Corrective Action Plans

The institution does not dispute this finding. There was a change in personnel within the Registrar’s Office whereby proper training was not given to the staff member responsible for notification of enrollment changes to the Financial Aid department. This impacted the two students that were under-awarded Pell. Upon learning of this finding (and after disbursing the aid that was properly due), the issue was brought to the attention of senior leadership. The Registrar now sends out an electronic communication for all enrollment changes along with a document requiring signature from multiple departments (including Financial Aid). The Financial Aid department is also generating a weekly report that tracks all status changes from the prior week in order to make proper aid adjustments in a timely manner.

The institution does not dispute this finding. There was a change in personnel within the Registrar’s Office whereby proper training was not given to the staff member responsible for notification of enrollment changes to the Financial Aid department. This impacted the two students that were under-awarded Pell. Upon learning of this finding (and after disbursing the aid that was properly due), the issue was brought to the attention of senior leadership. The Registrar now sends out an electronic communication for all enrollment changes along with a document requiring signature from multiple departments (including Financial Aid). The Financial Aid department is also generating a weekly report that tracks all status changes from the prior week in order to make proper aid adjustments in a timely manner.

Finding Number: 2023-001 Federal Assistance Listing Number: 84.038 Federal Perkins Loan Program Year Ended: June 30, 2023 Responsible Individual: Christine Banewicz Director of Student Accounts Management’s Response and Corrective Action Plan: The College agrees with the finding and recommendation. For students whose Perkins loans were paid off, the College did not return the original or a true and exact copy of the note to the borrower, or otherwise notify the borrower in writing that the loan was paid in full. The College will take corrective action with their third party service provider, University Accounting Services (UAS) to send the required communications to students with loans that have been paid in full. The College also plans to contract with UAS to send these communications to borrowers as the loans are paid off going forward. The above procedures have already been implemented.

Drake University respectfully submits the following corrective action plan for the year ended June 30, 2023. Audit period: July 1, 2022 to 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 No findings to report. FINDINGS—FEDERAL AWARD PROGRAMS AUDITS Department of Education 2023-001 Student Financial Assistance Cluster – Assistance Listing No. Various Recommendation: We recommend the University reevaluate its procedures and review policies surrounding reporting status changes to NSLDS to put a process in place to ensure the student status changes are being reported timely. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Subsequent to the final submission of the enrollment file to the NSC, the Registrar’s Office will manually update the enrollment status in the NSC for any student whose enrollment status was determined to have changed immediately upon the discovery of that change. This ensures that the enrollment status is updated for “unofficial withdrawals”, since the University’s date of determination that the student withdrew occurs after the end of the spring semester and often after the submission of the first enrollment file for the next semester. Prior to the 60-day reporting deadline (starting at the school’s date of determination that the student’s status changed) the Assistant Director for New Student Programs will verify that the enrollment status change is correctly reflected in NSLDS. In addition, the Financial Aid and Registrar’s Offices are exploring reports that are available from NSLDS to assist in identifying any discrepancies between University and NSLDS records. Name(s) of the contact person(s) responsible for corrective action: Kevin Moenkhaus, Associate Registrar Planned completion date for corrective action plan: September 30, 2023. If the Department of Education has questions regarding this plan, please call Ryan Zantingh at 515-271-3048.

Inaccurate and Untimely Return of Title IV Funds (R2T4) Planned Corrective Action: A new administrative withdrawal procedure has been created to ensure that Title IV is both timely and accurately returned to the Federal Government in the case of an official / unofficial withdrawal from the university. A shared Office365 document was created to track the number of days in each segment of the withdrawal process. The Student Financial Services (SFS) Representative initiates the process upon notification of withdrawal from the Registrar. Appropriate documentation is gathered at the time of withdrawal to establish the correct timeline for the potential return of Title IV funds. The SFS Representative then determines if an R2T4 calculation is required. If an R2T4 calculation is required, the SFS Representative will assign the task to the Student Loan Processor or the Director of Student Financial Services. The Student Loan Processor and Director of Student Financial Services will use Microsoft Outlook, as prompted by the shared Office365 document, to assign “due dates” for both the R2T4 calculation as well as the return of funds to COD to ensure compliance. The Director of Student Financial Services and the Chief Student Finance Officer will perform a weekly review of the shared Office365 document to confirm the accuracy of R2T4 calculations and the required timeline of the return of Title IV funds. A secondary review by a financial aid representative with the appropriate level of experience will ensure that internal controls over such processes can operate effectively and achieve compliance. Person Responsible for Corrective Action Plan: David Burney, Chief Student Finance Officer Anticipated Date of Completion: Implemented August 21, 2023

Corrective Action Plan 2023-002: The University concurs with the finding and has provided corrective action through correcting the identified errors and adding additional review of the R2T4 calculations. Anticipated Completion Date: June 2023 Contact Person: Reta George, Director of Student Financial Services

Regarding student status change reporting, we identified a primary issue as the cause of late reporting this year for 32 of the 33 issues identified by our auditors. Upon review, we have determined changes that will prevent future instances of late reporting. As would be known to the federal government, a website and database conversion of the National Student Loan Data System (NSLDS) made enrollment reporting unavailable to schools for most of the academic year. One consequence to this was that the National Student Clearinghouse (NSC), transitioned away from what they refer to as a mid-month roster response. It was not known to us that the NSC was not regularly submitting mid-month response files to NSLDS after enrollment reporting resumed in January of 2023. Our monthly enrollment SSCR file is scheduled to be sent to the NSC on the first of each month. Our scheduled graduation date is the end of April or start of May, so we typically send an updated graduated student list around the middle of May. We were delayed from submitting this until the first week of June. The data submission was too late to be caught by the June 1st SSCR sent by NSLDS, but we expected that it would be sent by the mid-month file sent by NSC to NSLDS around June 15th. This would have kept us within 60 days for reporting. However, since NSC did not conduct mid-month reporting in June, the data we submitted indicating graduations that occurred at the end of April/start of May sat until July 1st with NSC and it was not sent to NSLDS within 60 days. Conversations we have had with the NSC since this discovery assured us that they have resumed mid-month reporting as of July, 2023. Additionally, our analyst with the NSC assured us they would track our transmission schedule to know if data is refreshed and current at the time of their responses to the first of month SSCR files they receive from NSLDS. When the data we send comes through after a scheduled SSCR file has been processed, they will reach out to inform us of a mid-month roster being sent. To provide accountability toward this, we will make it our process to check with them on whether a mid-month roster will be sent also. When NSC does not expect to send mid-month files automatically, we will order an ad-hoc enrollment report from the NSLDS website. We experimented with this process in recent months when we became aware of this issue with mid-month reporting and found it successful. In discussion with NSC and NSLDS, we inquired as to whether we should simply increase the frequency of our NSLDS SSCR to twice per month. For the majority of the year, this is not necessary. It was a unique situation this year in that mid-month reporting had ceased following the NSLDS Enrollment Reporting being offline for half or our academic year. For one additional student in the sample, an error was found with our student information system not updating the effective date of their enrollment change. Our software vendor was asked about the conditions of this error. They had made a modification to the reporting logic early on this past year, and this logic has proven to be inaccurate. The issue was not apparent through most of the year because enrollment reporting was not being conducted because of the previously mentioned NSLDS website transitions. Upon learning of the error, our software vendor updated their logic and has issued a patch that will correctly update the enrollment status effective date. All corrective actions will be fully implemented by October 31, 2023.

Finding 2023-002 Enrollment Reporting Views of Responsible Officials The University agrees with the auditor’s findings and recommendations. Corrective Action Plan The University has identified an issue that delayed identification and reporting of changes in student enrollment status for reporting on this NSLDS component for a small group of students. In response, internal report parameters will be updated to capture timely data and resolve this error. This report is provided to the Registrar who is responsible for reporting the change in enrollment status to NSLDS. The Registrar will be responsible for correcting the reporting error that was identified. Implementation Date Immediate Individual(s) Responsible Yvonne Harwood, Vice President of Institutional Effectiveness and Sonja Dixon, Registrar

For the executive bonuses, the Academy will award a blanket bonus based on a review from the executives' team members and manager, which provides feedback on overall leadership and communication skills associated with the teams being managed by the AAC executives. The review will not include any datea regarding attaining certain metrics related to recruitment and attaining any financial aid goals

Action Plan for Enrollment Reporting Audit Finding 2023-001 Issue - It was discovered that there was a Colleague system update that occurred that caused the Standard Reporting Flag to change from Yes to No, which resulted in inaccurate reporting to NSC. For all terms that a student can attend, the flag must be set to Yes for the reporting to be accurate. The following action plans will be put into place, to ensure that reporting is accurate: Action Plan 1 - A self-audit will be completed monthly when National Student Clearinghouse enrollment reporting is completed. This self-audit is to verify the students' enrollment status is accurate. To verify the accuracy, a sample of students will be pulled from the self-audit who have withdrawn, graduated, or had enrollment changes. Action Plan 2 - Admissions and Records and Financial Aid will work closely with the IT department any time there is a Colleague system update to fully comprehend the implications of the system update and how that could impact reporting and documented procedures.

Identifying Number: 2023-005 Finding: The College did not apply the appropriate clock to credit hour conversion formula for certain applicable financial aid eligible programs. The College also did not have sufficient evidence of controls being in place to ensure compliance with this requirement. Corrective Action Planned: Moraine Valley Community College will evaluate all certificates that are standalone programs. Financial Aid will receive a list of these programs and work with IT to identify students enrolled in those programs. Financial Aid will also update our policies and procedures to ensure that all clock to credit hour conversion formulas are being applied and documented per Uniform Grant Guidance (34 CFR 688.8). Anticipated Completion Date: June 30, 2024 Responsible Person: Tasha Campbell, Director of Financial Aid campbellt68@morainevalley.edu

Identifying Number: 2023-001 Finding: For eight out of ten students tested (80%) who withdrew from the College, the students' status change at the campus level and program level was not reported to the National Student Loan Data System (NSLDS) within the 60-day requirement. Corrective Action Planned: Enrollment Services staff have created a shared logbook that will track and compile NSC transactions. This logbook is saved to a shared drive with access given to appropriate staff, VP of Student Development and Dean of Enrollment Services. Additionally, any extended gaps in reports being verified, submitted and/or responses by either College staff or NSC staff will be followed up with by the Assistant Dean of Enrollment Services and logged in the NSC logbook for audit purposes. Anticipated Completion Date: June 30, 2024 Responsible Person: Tasha Campbell, Director of Financial Aid campbellt68@morainevalley.edu

Corrective Action Plan for Finding 2023-001 - The University experienced turnover in the Institutional Research position that attributed to the reporting errors. The University will provide additional training and monitoring to ensure that information reported to the National Student Loan Data System (NSLDS) is timely and accurate. The University also has a team represented by personnel from the Financial Aid office and Registrar's office that are evaulating our third-party agent assisting with enrollment verification reporting to the NSLDS, and the University will make a change in that relationship if warranted. The corrective action is currently in process and is being coordinated by Michelle Otwell, Assistant Professor and University Registrar; Breanna Yarbrough, Assistant Professor and Director of the Center for Assessment, Research, Effectiveness & Enhancement (CAREE); Linda Pynes, Director of Financial Aid. The corrective training will be completed immediately and monitoring will be an ongoing activity. The decision on whether to make a change in the agent assisting with transmitting data to the NSLDS will be made before May 31, 2024.

The Director of Financial Aid reviewed all students who had withdrawn and determined that only two were impacted. These two students' refund calculations were reviewed and corrected, and appropriate funds were returned. The dates used in the R2T 4 calculation for the upcoming year have been reviewed by the Director of Financial Aid to verify the proper number of days will be used in the Title IV Refund calculations. The Assistant Registrar will review the academic calendar each semester to be used in the R2T4 calculations. The University implemented these procedures for the Fall 2023 semester.

To prevent future errors and oversight in the preparation and review process, hard copies of the documents used to prepare the FI SAP will be cross-checked and verified by the Student Financial Aid Director. The documentation of the review then will be re-verified by the Vice President of Business & Finance. The University implemented these procedures for the FI SAP due October 1, 2023.

Enrollment Reporting to National Student Loan Data System (NSLDS) Planned Corrective Action: A review is being completed by the Registrar’s Office to determine if something is in the student record that may prevent a student from being reported correctly. If a common factor can be determined, then it will be corrected. Until then, Enrollment reporting to NSC will be reviewed twice. Follow up will be done regarding last date of attendance reporting for those students who do fail to complete the semester. Person Responsible for Corrective Action Plan: Karen LaQuey, Director, Student Financial Aid Director; Wendy McNeeley, previous Registrar; Kristina Penland, Registrar Anticipated Date of Completion: 12/12/2023

Amberton University will strengthen the internal controls related to NSLDS reporting and provide additional training to ensure data is reported accurately to ensure proper compliance with the established guidelines. The University is also beginning to work with the National Student Clearinghouse in the reporting of enrollment information.

Amberton University will strengthen the internal controls related to notifying students of the requirement to complete Exit Counseling and will provide additional training to ensure proper compliance with the established guidelines. Additional steps have been implemented to provide notification of exit counseling to students.

Name of Responsible Individual: Sarah Christoffersen, Interim Director of Financial Aid Corrective Action: An incorrect date was used to process one student’s Return of Title IV (R2T4) calculation. Training has been provided to financial aid staff in properly performing the R2T4 calculations and a report is being run several times a month to identify possible data entry errors in R2T4 calculations. Anticipated Completion Date: Completed

Name of Responsible Individual: Sarah Christoffersen, Interim Director of Financial Aid Corrective Action: The majority of the certification delays were one day late. Corrective action has been taken. The financial aid office is working jointly with the registrar’s office to report enrollment information via the National Student Clearinghouse (NSC) which will facilitate more timely reporting of future enrollment status changes to NSLDS and reporting of all significant data elements to NSLDS. Reporting to NSC by the University Registrar’s Office has begun. Anticipated Completion Date: Completed

Name of Responsible Individual: Sarah Christoffersen, Interim Director of Financial Aid Corrective Action: This finding affected a mere 2 of 40 records tested. Corrective action has been taken. The financial aid office has set up daily disbursement record submissions through its financial aid processing system, Jenzabar Financial Aid, which will simplify the process and prevent reporting delays. Anticipated Completion Date: Completed

Name of Responsible Individual: Ruth Casper & Stephanie Furlough Corrective Action: The University Financial Aid Office has restructured the disbursement process as noted below: • Staff members will be retrained on the importance of timely reporting and record compliance. • A disbursement and documentation process will be created to track, manage and reconcile the disbursement requests sent to COD. This process will aidin recognizing approved disbursements, rejected requests, and posting of disbursements. • The disbursement and reconciliation log will be reviewed by the Asst. Vice President for Student Financial Services as well as the Asst Vice President for Analytics & Audit. Anticipated Completion Date: The disbursement procedures will be monitored on an ongoing basis.

The enrollment reporting issue specifically relates to the integrated BS/PharmD degree program. The University's primary operating system, Jenzabar, reports concurrent enrollment status for P1 students and students who have graduated from the bachelor's degree component of the program. Since the National Student Clearinghouse's (NSC's) system automatically overrides the graduation data in the University's Jenzabar report without notifying the University, a two-step corrective action plan has been initiated. The modified reporting process to improve internal controls consists of the following steps: 1. Upload the initial Jenzabar enrollment reporting into the NSC system which will show full-time enrollment for both the bachelor's degree and the PharmD program; 2. File a second report reflecting the date of completion of the bachelor's degree for all students in the integrated program to remedy the NSC system override of graduation data in the initial Jenzabar report; and 3. Conduct a manual verification of graduation data in the National Student Loan Data System to ensure complete, accurate and timely reporting of graduation information from NSC. The modified reporting process is expected to be fully implemented at the conclusion of the 2023-2024 academic year in conjunction with completion of commencement, which is scheduled to occur in May 2024.

Criteria: Regulations require the Institution ensure exit counseling is conducted with each Direct Subsidized Loan or Direct Unsubsidized Loan borrower and graduate borrower shortly before the student borrower ceases at least half-time study. Exit counseling must be conducted within 30 days after the school learns the student borrower has withdrawn from school or failed to complete the exit counseling [34 CFR 685.304(b), (1) & 34 CFR 674.42(b)]. The University concurs with this finding and will adhere to the corrective action plan. Corrective Action: The audit for FY22 was not finalized until June 27, 2023. The plan date for correction for this finding was December 31, 2023. Therefore, the plan was not realized due to the timing of completion of the FY22 audit. Now that the FY23 audit is completed, the Registrar will email exit counseling materials as an attachment to the email or send a email containing URL or hyperlink which will take the student directly to the Exit Counseling page on StudentAid.gov. Responsbile Person(s): Doreen Dixon, Registrar ddixon@vuu.edu 804 257-5845. Robert Merino, Executive Director jrmerino@vuu.edu 281 795-6190. Planned Date of Completion of Corrective Action: December 31, 2023.

Criteria: Under the Pell grant and ED loan programs, Institutions are responsbile for timely enrollment reporting to the NSLDS whether they report directly or via a third-party servicer such as the National Student Clearinghouse (NSC). Enrollment reporting in a timely and accurate manner is critical for effective management of the programs. Enrollment information must be reported within 60 days whenever enrollment status changes for students unless a roster is submitted within 60 days. These changes include reductions or increases in attendance levels, withdrawals, graduations, or approved leave-of-absence. The University concurs with this finding and will adhere to the corrective action plan. Corrective Action: The audit for FY22 was not finalized until June 27, 2023. The plan date for correction for this finding was December 31, 2023. Therefore, the plan was not realized due to the timing of completion of the FY22 audit. Now that the FY23 audit is completed, the Registrar and Information Technology will ensure monthly reporting to the National Clearinghouse. In addition, the Registrar will determine the root cause is corrected and enrollment is reported correctly. These procedures will become part of the Registrar's Standard Operating Procedures. Responsbile Person(s): Doreen Dixon, Registrar ddixon@vuu.edu 804 257-5845. Kofi Jack, Chief Information Officer kjack@vuu.edu 804 257-5709. Planned Date of Completion of Corrective Action: December 31, 2023.