Corrective Action Plans

2022-002: Incorrect Pell Disbursement - Student Financial Aid Cluster Assistance Listing Number 84.007, 84.033, 84.063, 84.268, Grant Period - Year Ended August 31, 2022 Condition: During our student file testing we noted two students out of forty were not disbursed the correct Pell Grant. For the students the wrong Pell chart was used resulting in an under award of $150 for each student. We consider these errors to be instance of noncompliance relating to the Eligibility Compliance Requirement. Corrective Action Plan: East-West University will correct the two students to reflect the correct Pell Grant, in addition we will also be implementing check and balance system to ensure the correct Pell Grant is disbursed. Responsible Person for Corrective Action Plan: The Director of Financial Aid Cesar Campos will be the person for the corrective action plan. Implementation Date of Corrective Action Plan: 02/16/2023

Finding 2022-001 - Non-Compliance with Timely and Accurate Student Enrollment Change Submissions to the National Student Loan Data System (NSLDS) Grantor: U.S. Department of Education Program Name: Student Financial Assistance Cluster Award Names: Federal Pell Grant Program and Federal Direct Loan Program Award Year: 7/1/2021 - 6/30/2022 Award Number: Not applicable Assistance Listing Numbers: 84.063 and 84.268 Rensselaer agrees with the finding and in concurrence with the recommendations has developed and is implementing the following corrective action plans: Rensselaer?s Registrar?s Office is working with Rensselaer?s IT Department (?EIS?) to validate the logic of the data parameters included within every enrollment file. Validation will include ensuring all student status changes are reported in the enrollment file, including retroactive changes even if the student is not enrolled in the current semester. Rajni Soharu, the Institute?s Registrar, is responsible for implementing this corrective action plan by March 31, 2023. As of the date of this report, the Registrar?s Office is now fully staffed and employees are trained on the student status change requirements and system usage. Additionally, Rensselaer?s Student Success Office will now communicate changes in student enrollment information to the Registrar?s Office in real-time through a shared file. The shared file will be updated by the Student Success Office as soon as they receive any new approved leave of absence or withdrawal information from Student Health Services or other departments. The Registrar?s Office will update the student?s enrollment information within the student information system within three business days of the change reported and ensure the student?s status change is timely and accurately submitted to the National Student Clearinghouse. Rajni Soharu, the Institute?s Registrar, in collaboration with members of the Student Success Office are responsible for implementing this corrective action plan by January 31, 2023. Eileen McLoughlin Vice President for Finance and CFO

Corrective Action Plan Audit Finding Reference: 2022-002 Planned Corrective Action: In response to audit finding 2022-002, the current policy requires a master promissory note (MPN) to be stored in a locked, fireproof safe. We acknowledge there may have been gaps in internal controls during the 1970s and 1980s resulting in the missing MPN. Since 2005, MPNs are electronically signed and maintained by ECSI, our third-party servicer. During 2022, Trinity submitted 154 loans to the Department of Education (DOE) for assignment. While the University did not have an MPN for nine of these loans, the DOE accepted all but one loan based on additional documentation provided in lieu of an MPN. To determine potential future exposure, the University reviewed paper files for the 25 borrowers with loans disbursed prior to 2005 and found only three additional borrowers with a missing MPN. If the University were required to purchase these loans from the DOE, the estimated purchase amount would be less than $30,000. Date of Remediation: October 2022 Contact Person Responsible: Clara Wells

CORRECTIVE ACTION PLAN February 8, 2023 Juniata College respectfully submits the following corrective action plan for the year ended May 31, 2022. FINDING 2022-001 Corrective Action Taken: The Controller & Chief Financial Officer, in response to the finding of the incorrect rounding in the return to Title IV calculation, reviewed the FSA Handbook and communicated the finding with both the Director of Student Financial Planning and the Bursar. As a result, the Bursar updated the calculation spreadsheet to ensure that the calculation was rounding to three decimal places for the current academic year. The Senior Leadership Team was also apprised of the finding. Name of Contact Responsible for Corrective Action: Karla D. Wiser, CPA Anticipated Completion Date of Corrective Action: August 18, 2022

View of Responsible Officials Condition A We concur. The department received the notice of non-cooperation on 9/14/21 and did not enter the non-cooperation until 9/29/21, which was beyond the 10-day time frame. The case should have then been confirmed to impose the sanction on or before 9/24/21. This resulted in the client being over issued by approximately $222.37. Condition B We concur. The sanction for non-cooperation with Child Support was entered in error as Child Support did not issue a non-compliance. This resulted in the client being under issued by approximately $446.50 Follow-up We will be informing all supervisors of the specific errors found during the audit. We will also require supervisors to include these topics at their next staff meeting. In addition, individual emails will be sent to the staff involved with the errors and provide guidance. Anticipated Completion Date: N/A Contact Person: Karyl Provost

2022-003 NSLDS Reporting Recommendation: We recommend the University review its reporting procedures to ensure that students? statuses are accurately reported to NSLDS as required by regulations. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: please see below Name(s) of the contact person(s) responsible for corrective action: Elizabeth Vestal, Registrar. Planned completion date for corrective action plan: December 31, 2022 with continued auditing after. Four areas of deficiency have been identified within our current enrollment reporting process. Specifically, 1) the university did not correct errors within ten days, 2) the program begin date reported to NSLDS (National Student Loan Data System) does not match the university?s records, 3) the student?s program enrollment effective date is incorrectly reported to NSLDS and 4) status changes were not certified and/or received within sixty days. In response to your findings, the Registrar?s Office has created a plan of action to remedy the errors. The enrollment reporting process has new leadership at the university. The findings from the new audit team will be corrected. The corrections will require the university to change current behaviors, practices, and reports. Findings two and three are connected to the program start date entered into Colleague. Currently, when processing a program add or change in Colleague (student information system), the program start date defaults to the first day of the month of the start of the term. In the past admissions and advising have been instructed to enter the upcoming term date as the program start date in the SACP (Student Academic Program) screen of Colleague. Unfortunately, this is not being done consistently and several teams have reverted to using the default date and the issue was not identified prior to reporting. The following outlines the proposed corrective action plan: 1) New and re-entry/re-admit students, program changes, or change of residency a. Effective for student programs starting in Fall 2 2022, the program start date in Colleague will match the start date of the upcoming term or end date of prior term. The operator will manually correct the default date to mirror the first day of the start term or end date of prior term in Colleague. i. If there is a potential issue with the date of the upcoming term, the Registrar?s Office must be consulted prior to committing to an alternate date. 2) Active continuing students a. Phase 1: The Fall 1 2022 census report will be used to generate a list of all currently active students. Each student will be manually reviewed to verify the program effective start date reflects the start of term at the university or start of term for the next declared program/major. Although the start date of a program change is not required to match the start of term for enrollment reporting purposes, this will eliminate processing confusion and increase consistency. i. The first phase of corrections will be completed by October 24, 2022. b. Phase 2: Prior census reports will be used to capture students who had been active in terms from Summer 1 2021 to Fall 1 2022. The program effective start dates will be reviewed and corrected as needed. i. The second phase of corrections will be completed by December 31, 2022. 3) Communication a. Issue a Registrar Communication memorandum (RegCom) outlining the new expectations for assigning the program effective start date, auditing schedule, and implications of errors to the following within the university, by October 24, 2022. i. Registrar team ii. Admissions operations iii. Deans, Chairs, and Program Directors iv. Campus success coaches, faculty advisors, and coordinators v. Center directors and staff 4) Inactive students (have not attended since Summer 1 2021) a. The program effective start date of students who have not been active at the university since the Summer 1 2021 term will be reviewed and updated upon re-entry/re-admit to the university (See bullet 1 above). 5) Report/Audit a. Coordinate with the Department of Information Technology (DoIT) to create a SQL report to pull student information from Colleague, including the student?s start term and declared program effective start date. b. The Registrar?s Office will audit the report weekly to ensure all dates are compliant and accurate prior to generating the enrollment file. 6) Colleague functionality a. Explore the possibility of amending the default date assigned by Colleague. i. This is restricted by the capabilities of the SIS. If unable to amend, we would continue with manual process noted above. Findings one and four relate to the timing of file submission and correcting roster errors. The Registrar will review the university?s reporting procedures and schedule to ensure that student statuses are accurately reported through the servicer to NSLDS within sixty days and errors are corrected within ten days. To do so, the Registrar will: 1) Establish an annual schedule to report student statuses every thirty to sixty days. a. Attention will be given to term dates, withdraw deadlines, as well as weekends and calendar holidays. 2) Create a sub-schedule of timing for correcting errors. This schedule should account for days necessary for the servicer and NSLDS to process the data. 3) Audit the SCHER5 and other reports weekly to ensure any remaining errors are corrected within ten days. By taking the above actions, Saint Leo will have processes in place to establish and maintain procedures to reasonably achieve compliance with NSLDS regulations providing timely and accurate data and audit the effectiveness of our data collection and reporting procedures. The university, specifically the Registrar?s Office, is committed to submitting complete, accurate, and timely enrollment data for Saint Leo University students.

2022-002 Return to Title IV 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 completed accurately. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Report is being created that will allow staff to compare R2T4 manual data entries against source data. Discrepancies will be researched and corrected within 5 business days. Report will be generated weekly and reviewed by the manager over this area. Name(s) of the contact person(s) responsible for corrective action: Brenda Clark, Director of Financial aid Planned completion date for corrective action plan: Implementation of new quality control R2T4 report planned for October 24, 2022.

This letter is in reference to the following audit finding reference. The enrollment status change was not appropriately reported for three students out of a sample of forty. In each instance, the University of Bridgeport notified the National Student Clearinghouse of the student graduating from the University, but the student?s enrollment status had not been properly updated within the system. The University of Bridgeport has a reconciliation process in place to verify that student?s enrollment status is checked after submitting batch rosters to the National Student Clearinghouse, however the process failed to identify these exceptions. The university of Bridgeport?s proposed corrective action is as follows: 1. The Office of the Registrar will take over Clearinghouse reporting responsibilities from Information Technology. 2. The Office of the Registrar will submit to Clearinghouse enrollment and DegreeVerify files. 3. IF, exceptions are received back from the Clearinghouse, the corrections will made by The Office of the Registrar and with support from Information Technology if needed. 4. Corrections to the file are then sent to Financial Aid. 5. Financial Aid will then submit the corrections to the National Student Loan Database System. 4. These procedures will be recorded in a comprehensive manual. Anticipated Completion date: October 1, 2023 Name of Contact Person: Melissa Quinlan, Ph.D. Vice President of Institutional Effectiveness and Student Systems Carmen Rosa University Registrar Sincerely, Melissa Quinlan, Ph.D. Vice President of Institutional Effectiveness and Student Systems

Audit Finding Reference: Finding 2022-002 Disbursements to or on Behalf of Students Planned Corrective Action: Based on this finding, we will implement a new process starting with the summer 2023 semester. Disbursement notifications will be sent weekly. Name of Contact Person: Kristen Piscioneri Anticipated Completion Date: April 23, 2023 Please feel free to contact me with any questions regarding the corrective action plan. Kristen Piscioneri Director of Financial Aid Operations

RE: Finding 2022-001 Disbursements to or on Behalf of Students Corrective Action Plan: Based on the finding, we implemented a new process to ensure email addresses are populated in the financial aid system, PowerFaids, prior to disbursement. In addition, we incorporate a mix of manual reviews of files as well as an exception report that we run immediately after any disbursements to ensure all notifications have been processed. In addition, our new processes aim to notify students the following business day, but will now always ensure notification within the 7 days allowed under the regulations. Person Responsible for Corrective Action Plan: Name: Bonnie Soltz-Knowlton Title: Assistant Vice President of Financial Aid Anticipated Completion Date: January 11, 2023

2022-002 COD Dates Not Reflecting Actual Disbursement Dates Planned Corrective Action: All 21-22 batch disbursement dates will be checked within COD. Any dates that do not match will be updated to match with the date the funds were disbursed as recorded in Populi. To prevent this in the future when the finance office receives funds and posts them on student accounts in Populi the financial aid office will manually mark each disbursement in Populi to sync and send them to COD. This will cause the disbursements COD status to change to pending in Populi while it processes, when the status changes back to accepted the Populi and COD disbursement data will align. Once updates process with COD each disbursement will again show as accepted a PDF of the disbursement batch will be saved in our files which displays that the awards are synced with COD. We will perform a spot check of the disbursements within each batch by looking up individuals in COD and verifying that the disbursement date updated in the sync from Populi. Person Responsible for Corrective Action Plan: Anna Bergh, Financial Aid Director Anticipated Date of Completion: January 1, 2023

Identifying number: 2022-002 Finding: There are allowable costs such as a benefit allocation and supplies in which there was no formal approval of the cost. Corrective actions taken or planned: Additional levels of review will be added to verify the allowable cost have been approved. Contact person: Steve Schuring, CFO Date of completion: June 2023

Identifying Number: 2022-001 Finding: There were two individuals that did not have a service planning conference within 5 business days of the individual admission date. Corrective Actions Taken or Planned: Additional levels of review and monitoring over compliance with the contract will be put in place. Contact person: Steve Schuring, CFO Date of completion: June 2023

Finding Number: 2022-001 ALN, Federal Agency, and Program Name - Student Financial Assistance Cluster-Federal Direct Student Loan Program ALN 84.268 Condition: The College was not sending notifications meeting the required criteria during the year. Planned Corrective Action: The College has updated notifications to include the required elements beginning in the Fall 2022 semester. Contact person responsible for corrective action: Nicole Hatter Anticipated Completion Date: 11/22/2022

View of Responsible Officials: Management concurred with the finding and has implemented procedures to review the information shared between College of the Ozarks and the NSLDS.

Corrective Action for Audit Finding Background: We tested a sample of 25 students, 13 graduates and 12 withdrawals, for proper compliance with enrollment reporting requirements. We found that the enrollment reporting for the change in status of the 12 withdrawal students were completed within the appropriate timeframe and the withdrawal date per the NSLDS enrollment detail matched the withdrawal date per the student?s academic file. Of the 13 graduates tested, 11 of the students had completed their required courses as of their respective graduation dates and their status change dates were properly reported to the NSLDS. Of the 13 graduates tested, 2 of the students had not completed their required courses as of their standard graduation date; and although they had subsequently completed their test/work and were marked as graduated in the student?s academic file, the change in their statuses was not reported to the NSLDS within the 60-day timeframe. Audit Finding: The Citadel failed to timely report the students? status change in its reporting submission to the NSLDS. Corrective Actions: The Registrar's Office will submit degree files to the Clearinghouse every 30 days for 3 months after the end of the term to help ensure we are able to update the graduation status of student?s whose degrees are awarded after the graduation date. Members of the Registrar's Office will update the Clearinghouse for individuals by hand those students whose graduation takes place after the 3-month period. Keith Gauvin Registrar (843)953-6964 kgauvin@citadel.edu

Finding number: 2022-001 Federal agency: U.S. Department of Education Program: Student Financial Assistance Cluster AL #?s: 84.063, 84.268 Award year: 2022 Corrective Action Plan: Management concurs with audit finding 2022-001 and are planning the follow: 1. Four of the student statuses were linked to students with no earned credit in the Fall 2022 or Spring 2023 semester. Bunker Hill is re-evaluating the walk-away reporting process. In addition, the College will specifically monitor students in NSLDS who are viewed as a walk-away. 2. The one graduated student not reported was due to the student having a second active program. Students with double majors will now be reviewed separately during reporting. This will ensure students graduating from just one of their two majors are reported correctly. Timeline for Implementation of Corrective Action Plan: Effective immediately Contact Person Susan Martin, Registrar, Academic Records Jake Deehan, Business Analyst Melissa Holster, Executive Director of Student Financial Services

Finding 2022-001: Return of Title IV Funds Federal Program: Student Financial Assistance Cluster, Federal Direct Student Loan Program, Federal Pell Grant Program Federal Agency: U.S. Department of Education Pass-Through Entity: Not Applicable Assistance Listing Number: 84.268, 84.063 Federal Award Year: June 30, 2022 Corrective Action Taken The University?s Interim Financial Aid Director, Stephanie Schrift, has required all Student Financial Services staff to attend virtual trainings on the return of Title IV funds process in April 2023. In addition, Stephanie Schrift (Interim Director) will process all R2T4s via COD's calculator and Elizabeth Susick (Assistant Director) will verify and sign off on the calculations once complete. This will provide a two-step validation procedure for all R2T4 returns.

2022-002 Enrollment Status Reporting Recommendation: We recommend that the University review their enrollment reporting policies and procedures to ensure accurate reporting. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Reason for finding: Turnover with key personnel within the Registrar office. Action taken in response to finding: After significant turnover of the Registrar and staff, Piedmont University has a new experienced Registrar starting on November 14, 2022. The University is also in the process of filling the other vacancies within the department. Once the Registrar is in place, the National Student Clearinghouse data origination file will be reviewed to ensure that the correct program start and end dates are collected and reported to the NSC. A process for communicating program changes with effective dates will be implemented in collaboration with the financial aid office to ensure the consistency of reported dates to NSLDS Name(s) of the contact person(s) responsible for corrective action: Whitney Merinar Planned completion date for corrective action plan: June 30, 2023 If the U.S. Department of Education has questions regarding this plan, please call Brant Wright at 706-778-8500 ext.1457.

2022-001 Enrollment Roster Reporting Recommendation: We recommend that the University review their policies and procedures to ensure accurate reporting and responding to enrollment rosters disbursed to the University. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Reason for finding: Turnover with key personnel within the Registrar office Action taken in response to finding: After significant turnover of the Registrar and staff, Piedmont University has a new experienced Registrar starting on November 14, 2022. The University is also in the process of filling the other vacancies within the department. Once the Registrar is in place, she will work in collaboration with the offices of student accounts and financial aid, in crafting written procedures that determine consistent and appropriate changes in registration status and a procedure for determining the appropriate effective dates for changes in status. Further steps will be taken to confirm that registration status fields and effective dates entered in the SIS by the registrar's office align with the financial aid office's NSLDS report fields for affected students. Name(s) of the contact person(s) responsible for corrective action: Whitney Merinar Planned completion date for corrective action plan: June 30, 2023

Corrective Action Plan Year Ended June 30, 2022 Findings from the 2021-2022 Audit The Auditor's Report on Compliance for Each Major Program and on Internal Control over Compliance required by the Uniform Guidance noted one finding from the 2021-2022 audit: Finding 2022-001. 2022-001 Significant Deficiency: National Student Loan Data System (NSLDS) Report (U.S. Department of Education, William D. Ford Direct Loan Program, CFDA #84.268 and Federal Pell Grant Program, CFDA #84.063). The University reported the incorrect date to NSLDS for the withdrawal date. Name of Contact Person Management agrees with finding 2022-001. We acknowledge that the internal control over the details, procedures, communication, and language used in processing unofficial withdrawals needs to be strengthened to reduce the risk of errors. Kimberly Noe of Financial Aid, and Kathryn McCune, Registrar, are the responsible parties for the corrective action. Corrective Action Plan The prior corrective action plan was implemented and shown to be beneficial in reducing the number of errors in the enrollment reporting process. The plan proved to be effective in addressing the previous clerical errors surrounding official withdrawal dates. However, the University acknowledges the need to strengthen our procedures regarding unofficial withdrawal date reporting at the conclusion of each semester. The Registrar's Office and Financial Aid Office have determined the need for a supplemental enrollment reporting file after the end of each semester to automate the reporting of unofficial withdrawals. This additional file will lessen the number of manual corrections to withdrawal dates in NSLDS, thus increasing the level of accuracy in reporting. The date the supplemental enrollment reporting file should be processed after the conclusion of each term is by the 15th of the following month. The Financial Aid and Registrar's offices have identified additional reporting resources that will assist in the timely secondary review of the NSLDS data entered each semester to ensure compliance. The University of the Cumberlands will document the monthly secondary review of withdrawals and maintain our reconciliation records. The reconciliation process will be completed within 30 days of NSLDS certifying the submitted enrollment file. Anticipated Completion Date All records with errors noted during the 2021-2022 audit findings were corrected by October 13, 2022. The current Corrective Action Plan is anticipated to be fully implemented by January 31, 2023.

FINDING 2022-002 ? R2T4 Calculation Program Name: Federal Pell Grant ALN and Program Expenditures: 84.063 ($729,843) Award Number: P063P213629 Federal Award Year: July 1, 2021 to June 30, 2022 Questioned Costs: $1,988 Condition Found: The R2T4 calculation was completed incorrectly for three of the five students in our R2T4 testing sample. The Federal Pell Grant funds disbursed were not adjusted for module courses that the students did not begin. In addition, the incorrect semester start date was used for two of the three students. Corrective Action Plan: Management agrees with the auditors? finding and their recommendation. The Financial Aid Director recalculated the R2T4s for the students in question. The Financial Aid Director determined that $1,988 of Federal Pell Grant funds should be returned for these students. On September 12, 2022 these funds were returned to the Department of Education. The remaining R2T4 calculations completed by the College were reviewed and there were no additional errors. The Financial Aid Director has improved R2T4 calculation procedures to ensure that the Federal Pell Grant is adjusted for module courses that a student does not begin attendance in before completing the R2T4 calculation. Anticipated Completion Date: The corrective action was completed on September 12, 2022. Contact Person (for both findings): Brian Rains, Director of Financial Aid 417-268-6045

FINDING 2022-001 ? Verification Program Name: Federal Pell Grant ALN and Program Expenditures: 84.063 ($729,843) Award Number: P063P213629 Federal Award Year: July 1, 2021 to June 30, 2022 Questioned Costs: $1,000 Condition Found: The adjusted gross income was not updated to the amount reported on the tax return during the verification process for one of the forty students in our sample. Corrective Action Plan: Management agrees with the auditors? finding and their recommendation. The Financial Aid Director updated the adjusted gross income and recalculated the EFC and Federal Pell Grant award for the student in question. The Financial Aid Director determined that $1,000 of Federal Pell Grant funds should be returned for this student. On September 12, 2022, $1,000 of Federal Pell Grant funds was returned to the Department of Education. Anticipated Completion Date: The corrective action was completed on September 12, 2022.

Finding Number: 2022-1 Enrollment Reporting to NSLDS Planned Corrective Action: An existing report has been tweaked to include all potential SSN issues, and the Registrar?s Office will be retrained on how to use this report. Each time an enrollment report is submitted, this report will be reviewed to verify that no issues exist. Person Responsible for Corrective Action Plan: Kelly Vickers (Registrar) Anticipated Date of Completion: October 1, 2022

Finding Number: 2022-1 Untimely and Inaccurate Returns of Title IV Funds (R2T4) Planned Corrective Action: Timeliness: Upon the completion of the Fall 2021 term, the Director of Financial Aid became aware of a deficiency regarding the tracking of attendance for students enrolled in online courses due to the higher than usual number of students will All F grades due to non-attendance. Prior to the start of the Spring 2022 semester, the Director of Financial Aid, Registrar, and Dean of Distance Education met to discuss the issue and developed a plan to require all professors of online courses to report the names of students who were not submitting assignments in their courses. The Dean of Distance Education sends multiple email reminders to professors throughout the term, and members of the Distance Education Office perform periodic spot-checks of course data to ensure that professors are performing required duties. Accuracy: All financial aid staff are encouraged to participate in as many R2T4 training events as possible but are required to participate in at least three training events (one led by NASFAA, one led by ED, and one internal training event). Additionally, performing R2T4s will become the responsibility of the entire team beginning with the Fall 2022 semester. With more staff members calculating and reviewing the data, it is believed that the potential for human error will decrease. Person Responsible for Corrective Action Plan: Timeliness: Donovan Smith (Director of Financial Aid) Accuracy: Donovan Smith (Director of Financial Aid) Anticipated Date of Completion: Timeliness: Implemented prior to Spring 2022 semester and resulted in no findings of this nature for Spring 2022 Accuracy: Implemented beginning with the Fall 2022 semester and will be completed by the end of the Spring 2023 semester