Corrective Action Plans

Finding 2023-003 - Federal Pell Grant Enrollment Status Condition: A qualifying student was awarded a Federal Pell Grant for the Fall semester as a full-time student. Upon review of the student's transcript, it showed the student was enrolled in 10 credit hours, categorizing the student as a three-quarter time student, therefore, an over award of PELL occurred. In conjunction with our FY2023 audit, please see the College's corrective action plan below: We concur with this finding and have reinforced with enrollment staff the internal control procedures to ensure the proper process is followed for students who withdraw or are considered no-shows. The enterprise management system for the College should adjust the credit hours for all dropped courses. Due to the student being administratively withdrawn after the last day to drop courses our system did not adjust these courses from the student financial aid aspect. We are aware of this and working toward ensuring this does not occur in the future. We will be scheduling additional training with our system in the upcoming year address this. Expected completion date: 11/17/2023 Party Responsible: Trisha White, Vice President of Business Affairs Contact Information: twhite@eosc.edu

Condition: A student received a direct subsidized loan despite showing no financial need, as the student's EFC was higher than the student's COA. The student's EFC was determined to be $24,282, whereas their COA was $20,686. Despite no financial need existing, the student was awarded a direct subsidized loan of $3,500, resulting in an over award. In conjunction with our FY2023 audit, please see the College's corrective action plan below: Management agrees this student had an incorrect type of loan awarded. Based off the students EFC number the loan should have been an unsubsidized loan and not the subsidized loan. The Financial Aid office will make the corrections of the loan type to the student's account. Financial Aid will add an internal control process to ensure there is a second verification of student federal loans in place. Expected completion date: 11/17/2023 Party Responsible: Trisha White, Vice President of Business Affairs Contact Information: twhite@eosc.edu

Comments on Findings and Recommendations: We agree with the finding and recommendations. Planned Corrective Action: The organization will undergo a software upgrade aimed at augmenting the efficiency and precision of the financial aid department. We anticipate that this upgrade will be fully operational by the end of the first quarter of the next calendar year. Anticipated Completion Date: 03/29/2024

The following is the Management's Response to Auditor's Findings, Summary Schedule of Prior Audit Findings and Corrective Action Plan. This document was prepared by management of the University of Oklahoma. 2023-001 Student Financial Assistance Cluster, ALN 84.063 Federal Pell Grant Program and ALN 84.268 Federal Direct Student Loans, Department of Education, Award Year 2023 Criteria or Specific Requirement - Special Tests and Provisions - Enrollment Reporting - 34 CFR § 690.83(b)(2) and 34 CFR §685.309(b)(1) Finding Summary: The University is required to implement a system of internal controls that ensure enrollment information is reported to Department of Education's National Student Loan Data System (NSLDS) each 60 days, at minimum. Enrollment information for eight students graduating in Spring 2023 was not reported timely to NSLDS. Explanation of Agreement/Disagreement: Management concurs with the finding and proper internal controls are being implemented during FY2024. Officials Responsible for Ensuring Corrective Action: Courtney Henderson, Acting Financial Aid Director. Planned Completion for Corrective Action: Corrected enrollment information was submitted to NSLDS on August 18, 2023. Corrective internal controls have been implemented as of October 12, 2023. Plan to Monitor Completion of Corrective Action: Management concurs with the finding and proper internal controls were implemented during FY2024. Management has implemented regular monthly meetings between the Financial Aid Services and Academic Records departments of the University to review graduation error reports and ensure timely processing.

Finding 2023-001 Cash Management - Heightened cash monitoring payment method Federal Agency Name: Department of Education Program Name: Student Financial Aid Cluster ALN #84.063 - Federal Pell Grant Program ALN #84.007 - Federal Supplemental Educational Opportunity Grants ALN #84.033 - Federal Work-Study Program ALN #84.268 - Federal Direct Student Loans Finding Summary: During testing of cash management, which includes disbursing of Title IV program funds under HCM1, a sample of 11 students was selected from the population of students receiving Title IV funding during fiscal year 2023. From this selection of students, the following deficiencies were noted where the College received Title IV payments from the Department of Education before either applying the funds to the students account or clearing any credit balances owed to the student/parent that were created by applying the funds to the students account. • Pell Grants – 10 of the 19 disbursements • Subsidized Loans – 17 of the 30 disbursements • Unsubsidized Loans – 18 of the 29 disbursements • Plus Loans – 4 of the 6 disbursements • FSEOG Grants – 9 of the 14 disbursements Responsible Individuals: Bryan Tarrant (Director of Operations) and Ryan Apple (Financial Aid Director) Corrective Action Plan: Management acknowledges the importance of continued training for staff to strengthen their knowledge of cash management practices and that processes and procedures relating to cash management are continually reviewed and updated. Anticipated Completion Date: We anticipate management’s review of practices and processes and additional training to be completed by December 31, 2023. The College anticipates continued review of policies and procedures on a yearly basis and additional training as the need arises.

CORRECTIVE ACTION PLAN Finding 2023-001 Federal Agency Name: U.S. Department of Education Program Name: Student Financial Assistance Cluster ALN: 84.268 Finding Summary: The UMHB Financial Aid Office initially did not correctly identify and include new entering spring students in the disbursement notification process. Subsequently, 100 spring-only students received disbursement notifications after the 30-day required timeframe. UMHB identified and corrected this discrepancy prior to the beginning of the Single Audit. Responsible Individuals: David Orsag, Director Melissa Jones, Assistant Director Corrective Action Plan: The UMHB Financial Aid Office modified the disbursement notification selection for Fall 2023 to ensure all students are included in the weekly evaluation for disclosures. Additionally, on September 6, 2023, UMHB implemented a bi-weekly review of disbursement notifications to identify any students with missing disclosures. Anticipated Completion Date: September 6, 2023

2023-001 Incorrect Pell 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 had was not disbursed the correct Pell Grant award. Based on the student’s enrollment status and need, the College under awarded the student by $200. We consider this to be an instance of noncompliance relating to the Eligibility Compliance Requirement. Corrective Action Plan: Run enhanced quality assurance (QA) checks with awarding analysis both prior to disbursement of funds and at the end of each semester. Execute 100% QA procedures to ensure accurate system awarding. Responsible Person for Corrective Action Plan: Mary Cobb, Program Manager Financial Aid, and Ana Mirnic, Program Manager Financial Aid, and Executive Director of Financial Aid (new hire in process) Implementation Date of Corrective Action Plan: September 1, 2023

Asbury University's Financial Aid office has had a turnover in positions. Submitting a disbursement date adjustment file for TEACH Grant disbursements was missed in training Dawn Hopkins the new Financial Aid Specialist. Leslie Kurtz (Director of Financial Aid) has shown Ms. Hopkins how to create and transmit a TEACH Grant adjustment file to COD. Ms. Hopkins sent a file to correct the 22-23 disbursement dates on July 14, 2023. Ms. Hopkins also updated her desk manual on July 14, 2023, adding the steps to create and submit a disbursement date adjustment file after each TEACH Grant is disbursed to a student's ledger. Leslie Kurtz and Dawn Hopkins have manually reviewed TEACH Grant recipients for the 22-23 at COD to ensure that our ledger and COD are in agreement. On July 14, 2023, Leslie Kurtz modified the receipt that is sent to students to indicate that they have the right to cancel the TEACH Grant by notifying our office.

Management’s Corrective Action Plan Finding 2023-001 Special Tests and Provisions- Enrollment Reporting- Significant Deficiency in Internal Control over Compliance. Responsible Office and Individuals The Associate Vice President of Student Financial Services, Jazmin Martin and the Executive Vice President/Chief Operations Officer, Mark Mendoza are responsible for the development of the processes, and implementation of the corrective actions described in the Corrective Action Plan. The corrective actions will result in timely and accurate reporting to NSLDS. Corrective Action Plan Management accepts responsibility for this significant deficiency in internal control over compliance and has implemented a new financial aid management system (Campus Ivy) and process to ensure that students’ statuses are reported timely. To maintain accuracy and compliance with the Title IV regulations, Campus Ivy will perform weekly, monthly, and bi-monthly National Student Loan Data System (NSLDS) enrollment reporting. Enrollment reporting is a process by which a student’s enrollment status and program of study is reported to NSLDS on a timely basis to meet the U.S. Department of Education’s 30-day and 60-day reporting requirements. The Student Financial Services Department will provide accurate and timely information to Campus Ivy and Campus Ivy will report that information timely and accurately to NSLDS. Campus Ivy’s Core system receives the NSLDS Enrollment Roster as scheduled on the 5th of the month every 60-days. The Core system will automatically load the roster and update all relevant enrollment data based on the information sent from CLU through the secure data import on an ongoing basis. These updates are then batched by the system to be transmitted to NSLDS. The Student Financial Services Department, through the student information system (Maestro), will provide student information updates. The Student Financial Services Department will sync updates to the Campus Ivy Core Financial Aid Management System (Core) with all students’ academic and demographic information from Maestro, by imports through Campus Ivy’s secure encrypted portal or through direct integration. The Student Financial Services Department will be responsible for timely and accurate updates of the Core system. The Student Financial Services Department will ensure daily updates from Maestro to clear any failed validations. The student data import process has built in validations to assist CLU with maintaining accurate data. These validations are on both the student’s demographic and academic information. In addition to the bi-monthly roster process, Campus Ivy also sends bi-weekly updates to NSLDS to record enrollment updates on an ongoing basis, well within the 30-day timeframe set by the Department of Education. The NSLDS module within Campus Ivy stores all roster batches processed by the system. CLU will have access to view our Roster Batches at any time and can request changes through our 24/7 Support Site. Anticipated Completion Date The anticipated completion date of the corrective action plan is November 30, 2023

Corrective Action Plan: New procedures to effectively collaborate and share information between financial aid and student accounts will be drafted to ensure unclaimed checks are processed within the required window. Timeline for Implementation of Corrective Action Plan: Immediately Contact Person Sharron Scott, CFO

Corrective Action Plan: CCV In June 2023 CCV implemented a new process to verify that student records reported to the Clearinghouse have been correctly and accurately reported to the National Student Database (“NSLDS”). VTSU In March 2023 VTSU implemented new procedures to ensure all enrollment status changes were processed consistently. Since implementation, no new findings were identified. Timeline for Implementation of Corrective Action Plan: Immediately

Corrective Action Plan: CCV CCV implemented new processes in March and June of 2023 to address these issues. The first process verifies that a student’s aid has been updated and recalculated before closing the record. The second process ensures additional training and controls to make sure student withdrawals occur within the appropriate timeframe. VTSU VTSU reprocessed the error return to the Title IV funds with the correct information and cancelled the loan completely. Training with all staff has been reinforced. Timeline for Implementation of Corrective Action Plan: Immediately Contact Person Sharron Scott, CFO

Corrective Action Plan: VTSU A new process for verifying last date of attendance by the registrar’s office was implemented for the 2023-2024 academic year. The new process includes verifying last date of attendance supplied by the student on their withdrawal form with faculty. The verified date will be used for all transactions of record. Timeline for Implementation of Corrective Action Plan: Immediately Contact Person Sharron Scott, CFO

Corrective Action Plan: VTSU This was an isolated instance and attributed to human error. Training with all staff has been reinforced. Timeline for Implementation of Corrective Action Plan: Immediately Contact Person Sharron Scott, CFO

Corrective Action Plan: CCV Disbursement errors noted are isolated errors due to system issues within COD, testing of processes that resulted in an error, and a scheduling issue related to a holiday break. A new automated COD report in Colleague will be created by CCV and implemented in November 2023. VTSU VTSU will continue to monitor and report weekly. Timeline for Implementation of Corrective Action Plan: Immediately Contact Person Sharron Scott, CFO Finding number: 2023-02 Federal agency: U.S. Department of Education Programs: Student Financial Assistance Cluster CFDA #: 84.007, 84.033, 84.038, 84.063, 84.268 Award year: 2023

Finding: The University did not timely or accurately report enrollment changes to the National Student Loan Data System (NSLDS). Corrective Actions Taken or Planned: The Registrar’s Office submits a monthly report to the National Student Clearinghouse (NSC). Summer is an optional term for students and only students who are enrolled for that semester are submitted to NSC. To ensure withdraw dates during the summer semester are being reported on a timely basis Financial Planning will manually enter dates of withdrawn students to NSC and National Student Loan Data Systems (NSLDS). Students who have withdrawn at the end of the spring semester will be manually entered and monitored closely by the Registrar’s Office who will adjust reporting schedule to ensure timely reporting of withdrawn dates. Person Responsible: Sara Sroka (ssroka@dbq.edu) Anticipated completion date: 10/18/2023

Incorrect Enrollment Reporting to National Student Loan Data System (NSLDS) Planned Corrective Action: 100% of example students (16 which overlap with the 12 mentioned) were accurately reported with a “W” withdrawn status to National Student Clearinghouse (NSC) in a timely (monthly) manner, but this correct status did not get transferred to NSLDS. An internal SSRS report for official and unofficial withdrawals, which also accurately reflects these withdrawn students, will remain available to the WBU offices of Financial Aid and the Registrar for verification as part of the planned corrective action. Several related WBU questions to our primary NSC support employee are awaiting a response from NSC. The NSC reporting tool(s) will be updated to make sure the correct combination of fields and corresponding data sources are used for dates. One of multiple date fields may have been misunderstood by the tool’s historical authors. A field-by-field analysis plus any needed corrections to the queries are part of the planned corrective action. Post-submission error corrections by registrar staff via NSC will be spot-checked by Information Technology for date-related warnings. If this cannot be resolved satisfactorily via NSC alone, then corrective measures via NSLDS directly may be considered. Data improvements needed for the PowerCampus baseline product’s NSC reporting tool will also be included in testing this further. Person Responsible for Corrective Action Plan: Cagan Cummings, CIO and Andrew Shamblin, Programmer Analyst Anticipated Date of Completion: June 30, 2024

Return of Title IV (R2T4) Calculations Planned Corrective Action: Executive Director of Financial Aid will continue to provide regular in-house R2T4 training specific to WBU for all staff and will ensure all pertinent staff responsible for R2T4 complete R2T4 training provided by FSA and purchased through NASFAA. The staff member responsible for disbursements, being new to her role in fall of 2022, did not realize that fall disbursements needed to be processed even after the end of the fall term. Once discovered, this was immediately addressed. In June 2023, WBU hired a full-time staff member to serve as a Financial Aid Compliance Specialist in the Office of Financial Aid and this position is devoted to internal audit and federal/state regulation compliance. Person Responsible for Corrective Action Plan: Christy Miller, Executive Director of Financial Aid Anticipated Date of Completion: October 31, 2023

Noncompliance with Federal Work Study/Federal Work Colleges Regulations Planned Corrective Action: The federal funds have been returned and re-disbursed to the student with only institutional funds (Practical Training Tuition Scholarship). We have added a checklist to our SAP report for students who go on Financial Suspension due to not meeting SAP to make sure each award is addressed. Person Responsible for Corrective Action Plan: Anna Bergh, Financial Aid Director Anticipated Date of Completion: 10/27/23

Incorrect and Untimely Return of Title IV (R2T4) Calculations Planned Corrective Action: The academics and financial aid office will work in conjunction to run a zero-credit earned report at the end of each term and determine if there are any unidentified unofficial withdrawals that must be processed. Throughout the semester the academics department is logging attendance daily to ensure students do not fail for non-attendance and are not missing more than five without proper notice. For students in online courses, professors will check in on student engagement every two days, and the academic administrative team will do a check once a week to identify any students who may be an unofficial withdrawal. For the calendar for R2T4’s the Financial Aid office keeps an excel sheet with the term dates and breaks for the year and will manually check that the dates/percentages align with the calculations on the COD R2T4 calculator. The first couple of students processed will be calculated manually with the information in the excel sheet to ensure it aligns with the calculation completed on COD. Person Responsible for Corrective Action Plan: Anna Bergh, Financial Aid Director and Tiffany Garrison, Interim Registrar Anticipated Date of Completion: 10/27/23

Lack of Documentation of Exit Counseling Planned Corrective Action: New student information system (Campus Café) is set to send automatic message when a student is set to Withdrawn. The email notifies them of their responsibility to complete the exit counseling along with the link to the website. Person Responsible for Corrective Action Plan: Stephanie Castillo, Director of Financial Aid Anticipated Date of Completion: Fall 2023.

Return of Title IV (R2T4) Calculations Planned Corrective Action: Set the calendar to match academic calendar and set up for awarding in COD. Person Responsible for Corrective Action Plan: Stephanie Castillo, Director of Financial Aid Anticipated Date of Completion: Fall 2023.

Enrollment Reporting to NSLDS Planned Corrective Action: Enroll in The National Clearing house to make reporting more automated and accurate. Set calendar reminder to send reports on a monthly schedule to make sure we report timely and accurately. Person Responsible for Corrective Action Plan: Stephanie Castillo, Director of Financial Aid Anticipated Date of Completion: Fall 2023.

Incorrect Enrollment Reporting to National Student Loan Data System (NSLDS) Planned Corrective Action: Incorrect enrollment reporting was found for one student. Currently, the Registrar’s Office, in coordination with the National Student Clearinghouse, reports enrollment to NSLDS. The program for that one student was shown incorrectly in the system for a period during the audit. When checked later, still during the audit, the program was shown correctly without any action by personnel of the college. We are unsure of the cause of this inconsistency in that instance. The Financial Aid Office will start conducting weekly spot checks directly in NSLDS to help catch enrollment that may have been reported incorrectly. The first spot check is expected to be completed the week of November 13-17. Person Responsible for Corrective Action Plan: Jean-Claude St Juste, Financial Aid Director Anticipated Date of Completion: Immediately

Return of Title IV (R2T4) Calculations Planned Corrective Action: Incorrect R2T4 calculations were found for one new student due to the wrong start date being used for the calculations. In the future, the Financial Aid Office will review R2T4s submitted for new students to ensure the new student start listed in the catalog is used for the calculations irrespective of the course dates on the student’s schedule. Person Responsible for Corrective Action Plan: Jean-Claude St Juste, Financial Aid Director Anticipated Date of Completion: Immediately