Corrective Action Plans

Return to Title IV (R2T4) Calculations (OPEID: 04278800) Planned Corrective Action: The Academic Affairs leaders, partnering with the Digital Learning Solutions team and Information Technology team, have developed a query that removes the uncertainty from the F and FN assignments and will be implementing this in the Fall 1 2023 session. Prior to this the process was largely manual and at the discretion of individual instructors. With this query, academic administrators will be able to verify any grades that have been entered incorrectly by the instructor and ensure they are immediately changed to reflect the correct grade. Once this new process is implemented LAPU academic leaders hope to refine the process further in order to automate issuing FN grades to those who qualify, thereby preventing such mistakes in the future. Upon receipt of the report from the Digital Learning Solutions team the Financial Aid team will conduct a thorough evaluation to compare the F and FN grades against the Last Date of Attendance (LDA) to ascertain the correctness of the F or FN grade, taking into consideration the date of the last recorded academic activity. Should any disparities emerge during this evaluation, Financial Aid will initiate a request for Academics to re-examine the student’s grade for accuracy. Person Responsible for Corrective Action Plan: Dr. Wayne R. Herman, Vice President, Chief Academic Officer Anne Rodriguez, Director of Financial Aid Anticipated Date of Completion: October 27, 2023

Name of Responsible Individual: Samuel Matheny, Chief Student Services Officer, Offices of Financial Aid and Registrar Corrective Action: In fiscal year 2023 (FY23), the return of federal funds calculation and process was automated in the Banner student information system; therefore, reducing the possibility of an incorrect calculation. Furthermore, a financial aid staff member reviewed the return of federal funds calculations twice during the fiscal year to ensure accuracy. However, it was determined that two of the students selected in the FY23 audit sample had incorrect academic dates used in their calculation. As a graduate/professional school, PCOM has several academic calendars rather than one institutional calendar. The need for multiple academic calendars is due to the variations in the start and end times of our students completing offsite clinical rotations. For fiscal year 2024 (FY24), PCOM will be implementing the following additional controls to ensure the correct academic calendar is used in the return of title 4 calculations: 1. Academic calendar dates will be added to the report used to review students who have withdrawn from their coursework. 2. The report will be run after the end of every term (4 times a year) and it will go through an initial review by one staff member and then a final review by another staff member. Anticipated Completion Date: September 1, 2023

Name of Responsible Individual: Andy Mueller, Director of Financial Reporting and Planning Corrective Action: Through 9/13/22, PCOM used a Banner generated report to draw down direct loan funds. PCOM found there was an error with the Banner report causing excess funds to be drawn on 6/30/22, 8/2/22 and 8/31/22. With the assistance of the Student Services department a new process to draw direct loans began in November 2022. The process compares disbursements recorded by the Department of Education's Common Origination and Disbursement (COD) website to that of the disbursements paid in PCOM’s ERP information system. The finance department ensures the amount to be drawn from COD is either less than or matches the available funds on the COD site. Since the implementation of the new process there have been no drawdowns that resulted in an excess cash situation. Anticipated Completion Date: November 30, 2022

October 24, 2023 Corrective Action Plan for University of San Diego Audit finding 2023-001 FINDING 2023-001 – Special Tests and Provisions – Borrower Data Transmission and Reconciliation: Significant Deficiency in Internal Control Over Compliance Criteria –34 CFR section 685.300(b)(5): On a monthly basis, the University of San Diego must reconcile institutional records with Direct Loan funds received from the Secretary and Direct Loan disbursement records submitted to and accepted by the Secretary. Condition/Context – The University of San Diego operates a law school and an undergraduate and graduate school. A sample of 6 direct loan reconciliations were selected from the population of all reconciliations performed by the University, under both schools during the year ended June 30, 2023. We obtained the supporting schedules used to reconcile the disbursed direct loan funds to the federal government’s records. The University did not complete reconciliations of its direct loan program disbursements for the law school between December 2022 and June 2023. Cause – There was turnover in the position responsible for reconciling this data, and the responsibility did not transfer to another individual, and as a result, the reconciliations were not completed. Effect – There is a chance that the University of San Diego’s records may not match the federal government’s records of direct loan disbursement. Recommendation – The auditors recommend the University of San Diego revise the existing policies and procedures to ensure when a change in personnel occurs, responsibilities appropriately transfer to a new individual. Corrective action plan – Management concurs with this finding. This exception was due to the monthly reconciliation not being part of the established policies and procedures for the Law School Financial Aid Office. As a result, during staff turnover the interim staff were unaware of the responsibilities and requirements for the monthly reconciliation. Management updated the direct lending servicing system reconciliation procedures for the Law School to clearly delineate the responsible parties. Management believes these enhancements will be sufficient to prevent future errors. Anticipated completion date: October 2023 Persons responsible: Mike Chavez, Director of JD Admissions, Financial Aid & Diversity Initiatives

Return of Title IV (R2T4) Errors Planned Corrective Action: Our process for identifying unofficial withdrawals begins with a report from our Workday software to identify students who had unearned credits in a semester at the conclusion of that semester, after the grade due date. We then reach out to the individual professors of the courses and/or the Instructional Design team to determine if each student completed the semester or if (s)he had unearned credits having ceased attending at some point during the semester. If the student ceased attending, we would determine if a Return of Title IV (R2T4) calculation was needed and would complete it if necessary. The report was corrected for AY 2022/2023 to include No Credit (NC), Incomplete (I) and Failed (F) grades to enable PLNU to identify all the students who need to be reviewed going forward. In addition, we have added to our process instructions to run this report after the grades for module 1 are due, and after the grades for module 2 are due, rather than at the end of each semester. This was intended to ensure the review of any unofficial withdrawals in a timelier manner, meeting the 45-day deadline for any possible returns that must be made. The modified report, however, produced a far greater number of students for review, which was too broad of a selection and was unmanageable. We are working to refine the reporting criteria further to accurately identify students who require review and we have assigned additional staff for the review process. Person Responsible for Corrective Action Plan: Daniel Reed, Director of Financial Aid; Joanna Castro, Associate Director of Financial Aid; Jamie Asche, Director of Student Financial Services Business Analysis and Compliance Anticipated Date of Completion: 1/1/2024

Need Analysis Planned Corrective Action: PowerFAIDS, a new financial aid processing software, was adopted by the Anderson University Office of Financial Aid this year. It was discovered that PowerFAIDS does not automatically correct the student’s need-based aid when additional aid is added manually after a student has been packaged. The assumption of the Financial Aid Office was that this was automatically adjusting as it had done in the previous system used. The Senior Associate Director reached out to PowerFAIDS to get an understanding of when manual calculations need to be done to a student’s need-based aid. In light of this new information, the Financial Aid Office will adjust their practice going forward. When additional aid is awarded going forward, need based aid will be manually adjusted so that students are not over awarded in need-based aid. Person Responsible for Corrective Action Plan: David J. Sarah, Director Anticipated Date of Completion: Students who were over awarded in Federal Direct Subsidized Loans were corrected on COD effective 08/17/2023.

Incorrect Pell Calculations Planned Corrective Action: Anderson University will update course withdrawal forms to include documentation from professors of last date of attendance and affirmation of whether or not the student began the course they are dropping. The Office of Financial Aid and Scholarships will receive all completed withdrawal forms to review for changes to academic level and any necessary return of federal aid. Person Responsible for Corrective Action Plan: David J. Sarah, Director Anticipated Date of Completion: N/A

Untimely and Inaccurate Return of Title IV Funds Planned Corrective Action: FA Solutions (FAS), a third-party vendor, was contracted to assist with compliance and other processing responsibilities that included the processing of all R2T4s for Anderson University. While the staff of the Office of Financial Aid and Scholarships supplied documentation to FAS in a timely manner, FAS processed R2T4 late and, in some cases, inaccurately. When this was discovered by the Office of Financial Aid and Scholarships, all R2T4 and processing responsibilities were brought back under the in-office staff at AU in order to process Return of Title IV funds accurately and in compliance. Anderson University has enrolled our Senior Counselor in a 6-week R2T4 course with the National Association of Student Financial Aid Administrators (NASFAA) where she will pursue credentialing in Return of Title IV Funds with NASFAA as well as R2T4 Specialist designation. Additionally, policies for students who stop attending, and for whom the last day of attendance can not be determined, will be reviewed and revised for clarity and better communication with the Office of Financial Aid and Scholarships. Person Responsible for Corrective Action Plan: David J. Sarah, Director Anticipated Date of Completion: The return of all processing of financial aid was brought back to AU effective 06/20/2023. The R2T4 course taken by our Senior Counselor will be completed 11/06/2023. Final R2T4 adjustments completed 10/20/2023.

U.S. Department of Education Concordia University, Nebraska 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 financial statement findings in the current year. FINDINGS—FEDERAL AWARD PROGRAMS AUDITS U.S. Department of Education 2023-001 Student Financial Assistance Cluster – Assistance Listing No. Various Recommendation: We recommend the University evaluate its procedures and a policy around how level of education is determined and verified when packaging and awarding students. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Name(s) of the contact person(s) responsible for corrective action: David L Kumm, Executive VP CFO/COO Planned completion date for corrective action plan: 7/1/2022

To correct this error and ensure all disbursement notifications are sent, the following corrective actions have been implemented. 1. Modified the FA_RZLNDSB_Loan_Process_to_BDM script (weekly job that emails students with loan disbursements within the last 7 days) by removing the logic that used aid year to identify which year to use when pulling disbursement records and instead allows all disbursed loans that occurred within the last 7 days, regardless of aid year, to be pulled for notification. 2 Created a new FA_RZLNDSB_Loan_Process_to_BDM_Weekly Error script, that identifies students that do not have an email entry on RUAMAIL form (GURMAIL table) for disbursed loans. This script then generates the email and PDF to be sent to the student.

Finding No. 2023-001 Excess of Cash Condition Found In three (3) of thirty-six (36) G-5 Direct Loan drawdowns from the San Juan Campus, refunds were not properly returned on G-5 during the required period of ten (10) days (3 business days plus an additional 7 calendar days). Corrective Action Plan The Institution will retrain all personnel of the financial areas teams that interact in the implementation of this procedure. The T-IV Compliance Coordinator will oversee the training to ensure all procedures and guidelines are fully understood. The procedures in question will involve a written internal document of the process. We will be assigning the specific responsibilities of the process by function and the interactions with other functions. Name(s) of the Contact Person(s) Responsible for Corrective Action Héctor Peña, Director of Finance (San Juan) Luis Barreto, Director of Finance (Miami) Carmen Rivera, Compliance Officer Anticipated Completion Date Will be completed on or before November 15, 2023.

2023-002: Late Return of Title IV Credit Balance - Student Financial Aid Cluster Assistance Listing #s 84.007, 84.033, 84.038, 84.063, 84.268, 84.379, 93.264- Grant Period - Year Ended June 30, 2023 Condition Found: During our Credit Balance testing, we noted that the University did not return the credit balances for two out of forty students we tested within the required time frame. We consider the untimely return of credit balance to the students accounts to be a significant deficiency to the Special Tests and Provisions Compliance Requirement. Corrective Action Plan - The refund date is calculated manually. There was a miscommunication in the department and refunds were processed at 16 days instead of the required 14. Staff have been retrained and will start the refund process sooner. Responsible Person for Corrective Action Plan - Karrie Mallo, Director of Student Accounts Implementation Date of Corrective Action Plan - Action has already been completed. Staff have been retrained. The Director of Student Accounts will review all calculated refund dates.

2023-001: Improper Return of Title IV Financial Aid - Student Financial Aid Cluster Assistance Listing #s 84.007, 84.033, 84.038, 84.063, 84.268, 84.379, 93.264 - Grant Period - Year Ended June 30, 2023 Condition Found: During our Return of Title IV Fund testing, we noted that the University did not calculate properly or return Title IV Student Financial Aid in the required time frame for two out of twenty-five students we tested. We consider the untimely returns and incorrect calculations of the Return of Title IV to be an instance of noncompliance to the Special Tests and Provisions Compliance Requirement. This is also a repeat finding reported in Section IV Prior Year Financial Statement and Federal Award findings as 2022-001. Corrective Action Plan Action has already been completed. In both cases, the calculation was complete timely, but there were errors in the calculation. When the errors were identified, both calculations were purged and recalculated and the correct funds were returned. Manager currently reviews all refund calculations to ensure accurate calculations and will continue that practice to ensure compliance. Responsible Person for Corrective Action Plan Susan Swisher, Executive Director Office of Financial Aid. Implementation Date of Corrective Action Plan

Inaccurate and Untimely Return of Title IV Funds (R2T4) Planned Corrective Action: Context: The financial aid staff will continue to take advantage of the training resources provided by the National Association of Student Financial Aid Administrators (NASFAA) to ensure understanding of the newer regulations related to R2T4 calculations for modular-based programs. They will also ensure that our internal R2T4 procedure document is accurate and that it is followed as a guide when completing calculations for these programs. And lastly, the team will have two trained aid administrators review R2T4 calculations, specifically for the modular-based programs (online and graduate students), to monitor for accuracy. Person Responsible for Corrective Action Plan: Cindi Patterson, Director for Financial Aid Anticipated Date of Completion: October 2023

Disbursements to Ineligible Students Planned Corrective Action: While the Office of Financial Aid sought to replicate controls that were in place within the legacy system, the noted disbursements to ineligible students were a direct result of the system conversion to Workday. The following measures have been or will be taken to prevent such disbursements in the future. Transfer credit evaluation (prior degree and TEACH grant) To ensure students with prior bachelor’s degrees are not awarded incorrectly, the office will coordinate with the Registrar’s Office to ensure that all undergraduate students with a prior degree are flagged immediately after transcript evaluation. The transfer credit coordinator will notify the Office of Financial Aid. If the student’s ISIR does not reflect they have earned a prior bachelor’s degree the student will be notified and the ISIR will be corrected. Existing award programming prevents students with ISIRs indicating a prior degree from being awarded aid for which they are ineligible. To ensure transfer students with GPAs that do not meet the requirements to receive TEACH grant are not awarded incorrectly, the office will conduct a review of all transfer students awarded TEACH grant once all their transcripts have been received to ensure they meet transfer GPA eligibility requirements. Loans in excess of limits To ensure students are not awarded loans in excess of their aggregate limits, the financial aid operations department has begun to proactively review NSLDS data for any student that is seen to be approaching loan limits. When an ISIR indicates an eligibility amount that is less than a single year’s maximum award, the operations department reviews NSLDS and overrides aggregate totals as needed to ensure students are not awarded over their limits. We are going to work with our post-implementation consulting partner, Alchemy, to determine other best practices within Workday. Pell Grant awarded for courses that do not apply to student’s program of study To ensure students are not awarded Pell grant for courses that do not apply to their program of study, the office developed reports to compare the financial aid load used to calculate the award with the financial aid loan within the student’s program of study. While these reports were in use during the 2022-2023 award year, there were some academic programs that had to be updated because of issues with their initial setup. Those changes have abated in this second academic year, but the financial aid technician will conduct a final check in the last week of the 7A and 7B terms so any changes to program of study load status can be reevaluated. Person Responsible for Corrective Action Plan: Michael Sapienza, Associate Vice President of Enrollment Services Anticipated Date of Completion: Necessary reports and calculations will be developed prior to December 1, 2023. Review will continue on a continuous basis.

Finding 2023-001: Perkins Loan Recordkeeping and Retention Finding: Lake Forest College had two instances where the original promissory could not be located for a student who received a Federal Perkins Loan. Cause: Attributing to human error, the College was unsuccessful in finding the original promissory notes. Over the course of the past 20 years numerous staff changes, along with transitioning from physical paper MPN’s to electronic copies has resulted in the potential misplacement of these two MPN’s. Corrective Actions Taken or Planned: In 2018 the College transitioned from keeping physical paper copies of MPN’s, to a digital/electronically managed system, hosted through ECSI, a third-party that specializes in managing Perkins loans. The College believes this migration has and will continue to aid the maintenance of Perkins Loan records. Additionally, the College will self-audit its Perkins Loans files to identify which records are maintained onsite vs. electronically through ECSI and determine if there are any other paper records that have been misplaced. Contact Person Responsible: AJ Rodino, Controller arodino@lakeforest.edu Anticipated Completion Date: May 2024

Finding 2023-003 Federal Agency Name: U.S. Department of Education Program Name: Student Financial Assistance Cluster ALN: 84.268 Finding Summary: Late or missing loan disbursement notification: The University was required to give notification of Title IV loan disbursements within 30 days before or 7 days after the date of a loan disbursement. Thirty-nine students were found with missing or late loan disbursement notifications. Responsible Individuals: Tim Sechrist, Director of Financial Aid Corrective Action Plan: We agree with the auditors’ findings and recommendations. Training will be completed with staff that disburse federal student loans. Additionally, a report has been created to identify students that have not been sent a disbursement notification. This report will be run weekly to ensure students are notified within 7 days of any disbursement. Anticipated Completion Date: December 22, 2023.

Finding 2023-002 Federal Agency Name: U.S. Department of Education Program Name: Student Financial Assistance Cluster ALN: 84.268 and 84.063 Finding Summary: Errors in return to Title IV calculations: Calculations for five students included various errors. Errors included one late determination of withdrawal date (more than 30 days after the end of the period of enrollment), three returns completed more than 45 days after the withdrawal date, two incorrect percentage of aid earned calculations, and one overpayment of $9 to the Department of Education. Responsible Individuals: Tim Sechrist, Director of Financial Aid Corrective Action Plan: We agree with the auditors’ findings and recommendations. Training will be completed with all staff that complete and review R2T4 calculations (Tim Sechrist, Johnna Bolden, Dora Caffey). Additionally, the process of calculations will be updated to include an additional staff member. Dora Caffey will review all incoming withdrawals and begin the process of the calculation. This additional person will ensure timely and accurate calculations. Anticipated Completion Date: December 22, 2023.

Finding 2023-004 Federal Agency Name: U.S. Department of Education Program Name: Student Financial Assistance Cluster ALN: 84.007, 84.033, 84.063, 84.268 and 84.379 Finding Summary: Unauthorized credit balances: In the event that a Title IV aid disbursement results in a credit balance on a student’s account, the University is required to disburse the funds to the student within 14 days of the disbursement, unless the student or parent has authorized the retention of a credit balance. Five students who received Title IV aid resulting in a credit balance on their accounts did not receive a disbursement of the funds within 14 days of the disbursement. The University did not have an authorization from the student or parent to retain the credit balance. Responsible Individuals: Shawnta Clark, Director of Student Accounts Corrective Action Plan: We agree with the auditors’ findings and recommendations. Credit balance reports will be pulled twice weekly (Monday and Wednesday) to ensure federal funds credits are timely disbursed on designated check run days. A management review procedure will be added for monitoring credit balance reports. Anticipated Completion Date: December 22, 2023

College Work Study – Assistance Listing No. 84.033 Recommendation: We recommend the College implement policies to review all student award packages at the start of the academic year to ensure no overawards exist. View of responsible officials: There is no disagreement with the audit finding. Action taken in response to finding: The Federal Work Study (FWS) earnings are tracked in the payroll department and reported to Student Financial Services (SFS) on a monthly basis. In November 2022, Union College hired a new Payroll Accountant who failed to provide FWS earnings to SFS after her hire date. Had SFS been notified of the actual amount the student earned, the department would have increased the award. The Controller in the Accounting office is aware of the lack of competence in this position, and took steps to ensure this finding does not come up in future years. A new Payroll Accountant was hired in October 2023. The new employee has many years of higher-education experience, including work with financial award packages. The Controller believes this will be a positive change for the Accounting office, and believes this finding will be eliminated in FY24. Name(s) of the contact person(s) responsible for corrective action: Steve Trana, VP for Financial Administration Planned completion date for corrective action plan: October 31, 2023

Perkins Promissory Notes – Assistance Listing No. 84.038 Recommendation: We recommend that the College put a procedure in place to ensure that all students have a promissory note prior to disbursing of funds. Also recommend a procedure be put in place to ensure proper record retention documenting the completion of promissory note. View of responsible officials: There is no disagreement with the audit finding. Action taken in response to finding: The process Union College follows to ensure promissory notes are signed is coordinated through Student Financial Services (SFS). SFS determines eligibility of awards and adds them to the student financial package. Once a loan has been accepted SFS has the student sign the promissory note. The loan is disbursed once the paperwork has been completed and reviewed. Perkins loans followed this procedure in the time they were available. The Perkins program is no longer active so there are no new promissory notes going forward. Student accounts is currently reviewing student files to ensure promissory notes, or documentation deemed appropriate by the Department of Education, are available for the Perkins loans that will be assigned to the Department of Education. Unfortunately, previous employees did not keep accurate records; this was brought to light when a new employee took over student accounts in August 2021. While the new employee has worked hard to track down all MPNs, we know that there are some that will never be found. As a result, this will likely be a repeat finding until all Perkins Loans are assigned or liquidated. It is our hope that this process will be completed by May 31, 2025. Promissory notes or documentation will be retained until the loans are either assigned or liquidated. Name(s) of the contact person(s) responsible for corrective action: Steve Trana, VP for Financial Administration Planned completion date for corrective action plan: We hope to assign or liquidate all Perkins loans by May 31, 2025. Until then, it is likely that this will be a recurring item on our corrective action report.

Corrective Action Plan: Federal Direct Loan exit interview information was sent to the students in question in August 2023. Procedures will be improved to ensure Federal Direct Loan exit interviews are completed or information is sent to students when they cease enrollment at the University. Anticipated Completion Date: The corrective action was completed in August 2023. Contact Person: Tasha Young, Staff Accountant 816-425-6151

Finding 2023-001 The University found the disbursement notifications that were scheduled to be made during a 45 day period, using our automated process, failed to transmit and therefore some borrowers did not receive the required notifications for Direct Loan funds. Response The University subsequently notified these students or parents following the identification of the error on November 16, 2022. As a result of the error in the automated process, a population of borrowers did not receive timely written notice of their right to cancel their Direct Loans until after the 30 day notification requirement ended. Corrective Action The disbursement notification process is run manually after each disbursement file is transmitted to the Student Accounts Office. Staff continue to work with the IT department to work towards making this an automated process. Status Corrected, November 16, 2022 Responsible Official Anne Tabor, Executive Director of Financial Aid

Finding 2023-002 The Return to Title IV calculations completed during Fall 2022 semester were based on the incorrect number of days in the term because it did not include the Thanksgiving break. Response Upon review, we were required to correct calculations for 25 students for Fall 2022. We reviewed Spring 2023 as well and that resulted in correcting calculations for another 7 students. Corrective Action We made sure the 2023-2024 academic year has been set up correctly to avoid these issues in the future and noted in the procedure to review breaks when setting up the new academic calendar each year in PowerFAIDS. Status Corrected, June 29, 2023 Responsible Official Anne Tabor, Executive Director of Financial Aid

The Institute agrees with the comment and has developed a plan to correct the finding. The Institute has examined the documented destruction date on the other student related files related to federal compliance requirements to ensure accuracy of the documented destruction date.