Corrective Action Plans

Department of Education 2023-001 Student Financial Assistance Cluster – Federal Assistance Listing Numbers 84.007, 84.033, 84.038, 84.063, 84.268 Recommendation: We recommend the College evaluate its policies and procedures surrounding the completion of R2T4 calculations to ensure scheduled breaks are properly factored into calculations. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Swarthmore College utilizes the Return of Title IV Funds Calculation Web Tool available through the Department of Education’s (DOE) Common Origination and Disbursement (COD) site to calculate the amount of federal funds needing to be returned to the DOE when a student withdraws during a semester. Upon the withdraw of an eligible student, two Financial Aid professionals review the calculation of the return of Title IV funds. In addition, Financial Aid will have two professionals review the initial set up of semesters, dates and cost configurations in the COD Return of Title IV Funds Calculation Web Tool. Please note, each year, Swarthmore College has less than five students withdraw resulting in a return of Title IV Funds Calculation. The 2022-23 finding impacted three students with less than $100 of Title IV funds per student returned to the DOE. Name of the contact person responsible for corrective action: Judy Strauser, Director of Operations, Financial Aid Planned completion date for corrective action plan: Fall 2024

Corrective Action Planned: As soon as the improper calculation was brought to the attention of the College, all fourteen students for whom a Spring Return of Title IV calculation was performed, had their R2T4s recalculated. Going forward, the Assistant Vice President of Financial Aid (Asst. VP) will review the academic year calendar and determine the start and end dates of each term and each break in attendance. The Asst. VP will enter the appropriate dates into the PowerFAIDS Administration POEs and Budgets module. The Associate Director of Financial Aid (Associate Director) will then review the academic calendar and confirm that the dates entered into the PowerFAIDS Administration POEs and Budgets module are accurate. An email will be sent from the Associate Director to the Asst. VP for record keeping and confirmation of the review. In addition, for a student who may be eligible for a post withdrawal disbursement, the Associate Director will calculate the amount to be disbursed and then the Asst. VP will confirm the amount to be disbursed at the time the disbursement is authorized. The College believes this two‐step confirmation approach will reduce the likelihood of an error moving forward. Names of Contact Persons Responsible for Corrective Action: Paula Lehrberger, Assistant Vice President of Financial Aid and Wendy Kern, Associate Director of Financial Aid Anticipated Completion Date: September 19, 2023

Personnel Responsible for Corrective Action Plan: Eva Painter – Director of Institutional Research Anticipated Completion Date: February 15, 2024 Corrective Action Plan Context - As is noted in the original finding, the Institution submitted all enrollment and degree verify files to servicer (National Student Clearinghouse) according to the transmission schedule. After reviewing the timeline and files noted in the finding, it appears that the subsequent enrollment file was sent to National Student Clearinghouse on 5/16/23, which was consequently, prior to the Registrar completing process to roll students who graduated to a “G” status. Therefore, only some of our graduates were noted as “G” status in the May Enrollment Transmission. These students that were included were reported to NSLDS with a “G” status within the prescribed time period. All graduates were included in the Degree Verify transmission later in May; however, our institution does not participate in the Clearinghouse service to automatically roll degree verify transmissions to G status. Furthermore, the following scheduled enrollment transmission in July also included all of the Graduated students as a G status, but it was not received by NSLDS within the 60-day window. It is clear that the transmission schedule needs to be edited to avoid future issues. Additionally, this finding has also shed light on the need for a clear policy on the window in which we will allow students to reverse transfer back credit, should they want to be considered graduated in the same term they were last enrolled. The director of institutional research therefore recommends two action plan items and a set of best practices to follow on a continual basis. Corrective Action Items: 1. Review and edit the Clearinghouse Transmission Schedule The submission calendar will be reviewed by both the director of institutional research and the registrar to ensure the scheduled enrollment transmissions following graduation are scheduled so that there is enough time to roll all students to G status, but also that it will be received by NSLDS within 60 days. It will be recommended that all enrollment transmissions following a scheduled graduation be transmitted by the 30th of the month graduation took place and within 14 to 16 days. For example, a transmission will be submitted by the 30th of May following a May 11th graduation. 2. Develop and Codify Reverse Transfer Policy Best Practices The Registrar and Director of Institutional Research will develop a Reverse Transfer Policy and submit to Chief Academic Officer for approval. The policy will recommend that students who wish to receive a graduation award for a graduation date that falls within their last semester attended must submit any necessary reverse transfer credit within 14 business days (excluding holidays) “of the concurred graduation date of that semester. Should the student submit reverse transfer credit after that window, the student’s graduation date will reflect that of the following concurred graduation date. Ongoing Best Practice Protocols to be immediately implemented: 1. The Director of Institutional Research will confer with Registrar to ensure all graduates have been rolled over to g status prior to sending the enrollment transmission to Clearinghouse. 2. Upon receiving any reverse transfer credit, the Registrar will notify the Director of Institutional Research, so that the student can be manually changed to “G” status in the Clearinghouse System.

CORRECTIVE ACTION: THE UNIVERSITY CURRENTLY USES AN AUTOMATED WITHDRAWAL PROCESS FOR MAIN-CAMPUS UNDERGRADUATE STUDENTS. TO REMAIN COMPLIANT WITH RETURN OF TITLE IV REGULATIONS, THE OFFICE OF FINANCIAL AID WILL ENGAGE WITH ALL ACADEMIC LEVELS AND DEPARTMENTS ON CAMPUS AND ENCOURAGE THE USE OF THE AUTOMATED WITHDRAWAL PROCESS. THIS WILL ENSURE THE OFFICE OF FINANCIAL AID IS MADE AWARE WHEN A STUDENT IS NO LONGER ATTENDING THE UNIVERSITY AND CAN PROCESS THE R2T4 WITHIN REQUIRED TIMELINES. ANTICIPATED COMPLETION DATE: MAY 31, 2024. INDIVIDUALS RESPONSIBLE FOR CORRECTIVE ACTION PLAN: PRESTON DODSON, DIRECTOR OF FINANCIAL AID.

To ensure that student enrollment statuses are updated following any change in full time enrollment status, the University of Lynchburg is implementing a new Student information system (Ellucian Colleague) that will automate the management of student statuses based on NSLDS parameters and guidelines. The new system will drastically reduce the previous needs for the manual monitoring of student statuses. This new system will be fully implemented by August 2024. In the interim, the Registrar's Office is stepping up its efforts to ensure that the current manual monitoring process is effective.

Management determined the root cause of errors in the date of determination that the student withdrew (determination date), which ultimately led to funds not being returned within 45 days, was due to a process error. The old process relied on the Registrar's Office to provide the actual date to use (through a Withdrawal Report). It was discovered that with only one date able to be captured in the current (antiquated) ERP that the Date of Withdrawal was the only date provided. In the short term, this is being resolved by the Registrar's Office directly notifying the Financial Aid Office with both dates (not relying on a withdrawal report): Date of Withdrawal and Date of School's Determination. Beginning 2024 5 a new ERP will be in place that will allow both dates to show in the Financial Aid R2T4 module immediately as reported from the Registrar's Office.

Student Financial Aid Cluster – Federal Assistance Listing Numbers 84.007, 84.033, 84.063 and 84.268 Auditors’ Recommendation: We recommend the University review its policies and procedures related to outstanding student refund checks to ensure they are being returned to the Department of Education after 240 days. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The University has developed a policy to identify uncashed Title IV refund checks prior to the 240-day expiration date. The policy includes steps to contact students whose checks did not clear and to return the funds to the Department within 240 days after the issue date of the check. The procedures will ensure that reviews are completed and returned timely according to applicable regulations. Name(s) of the contact person(s) responsible for corrective action: Cynthia McDaniel, Controller, (201) 761-7424 Planned completion date for corrective action plan: Completed

Student Financial Aid Cluster – Federal Assistance Listing Numbers 84.007, 84.033, 84.063 and 84.268 Recommendation: We recommend the University review the R2T4 requirements and implement procedures to ensure scheduled breaks are properly factored into the R2T4 calculations as well as the correct date of withdrawal. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The error identified has been recalculated with the correct date and funds have been returned. The office of Financial Aid will have two staff members review each withdrawal to ensure that withdrawal dates are checked and that scheduled breaks are appropriately accounted for prior to finalizing the calculations. Name(s) of the contact person(s) responsible for corrective action: Jennifer Ragsdale, Director of Student Financial Aid, (201) 761-6060 Planned completion date for corrective action plan: Completed

Student Financial Aid Cluster – Federal Assistance Listing Numbers 84.063 and 84.268 Recommendation: We recommend the University evaluate its procedures and review policies in overseeing submissions to the NSLDS completed by the third-party servicer. Additionally, we recommend the University review its policies and procedures on reporting enrollment information to the NSLDS to ensure that all relevant information is being captured and reported timely in accordance with applicable regulations. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: University has updated its policies and procedures for NSLDS submissions via their third-party servicer to ensure relevant information is being captured and reported timely in accordance with applicable regulations. Name(s) of the contact person(s) responsible for corrective action: Kamla Singh-Ramoutar, University Registrar, (201) 761-6051 Planned completion date for corrective action plan: Completed

Student Financial Aid Cluster – Federal Assistance Listing Number 84.063 Recommendation: We recommend that the University establish a process to review changes and updates to a student’s FASFA prior to disbursing funds to ensure the most up to date and accurate information is being used for Pell awards. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The error was identified prior to the end of the award year and the student’s award was corrected. The ISIR Alert Report (IART) is generated during the ISIR import process and identifies all ISIR transaction updates. All updates are reviewed and the student accounts are updated appropriately where necessary prior to the completion of the rest of the import process. The office of Financial Aid will add a 2nd reviewer of the IART report. Name(s) of the contact person(s) responsible for corrective action: Jennifer Ragsdale, Director of Student Financial Aid, (201) 761-6060 Planned completion date for corrective action plan: Completed

Action taken in response to finding:  The Financial Aid Office (FAO) has implemented, another line of communication with the Registrar’s office to ensure that all complete withdrawals are sent to the financial aid office by forwarding them to a designated email box. The Financial Aid Office is also working with IT services to develop a report that can be pulled to capture and compare all withdrawal students, with the Registrar’s office to make sure none are overlooked.  The Financial Aid Office is working with our 3rd Party Servicer, Ellucian, to identity the issues with our rules that do not capture the correct data elements, so that loans are not disbursed after a student has completely withdrawn.

Identifying Number: 2023-004 Finding: While the College does have a program that addresses information security, the College did not have a readily accessible program document to address the required safeguards for the nine required elements under the implementing regulations of the Gramm-Leach Bliley Act (GLBA) known as the “Safeguards Rule” by June 9, 2023. Corrective Action Taken or Planned: The College will create a readily accessible written information security program document outlining all standards to meet and maintain compliance with the GLBA. While the College has not yet formally adopted an information security program, they have demonstrated substantial compliance with the required elements under the Gramm-Leach Bliley Act, including: • Development and implementation of risk assessment frameworks that include penetration testing (16 C.F.R. 314.4(b)); • Adoption of a cybersecurity roadmap and various College policies based on internationally recognized NIST standards (16 C.F.R. 314.4(c)); • Regular testing and monitoring of the effectiveness of the safeguards currently implemented (16 C.F.R. 314.4(d)); • Implementation of policies and procedures to ensure personnel can enact safeguards that should be formally included in the information security program (16 C.F.R. 314.4(e)); • Adoption of procedures and policies for the evaluating and adjusting the safeguards that have been implemented, including monthly vulnerability scans accompanied by a remediation plan for any vulnerabilities identified (16 C.F.R. 314.4(g)); • Creation of a Cybersecurity Incident Response Plan (16 C.F.R. 314.4(h)); and • Annual training and reporting for the College’s Board of Trustees on cybersecurity safeguards (16 C.F.R. 314.4(i)). The Director of Cybersecurity and the Chief Information Officer are designated as the responsible parties for oversight and implementation of the program. Anticipated Completion Date: June 30, 2024 Responsible Person: Allison Porterfield-Woods, Chief Information Officer

Finding 2023-001 Federal Agency Name: U.S. Department of Education Federal Financial Assistance Listing: 84.063, 84.007, 84.268, 84.033, 84.038, 84.379 Program Name: Student Financial Assistance Cluster Compliance Requirement: Special Tests & Provisions – Enrollment Reporting Type of Finding: Material Weakness in Internal Controls Finding Summary: During the testing of compliance for Enrollment Reporting, there were instances where the National Student Loan Data System (NLSDS) did not reflect accurate or timely reporting of a student’s change in enrollment status. While records were submitted accurately and timely to the National Student Clearinghouse, those records were not reflected in NSLDS. Responsible Individuals: Kella Helyer, Director of Financial Aid and Amy Clark, University Registrar Corrective Action Plan: Management agrees with this finding. The initial response to this request for data did not include the active and inactive enrollment levels for the requested sample students. Initially it appeared that there was a systems issue between the National Student Clearinghouse (NSC) and the National Student Loan Data System (NSLDS); however, upon further investigation and in conversation with NSLDS, the required information was found and subsequently provided to Eide Bailly on December 1, 2023. The resolution of this request for data was resolved but after the final audit report was submitted. Anticipated Completion Date: Completed December 1, 2023

Enrollment Reporting Cluster: Student Financial Assistance Sponsoring Agency: Department of Education Award Name: Federal Pell Grant Program and Federal Direct Student Loans Award Numbers: Not applicable Assistance Listing Titles: Federal Pell Grant Program and Federal Direct Student Loans Assistance Listing Numbers: 84.063 and 84.268 Award Year: 2022-2023 Pass-through entity: Not applicable The enrollment reporting exceptions identified by PwC were isolated to one Harvard school and did not impact the loan repayment status for any student. The exceptions were the result of system reporting and management has completed corrective actions. Program level enrollment effective date was addressed by correcting the enrollment reporting logic within the Harvard school’s reporting system, Ellucian Banner. This updated logic now provides accurate program status effective dates in the National Student Clearinghouse (NSC) reporting file. Harvard successfully transmitted its first file with the updated logic to NSC in November 2023. As program level enrollment data is not used to initiate loan repayment or other loan status changes; these students were not negatively impacted. Withdrawn versus graduation status issue was isolated to off-cycle graduation events in November and March. Although the final status was reported as withdrawn instead of graduated for these selections, there was no impact on the student’s loan repayment or eligibility as we appropriately reported the initial separation event. Harvard implemented a “Graduates Only” NSC reporting file to correctly transmit the graduation status for these off-cycle graduates which will ensure compliance going forward. Sincerely, Amanda McDonnell University Controller 617-495-8032

Corrective Action Plan: Currently, UNM sends award information upon initial packaging which includes type of loan offered, if any, amount, and semester. The packaging process typically begins in March for the following aid year and runs on a nightly basis. A separate loan offer notification is sent upon packaging which includes type of loan offered, amount, and semester. The loan offer also includes instructions on how to accept the loan and links to resources such as loan interest rates, promissory notes, entrance counseling and how to access loan history via NSLDS. If students choose to accept the loan(s), a loan acceptance notification is sent. This notification includes type of loan, amount, and semester. It also includes right to cancel information, cancellation procedures and instructions on accessing loan history. Loan acceptance notifications are sent nightly upon acceptance. The timing of the loan offer and acceptance notifications is based on when the student completes their financial aid file and is packaged, and when they accept their loan(s) but does not correspond with the actual loan disbursement. UNM has been relying on the loan offer and acceptance notifications and COD disbursement notifications to convey the loan disbursement notification information as required per 34 CFR 668.165. Effective immediately, UNM will establish an internal process to send loan disbursement notifications within 30 days of the actual loan disbursement. The internal process will duplicate our current offer and acceptance notifications. UNM will continue to opt in to COD disbursement notifications as a secondary method of communication. Contact Person: Elizabeth Jacquez-Amador Anticipated Completion Date: October 31, 2023

Gavilan’s current process in submitting enrollment files to NSC involves a collaboration between two departments: Admissions and Records and Information Technology. During this period, primarily in Spring 2023, the two parties experienced a miscommunication between which file contained the current enrollment data versus which file was being submitted to NSC. Admissions and Records mistakenly submitted 4 incorrect files. Since, Admissions and Records has worked with IT to update procedures and strengthen communication when collecting the current enrollment data. To further correct the deficiency, discussions circled around Admissions and records working with a Banner Ellucian Consultant to review our Banner capabilities and strengthen the user control to oversee and submit the enrollment reports independent of IT’ s assistance. Admissions and Records will also develop a written manual to cover the step-by-step process in submitting the School Enrollment Transmission to National Student Clearinghouse in order for the correct NSLDS monitoring. The written manual will document: • Banner pages and strokes, including screen shots. • Current IT process, point of contact and file name • Link to future transmission page on the Na1onal Student Clearinghouse user page • Link to NSDLS Repor1ng page to validate and confirm correct submissions have been reported. The Director of Admissions and Records will coordinate business practices with Admissions and Records, Financial Aid and IT to ensure the school enrollment transmissions are submitted on time and are correct. The business process will be documented by Admissions and Records and shared with Financial Aid, IT, and the VP of Student Services

Date: 12/26/2023 Division: Human Services Agency Corrective Action Plan Audit Report Number: Year ended June 30, 2023 Finding Number: 2023-011 Finding: The Washoe County Human Services Agency (HSA) did not have adequate internal controls to ensure the amounts reported on the quarterly CB-496 reports agreed to underlying supporting records. Corrective Action Taken or To Be Taken: Notify DCFS partner of incorrect submission. Reviewed proper process with cost allocation team. Expanded and strengthened QA process for client count submissions. If already taken, date of completion: 8/14/2023 If to be taken, estimated date of completion: Agency Response Does the Agency Agree with finding?: Yes ☒ No ☐ Partially ☐ If No or Partial, Please explain reason(s) why: Additional Comments: Division Responsible for Corrective Action Plan Name, Title: Pamela Mann Address or Mailstop: 350 S. Center St. City, State, Zip Code: Reno, NV 89501 Phone Number: 775-685-6698 Email: pmann@washoecounty.gov Reviewed and Approved December 26, 2023 Signature Date:

Gramm-Leach-Bliley Act (GLBA) Recommendation: We recommend that the College review the updated GLBA requirements and ensure their written information security program (WISP) includes all required elements. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Reason for finding: Non-compliance with GLBA Action taken in response to finding: Management has already taken action and developed a written information security plan and will implement the written policy that includes all the required elements. Name(s) of the contact person(s) responsible for corrective action: Brant Wright Planned completion date for corrective action plan: December 31, 2023

Finding 2023-001: Special Tests and Provisions: Enrollment Reporting Context/Condition: Of the 40 students selected for enrollment reporting testing, 3 students within the sample were reported to NSLDS outside the maximum 60-day window. Recommendation: The auditor recommended that the College review and update internal controls to ensure student enrollment status in the National Student Loan Data System (NSLDS) is updated in a timely manner to ensure compliance with Federal requirements. Persons Responsible for Corrective Action: Dr. Deokhyo Kim, Registrar Planned Corrective Action: We communicated with our software vendor, Aptron, to determine what caused the enrollment reporting issues. We identified two issues and worked with Aptron to put measures in place so that these issues do not happen in the future. 1. Missing withdrawn students who were not pulled up by system when they withdrew before or on the 1st enrollment report date. APTRON fixed the programming and the system now pulls those who are withdrawn before or on the 1st enrollment report date for each semester. 2. Missing graduates with their 2nd degree. APTRON fixed the programming, so that our Degree Verify file will now report a student who has earned a second degree with us. A Degree Verify File of graduates was submitted to the NSCH for any student who had earned a second degree not previously reported. Anticipated Completion Date: Fixes with our software vendor have been completed.

Student Financial Aid Cluster – CFDA No. 84.268 Recommendation: We recommend that the Seminary review the updated GLBA requirements and ensure their WISP includes all required elements. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The seminary will update our current WISP to comply with additional requirements and newer standards. Name(s) of the contact person(s) responsible for corrective action: Raymond Ingram, Director of Finance Planned completion date for corrective action plan: February 1,2024

Student Financial Aid Cluster – CFDA No. 84.268 Recommendation: We recommend the Seminary reevaluate its procedures and review policies surrounding reporting status changes to NSLDS to ensure timely reporting as well as put a process in place to ensure the enrollment effective date reported to NSLDS is aligning with the Seminary's last date of attendance. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Seminary will continue to use the import / export function to report to NSLDS. Financial Aid Services will reiew the report, prior to submission, for any errors, duplications, etc. Name(s) of the contact person(s) responsible for corrective action: Maryjo Lewis, Registar Planned completion date for corrective action plan: January 1,2024

Christopher Natelborg (Director of Financial Aid) and Dawn Sallee-Justesen (Director of Enrollment Services) will implement the following procedures and internal controls to ensure accurate dates are reported to NSLDS that agree with District records: • For NSLDS Enrollment Reporting purposes, 34 CFR 685.305(c) requires schools to report the same withdrawal date that the school used for the return of Title IV funds (R2T4) purposes under 668.22(b) or (c). That is, the effective date for the withdrawn (‘W’) status is the withdrawal date used by the school in the R2T4 calculation. To ensure reporting is accurate, the Office of Financial Aid will communicate to the Registrar the specific student files and the dates of withdrawal used for any unofficial withdrawal R2T4 calculations after each term and the Registrar will update the student’s date of withdrawal on file with NSLDS within the required enrollment reporting deadlines. • The Director of Financial Aid and Director of Enrollment Services will also explore Information Technology automating the unofficial withdrawal date reporting to NSLDS. These corrective actions will be implemented by February 2024, including updating the dates in NSLDS for the 2023 summer and fall term unofficial withdrawals.

2023-004: 240 Days Outstanding Check Recommendation: We recommend the District re-evaluate their procedures for processing and documenting outstanding Title IV funds to the Department of Education. Action taken in response to finding: This issue is the result of a conflict between the procedures used by the awarding team (Financial Aid) and the disbursement team (Fiscal Services). The Financial Aid team was operating with a set of pre-pandemic instructions that had them contact students to fix their address information (the typical reason that disbursements timeout) and send a list of students with verified addresses to Fiscal Services for reissuing. Nothing in their procedures mentioned the need to rescind aid—only the need to verify addresses to allow funds to reach students. The Fiscal Services team’s procedures, on the other hand, assumed the Financial Aid team was rescinding aid as necessary and thus would reissue repeatedly as long as the funds remained awarded in the school’s information system, even in cases where the initial disbursement had been made more than 240 days prior. The combination of these two procedures led to the findings in this year’s audit and last year’s audit, as well. The Financial Aid team’s procedures were updated and presented to the team on October 4, 2023. These new procedures included:  Directions on how to rescind funds  A policy statement requiring recission when the time since first disbursement has exceeded 90 days (an institutional policy that is stricter than the 240 days allowable under federal regulations)  A clear set of instructions on how to make the determination to rescind funds. Name of the contact person responsible for corrective action: Patrick Scott, Dean – Financial Aid Planned completion date for corrective action plan: October 2023 for procedure correction. February 2024 for completed review of affected students in audit list.

2023-003: NSLDS Enrollment Reporting Recommendation: We recommend that the District review its enrollment reporting procedures to ensure information is accurately reported to NSLDS as required by regulations. Action taken in response to finding: The District will review its enrollment reporting procedures to ensure information is accurately reported to NSLDS as required by regulations. Name of the contact person responsible for corrective action: Patrick Scott, Dean – Financial Aid Planned completion date for corrective action plan: Spring 2024

Recommendation: We recommend that the District improve the existing procedures and controls to ensure compliance with the aforementioned criteria. Action taken in response to finding: This issue was discovered during the audit process and the staff member associated with this error was made aware of it in July 2023. Refresher training occurred during August 2023 and we have added members to the R2T4 calculation team in December 2023 in hopes of spreading workload and allowing more time to complete calculations and returns before the relevant deadlines. Names of the contact persons responsible for corrective action: Patrick Scott, Dean – Financial Aid, and Kate Larot, Financial Aid Specialist Planned completion date for corrective action plan: January 2024