Clearinghouse to ensure its student data would not be compromised. The College’s policies and procedures are adequate to meet the 60 day requirement for reporting student status changes under normal circumstances. The College has reviewed the misreporting of one student’s campus and program-level record information and has determined that this is a unique circumstance. However, to strengthen its policies and procedures, a new form is being developed to properly document the timing of student enrollment changes to the Registrar. The document will be retained in the student’s file. Person Responsible For Corrective Action: Deann Schloesser, Registrar Anticipated Completion Date: October 2023

We concur with the auditor’s finding. We will be completing a full audit of remaining Perkins files to ensure that all necessary documentation is accounted for and properly filed. Contact Person Responsible for Corrective Action: Carol Summervill, VP for Finance Anticipated Completion Date: Corrective action was started in October and will be completed by December.

We concur with the auditor’s finding. We have reviewed our processes related to the enrollment reporting of withdrawing students. The financial aid department has added a column in the tracking document to record the effective withdrawal date from NSLDS. On a weekly basis, the withdrawal dates from NSLDS will be compared to the withdrawal dates per the financial aid records to ensure the two dates are the same. Contact Person Responsible for Corrective Action: Andy Olsen, Director of Financial Aid; Rhianna Reed, Assistant Registrar Anticipated Completion Date: Corrective action was completed in October.

2023-002 Student Financial Assistance Cluster – Assistance Listing No. Various Recommendation: We recommend the College work with their consulting firm to review their documentation and ensure that there are documented safeguards for identified risks and the required documentation and practices are implemented. We also recommend reviewing the changes in the Gramm-Leach-Bliley Act (GLBA) 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 College engaged a consulting firm as our Virtual Chief Information Security Officer (vCISO) in 2022-23 to assist in compliance with the GLBA. The College’s work with our vCISO includes a comprehensive risk assessment of the College’s information security posture, a determination of identified risks, access to expert security resources to build an effective and measurable security program, and an evaluation of the controls protecting the external network. These action items began in the 2022-23 fiscal year and are ongoing in the 2023-24 fiscal year. The vCISO program includes virtual multi-year ongoing support. Name(s) of the contact person(s) responsible for corrective action: Harlan Jorgensen, Director of Computing Services Planned completion date for corrective action plan: June 30, 2024

2023-001 Student Financial Assistance Cluster – Assistance Listing No. Various Recommendation: We recommend the College review its reporting procedures to ensure that students’ statuses are accurately and timely reported to National Student Loan Data System (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: After being alerted to the finding, the Registrar changed the submission dates to the National Student Clearinghouse (NSC) to allow more time for the NSC to timely report to the NSLDS. The Registrar’s Office will notify the Business Office when files have been submitted to the NSC. The Business Office will periodically monitor the NSLDS system and alert the Registrar of their observations. Name(s) of the contact person(s) responsible for corrective action: Austin Nyhof, Registrar Planned completion date for corrective action plan: June 30, 2024

South Plains College will modify system generated reports to include all reportable status changes and resubmit enrollment reports in which errors were identified. The College will implement a process to monitor the accuracy of enrollment reporting for future submissions. The anticipated completion date for the corrective action plan is no later than May 31, 2024.

November 20, 2023 To Whom It May concern: Corrective Action Plan – finding number 2023-001 Overall responsible individual for implementation of plan – Amy Hoss, Senior Director of Financial Aid While most of the reporting discrepancies occurred during the Christmas and New Year holidays ensuring that students would receive their funding in a timely manner, Parker has put in place additional controls to ensure compliance is dependent on initial and monthly reviews. Amanda Etheridge, Academic Business Analyst, and Amy Hoss, Senior Director of Financial Aid, will review PowerFAIDS and ensure that disbursement dates are appropriate and accurate, 10 days prior to the start of a term, regardless of the calendar day. Parker University will ensure that Title IV funds disbursed via PowerFAIDS are applied to student accounts via Jenzabar and reported to COD the same day. Parker University will further enhance the monthly reconciliation process. Once SAS reports are received, imported into PowerFAIDS, and the reconciliation report is generated for the respective Title IV programs, the file will be reviewed for any discrepancies in dates between the reported To_COD_Disb_Date, From_SAS_Disb_Date, and To_Bus_Disb_Date. Rodica Calin, Senior Accounting Analyst, will identify students with discrepant dates and provide to Angela McFadden, Compliance Officer, for further review. If the Compliance Officer confirms a discrepancy, the Academic Business Analyst or Senior Director of Financial Aid will complete a second review and update the appropriate system (PowerFAIDS, Jenzabar, or COD). Parker University will complete this data review for September disbursements by December 15, 2023 and October disbursements by December 31, 2023. It will be a part of our updated reconciliation process for subsequent months.

Finding: 2023-001 Estimated Completion Date: Year Ended June 30, 2023 November 15, 2023 Pennsylvania College of Health Sciences is committed to meeting all regulatory policies and procedures related to student financial aid. Below are the changes that were implemented in March 2023 and communicated to all staff members involved with student financial services: 1. Require the Student Account Specialist to run the Batch Assign Transmittal Communication process in the student information system immediately following each transmittal of financial aid. This will ensure communication will occur within the regulated timeframe. 2. Request that the Student Financial Services Coordinator note when loan disbursement notification e-mails are sent and alert the Student Account Specialist if notifications are not pulling in communications. These steps are monitored by the Director of Student Financial Services to ensure all updates and communication are occurring in a timely manner and in compliance with all regulations.

Finding 2023-003 Finding Title: Student Financial Assistance Cluster Name of Contact Person: Traci Boeve, Director of Financial Aid Corrective Action: Hastings College will add additional staff as a control to the current process. The Assistant Registrar and the Office of Financial Aid will be included in the receipt of the graduation file. The Assistant Registrar will confirm in NSC (National Student Clearinghouse) the file was uploaded with no errors. The Office of Financial Aid will also request a report from NSLDS, which can be compared to the file that was directly uploaded to NSC. Anticipated Date of Completion: In place for 2023-2024 school year.

Corrective Action Plan: The University has a previously established detailed policy and procedure in place to process and to accurately report status changes timely via the National Student Clearinghouse (NSC) to NSLDS. The reporting of the Initial Submission along with the Subsequent Submissions occurs approximately 5 business days prior to the month for which the report is due. This then ensures that NSC has the opportunity to transmit the data to NSLDS within 14 days of the 1st of the month. Submission of additional rosters would not change anything as NSC only submits once per month to NSLDS. The University will continue to submit on time to NSC and will continue to monitor when NSC transmit to NSLDS. Timeline for Implementation of Corrective Action Plan: The corrective action plan was implemented as of October 2023. Contact Person Mark Powers, Registrar Finding number: 2023-001 Federal agency: U.S. Department of Education Programs: Student Financial Assistance Cluster CFDA #: 84.063 and 84.268 Award year: 2023

The College has created procedures to review outstanding checks monthly. Outstanding checks that are not resolved after several notifications to the student will be returned to the Department of Education. Checks will be returned within four months of the initial check issued date.

The Financial Aid Office worked with the Information Technology department to determine the issue with the exit conference report and had corrected it.

Lincoln Land Community College (LLCC) acknowledges and takes seriously the audit findings presented, highlighting areas where compliance requirements were not met. These findings are crucial in ensuring the ongoing enhancement of our Information Security Program. To address these concerns LLCC has proactively taken several measures. In June 2022, the College appointed an IT Security and Assurance Manager, tasked with overseeing the Information Security Program and ensuring compliance with the Gramm-Leach-Bliley Act (GLBA). The Manager has played a pivotal role in developing a comprehensive roadmap to guide the continued evolution of our Information Security Program. This roadmap specifically outlines the steps required to address the identified deficiencies, as detailed in the schedule of findings document received from the CLA. LLCC affirms its agreement with the details provided in the document and has prioritized these findings as top-level concerns in the roadmap. In the upcoming Fiscal Year 2024 (FY24), LLCC commits to diligently implementing the roadmap, with a focused emphasis on the following key areas: 1. Implementation and Periodic Review of Access Controls: The IT Security and Assurance Manager will lead efforts to establish robust access controls and ensure regular reviews to align with compliance requirements. 2. Encryption of Customer Information: Although informal procedures are in place, a comprehensive strategy for encrypting customer information both within the College’s system and during transit will be implemented to safeguard sensitive data. 3. Security Assessment of Applications: Rigorous evaluations, assessments, and testing procedures for applications transmitting sensitive information will be instituted to bolster the overall security posture. 4. Anticipation and Evaluation of System Changes: Proactive measures will be taken to anticipate and evaluate changes to the information system or network, ensuring a proactive stance against potential vulnerabilities, including the development of a formalized change management process. 5. Regular Testing and Monitoring: LLCC is committed to instituting regular testing, monitoring, and assessing protocols for established safeguards to ensure their ongoing effectiveness. 6. Implementation of Policies and Procedures: Policies and procedures will be refined and enforced to guarantee that personnel can effectively enact the information security program. 7. Monitoring Information System Service Providers: Development of a comprehensive approach to monitoring the College’s information system service providers has been initiated and will be established to ensure compliance with security standards. Lincoln Land Community College views this as an opportunity for continuous improvement and remains dedicated to upholding the highest standards of information security. The commitment to addressing these findings is integral to our ongoing efforts to safeguard sensitive information and maintain compliance with regulatory requirements.

Views of Responsible Officials and Corrective Action Plan (Finding 2023-001) In the process of assessing internal controls related to the prohibition of incentive compensation for enrollment recruiting, the College determined that three admissions personnel had been assigned an individual goal for securing enrollment. The enrollment goal was one of multiple criteria used to determine an overall performance rating that was the basis for merit increases awarded on July 1, 2022. The total merit increases awarded to certain of the College's admissions employees was $2,541, which were based in part upon success in securing enrollments. The College was not aware of the prohibition on merit-based adjustments based in any part, directly or indirectly, upon success in securing enrollments. The College has revised the annual Performance Management Review form to expressly prohibit a performance metric for securing enrollment. All personnel have been re-trained. For questions, please reach out to Elizabeth M. Krapp, Vice President, Finance and Administration at emkrapp@peirce.edu or Brad Hodge, Vice President, Enrollment Management & Student Services at bkhodge@peirce.edu.

Title: Student Financial Assistance Cluster – Assistance Listing Nos. 84.007, 84.033, 84.063, 84.268 Recommendation: We recommend the University review its SAP review policies to ensure it is completed timely and before Title IV disbursements occur. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Prior to this finding, in November 2022 our Registrar implemented a change in process to require a form when assigning either an L and I grade to a student. This ensures that the correct grade type is used in all cases depending on the nature of the work still outstanding. In doing so, it allows more accurate and timely assess a student’s GPA for SAP status on a regular schedule within the timeline expected for each type of grade when a final grade is determined. The Financial Aid office had also implemented an additional tracking mechanism outside of our ERP system to monitor the SAP status of each student to augment deficiencies in our ERP related to tracking the correct status over time. This tracking occurs regardless of the timing of a FAFSA being completed or the consistency of student enrollment from one semester to the next. This allows us to know the eligibility status of a student prior to awarding and disbursement, and require an appeal when appropriate. This was implemented May 2023. Regardless, as per policy and as we’ve been doing, we will continue to evaluate grade changes at the time of the next regular SAP evaluation period, and enforce the policy based on their status from that point forward. Name(s) of the contact person(s) responsible for corrective action: Dwight R Berreth Planned completion date for corrective action plan: August 2023