Corrective Action Plans

Student Financial Assistance - Cluster - Federal Pell Grant Program; Award ID No. P063P210331, 2021 - 2022 Federal Award Year Identifying Number: 2022-005 Audit Finding: The University was required, as a result of the Focused Program Review (OPE ID: 00301200) (FPR) regarding the University?s participation in the ?Pell for Students Who Are Incarcerated? experiment (Second Chance Pell), to complete a full file review (enrollment status, effective dates and reporting dates) of all National Student Loan Data System (NSLDS) enrollment reporting for the 2019-20 and 2020-21 award years and update and correct errors identified. Corrective Actions Taken or Planned: Management concurs with the finding. The Registrar?s Office has performed a review of its policies and procedures and has revised them accordingly to ensure timely, accurate and complete submissions to the NSLDS. The determination of the review was that the enrollment effective status data field required correction in the NSLDS Enrollment History system. Since the restoration of the NSLDS system in November 2022, the Registrar?s Office has been correcting the data.

Student Financial Assistance - Cluster - Federal Pell Grant Program; Award ID No. P063P210331, 2021 - 2022 Federal Award Year Identifying Number: 2022-004 Audit Finding: The University did not have an established policy and procedure to ensure that the University consistently applied the regulations regarding payments of Pell if a student?s program crossed over an award year. Corrective Actions Taken or Planned: Management concurs with the finding. In April 2022 a formal policy and procedures addressing the awarding of the Pell Grant has been established to ensure compliance including staff training.

Student Financial Assistance - Cluster - Federal Pell Grant Program; Award ID No. P063P210331, 2021 - 2022 Federal Award Year Identifying Number: 2022-003 Audit Finding: As part of Schneider Downs testing of the origination records, we noted within a sample of 25 transactions, there were three records that had differences between the Common Origination and Disbursement (COD) data and the University?s data for their verification status codes. Corrective Actions Taken or Planned: Management concurs with the finding. Once management was made aware of the unresolved variances of verification codes, the variances were corrected immediately. Upon discovery in August 2022, the Student Financial Aid Office immediately implemented additional controls and training of staff to ensure that these issues do not reoccur.

Student Financial Assistance - Cluster - Federal Pell Grant Program; Award ID No. P063P210331, 2021 - 2022 Federal Award Year Identifying Number: 2022-002 Audit Finding: As part of the audit for the 2021- 2022 Federal award year, Schneider Downs determined that the University used the same determination for the payment period for those students who had been awarded Pell grants that it had been using in the periods for which the U.S. Department of Education (ED) conducted the Focused Program Review (FPR). In addition to the population of students who are participating the Second Chance Pell program, the University also identified additional students, that when using ED?s interpretation of the Code of Federal Regulations (CFR), the University used a payment period that did not reflect enrollment in a nonstandard instructional term program. Corrective Actions Taken or Planned: Management does not concur with the criteria of this finding due to a disagreement with the interpretation of the regulations included in ED?s Final Program Review Determination (FPRD) and has appealed the finding as stated in the following paragraphs. Management followed the direction received from the ED Reviewers during the FPR exit interview on September 24, 2021, stating the University should not change its practice for the Second Chance Pell students enrolled in their respective instructional program nor the calculation using Formula 1 for the payment period until the Program Review Report (PRR) is received. The PRR was received on January 3, 2022, which was after the summer and fall 2021 semesters and just weeks prior to the start of the spring 2022 semester. Moreover, pursuant to the Higher Education Act ?498A(b), the University was entitled to an opportunity to review the PRR and within 60 days of receipt, submit a response for ED?s review prior to their preparing a final determination. The University submitted its response to the PRR on March 11, 2022. The University disagrees with the determinations in the FPRD and is vigorously defending itself against the ED interpretation of the regulations, the findings and the proposed financial assessments. The University filed an appeal of the findings and the associated financial assessments contained in the FPRD on October 24, 2022, and submitted a brief in support of the appeal on January 22, 2023, to the ED Office of Hearings and Appeals within the guidelines as prescribed by the Higher Education Act ? 487(b)(2) and U.S.C. ? 1094(b)(2). Effective with the fall 2022 semester term and each fall and spring terms thereafter, the Second Chance Pell students enrolled in their respective instructional programs have a fifteen (15) week standard instructional term and the payment period qualifies for calculations utilizing Pell Formula 1.

Responsible Individual(s): Ron Anderson, Associate VP of Student Financial Services Finding 2022-002 Federal Agency Name: Department of Education Program Name: Student Financial Aid Cluster CFDA No.: Various Finding Summary: When a recipient of Title IV grant or loan assistance withdraws from an institution during a payment period or period of enrollment in which the recipient began attendance, the institution must determine the amount of Title IV grant or loan assistance that the student earned as of the student's withdrawal date and must return the amount of Title IV funds for which it is responsible as soon as possible but no later than 45 days after the date of the institution's determination that the student withdrew. During 2022, three students that withdrew during the period of enrollment required a refund of funds. These returns of Title IV funds were not made within the 45 day period required. Corrective Action Plan (CAP): The University will partner with the Registrar?s Office to determine students who have withdrawn from Lipscomb and need to have Federal Title IV funds returned. These returns will be tracked in a spreadsheet, calculated within the Student Information System, and returned through Common Origination and Disbursement within the regulated 45 days. Anticipated Completion Date: The procedures will be implemented for the 2022-2023 Financial Aid Year. Responsible Parties: The Return to Title IV process will be done by staff in the Financial Aid Office as assigned by the Director and monitored by the Associate VP of Student Financial Services.

Responsible Individual(s): Ron Anderson, Associate VP of Student Financial Services Finding 2022-001 Federal Agency Name: Department of Education Program Name: Student Financial Aid Cluster CFDA No.: Various Finding Summary: In accordance with 34 CFR Sections 685.102(b), 685.301, and 303, each month, the Common Origination and Disbursement system provides institutions with a School Account Statement (SAS) data file which consists of a Cash Summary, Cash Detail, and (optional at the request of the institution) Loan Detail records. The institution is required to reconcile these files to the institution's financial records. Since up to three Direct Loan program years may be open at any given time, institutions may receive three SAS data files each month. During fiscal year 2022, only three of the twelve monthly reconciliations were completed due to a system conversion and turnover in the financial aid department. Corrective Action Plan (CAP): The University will implement procedures to reconcile the Common Origination and Disbursement system to the University?s financial records for Direct Loans monthly. This task will be completed in the Financial Aid Office as assigned by the Director of Financial Aid and monitored by the Associate VP for Student Financial Services. Reconciliations will be completed for each month with disbursements, staring with the 2022-2023 Financial Aid Year. Anticipated Completion Date: The procedures will be implemented for the 2022-2023 Financial Aid Year. Responsible Parties: The monthly reconciliation will be done by staff in the Financial Aid Office as assigned by the Director and monitored by the Associate VP of Student Financial Services.

Aggregate Loan Limits Planned Corrective Action: I) We will ensure our automated process for verifying Direct Loan eligibility is functioning properly in Powerfaids (financial aid software). We will ensure that we are capturing all aggregate loan limits and are verified when a student is clo e to or at their aggregate limits. In addition, we will review our automated processing when FAFSAs come into the financial aid department to identify the correct people who need to be reviewed. 2) Counselor will go in and reviews NSLDS information and verifies loan eligibility and corrects if needed. 3) Counselor determines proper loan amount and adjusts the loan limit if student is eligible for funding Person Responsible for Corrective Action Plan: Dr. Anthony Turner, Vice President of Enrollment and Marketing Anticipated Date of Completion: 12/17/2022

Finding Number: 2022-007 Condition: The Seminary did not maintain appropriate documentation to substantiate the allowable charges on the students ledger account to identity whether credit balances were created and required additional documentation from the student to hold the credit balance. Planned Corrective Action: The Seminary will no longer be holding any credit balances for students. Any Title IV aid that is disbursed for 23-24 and creates a credit balance will be refunded to the student within 14 days of disbursement. Contact person responsible for corrective action: Vu Huynh Anticipated Completion Date: 07/31/2023

Finding Number: 2022-003 Condition: Of the 16 students who received disbursements selected for testing, the Seminary did not notify 11 students or parents, as applicable, that received direct federal loans within the required 30 days. Planned Corrective Action: Financial Aid Director has already set up a disbursement notification email to be sent out of the new financial aid management system (JFA). Shortly after Title IV disbursements are made, the Director will send out the disbursement notification to any group of students who have had aid disbursed. Each time a disbursement is made, these notifications will be sent to the necessary students. These notifications will be documented in each students? records. Contact person responsible for corrective action: Ashley Schreiner Anticipated Completion Date: 07/31/2024 (to be completed throughout 23-24 academic year)

Finding Number: 2022-005 Condition: The Seminary was unable to support that required records were retained for outstanding Perkins loans. Planned Corrective Action: Garrett has finalized the closeout of the Perkins Loan program (except for the audit final step, which is to be conducted as part of the 2022 audit. The Seminary has purchased the loans that were not accepted by the Department of Education. Contact person responsible for corrective action: Ashley Schreiner Anticipated Completion Date: 08/25/2023

Finding Number: 2022-008 Condition: The Seminary did not have the appropriate procedures and controls in place to file an accurate and timely Fiscal Operations Report and Application to Participate ("FISAP"). Planned Corrective Action: Financial Aid Director plans to have the FISAP completed and submitted by the required deadline of September 29th, 2023. The Seminary will implement an independent second review of the FISAP, where the supporting records will be included. Contact person responsible for corrective action: Ashley Schreiner Anticipated Completion Date: 09/29/2023

Finding Number: 2022-006 Condition: The Seminary did not have controls in place to identify and document the students who have withdrawn and the applicability of performing a return of Title IV funds. Planned Corrective Action: Financial Aid Director has created a spreadsheet to document detailed student information for withdrawals to include withdrawal date, whether federal funds were received, date R2T4 was calculated, if/how much unearned aid was returned, date processed, and any helpful notes for each student. Registrar will continue to email Financial Aid with any withdrawal details. Contact person responsible for corrective action: Ashley Schreiner Anticipated Completion Date: 07/31/2024 (to be completed throughout 23-24 academic year)

FINDING 2022-002 ? Special Tests and Provisions ? Borrower Data Transmission and Reconciliation: Condition/context: The University did not have effective internal control in place that would provide reasonable assurance that the University complied with federal regulations, and the University did not complete reconciliations for all of 2022 except March 2022. Cause: Management did not have an established policy and procedure for borrower data transmission and reconciliation. Further, the process was not completed in the noted months due to turnover in the position responsible for performing the monthly reconciliation. Corrective Action Plan: Due to significant turnover in the Financial Aid Office, management has outsourced its financial aid function to a third party. This partnership will ensure monthly loan reconciliations are performed on time and approved by the CFO. Responsible person: Sarah Stooksberry / Cindy Farrington Planned completion date: Completed as of the date of this letter.

FINDING 2022-004 ? Special Tests and Provisions ? Enrollment Reporting: Significant Deficiency in Internal Control Over Compliance Condition/context: An exception was noted whereby the status change of 1 graduated student selected for testing was not reported to the NSLDS. Cause: Due to turnover in the position responsible for performing the manual reporting process reporting was completed when the responsibility was assigned to a new employee. Corrective Action Plan: Due to significant turnover in the Financial Aid Office, management has outsourced its financial aid function to a third party. This partnership enables us to improve our attention to detail and increase our internal controls over compliance matters. Responsible person: Sarah Stooksberry / Cindy Farrington Planned completion date: Completed as of the date of this letter.

FINDING 2022-003 ? Special Tests and Provisions ? Disbursements: Significant Deficiency in Internal Control Over Compliance Condition/context: For one undergraduate student selected, federal student aid was disbursed, creating a credit balance that should have been refunded to the student within the 14-day requirement. Cause: Due to turnover in the position responsible for monitoring credit balances and disbursement date compliance requirements, individuals performing the responsibility could not perform the task according to the required timeframes. - Corrective Action Plan: Due to significant turnover in the Financial Aid Office, management has outsourced its financial aid function to a third party. This partnership enables us to improve our attention to detail and increase our internal controls over compliance matters. It also enables the financial aid function to communicate effectively with the accounting office and ensure disbursements and refunds are processed timely and in accordance with the Department of Education rules and regulations. Responsible person: Sarah Stooksberry / Cindy Farrington Planned completion date: Completed as of the date of this letter.

FINDING 2022-001 ? Eligibility: Significant Deficiency in Internal Control Over Compliance Condition/context ? The University did not have effective internal control in place to ensure ISIR flags had been cleared. Cause ? Individuals responsible for awarding and packaging students were unaware of the requirement to clear ISIR flags. Corrective Action Plan: Due to significant turnover in the Financial Aid Office, management has outsourced its financial aid function to a third party. This partnership enables us to improve our attention to detail and increase our internal controls over compliance matters. Responsible person: Sarah Stooksberry / Cindy Farrington Planned completion date: Completed as of the date of this letter.

Cluster name: Student Financial Assistance Cluster Assistance Listings numbers and names: 84.007 Federal Supplemental Educational Opportunity Grants 84.033 Federal Work Study Program 84.063 Federal Pell Grant Program 84.268 Federal Direct Student Loans Chris Wodka Anticipated completion date: June 30, 2023 The District agrees with the finding. The District worked with the SIS Vendor to improve the accuracy of Enrollment Reporting out of the SIS. Initial reviews of the reporting have been positive, however close monitoring will continue to ensure proper compliance.

Cluster name: Student Financial Assistance Cluster Assistance Listings numbers and names: 84.007 Federal Supplemental Educational Opportunity Grants 84.033 Federal Work-Study Program 84.063 Federal Pell Grant Program 84.268 Federal Direct Student Loans Chris Wodka Anticipated completion date: June 30, 2023 The District agrees with the finding. After reviewing the student in the finding, the District re-processed the Return of Title IV calculation. The one student record was updated and resulted in an amount of $275 to be returned to the student by offsetting their current balance with the District. The District will fund the reimbursement with institutional funds. During the fiscal year ending June 30, 2023, the District continued to enhance the monitoring of refunds processed. The District plans to begin exploring the use of the SIS to calculate Return to Title IV based on compliance requirements. The District will continue to strengthen our policies and procedures surrounding Return to Title IV compliance requirements.

Name of Responsible Individual: Bonnie Adamson Corrective Action: Going forward, this has been corrected using ?Tasks? in PowerFAIDS, which will identify mid-year transfer students, alerting the financial aid staff to enter the student into the ?NSLDS Mid-Year Transfer? section in PowerFAIDS and transmitting the file to NSLDS. Anticipated Completion Date: February 2023

Finding 2022-003 Significant Deficiency in Internal Controls over Compliance, Nonmaterial Noncompliance Name of contact person(s): Susan Lee and Jovetta Whitfield Management agrees with this finding. Staff was able to go back and locate the missing documents after the audit review period. The Department will educate staff on the location of historical documents (data of repository location/access prior to 2013 and filing guidelines for adoptive head of household). The agency has transitioned where data is housed and how records are filed. Will conduct training and will establish written guidance in order to maintain the history of our records. Proposed completion date: March 30, 2023

40 files were sampled, and 3 files were found to have late reporting. We agree with the findings and have placed an action plan to ensure this is not a repeated finding. The findings were all unique system related issues. Registrar will conduct an additional QA process to ensure that not only statuses are reported timely, but any changes to student?s status after reporting has been reviewed for accuracy. Two of the students were students that were in withdrawal status and later graduated. Our system report does (grad only file) not capture students in withdrawal status, therefore, an additional report is required to ensure the Graduated status is captured and reported to National Students Clearinghouse. One of the students was student on a leave of absence that was reported after 60 days. The leave of absence requests is recorded outside of our Student Information System. Registrar will work on enhancing the leave of absence report and ensure they are correctly reported on the enrollment submissions sent to National Student Clearinghouse. Registrar will run an additional report to review any conferrals or leave of absences and submit enrollment update if any discrepancies are found. Implementation of new control:Registrar to run an enrollment status change report and identify any status changes that need to be updated. This QA process will ensure that enrollment status is accurately reported in situations where the system report does not automatically generate the accurate status. Name of contact person responsible for corrective action plan: Greg Ball Anticipated Completion Date: Already implemented.

Department of Education, South Orange County Community College District 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 Department of Education 2022 ? 001 Special Tests and Provisions Recommendation: The District should strengthen internal controls to ensure that they are identifying students who withdraw without notification in a timely manner. Additionally, the District should also establish controls for further review of the Return to Title IV (R2T4) calculations to ensure that the data utilized in preparing the calculation is accurate. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: In order to ensure R2T4 calculations are performed within 30 days of the end of the period of enrollment, Saddleback College Financial Aid will review the report that identifies students who withdraw without providing notification to the institution periodically throughout the term. Initially after the freeze date, a second time after the grade posting deadline date for each term, and a third time within 30 days from the day the term ends. Scheduled review dates will also be included on the annual R2T4 Schedule. Further, in order to ensure the data utilized to calculate the R2T4 is accurate, all R2T4 worksheets and supporting documentation will be reviewed by the Senior Financial Aid Specialist or Director, Financial Aid prior to processing the return of funds. In addition, corrected calculations were completed and additional funds were returned, as required.Name(s) of the contact person(s) responsible for corrective action: Anthony Becerra (Saddleback College, Director, Financial Aid) and Christian Alvarado (Saddleback College, Dean, Enrollment Services) Planned completion date for corrective action plan: June 30, 2023 If the Department of Education has questions regarding this plan, please call Richard Kudlik, District Internal Auditor, at (949)582-4647

Student Financial Assistance Cluster Recommendation: We recommend the University review its procedures to ensure the students' academic level is correctly reported to ensure proper awarding. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Financial Aid Director and Associate Director reviewed the student?s file associated with this finding. The error in certifying was associated with a one-time deviation from normal business practices in certifying loans. Financial aid staff involved in certifying loans were reminded, by the Associate Director, of the need to follow established business practices so these types of errors do not occur. Name of the contact person responsible for corrective action: Jeffrey Olson, Director of Financial Aid Planned completion date for corrective action plan: February 20, 2023

Student Financial Assistance Cluster Recommendation: We recommend the University review the return of Title IV funds requirements and implement procedures to ensure the return of Title IV funds calculations are using the correct number of break days and are accurately completed. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The financial aid office reviewed all R2T4 calculations for the 2021-2022 award year, recalculating the ?percent of aid earned? calculation when necessary. Information gleaned from the review of 2021-2022 R2T4 calculations was used to modify the spreadsheet used to process R2T4 calculations for 2022-2023. All 2022-2023 R2T4 calculations made prior to fixing the ?percent of aid earned? calculations were reviewed and adjusted, as needed. The audit tool we used to double-check the 2021-2022 ?percent of earned aid? calculations was added to the 2022-2023 R2T4 tool, as a way to flag calculation inconsistencies for 2022-2023 R2T4 calculations. Financial aid staff involved in processing R2T4 calculations were trained in how to use the revised R2T4 calculation tool. Name of the contact person responsible for corrective action: Jeffrey Olson, Director of Financial Aid Planned completion date for corrective action plan: February 20, 2023

Student Financial Assistance Cluster Recommendation: We recommend the University review its reporting procedures to ensure that students? statuses are accurately and timely reported to NSLDS and all errors are corrected with the appropriate timeframe as required by regulations. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: First, we will do a full audit of our report schedule to ensure the correct information is pulling into the correct report. Our current schedule shows that regular enrollment reports are submitted to the Clearinghouse every month. In addition, corrections are made within a few days of receiving the error reports. We will confirm with NSC that they are receiving all of our transmissions and corrections. Second, we will also ensure that that multiple staff are thoroughly trained on the process of submitting files and correcting errors. This will provide redundancy to ensure transmissions and corrections are done in the required windows of time. Name of the contact person responsible for corrective action: Cheryl Fisk, Registrar Planned completion date for corrective action plan: June 1, 2023