Corrective Action Plans

Finding 2023-002 – Short-Term Program Completion and Placement Rates Condition The College did not achieve the required 70% completion rate for a short-term program. The College cannot demonstrate compliance with the gainful employment placement rate calculation for a short-term program. Cause The financial aid office did not follow-up on the gainful employment of students. Corrective Action Taken or Planned The Financial Aid Office will work with campus leadership and staff to ensure an accurate reporting process is in place to track gainful employment and completion. Documentation will be required by campus leadership to show communication efforts for students. Contact Person: Tiffany Morrison, Associate Vice Chancellor, Financial Aid Anticipated Completion Date: December 31, 2023

Finding 2023-001 – Enrollment Reporting Condition For four out of sixty students tested (7%) who withdrew from City Colleges, the students’ withdrawal date reported to the National Student Loan Data System (NSLDS) for campus level and program level did not match the institution’s records. Cause The financial aid office does not have an effective system in place to ensure all official student status changes are reported to the lender accurately. Corrective Action Taken or Planned City Colleges sends enrollment files of all students to the National Student Clearinghouse monthly, who then reports CCC enrollment data to NSLDS. City Colleges (Records, Financial Aid, Decision Support and the Office of Information Technology) continues to meet bi-weekly to review and update the enrollment reporting logic to ensure the dates for student enrollment actions align at the campus level and the program level. Contact Person: Laura Clark, Associate Vice Chancellor, Academic Systems and Tiffany Morrison, Associate Vice Chancellor, Financial Aid. Anticipated Completion Date: May 1, 2024

The School returned the $2,585.50 in question to the Department of Education on September 6, 2023. Communication will be improved between the various offices on campus. Policies and procedures are being reviewed and updated, as needed, for the students participating in on-line courses. Anticipated Completion Date: The corrective action was completed on September 6, 2023. Contact Person Valorie Quesenberry, Financial Aid Coordinator 513-763-6659

The credit balances were returned to the students in question before the end of the academic year. The financial aid office will follow-up with the cashier to ensure that, in the absence of a signed authorization to hold credit balances authorization, the credit balance refunds requested are processed timely. Anticipated Completion Date: The corrective action was completed in May 2023. Contact Person Valorie Quesenberry, Financial Aid Coordinator 513-763-6659

Management agrees with the auditors’ finding. Federal Pell Grant funds are entitlement funds and cannot be returned. The student in question also worked the hours in which Federal Work Study funds were awarded. Going forward, the School has made changes to the provisions of the institutional scholarship to avoid overawards. All state and federal aid and endowed scholarships are applied first and then the scholarship covers the remaining tuition cost. The corrective action was completed in September 2023. Contact Person Valorie Quesenberry, Financial Aid Coordinator 513-763-6659

Federal Direct Loan exit interview information was sent to the student in question on October 27, 2023. Procedures will be improved to ensure Federal Direct Loan exit interviews are completed or information is sent to students when they drop below a half-time enrollment status at the School. Anticipated Completion Date: The corrective action was completed on October 27, 2023 Contact Person Valorie Quesenberry, Financial Aid Coordinator 513-763-6659

Regarding finding 2023-002, Due to costs associated with full and immediate implementation, The College use a phased approach and will continue to make progress of meeting the federal standards related to the GLBA security program. The college expects to at minimum 80% in compliance by the end of FY24 and in full compliance by the end of FY25. The college will prioritize key elements such as reviewing access controls, implementing multi-factor authentication for the campus, disposing of student information securely, performing annual penetration testing, and encrypting all the institution's information. ECD: June 30, 2026. Action Officer: Mr. Scott Merritt, Director of Information and Technology & CIO.

Regarding finding 2023-001, The Financial Aid Director will no longer enter the dates of semesters/sessions in the Banner ERP system. The Registrar will assume responsibility for this task and work in conjunction with directors of Financial Aid and the MBA program to ensure term dates are established when needed and accurately maintained. ECD: Effective immediately. Action Officer: Dr. Lolita Rogers, Registrar.

The College agrees that Enrollment Reporting should be submitted in a timely manner. The College is actively working with the new SIS to ensure the ability to be able to produce the reports.

2023-001 Incorrect Direct Loans Disbursement Amount - Student Financial Aid Cluster Assistance Listing Number 84.007, 84.033, 84.063, 84.268, Grant Period - Year Ended June 30, 2023 Condition Found During our student file testing we noted one student out of forty was disbursed the incorrect Direct Loan amount. Based on the student’s enrollment status and need this student was eligible for $1,750 in Subsidized Loans and $1,000 in Unsubsidized Loans; however, the College awarded the student $1,750 in Subsidized loans and $1,250 in Unsubsidized loans which resulted in an over award of $250 in Unsubsidized Loans. We consider this error in awarding to be an instance of noncompliance of the Eligibility Compliance Requirement. Corrective Action Plan During the audit for the year ending Jun 30, 2023, the financial aid office reviewed the finding and was able to refund the over-award of $250 in Unsub within the student’s loan period. Since the finding our Financial Aid Coordinator completed additional trainings related to the administration of Financial Aid. Within these trainings, successful completion of loan processing training was required. As of May 12, 2023, our Financial Aid Coordinator is a certified Financial Aid Administrator through the National Association of Financial Aid Administrators. Responsible Person for Corrective Action Plan Gregory Putra, Director of Financial Aid & Veterans Affairs Implementation Date of Corrective Action Plan 7/1/2023

Name of Responsible Individual: Brian K. Blackburn, Director of Financial Aid Corrective Action: An automated batch email process has been updated to ensure that all loan disbursement notifications will be sent the same day as the loans are disbursed. In addition to the automation, calendar reminders have been set for all scheduled disbursement days. It will be the duty of the Director to ensure the process is successful and would only fall to the Assistant Director in times that the Director is unavailable. Anticipated Completion Date: November 9, 2023

Name of Responsible Individual: Terri Grice, University Registrar Corrective Action: The Registrar’s Office is continuously cross-training all team members so duties are cross-checked, shared by at least two team members, and completed in a timely manner. The reports used by this office will be reviewed on a frequent basis to ensure information is being reported as it was intended. The team will also meet with other departments on a frequent basis to ensure information is shared in a timely manner and continue to train on the regulations and policies between our institution, Clearinghouse, and NSLDS to ensure accurate reporting of information. Anticipated Completion Date: February 23, 2024

Name of Responsible Individual: Brian K. Blackburn, Director of Financial Aid Corrective Action: The University has implemented a weekly COD maintenance file update that will report any change activity to a student’s COD funds. This process is ensured to take place by ongoing calendar reminders as well as progress checks between the Director and Assistant Director. Anticipated Completion Date: November 6, 2023

FINDING 2023-004 Name of Responsible Individual: Brian K. Blackburn, Director of Financial Aid Corrective Action: The link has been submitted to the Department of Education. Anticipated Completion Date: November 16, 2023

Responsible Individual: Eric Gumm Registrar and Director of the First-Year Program and Academic Development Center Abilene Christian University Finding 2023-001 concerning Enrollment Reporting Agency Name: U.S. Department of Education Program Name: Federal Pell Grant, Federal Direct Student Loans October 13, 2023 Finding Summary: Enrollment Reporting (34 CFR 690.93(b)(2); 34 CFR 682.610; 34 CFR 685.309) Institutions are required to report enrollment information. The University’s processes did not ensure timely and accurate student status reporting to National Student Loan Data System (NSLDS). Out of the population of 1,079 students with student attendance changes required to be reported prior to July 19, 2022 or after February 28, 2023, a sample of 25 students were selected for testing. The University reported the incorrect Program Enrollment Effective Date for 10 students and did not timely report a status change for one student. Corrective Action Plan (CAP): After review, the University acknowledges and understands the findings associated with the reporting date of enrollment changes. ACU's official policy regarding recording the effective date of a status change is to designate the date reflected in the SFAREGS screen in Banner as the official date of determination. This is the date that will be reported to NSLDS for any student status changes. Anticipated Completion Date: Within the Fall semester, the University Registrar’s Office will implement sole use of the dates as shown in our Banner mainframe system’s SFAREGS screen for reporting enrollment statuses. This will afford the consistency of dates needed.

Responsible Individual: Thomas Ratliff Director of Student Financial Services Abilene Christian University Finding 2023-002 concerning Return of Title IV Funds Agency Name: U.S. Department of Education Program Name: Federal Pell Grant, Federal Direct Student Loans, Federal Supplemental Educational Opportunity Grants, Federal Work Study Program, Teacher Education Assistance for College and Higher Education Grants October 13, 2023 Finding Summary: Return of Title IV Funds (34 CFR 668.173(b); 34 CFR 668.22€; 34 CFR 668.22(g) and 34 CFR 668.22(i) note that federal regulations state that the return of Title IV funds must be made in the proper amount and in a timely manner as well as apply the return of Title IV funds to federal programs as required. The University’s processes did not ensure the days in the semester were consistently calculated correctly to calculate the return of Title IV funds correctly. Out of the population of 266 students that withdrew during the year, 25 students were tested. Nine instances were noted in which the total days in the semester were not calculated correctly which resulted in the calculation of an incorrect refund amount. Corrective Action Plan (CAP): After review, the university agrees that the students identified had an incorrect number of days included in their Return of Title IV Aid calculations. There was an error in two of our standard academic calendars used for processing these calculations. The university has since manually reviewed every academic calendar for the 2023-2024 academic year to ensure all academic calendars are completely accurate for each possible enrollment variation. The Director of Student Financial Services reviewed these along with each individual who is responsible for processing Return of Title IV Aid calculations, so as to ensure all parties are in complete agreement about the calendar dates. Anticipated Completion Date: Our new manual confirmation assurance has been implemented for 2023-2024. Calendar reminders have been set for each semester of the coming years to ensure the calendars are reviewed again just before the terms begin, to ensure accuracy at the point that calculations are to start for new enrollment periods. We believe this finding will not be repeated due to our enhanced diligence.

Finding 2023-001 A. Comments on Findings and Recommendations: We agree with the finding and recommendation. B. Actions Taken or Planned: The Institution has reviewed the details of the findings and determined the errors to be due to human error. For student #13, the R2T4 in question was a refund which was returned on June 15, 2023, in the amount of $595 to the 2022-2023 Federal Pell Grant Program funds. The Institution should have recalculated the Federal Pell Grant funds to include in the R2T4 calculation. The Institution used $1,261 as Federal Pell disbursed, when we should have only used $420 (due to the student being less than ½ time). After recalculating the Federal Pell, the Institution should have returned $214 to 2022-2023 Federal Pell Grant program funds. This resulted in an under return of $460 in 2022-2023 Federal Pell program funds. In addition, the Institution used an incorrect number of days in the payment period in the R2T4 calculation, resulting in an incorrect percentage of aid earned. For student #AR1, the R2T4 in question was a refund which was returned on May 31, 2023, in the amount of $9 in 2022-2023 Federal Subsidized Direct Loan Program funds. The $9 was in the amount of R2T4 funds which was due to the student and not required to be returned by the Institution. The Institution did not have authorization from the student to return funds to the Federal Subsidized Direct Loan Program. This resulted in an over return of $9. For student #AR15, the R2T4 in question was a refund which was returned on October 24, 2022, in the amount of $929 to the 2022-2023 Federal Pell Grant Program funds. The Institution should have returned $1,431, which resulted in an under return of $502. The Institution used an incorrect number of days in the payment period in the R2T4 calculation, resulting in an incorrect percentage of aid earned. Subsequent to the audit, the Institution returned $962 to the Federal Pell Grant Program funds on behalf of student #13 and student #AR15. The Institution has planned the following immediate solutions to ensure accuracy for R2T4 calculations. • Share Corrective Action Plan (CAP) with accountable staff. • Create a scheduled hours chart for all programs to address the incorrect number of days being calculated in a payment period. Additionally, the Institution will standardize the usage of the automated calculations within the Institution’s Student Information System (Anthology) to help minimize potential human errors within our processes. • Evaluate and update R2T4 policies and procedures as necessary to incorporate these solutions. • Train staff on R2T4 calculations as well as conduct ongoing training on an annual basis. o This will also incorporate training on the Institution’s R2T4 policies, including covering the requirement that student files should be reviewed for appropriate student authorizations as well as the full-time/part-time status of a student. • Re-train staff on the Institution’s R2T4 peer review process. • Establish target dates to review CAP effectiveness. o The Institution will conduct a monthly review of the CAP’s effectiveness for the first six months after implementation of the CAP and then will conduct periodic reviews of the CAP thereafter.

Department of Education Augustana University respectfully submits the following corrective action plan for the year ended July 31, 2023. Audit period: August 01, 2022 – July 31, 2023 The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. FINDINGS—FINANCIAL STATEMENT AUDIT There were no findings in the current year that require corrective action plan. FINDINGS—FEDERAL AWARD PROGRAMS AUDITS DEPARTMENT OF EDUCATION 2023-001 Title: Student Financial Assistance Cluster – Assistance Listing Nos. 84.007, 84.0033, 84.063, 84.268, 84.379 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: We have implemented a secondary compliance check of student withdrawal dates. As the Registrar Assistant is notified of student withdrawals, the ‘Leave Date’ is entered into the Jenzabar/CX system. On a weekly basis, the Assistant Registrar will double check the withdrawal notice with the date in Jenzabar/CX. Performing this double check on a weekly basis should catch any incorrectly entered dates before they are transmitted to NSLDS. If an incorrectly entered date is found, the Assistant Registrar will notify the Director of Financial Aid, who will check NSLDS to further ensure the date has not been incorrectly included in enrollment reporting. Name(s) of the contact person(s) responsible for corrective action: Joni Krueger Planned completion date for corrective action plan: immediately / already implemented If the Department of Education has questions regarding this plan, please call Joni Krueger at 605.274.4121.

Department of Education Carleton College respectfully submits the following corrective action plan for the year ended June 30, 2023. Audit period: July 01, 2022 – June 30, 2023 The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. FINDINGS—FINANCIAL STATEMENT AUDIT There were no findings in the current year that require corrective action plan. FINDINGS—FEDERAL AWARD PROGRAMS AUDITS DEPARTMENT OF EDUCATION 2023-001 Title: Student Financial Assistance Cluster – Assistance Listing Nos. 84.007, 84.0033, 84.063, 84.268 Recommendation: We recommend the Institute 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: We have developed additional validation steps to confirm that the status of every student who has completed their program and graduated is accurately reflected at both the National Student Clearinghouse and at NSLDS. Name(s) of the contact person(s) responsible for corrective action: Theresa Rodriguez Planned completion date for corrective action plan: 9/30/2023 If the Department of Education has questions regarding this plan, please call Theresa Rodriguez, Registar at 507-222-4290.

The Vice President of Finance corrected the disbursement dates for the students in question in September 2023. Going forward, the Student Financial Aid Office and Business Office will coordinate the drawdown of funds, reporting to COD, and posting to student accounts. The personnel of the College understands that while on the cash advance method to disburse funds, they have three business days from the date the funds are received to post the funds to the student accounts. However, the disbursement date on the student account and in COD still must agree. Anticipated Completion Date: The corrective action was completed in September 2023. Contact Person: Stephanie Dickerson, Registrar/Financial Aid 910-323-5614

Pursuant to federal regulations, Uniform Administrative Requirements Section 200.511, the following are the findings as noted in the Macomb Community College Single Audit Act Compliance report for the year ended June 30, 2023, and corrective actions to be completed. 2023-001 Special Tests and Provisions - Enrollment Reporting Auditor Description of Condition and Effect. We noted that one out student of a testing population of two was not reported timely to NSLDS and did not have the correct status change reported. As a result of this condition, the College was exposed to an increased risk that incorrect and untimely information would be reported to NSLDS. Auditor Recommendation. We recommend that the College consistently apply their enrollment reporting procedures to prevent untimely status change reporting in the future. Corrective Action. This situation occurred because the student graduated during a term in which they were not enrolled. This is connected to our upload to the National Student Clearinghouse which did not mark the student as graduated (G Not Applied) in our degree verify file. There is a known defect in our student information system that causes this issue. We are currently working collaboratively with our information technology department to resolve this defect which will ensure that we capture students in this situation in the future. Responsible Person. Registrar/Director of Enrollment Services Anticipated Completion Date. June 30, 2024

Finding 2023-007 Special Tests and Provisions – Perkins Loan Recordkeeping and Record Retention Federal Agency Name: Department of Education Program Name: Student Financial Aid Cluster CFDA # 84.038 – Federal Perkins Loan Program Finding Summary: We did not maintain all records as required under the program and as a result, subsequent to yearend, were required to buy back specific Perkins Loans that did not have proper documentation maintained. Responsible Individuals: Jillaine Smith, Chief Operating Officer, Erin Drew, Facilitator of Advancement Services and Patty Pietz, Presentation Sisters Accountant. Corrective Action Plan: All loan documentation was provided to Department of Education as part of the liquidation process and any loans that did not have proper documentation were purchased back by the College in September 2023 and the Perkins Liquidation was complete with final reporting requirements completed. Anticipated Completion Date: September 30, 2023

Finding 2023-005 Special Tests and Provisions – Enrollment Reporting Federal Agency Name: Department of Education Program Name: Student Financial Aid Cluster CFDA # 84.268 – Federal Direct Student Loans CFDA # 84.063 – Federal Pell Grant Program Finding Summary: During testing of enrollment reporting, it was noted that 7 of 19 students tested were not reported to NSDLS with changes in effective dates and enrollment statuses; and the certification dates were not within 60 days of the changes and 8 of 19 students tested were reported to NSLDS with incorrect program begin dates. Responsible Individuals: Jillaine Smith, Chief Operating Officer, Erin Drew, Facilitator of Advancement Services and Patty Pietz, Presentation Sisters Accountant. Corrective Action Plan: The errors noted in tested were corrected when we were notified of the errors and additional review was taken to ensure that a final enrollment roster was submitted as required as part of the close audit process. Anticipated Completion Date: September 30, 2023

Finding 2023-004 Cash Management –Reconciliations (Direct Loan) Federal Agency Name: Department of Education Program Name: Student Financial Aid Cluster CFDA # 84.268 – Federal Direct Student Loans Finding Summary: When testing cash management related to reconciliations, the auditors noted 2 of the 12 monthly SAS reconciliations were not completed. Responsible Individuals: Jillaine Smith, Chief Operating Officer, Erin Drew, Facilitator of Advancement Services and Patty Pietz, Presentation Sisters Accountant. Corrective Action Plan: The Student Financial Aid Director completed a final reconciliation after final disbursements were made to students to ensure all aid awards was correctly reflected. Anticipated Completion Date: September 30, 2023

Finding 2023-003 Eligibility – Calculation of the Amount of Pell, Subsidized and Unsubsidized Direct Loan Assistance Awarded Federal Agency Name: Department of Education Program Name: Student Financial Aid Cluster CFDA # 84.033 – Federal Work Study Program CFDA # 84.268 – Federal Direct Student Loans CFDA # 84.007 – Federal Supplemental Educational Opportunity Grants (FSEOG) CFDA # 84.063 – Federal Pell Grant Program Finding Summary: During testing over the eligibility requirements, the following deficiencies were noted: • 2 of 60 students were not awarded the correct amount of Pell. One student was under awarded by $2,773 and one was over awarded by $862. • 7 of 60 students were not awarded the correct amount of subsidized loans. 4 students were under awarded subsidized loans based on being awarded as the wrong academic year in school; and 3 students were over awarded subsidized loans as the student did not have financial need. • 5 of 60 students were not awarded the correct amount of unsubsidized loans. All 5 of the students with errors were under awarded unsubsidized loans based on being awarded as the wrong academic year in school. Responsible Individuals: Jillaine Smith, Chief Operating Officer, Erin Drew, Facilitator of Advancement Services and Patty Pietz, Presentation Sisters Accountant. Corrective Action Plan: The College has reviewed all students impacted by the errors noted above and made corrections to the students as needed. Anticipated Completion Date: September 30, 2023