Corrective Action Plans

2022-001: Errors Relating to Return of Title IV Financial Aid - Student Financial Aid Cluster Assistance Listing Number 84.007, 84.033, 84.038, 84.063, 84.268, 84.379 Grant Period - Year Ended May 31, 2022 Condition Found: During our return of Title IV Fund testing we noted that the College did not calculate or return Title IV for students who ceased attendance correctly for three students out of ten. The College used the incorrect number of days for the total days in the period of enrollment when calculating the return of Title IV. We consider this to be a significant deficiency relating to the Special Tests and Provisions Compliance Requirement. Corrective Action Plan: It was discovered during the audit that the term break dates for Spring 2021 had been entered incorrectly, this caused certain R2T4's performed to be incorrect. All the affected records were corrected and rather than increasing the students' loans, USF funds were used to fill the void created by the incorrect calculations. This mistake was completely human error and great care will be taken to ensure the break dates are correct in the beginning of performed R2T4 calculations for the beginning of Fall 2022 and beyond. Responsible Perform for Corrective Action Plan: Bruce Foote, Director of Financial Aid, University of St. Francis, Joliet, IL 60435 Implementation Data of Corrective Action Plan: The Corrective Action Plan has been implemented immediately.

2022-001 Incorrect Pell Disbursement - Student Financial Aid Cluster Assistance Listing Number 84.007, 84.033, 84.063, 84.268, Grant Period - Year Ended June 30, 2022 Condition Found: During our student file testing we noted one student out of forty had was not disbursed the correct Pell Grant award. Based on the student?s enrollment status and need, the College under awarded the student by $680. We consider this to be an instance of noncompliance relating to the Eligibility Compliance Requirement. Corrective Action Plan: In response to this finding, Oakton Community College had already updated the student's federal Pell grant award, disbursed the additional Pell to the student, and reported the subsequent adjustment to COD on May 4, 2022. The Financial Aid Manager also met with the financial aid advisors to share the finding. Responsible Person for Corrective Action Plan: Jamie Peterson, Manager of Student Financial Assistance Dr. Cheryl Warmann, Registrar/Director of Student Financial Support Implementation Date of Corrective Action Plan: May 4, 2022- Student Record Adjustment June 14, 2022 - Internal training with financial aid advisors

Finding 2022-02 ? Enrollment Reporting Recommendation: The University should revise its procedures to ensure accurate enrollment information is sent to the NSLDS within the required timeframe for all students and that notifications between departments are communicated timely. Action Taken: As of the date that this student withdrew, the Registrar's office was working with the Information Technology (IT) department to implement a process of receiving automatic email notifications when a student has been determined as withdrawn in the student management system (Colleague). At the beginning of calendar year 2022, these notifications were implemented and are now sent to the Registrar?s Office, Student Billing Office, Residence Life Office, and the Financial Aid Office, notifying them when a student is withdrawn from all of their courses. These notifications will now help mitigate the risk of untimely reporting. Additionally, the University has created a weekly report that is pulled by the Registrar?s Office to find students who are active but not enrolled or listed as on Leave Of Absence (LOA) but are not enrolled in a future class. Responsible Individual for Corrective Action: Registrar ? Joanna Raudenbush Anticipated Completion Date: June 30, 2022

Finding 2022-001: Gramm-Leach Bliley Act (GLBA) Recommendation: The University should perform and document an annual risk assessment to determine the University's specific risks relevant to protecting consumer nonpublic personal information. At a minimum, the University should have at least one risk statement aligned or referenced to each of the three required areas noted in the GLBA law at 16 CFR 314.4 (b). Finally, the University should identify and document at least one safeguard (i.e., control) for each of the risks identified and document in the risk assessment. Each control should be aligned or referenced to the risk(s) to which the safeguard applies. Action Taken: The University has taken the following steps to address the risks identified during the audit: 1. Employee Training and Management a. The University deployed the Knowbe4 Security Awareness Program to all full time staff. The program provides training for managing user data and email messages. To date the University has distributed two campaigns to combat email phishing attempts. 2. Information systems, including network and software design, as well as information processing, storage, transmission and disposal a. The University has formulated a digital transformation strategy to reduce on premises systems and applications. All the critical business systems are hosted at a colocation or are SaaS solutions. b. The University performs backups of all on premises systems using technology that creates immutable storage. c. The University leverages the cybersecurity experience of resellers and manufacturers to ensure all core network technology is installed and configured to minimize any attack surface. 3. Detecting, preventing, and responding to attacks, intrusions, or other systems failures and document safeguards for identified risks as required by the Gramm-Leach Bliley Act (GLBA). a. The University has deployed a redundant pair of Fortinet Advanced Firewalls to monitor and block traffic with suspicious payloads. b. The University has updated to the latest version of Microsoft Advanced Threat Defender to serve as optimal end point protection for managing email traffic. c. The University contracted with the Cybersecurity and Infrastructure Security Agency (CISA) to perform vulnerability scans and penetration testing. The IT department evaluates the weekly reports and remediates highlighted deficiencies. d. The University has removed all admin rights from school managed computers, eliminating the ability to install local software. e. The University has deployed an updated VPN client to all school managed computers providing a secure tunnel for access network services. f. The University manages web browsers of all school managed computers. The University will take the results of the security assessment that was completed and draft the GLBA policy in conformity with the DOE requirements by June 2023. Responsible Individual for Corrective Action: Chief Information Officer ? Gregg Chottiner Anticipated Completion Date: June 30, 2023

Finding 2022-003 Issue: The University utilizes an automated notification system to send an email message to students when federal loans are disbursed. The message includes (1) the date and amount of the disbursement; (2) the student's right, or parent's right, to cancel all or a portion of that loan or loan disbursement and have the loan proceeds returned; and (3) the procedure and time by which the student or parent must notify the institution that he or she wishes to cancel the loan. However, as a result of a technical issue the automated notification system stopped working in September, 2021. Corrective Action: As of March 10, 2023, the University corrected the technical system scripts that failed approximately 19 months ago; as a result, students are once again receiving automated email notifications when federal aid is posted to their accounts. Responsibility: Director, Student Accounts Contact: Dayna Tinkey, Director, Student Accounts

Finding 2022-002 Issue: The University completed a Return to Title IV (R2T4) worksheet and returned more unearned aid than the school was responsible for per the calculation. The R2T4 calculation and return of funds was completed in a timely fashion but the amount of unearned Direct PLUS Loan funds was not properly scheduled by the counselor. Program closeout for the year has been completed and no adjustment can be made to reclaim funds at this time. While no financial liability has fallen upon the student or parent borrower the Financial Aid Office agrees with the finding of inaccuracy. Corrective Action: The University began implementation of an enhanced procedure for Return to Title IV calculations beginning with Fall 2022 semester and includes a detailed review of all calculations to ensure compliance & accuracy. Responsibility: Identification & evaluation of students will be completed by office staff and reviewed by the Director of Financial Aid. Contact: Robert Clemens, Director of Financial Aid

Finding 2022-001 Issue: The University did not notify the National Student Loan Data System (NSLDS) in a timely manner for 1 student with status changes of Graduated. The student in question graduated in December 2021. Per the assistant registrar, the degree verify files for both undergraduate and graduate students for December 2021 graduates were uploaded to the National Student Clearinghouse on 1/7/2022. It appears that the undergraduate file was processed by the graduate student file was not. We receive processing confirmations from the Clearinghouse, but when files are submitted in multiples, only one confirmation is received for all files, not separate confirmation. Corrective Action: The assistant registrar has been in communication with the National Student Clearinghouse regarding the missed file. The upload has been resolved. Going forward, the assistant registrar will submit each file separately to receive separate confirmations, and personally verify posting. Responsibility: Degree Verify reporting is uploaded by the Assistant Registrar. Contact: Katie Elverson, Registrar Issue: The University did not notify the National Student Loan Data System (NSLDS) in a timely manner for 2 students that changed enrollment status mid-semester. The students in question enrolled in fall 2021 classes full-time and was reported as full-time in the initial enrollment report They withdrew from all classes on 9/15/2023 and 10/21/2021, respectively. In the enrollment reports following their withdrawal, the students were reported as less-than half-time, rather than withdrawn. Students were reported as withdrawn following the end of the term. These reports with statuses are pulled by the student information system, so this seems to have been an issue with the SIS; they are spot checked, but all rows cannot be manually checked and verified before submission. Corrective Action: Upon notification of this issue, I began to investigate the original data report that was pulled out of CX (our SIS) to determine where the error was coming from Upon viewing the Fall 2021 data for the students, I saw that after their withdrawal they were reported as enrolled in zero credits, however they were also being classified in the report from CX as 'less than half time.' I immediately contacted Jenzabar (our SIS vendor) to inquire as to why the system would be calculating a zero-credit enrollment as 'less than half time.' They quickly responded and showed me how to adjust tables within CX that determine how student statuses are completed. Information in the tables was incomplete regarding students who withdraw midsemester. Bringing this to our attention enabled us to implement a corrective solution. Unfortunately, this solution will not be seen on enrollment reports until March 2023. Responsibility: Enrollment reporting is uploaded by the Registrar. Contact: Katie Elverson, Registrar

2022-001 - Student Financial Aid Cluster - (a) Federal Supplemental Educational Opportunity Grants (b) Federal Work Study Program (c) Federal Perkins Loan Program - Federal Capital Contributions (d) Federal Pell Grant Program (e) Federal Direct Student Loans (f) Teacher Education Assistance for College and Higher Education (TEACH), Assistance Listing No. (a) 84.007 (b) 84.033 (c) 84.038 (d) 84.063 (e) 84.268 (f) 84.379 - Year Ended June 30, 2022. Condition: We tested 40 files, 18 of which were Pell Grant recipients, and 2 students did not receive the full amount of their allowed Pell grants. The students were eligible for $65,480, but received $64,930. For one student, this condition was caused by using the 20-21 Pell Award Chart for a 21-22 Pell Award. For the other student, this condition was caused by using the College's institutional EFC instead of the student's EFC noted on their FAFSA. Management Response: We accept this finding and immediately filed a correction with the Federal Pell Grant Program when the discrepancy was discovered during fieldwork. The affected students had no adverse impact with this issue as the incorrect Pell award was initially offset by increased Knox College aid. Corrective Action Plan: The college will devote additional attention to awarding the Federal Pell Grants. Prior to disbursement, a report of all Title IV recipients will be reviewed with the amount of Federal Pell grant the recipient receiving. A manual review will occur to ensure that the accurate Federal Pell Grant amount is correct based on the Expected Family Contribution and Cost of Attendance. Responsible Person: Alexander Guroff, CFO Implementation Date: January 23, 2023

Name of Responsible Individual: Cinnamon Bradley, Associate Dean of Student Affairs Corrective Action: We concur. We understand that student status changes must be reported to our third-party servicer NSLDS within 30 days of the student?s enrollment change. In some cases, the student?s status change did not occur timely. We will review our system parameters and reporting to ensure timely notification of the student enrollment status changes. Additionally, we will automate manual processes related to enrollment change notifications to ensure timely notification of the student?s status change to the Registrar?s Office. Anticipated Completion Date: January 31, 2023

U.S. Department of Education Alcorn State University (ASU), Delta State University (DSU), and Mississippi University for Women (MUW) respectfully submit the following corrective action plans for the year ended June 30, 2022. Audit period: July 1, 2021 ? June 30, 2022 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?FEDERAL AWARD PROGRAMS AUDITS 2022-010: NSLDS Enrollment Reporting (ASU) Student Financial Assistance cluster - Assistance Listing No. 84.007, 84.033, 84.063, 84.268 Recommendation: We recommend the applicable institutions review its reporting procedures to ensure that students' statuses are accurately and timely 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: Effective Fall 2022, we began reporting enrollment twice a month to the National Student Clearinghouse. This eliminates any inaccuracies and oversights for timely enrollment reporting. Any additional enrollment reporting errors will be corrected directly in NSLDS. Name of contact person responsible for corrective action: Kisha Bond, Registrar and Director of Student Records Planned completion date for corrective action plan is June 30, 2023 If the Department of Education has any questions regarding this plan, please contact Juanita Edwards at 601-877-6672. 2022-010: NSLDS Enrollment Reporting (DSU) Student Financial Assistance cluster - Assistance Listing No. 84.007, 84.033, 84.063, 84.268 Recommendation: We recommend the applicable institutions review its reporting procedures to ensure that students' statuses are accurately and timely 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: The Office of Financial Aid will work with the Registrar's Office to verify each student's last date of attendance is entered in Banner to ensure accurate and timely reporting. Name of contact person responsible for corrective action: Megan Smith Planned completion date for corrective action plan is June 30, 2023. If the Department of Education has any questions regarding this plan, please contact Megan Smith at 662-846-4670. 2022-010: NSLDS Enrollment Reporting (MUW) Student Financial Assistance cluster - Assistance Listing No. 84.007, 84.033, 84.063, 84.268 Recommendation: We recommend the applicable institutions review its reporting procedures to ensure that students' statuses are accurately and timely 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: The Office of the Registrar will coordinate with the Information Technology Services department to ensure files are submitted by the due date. Name of contact person responsible for corrective action: Shannon Lucius, Registrar Planned completion date for corrective action plan is June 1, 2023. If the Department of Education has any questions regarding this plan, please contact Nicole Patrick at 662-329-7114.

U.S. Department of Education Alcorn State University (ASU), Jackson State University (JSU), Mississippi Valley State University (MVSU) and Mississippi University for Women (MUW) respectfully submit the following corrective action plans for the year ended June 30, 2022. Audit period: July 1, 2021 ? June 30, 2022 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?FEDERAL AWARD PROGRAMS AUDITS 2022-009: NSLDS Error Reporting (ASU) Student Financial Assistance cluster - Assistance Listing No. 84.007, 84.033, 84.063, 84.268 Recommendation: We recommend the applicable institutions review their reporting procedures to ensure that students' statuses are accurately and timely reported to NSLDS and the requisite response to error records occurs within the 10-day time period. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Effective Fall 2022, we began reporting enrollment twice a month to the National Student Clearinghouse. This eliminates any inaccuracies and oversights for timely enrollment reporting. Any additional enrollment reporting errors will be corercted directly in NSLDS. Name of contact person responsible for corrective action: Kisha Bond, Registrar and Director of Student Records Planned completion date for corrective action plan is June 30, 2023. If the Department of Education has any questions regarding this plan, please contact Juanita Edwards at 601-877-6672. 2022-009: NSLDS Error Reporting (JSU) Student Financial Assistance cluster - Assistance Listing No. 84.007, 84.033, 84.063, 84.268, 84.379 Recommendation: We recommend the applicable institutions review their reporting procedures to ensure that students' statuses are accurately and timely reported to NSLDS and the requisite response to error records occurs within the 10-day time period. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Jackson State has an established and published academic calendar which guides the day-to-day academic operations and functions of the University. In some instances, the census and financial purge deadlines are extended to ensure students complete their registration requirements. When extensions are provided, the enrollment file is unable to be submitted timely and also causes delays in processing the error report. To alleviate the untimely submission of the enrollment report, different practices have been established to aid students in completing their registration before the published deadline and subsequently ensuring the enrollment file is submitted by the deadline. Name of contact person responsible for corrective action: Ozie Ratcliff Planned completion date for corrective action plan is June 30, 2023. If the Department of Education has questions regarding this plan, please call Ozie at 601-979-3347. 2022-009: NSLDS Error Reporting (MVSU) Student Financial Assistance cluster - Assistance Listing No. 84.007, 84.033, 84.063, 84.268 Recommendation: We recommend the applicable institutions review their reporting procedures to ensure that students' statuses are accurately and timely reported to NSLDS and the requisite response to error records occurs within the 10-day time period. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Office of Student Records/University Registrar will closely monitor all errors received from the National Student Clearinghouse and correct them within the 10-day timeframe. For errors related to system updates and etc., the Office of Student Records/University Registrar will collaborate with the Department of Information Technology in an effort to correct the issues in a timely manner. This will allow submission of the error reports to be timelier. Additionally, the Office of Student Records/University Registrar will strengthen communication with the NSCH relative to technical issues online which may hinder the timeliness of submitting error reports. Lastly, our office will coordinate the collaboration between our Information Technology Team and the Technical Team of NSCH to resolve any technical issues forthcoming. Name of contact person responsible for corrective action: Jeffery Loggins, University Registrar Planned completion date for corrective action plan is April 13, 2023 If the Department of Education has questions regarding this plan, please call Deborah Banks at 662-254-3335 2022-009: NSLDS Error Reporting (MUW) Student Financial Assistance cluster - Assistance Listing No. 84.007, 84.033, 84.038, 84.063, 84.268 Recommendation: We recommend the applicable institutions review their reporting procedures to ensure that students' statuses are accurately and timely reported to NSLDS and the requisite response to error records occurs within the 10-day time period. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: A staff member has been designated to correct errors within the 10-day time period. Name of contact person responsible for corrective action: Shannon Lucius, Registrar Planned completion date for corrective action plan is June 1, 2023. If the Department of Education has questions regarding this plan, please call Shannon at 662-329-7135.

U.S. Department of Education Mississippi Valley State University (MVSU) respectfully submits the following corrective action plan for the year ended June 30, 2022. Audit period: July 1, 2021 ? June 30, 2022 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?FEDERAL AWARD PROGRAMS AUDITS 2022-008: Gramm-Leach-Bliley Act (MVSU) Student Financial Assistance cluster - Assistance Listing No. 84.007, 84.033, 84.038, 84.063, 84.268 Recommendation: For those institutions noncompliant with requirements, CLA recommends that the institution needs to complete all areas. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Office of Financial Aid stores all student files in a locked file room. There are only two keys to gain access which is held by the director and the associate director. The file room remains locked at all times unless a request is made by a counselor or if the director or associate director needs to obtain a file. All financial aid personnel have been trained to initiate the following processes - lock computer screens when leaving their area for a short period of time, if gone for an extended time frame the computer is locked and the financial aid representative's office door is locked. Financial aid documents are electronic and exist in the institution's software module. Name of contact person responsible for corrective action: Deborah Banks, Interim Director of Financial Aid Planned completion date for corrective action plan is April 13, 2023. If the Department of Education has questions regarding this plan, please call Deborah Banks at 662-254-3335.

The district will implement stricter procedures to ensure all expenditure reports are filed within the 20 day period after the quarter ends. To ensure this happens, the district will create calendar reminders and a system of checks and balances. See full Corrective Action Plan on the district letterhead.

Finding 2022-003 Federal Agency Name: U.S. Department of Education Program Name: Student Financial Assistance Cluster CFDA #: 84.063, 84.007, 84.268, 84.033 Finding Summary: Due to the changeover in software in the current year, the College did not have an internal control process in place to provide for an independent review over the return of Title IV calculations. Responsible Individuals: Frankie Everett, Director of Financial Aid Corrective Action Plan: The department will assign an individual to randomly sample 30% of the R2T4?s each term, documenting the results and ensuring the system is calculating and reporting these accurately throughout the year. Anticipated Completion Date: January 15, 2022

Condition: One of the 40 student files examined, we noted the students (2.5%) were not properly awarded Subsidized Direct loans. Corrective Action Plan: The financial aid office will implement a process of review of reallocation of federal financial aid funds at the time of notification from a student of the ineligibility of outside awards. Responsible Person for Corrective Action Plan: Becky Whithaus, Director of Financial Aid. Implementation Date for Corrective Action Plan: 1/2/2023.

202 Flex Subsidy Assistance Loan ? Assistance Listing No. 14.157 Replacement Reserve Deposits: Per the regulatory agreement a monthly deposit is to be made into the replacement reserve. Per HUD-9250, starting January 1, 2022 that monthly amount is $4,343.50 which equates to an annual deposit of $52,122. The replacement reserve was underfunded $1,122 at December 31, 2022. Recommendation: Recommend that a catch-up payment is made as soon as possible to make the replacement reserve whole. There is no disagreement with the audit finding. Action taken in response to finding: Management made the additional $1,122 deposit on February 24, 2023. Name of the contact person responsible for corrective action: Lisa Gindt Planned completion date for corrective action plan: February 24, 2023.

2022-001: Missing Exit Counseling Documentation - Student Financial Aid Cluster - Assistance Listing #s 84.033, 84.007, 84.063, 84.268, 84.038 - Grant Period - Year Ended August 31, 2022 Condition: During our student file testing, we noted one student out of 40 did not have documentation in their file that exit counseling was sent thirty days after the student withdrew. We consider the missing exit counseling to be an instance of non-compliance with the Eligibility Compliance Requirement. Corrective Action Plan: Our office has updated the document letter template to automatically input the date of creation. The office will also ensure that the letters are generated promptly when informed of student withdrawal. The office will also periodically review withdrawn students to verify exit notification was sent. Responsible Person for Corrective Action Plan: Director- Marc Yambao Assistant Director- Josie Extrom Implementation Date of Corrective Action Plan: 10/27/2022

Federal Student Aid - Corrective Action Plan Date written: 01/05/2023 Finding: Notification of Right to Cancel Direct Loans The Fiscal 2022 audit identified insufficient communication regarding borrowers' rights to cancel Direct Loans. Schools are required to notify borrowers in writing within 30 days of loan disbursement regarding their right to cancel the loan. NBSS agrees that these communications were insufficient to meet the requirement. Existing student account procedures already ensure that every borrower receives an account statement within 30 days of any Direct Loan disbursement. As such, NBSS has added the following statement which will appear on every account statement procedures from its billing software. "Federal Direct Loan recipients can cancel all or a portion of a loan within 30 days of disbursement date." This statement was added to the account statement template within the billing software on 12/01/2022. All statements produced after 12/01/2022 are in compliance with this requirement. The Direct of Finance is responsible for all student account procedures. Any questions regarding this matter should be directed to: Director of Finance Levi Barrett lbarrett@nbss.edu 617-227-0155 X 150

Finding 2022-001 ? Special Tests and Provisions ? Enrollment Reporting (Student Financial Assistance Cluster) Contact Persons: Diana Dimas, Registrar?s Office Cristen Alecia, Office of Financial Assistance Current Status: Correction of this finding is in-progress. Anticipated Completion Date: December 31, 2023 Condition: The University of the Incarnate Word did not accurately or timely report student status changes to the NSLDS for 6 out of 60 students selected for testing. Identification of Repeat Finding: 2021-001, 2020-001, 2019-002 While the condition reported above is considered a repeat finding, it is important to note that the errors are different this year and that these findings are not a reflection of the university ignoring previous findings or failing to make changes, but rather a reflection of the complexity of enrollment reporting. There were no inaccurate or untimely attendance level changes, and the official withdrawals were reported accurately and timely. In this year?s errors, we had a student who graduated outside of a normal conferral date, causing them not to be reported during our normal degree conferral report to NSC. The Registrar?s Office is putting changes in place to either eliminate out-of-cycle conferrals, or increase the number of conferral and reporting dates to effectively capture all graduates. We know that only 6 students were caught up in this out-of-cycle graduation, as it was a specific exception for the School of Osteopathic Medicine, and is not a wide-spread issue. We had two unofficial withdrawals reported later than 60 days ? at 69 and 70 days. While the withdrawal and the changes were processed timely, the timing of the roster from NSLDS compared to the submission to NSC caused the report not to be acknowledged until after the 60 days had passed. The Office of Financial Assistance is researching the option of manually reporting unofficial withdrawals outside of the monthly reporting cycle in order to eliminate this problem. The Registrar?s Office will review the roster and NSC submission schedules to see if changes need to be made in order to better align reporting dates. We had three students inaccurately reported as withdrawn for the summer semester. These students were at least half-time in the preceding Spring and the following Fall, and therefore were not required to be reported as withdrawn. The Office of Financial Assistance and the Registrar?s Office will work together to research options in Banner and with NSC. It may be necessary to create a separate withdrawal code to identify summer withdrawals that should not be reported as withdrawn, and create a report to monitor the fall enrollment for these students in case they later withdraw from Fall and transition to a withdrawal which must be reported. The Banner system alone does not allow for the complicated logic mandated for summer reporting in the NSLDS Enrollment Reporting Guide. Our offices will continue to work in partnership to resolve these enrollment reporting issues. Cristen Alicea Director Office of Financial Assistance 210.805.1238 gimenez@uiwtx.ed www.uiw.edu/finaid Diana Dimas Associate Registrar Registration and Technology Office of the Registrar 210.832.5484 dimasd@uiwtx.edu www.uiw.edu

Instructors will do a better job communicating to the Registrar of student course drops and reporting LDAs. The Registrar has implemented a review of all data to ensure it is correct moving forward. Our third-party financial aid processer, FAME, has agreed to review all r2T4 forms going forward for accuracy.

Finding No. 2022-002 Enrollment reporting Cluster: Student Financial Assistance Cluster Grantor: Department of Education Award Name: Federal Direct Student Loans Award Year: July 1, 2021 ? June 30, 2022 Award Number: Not applicable Assistance Listing Number: 84.268 The College agrees with the finding noting that this exception is an unusual occurrence as a result of improper recording of the leave status in Colleague, the student information system. The record in Colleague should have had hiatus data entered on April 11, 2022, the date in which the College was aware of the student?s enrollment change, which would allow the change in enrollment information to be queried and transmitted to the National Student Clearinghouse (?NSC?) in in the May 17, 2022 submission. As this hiatus data was not updated, the student?s enrollment record was reported as enrolled at that time, which is attributed to an error in data entry of the multiple fields required in Colleague to reflect a leave from the College. The student?s transcript was correctly marked as ?W? as of April 8, 2022. However, the effective date was not correctly reported to the NSLDS. Management is in the process of correcting the effective date reporting to the NSLDS. The College has since implemented Workday Student, the College?s new student information system, in August of 2022. New business processes for entering student leaves have been documented and staff have been trained. The Office of Student Affairs initiates the leave process and a system process prompts records, financial aid, and billing to review the student record. The leave is updated within the student information system once all of the relevant offices have completed their processing. Training was done as a part of the implementation and testing process. The NSC enrollment reporting in Workday is automated. Jesse Barba, Director of Institutional Research and Registrar Services, is responsible for the implemented corrective action plan.

Finding No. 2022-001: Review of Return of Title IV Funds calculation Cluster: Student Financial Assistance Cluster Grantor: Department of Education Award Names: Federal Pell Grant Program, Federal Supplemental Educational Opportunity Grants, Federal Direct Student Loans Award Year: July 1, 2021 ? June 30, 2022 Award Number: Not applicable Assistance Listing Numbers: 84.063, 84.007, 84.268 The College agrees with the finding noting that a business control process was in place for a review of all Return of Title IV aid calculations, however, the College did not retain documentation evidencing this review. The College confirmed none of the Return of Title IV aid calculations selected had errors and the control was working as it was designed. The control is taken seriously and both training and oversight of personnel performing return of title IV calculations is exercised. As of March 31, 2023, the review will be noted on the change sheet at the time of award revision with the signature stamp in Perceptive Content (imaging and workflow software). Gail Holt, Dean of Financial Aid is responsible for implementing this corrective action plan.

Individuals Responsible for Corrective Action Plan: Eileen F. Doyle, Associate Vice President of Student Financial Services, (914) 633-2483 Corrective Action Plan: In this instance, there was a manual intervention which caused a loan to credit to the student account. A decision was made to leave the credit but not refund as a motivation for the student to complete the required Entrance Counseling. The student subsequently completed the Entrance Counseling when the loan credit was reversed. As soon as the Entrance Counseling was completed the loan was recredited and the refund was processed within the appropriate timeframe. The individual who made the decision to not refund is no longer with the University. Staff have been trained that, unless the borrower has completed all requirements, loans cannot be credited to an account and the ?do not refund? option is not an appropriate tool in such an instance. Anticipated Completion Date: Completed.

Individuals Responsible for Corrective Action Plan: Eileen F. Doyle, Associate Vice President of Student Financial Services, (914) 633-2483 DJ Arndt, Registrar, (914) 633-2520 Corrective Action Plan: Iona University?s Registrar?s office updated the Holiday Calendar schedules in PeopleSoft, the Student Information System, to ensure that institutionally scheduled breaks of 5 or more consecutive days are properly reflecting weekend days. These updates will be used to accurately calculate the percent of a term attended and federal aid earned for federal aid recipients who withdraw from the University during a term as part of the Return to Title IV aid mandatory calculations. The calendar entries will be made by the Associate Registrar and reviewed and approved by the Registrar during the academic year set up process each academic year. Anticipated Completion Date: Completed.

Emmanuel College Audit Response Finding number 2022-001 from the 2022 audit has been copied below with the management response and corrective action plan provided. EMMANUEL COLLEGE SCHEDULE OF FINDINGS AND QUESTIONED COSTS JUNE 30, 2022 Condition: Out of a sample of 108 students there were 20 who withdrew. We decided to test all 20 of those students as it related to return of Title IV funds. Return of funds were sent in by the required date except for two instances. One was late due to the Thanksgiving Holiday. The school was closed on that Thursday and Friday, so the funds were not submitted until the following Monday. This was not a big deal; however, the other instance was simply late by 4 days and no Holidays were involved. Cause: Simply an oversight in which the date simply slipped by them. Effect: The Department of Education received the transferred return of funds 4 days later than they were required to be deposited into the SFA account. Recommendation: College management should design and implement procedures to ensure that there are checks and balances to make sure that when a student withdraws and the return of funds are calculated that the required return date is flagged and sent to whomever is responsible for submitting those funds to the SFA account. Management Response and Corrective Action Plan: Financial Aid personnel will utilize a built in Return to Title IV funds feature of the financial aid software, PowerFaids, to function as a quality assurance measure for Accounting Office staff. The PowerFaids function archives the date of withdrawal and calculates the deadline for return of funds. This feature will allow for quality assurance reports to be pulled no less than a week before the deadline so that Financial Aid staff can serve as an accountability partner for accounting staff in ensuring funds are returned in a timely fashion and in compliance with all federal guidelines. Contact Responsible for Corrective Action: Donna Quick, Vice President for Enrollment, 706-245-2872