Corrective Action Plans

REFERENCE: 2022-017 ? Special Tests and Provisions ? Disbursements to or on Behalf of StudentsSFA Cluster (84.268)Federal Grantor: U.S. Department of EducationFacility: Good Samaritan College of Nursing and Health ScienceFinding: Good Samaritan College of Nursing & Health Science did not send loan notifications to 2 of 28 students selected for disbursement testing for direct loans.Corrective Action Plan: Compliance will be verified through internal audit of student disbursements. A sample of disbursements will be checked for proper notifications on periodic basis throughout the semester.Person Responsible: James Younger, Dean of Financial Services and DevelopmentExpected Completion: April 2023

REFERENCE: 2022-001 ? Special Tests and Provisions ? Disbursements to or on Behalf of StudentsStudent Financial Assistance Cluster (Assistance listing No. 84.268)Federal Grantor: U.S. Department of EducationFacility: Good Samaritan College of Nursing and Health ScienceFinding: Good Samaritan College of Nursing & Health Science did not have evidence of whether the quality assurance system was operating effectively during the fiscal year ended June 30, 2022.Corrective Action Plan: This finding was corrected by June 30, 2022. In January 2021 the institution updated the Financial Aid Department Policy and Procedure Manual to include a section that address quality assurance oversight. The Quality Assurance Plan developed includes the following: reports loan records, disbursements, and adjustments to disbursements correctly to the Common Origination Disbursement system; disburses and returns loan funds in accordance with regulatory requirements; disburses the correct loan amount to the correct student; completes monthly reconciliation and Program Year Closeout. Program will be reviewed annually and updated accordingly by FAS and GSC Management. Compliance with the quality assurance policy is monitored through the reconciliation process which was implemented in June 2022.Person Responsible: Judy Kronenberger ? President Good Samaritan College of Nursing and Health ScienceCompletion: June 2022

REFERENCE: 2022-002 ? Special Tests and Provisions ? Borrower Data and Reconciliation (Direct Loan)Student Financial Assistance Cluster (Assistance Listing No. 84.268)Federal Grantor: U.S. Department of EducationFacility: Good Samaritan College of Nursing and Health ScienceFinding: Good Samaritan College of Nursing & Health Science did not perform the direct loan monthlyreconciliations for FY22.Corrective Action Plan: Good Samaritan implemented a formal monthly reconciliation process, includingcomparison of all systems for the period, a final review of G5 funds prior to draw down, a cover sheet noting anyexplaining any differences, proper sign off for preparation and review and the date by Good Samaritan management.A year end reconciliation will also be performed following the same process.Person Responsible: Judy Kronenberger ? President Good Samaritan College of Nursing and Health Scienceand Financial Aid Services (FAS)Completion: June 2022

REFERENCE: 2022-003 ? Reporting ? Common Origination and Disbursement (COD) SystemStudent Financial Assistance Cluster (Assistance listing No. 84.063)Federal Grantor: U.S. Department of EducationFacility: Good Samaritan College of Nursing and Health ScienceFinding: Good Samaritan College of Nursing & Health Science did not perform its internal control over therequirement to submit Pell payment data to the Department of Education through the COD system, which consists ofmonthly Pell COD reconciliations.Corrective Action Plan: Good Samaritan will implement a formal monthly reconciliation process, includingcomparison of all systems for the period, a final review of G5 funds prior to draw down, a cover sheet noting anyexplaining any differences, proper sign off for preparation and review and the date by Good Samaritan management.A year end reconciliation will also be performed following the same process.Person Responsible: Judy Kronenberger ? President Good Samaritan College of Nursing and Health Scienceand Financial Aid Services (FAS)Completion: June 2022

Lockhaven: Recommendation: The University should ensure all necessary employees receive proper training, support, and time to follow the university policies and federal requirements related to monthly reconciliations and maintenance of documentation.Explanation of disagreement with audit finding: There is no disagreement with the audit finding.Action taken in response to finding: All employees will receive proper training, support, and time to follow the university policies and federal requirements related to monthly reconciliations and maintenance of documentation. The reconciliation will be reviewed and signed off of monthly ensuring proper documentation is on file to validate the review process.Name(s) of the contact person(s) responsible for corrective action: Michael Hall, Director of Financial Aid.Planned completion date for corrective action plan: June 30, 2023

California: Recommendation: We recommend the Institute review its policies and procedures around sending entrance and exit counseling information to students to ensure students are receiving proper counseling and ensure entrance counseling is documented before loans disbursements are made.Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: A process in banner is run to catch any new students that need RRAAREQ updates with exit counseling. This will get students who have withdrawn, less than 1/2-time attendance, not enrolled, graduated or schedule to graduate. Once the requirement is on the account, then another process is run to get all of the students with the EXIT code still outstanding and send an e-mail to campus and personal e-mail. Students will receive emails every 30 days to complete the requirement until it is satisfied.Name(s) of the contact person(s) responsible for corrective action: Financial Aid Office, California, Clarion and Edinboro- Kelly Vitelli, Sue Bloom or Traci NecciaiPlanned completion date for corrective action plan: Plan is currently being employed.

Kutztown: Recommendation: The University should review its reporting procedures to ensure that students? statuses are timely reported to NSLDS as required by Federal regulations.Explanation of disagreement with audit finding: There is no disagreement with the audit finding.Action taken in response to finding: We are re-evaluating our reporting procedures and will work with the Registrar?s Office to further redefine our process(es). Currently, the Registrar?s Office submits monthly transmissions to NSC (National Student Clearinghouse), who in turn updates our information to NSLDS. Moving forward, a financial aid resource will work in conjunction with the Registrar?s Office to ensure errors are addressed timely to certify the accuracy of our reporting.Name(s) of the contact person(s) responsible for corrective action: Bernard McCree, Director of Financial Aid Services, at 610-683-4032 or mccree@kutztown.edu.Planned completion date for corrective action plan: June 30, 2023 Cheyney: Recommendation: The University should review its reporting procedures to ensure that students? statuses are timely reported to NSLDS as required by Federal regulations.Explanation of disagreement with audit finding: Per federal regulations 34 CFR 685.309(b), 682.610(c), and 674.33(j), Management concurs with the finding. There is no disagreement with the audit finding.Action taken in response to finding: Cheyney University of Pennsylvania utilizes the National Student Clearinghouse as a third-party service provider for enrollment reporting and provides all enrollment data to NSC, believing that enrollment would be reported to NSLDS in compliance with federal regulations; unfortunately, NSC only includes enrollment data for students on the enrollment roster they receive from the National Student Loan Data System (NSLDS). Cheyney University is a Heightened Cash Monitoring 2 (HCM2) institution, and students' Title IV aid/ disbursements are reported differently than advance pay institutions. Students did not appear on the rosters, so NSC did not provide the enrollment data to NSLDS. While investigating the issues with enrollment reporting for our HCM2 students, Cheyney University learned that NSLDS did not receive students' enrollment from NSC. As of spring 2023, Cheyney University has implemented procedures to report enrollment for all Title IV recipients to NSLDS.Name(s) of the contact person(s) responsible for corrective action: Rhonda Thompson, RegistrarPlanned completion date for corrective action plan: January 15, 2023

Kutztown: Recommendation: The University should review its policies and procedures around COD reporting to ensure students? information is reported timely and accurately.Explanation of disagreement with audit finding: There is no disagreement with the audit finding.Action taken in response to finding: We are reviewing our policies and procedures for COD reporting. A financial aid resource will refine their calendar to ensure that we are in compliance with the 15-day rule for PELL reporting is met consistently.Name(s) of the contact person(s) responsible for corrective action: Bernard McCree, Director of Financial Aid Services, at 610-683-4032 or mccree@kutztown.edu.Planned completion date for corrective action plan: June 30, 2023

Kutztown: Recommendation:a. The University should evaluate their procedures and review policies surrounding reporting status changes to NSLDS to ensure the enrollment effective date reported to NSLDS is aligning with the University?s last date of attendance.d. The Universities should evaluate their procedures and review policies surrounding reporting program enrollment statuses to NSLDS.Explanation of disagreement with audit finding: There is no disagreement with the audit finding.Action taken in response to finding: We are re-evaluating policies and procedures to ensure compliance in reporting. We will be working with the Registrar?s Office to rectify any errors in a timely fashion, as well as to detail and update our processes moving forward.Name(s) of the contact person(s) responsible for corrective action: Bernard McCree, Director of Financial Aid Services, at 610-683-4032 or mccree@kutztown.edu.Planned completion date for corrective action plan: June 30, 2023Cheyney: Recommendation: The University should evaluate their procedures and review policies surrounding reporting status changes to NSLDS to ensure the enrollment effective date reported to NSLDS is aligning with the University?s last date of attendance.Explanation of disagreement with audit finding: Per federal regulations 34 CFR685.309(b), 682.610(c), and 674.33(j), Management concurs with the finding. There is no disagreement with the audit finding.Action taken in response to finding: Cheyney University of Pennsylvania utilizes the National Student Clearinghouse as a third-party service provider for enrollment reporting and provides all enrollment data to the National Student Clearinghouse. The National Student Clearinghouse only includes enrollment data for students on the enrollment roster they receive from the National Student Loan Data System (NSLDS). Students did not appear on the rosters, so The National Student Clearinghouse did not provide the enrollment data to NSLDS. Cheyney University learned that NSLDS did not receive students' enrollment status changes from NSC. As of spring 2023, Cheyney University has implemented procedures to report enrollment status changes and last date of attendance for all Title IV recipients to NSLDS.Name(s) of the contact person(s) responsible for corrective action: Rhonda Thompson, RegistrarPlanned completion date for corrective action plan: April 30, 2023 California: Recommendation: The University should evaluate their procedures and review policies surrounding reporting enrollment statuses to NSLDS.Explanation of disagreement with audit finding: There is no disagreement with the audit finding.Action taken in response to finding: This finding was a direct result of the complexity of the integration. The finding is resolved when the timely submission of the graduation file to NSC and subsequent updating to NSLDS. The Office of the Registrar has a semester calendar that outlines important tasks and associated dates and what team is responsible to complete them. Once the team submits the degree file to NSC, the acceptance notice will be retained.Name(s) of the contact person(s) responsible for corrective action: Office of the Registrar Planned completion date for corrective action plan: Plan is currently being employed. Slippery Rock: Recommendation: The University should review its reporting procedures to ensure that students? statuses are timely reported to NSLDS as required by Federal regulations. Explanation of disagreement with audit finding: There is no disagreement with the audit finding.Action taken in response to finding: Before the office of Academic Records closes out a medical withdrawal, NSLDS/NSC files will be checked/notified of the proper LDA.Name(s) of the contact person(s) responsible for corrective action: Rebecca Farren, supervisor; Bobbi Jo Eakman, Clerical Assistant IIPlanned completion date for corrective action plan: immediate

California: Recommendation: We recommend the University review the R2T4 requirements and implement procedures to ensure the R2T4 calculations are using the correct amount of term days and are accurately completed.Explanation of disagreement with audit finding: There is no disagreement with the audit finding.Action taken in response to finding: The missing component in this finding was an isolated occurrence of a configuration that is directly related to the integration and is unlikely to occur again. The Office of the Registrar maintains a semester calendar of tasks to be completed with associated dates. The process in place is that the break days for any term are configured by the staff in the Office of the Registrar, management reviews that configuration and then financial aid staff review to confirm.Name(s) of the contact person(s) responsible for corrective action: Management reviews configuration of staff data entry of the break days.Planned completion date for corrective action plan: Plan is currently being employed.

Finding: 2022-084 - The enrollment effective date reported to the National Student Loan Database System for five of the ten sampled students from the UAS campus was incorrect and did not match the correct last dates of attendance on file in the institution?s records.Questioned Costs: NoneAssistance Listing Number: 84.007, 84.038, 84.063, 84.268, 84.379Assistance Listing Title: Student Financial Assistance ClusterViews of Responsible Officials (state whether your agency agrees or disagrees with the finding; if you disagree, briefly explain why): There is no disagreement with the audit finding.Corrective Action (corrective action planned): The UAS Financial Aid Office will work the Registrar?s Office to ensure that our last dates of attendance are being reported accurately. We are working on adjusting our procedures to have a process in place to ensure the last date of attendance can be manually updated to be sent to Clearinghouse and NSLDSCompletion Date (list anticipated completion date): June 30, 2023Agency Contact (name of person responsible for corrective action):Janelle Cook, Director of Financial Aid, 907-796-6257Jennifer Sweitzer, Associate Director of Financial Aid, 907-796-6296Trisha Lee, Registrar, 907-796-6294

Finding: 2022-083 - During the testing of the outstanding Title IV student check listing we observed nine instances of stale checks at the University of Alaska Southeast (UAS) and three stale checks at UAF that were aged greater than 240 days and not returned to the Department of Education.Questioned Costs: NoneAssistance Listing Number: 84.007, 84.038, 84.063, 84.268, 84.379Assistance Listing Title: Student Financial Assistance ClusterViews of Responsible Officials (state whether your agency agrees or disagrees with the finding; if you disagree, briefly explain why): There is no disagreement with the audit finding.Corrective Action (corrective action planned): UAF and UAS Financial Aid Offices will work with the Statewide Office of Finance and Accounting to pull a regular report of uncashed checks and review for Title IV aid. The Financial Aid Offices or Bursars? Offices will contact students with uncashed checks to attempt to provide the refund. Checks still uncashed after attempts will be canceled and returned to Title IV aid programs within 240 days of payment.Completion Date (list anticipated completion date): June 30, 2023Agency Contact (name of person responsible for corrective action):Janelle Cook, UAS Financial Aid Director, 907-796-6257Jon Lasinski, UAS Business Office Director, 907-796-6497Ashley Munro, UAF Financial Aid Director, 907-474-1934Jennie Witter, UAF Bursar, 907-474-6196

Recommendation: We recommend the College evaluate its procedures and policies around reporting Direct Loan disbursements to COD to ensure that student information is reported accurately and timely.Explanation of disagreement with audit finding: There is no disagreement with the audit finding.Action in Response to Finding: New selection sets were implemented in database to ensure students do not disburse until all documents are received and that they disburse to COD and to the Business Office at the same time.Name of the contact person responsible for corrective action: Shannon Amundson, Director of Financial Aid (719) 389-6651.Planned completion date for corrective action plan: Completed September 1, 2023

Recommendation: We recommend the College evaluate its procedures and policies around reporting to NSLDS, including those that are unique in nature, to ensure that student information is reported accurately and timely.Explanation of disagreement with audit finding: There is no disagreement with the audit finding.Action in Response to Finding: College personnel met with the National Student Loan Clearinghouse to determine what steps were needed to fix the issues we have. Adjusting the dates of submission was determined to be the best course of action to ensure that all rejects could be corrected at Clearinghouse prior to the NSLDS submission monthly.Name of the contact person responsible for corrective action: Shannon Amundson, Director of Financial Aid (719) 389-6651.Planned completion date for corrective action plan: Implemented September 1, 2022.

Recommendation: The auditors recommend the University follow and enhance existing policies to ensure all student changes in status are identified timely and submitted accurately within the required time frame. They also recommend the University establish a formal internal monitoring control whereby a designated individual with NSLDS access, on a sample basis, spot checks the status updates on NSLDS so to internally audit the National Student Clearinghouse submissions.Planned Corrective Action: Heritage University will adhere to and improve the current standards to guarantee that all student status changes are promptly identified and submitted accurately within the appropriate time period. In order to internally audit the National Student Clearinghouse submissions, the University will set up a formal internal monitoring system whereby a designated person with access to NSLDS periodically monitors the status updates on NSLDS.Name of Responsible Party:1. Dianne Fernandez, Director of Financial Aid2. Mary Neal, Registrar3. Thomas Richter, VP of Administration/CFOAnticipated Completion Date: June 30, 2023

Recommendation: The auditors recommend the University further educate and train those involved in the Financial Aid department regarding the Eligibility rules surrounding Federal awards, specifically regarding types of and scenarios using estimated financial assistance. They also recommend the University revise the inputs within the PowerFAIDS system so that the control established to prevent (and subsequently detect) overawards is appropriately considering all scholarships and institutional grants as estimated financial assistance, regardless of need-based or not. Lastly, as a monitoring control, the auditors recommend an overaward report showing both Federal and non-Federal overawards be developed and be run and reviewed at a set frequency by the Director.Planned Corrective Action: Heritage University is to give individuals working in the financial aid office more information and training about the eligibility requirements for federal awards, particularly with regard to the several forms and potential uses of anticipated financial aid. Additionally, the University is to update the PowerFAIDS system's inputs so that all institutional grants and scholarships, regardless of whether they are need-based or not, are adequately taken into account by the control mechanism created to avoid (and consequently detect) overawards. As a monitoring measure, the Director of Financial Aid will create an overaward report that lists both Federal and non-Federal overawards and runs it on a regular basis.Name of Responsible Party:1. Dianne Fernandez, Director of Financial Aid2. Thomas Richter, VP of Administration/CFOAnticipated Completion Date: June 30, 2023

2022 ? 001: Student Financial Aid Cluster - Student Eligibility and Awarding: Exit Counseling ?Program Number 84.268Recommendation: We recommend the college review its policies and procedures around disbursingexit counseling information to students to ensure students are receiving proper counseling and ensureentrance counseling is documented before loans disbursements are made.Explanation of disagreement with audit finding: There is no disagreement with the audit finding.Action taken in response to finding: The Financial Aid Office recognized that the exit loan counselingrule was not being met prior to the commencement of the 2021-2022 audit. The following action planwas already taking shape during the annual audit of 2021-2022 to ensure compliance rule would bemet for the 2022-2023 aid year.Process: Use SIS Colleague system to run query to identify current loan borrowers at beginning andend of term to identify those who have ceased half-time enrollment. Send communication via email andphysical letter notification to ensure student receive important information about loan repaymentresponsibilities, including Department of Education links and contact information.Procedure: Created documentation with step by step procedures for assigned staff to run query toidentify students, request exit loan counseling communication, and run batch posting of communication.Communication: Loan borrowers will receive an email on Day 1 run, a second email on Day 14 run, anda paper letter on Day 30 run.Staff Training: Staff assigned to the Loan program have been trained to run process by ourSystems/Programmer. Financial Aid Staff have been provided information about policy and proceduresto assist students who may contact our office for assistance after receiving exit loan counselingcommunication.Quality Assurance: Two additional staff members have been assigned to help with the Loan program.Name(s) of the contact person(s) responsible for corrective action: Chau Dao - Director ofFinancial AidPlanned completion date for corrective action plan: November 2022.

2022 ? 003: Student Financial Aid Cluster: Enrollment Reporting ? VariousRecommendation: Evaluate the current processes and possible backup controls to ensure errors arecaught in a timely manner.Explanation of disagreement with audit finding: There is no disagreement with the audit finding.Action taken in response to finding: El Camino College will review the Enrollment VerificationProcess to ensure it is capturing all student enrollments and reporting them properly to NationalStudent Clearinghouse. The Departments involved Information Technology, Admissions & Recordsand Financial Aid will review how the data is collected from the college?s student information system(Ellucian Colleague) and the submissions to the National Student Clearinghouse and The NationalStudent Loan Data System to ensure the records are correct and submitted in a timely fashion.Name(s) of the contact person(s) responsible for corrective action: Lillian Justice, RegistrarPlanned completion date for corrective action plan: Immediate review of the data collection processwith the Information Technology Department and Financial Aid to ensure it is capturing all currentlyenrolled students. This will be an ongoing review beginning February 2023 to ensure we are capturingthe correct data.

2022 ? 002: Student Financial Aid Cluster - Return to Title V Exit Counseling ? Program NumberVariousRecommendation: We recommend that the Colleges improve the existing procedures and controls toensure compliance with the aforementioned criteria. We also recommend an additional level of reviewis added in the process to ensure completed Return to Title IV calculations are properly completed.Action taken in response to finding: The Financial Aid office is implementing the following steps toensure all R2T4 rules are met.Process: Create new report to monitor return of unearned aid to ED within 45 days of determination.Training: Staff involved with R2T4 processing will be provided time to undergo annual training by ED orNASFAA to ensure understanding of rules and regulations. Trainings by ED and NASFAA includepractice case studies to ensure correct application of R2T4 regulations.Quality Assurance: Two additional staff members have been assigned to help with R2T4 processing.One member to assist with the review of R2T4 calculations with the second staff member to help withthe return of aid on the accounting side. Also added to our R2T4 procedures, is management review ofR2T4 calculations per term.Name(s) of the contact person(s) responsible for corrective action: Chau Dao - Director ofFinancial AidPlanned completion date for corrective action plan: December 2023.

Finding 2022-07 Return to Titel IV - Post withdrawal disbursement - Pell Grant - see corrective action plan submitted with the audit report.

Finding 2022-08 Return to Titel IV - Post withdrawal disbursement- Direct Loans - see corrective action plan submitted with the audit report.

Finding 2022-05 Return to Titel IV - refunds made late - see corrective action plan submitted with the audit report.

Finding 2022-04 Late Notification to NSLDS - see corrective action plan submitted with the audit report.

Finding 2022-02 Direct Loan exit counseling - see corrective action plan submitted with the audit report.

Finding 2022-01 Late Notification to NSLDS - see corrective action plan submitted with the audit report.