Corrective Action Plans

Finding 2023-006 Reporting – Special Reporting – Fiscal Operations Report and Application to Participate (FISAP). Federal Agency Name: Department of Education Program Name: Student Financial Aid Cluster CFDA # 84.033 – Federal Work Study Program CFDA # 84.007 – Federal Supplemental Educational Opportunity Grants (FSEOG) CFDA # 84.063 – Federal Pell Grant Program CFDA # 84.268 – Federal Direct Student Loans CFDA # 84.038 – Federal Perkins Loan Program Finding Summary: In testing key line items as indicated in the compliance supplement, the auditors noted 2 line items for which amounts reported in the FISAP did not agree to supporting records and documentation that were provided during testing. Lines that were not reported correctly were Part II, Section E Line 22 and Part II, Section D Line 7. Responsible Individuals: Jillaine Smith, Chief Operating Officer, Erin Drew, Facilitator of Advancement Services and Patty Pietz, Presentation Sisters Accountant. Corrective Action Plan: Any errors that were required to be corrected were made for 2022 and resubmitted to the Department of Education prior to the 2023 report being completed. Anticipated Completion Date: September 30, 2023

Department of Education Macalester College respectfully submits the following corrective action plan for the year ended May 31, 2023. Audit period: June 01, 2022 – May 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. 84.038, 84.268, 84.007, 84.063 Recommendation: We recommend the College evaluate the circumstances that delayed reporting disbursements to COD to ensure that it will not happen again. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: We experienced a malfunction in our reporting software and were not aware of the issue until after the reporting deadline. We now have procedures in place whereby we confirm that COD has received the file once we have submitted it. Name(s) of the contact person(s) responsible for corrective action: Jenae Schmidt Planned completion date for corrective action plan: Implemented in November 2022. If the Department of Education has questions regarding this plan, please call Jenae Schmidt at 651-696-6214.

WGU has implemented the appropriate identification of the TPD comment codes with our new aid year configuration and will continue this course of action whenever the new aid year FAFSA is released. The comment code numbering changed in 2024‐ 2025 from 2023‐2024. WGU will review and match the new 2024‐2025 codes with its corresponding 2023‐2024 codes to ensure our system is configured to identify ISIR records that are flagged by FSA requiring further action accordingly. Auditee Contact Person(s) Responsible for Corrective Action: Patti Kohler Vice President, Financial Aid.

The Financial Aid Director recalculated the “need” for each student in question. The Financial Aid Director agreed with the auditor’s calculations. The following corrections were made on August 8, 2023: For the first student, $2,000 of subsidized federal direct loans were reallocated to unsubsidized federal direct loans. For the second student, $382 of subsidized federal direct loans were reallocated to unsubsidized federal direct loans. For the third student, $1,649 of subsidized federal direct loans were reallocated to unsubsidized federal direct loans. For the fourth student, $1,145 of federal work study funds were returned to the Department of Education. The student had already worked for the University and earned the funds in question. He was treated as a regular employee of the University and paid with institutional funds instead of federal work study funds. Anticipated Completion Date: The corrective action was completed on August 8, 2023. Contact Person Shala LaTorraca, Director of Financial Aid 918-335-6260

2023-003 Student Financial Assistance Cluster – Assistance Listing No. Various Recommendation: We recommend the University review their documentation and ensure that there are documented safeguards for identified risks. We also recommend reviewing the changes in the Gramm-Leach-Bliley Act regulations that were required to be implemented as of June 9, 2023. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The IT Executive Director will review the completed risk assessment to identify specific shortcomings, so that safeguards can be documented in relation to those specific risks. Additionally, he will review the updated GBLA regulations and ensure the University is in compliance. Name of the contact person responsible for corrective action: Brandon Ray, Executive Director, Information Technology Planned completion date for corrective action plan: January 31, 2023.

Department of Education 2023-002 Student Financial Assistance Cluster – Assistance Listing No. Various Recommendation: We recommend the University review their internal control procedures over awarding, return of title IV calculations, and professional judgment and implement a formally documented review process. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The University will make the following changes: Awarding: The following are internal controls that the University already has in place to review awards for accuracy. • Financial aid worksheet: As part of the awarding process every award year, a financial aid worksheet is created to verify that the awards input in Colleague are accurate. The worksheet is updated each time there is a change to a student’s financial aid eligibility or status. • COD report monitoring: On a weekly basis, reports are processed to determine if there are any discrepancies between what has been awarded in Colleague and what is being reported/accepted in COD. Any discrepancies found are reviewed and corrected. • Monthly loan/grant reconciliation: The monthly loan/grant reconciliation monitors for any discrepancies between what is shown as disbursed in Colleague and the disbursements that have been accepted by COD. Any discrepancies found are reviewed and corrected. • Over award report: Processed at the beginning of each term, this report details if any students are awarded beyond unmet need and/or cost of attendance. Any discrepancies found are reviewed and corrected. • Enrollment level report: Processed before the start of each term and at the end of the add/drop period, this report evaluates awarded enrollment level against actual enrolled credits. Any discrepancies found are reviewed and corrected. • Disbursement processing rules: There are rules built into the Colleague system to limit disbursement of awards when actual enrollment status does not match awarded status. Any discrepancies found are reviewed and corrected. Beyond the internal controls already in place, the University will implement the following: • Secondary review of awards: For new Financial Aid Counselors, all awards will be reviewed for the first two months to ensure accuracy and commitment to proper training. Additionally, based on current staffing levels, a random selection of 10% of all awarded students will be reviewed to evaluate for awarding accuracy. • Grade level review: After the 10th day of each term, a review will be performed to compare the current class standing of each student to the grade level that was used for awarding. Any discrepancies found will be reviewed and corrected. Return to Title IV (R2T4) Calculations: The Colleague system is used to process R2T4 calculations. This system has been developed to correctly calculate the return formula based on limited information entered by the R2T4 processor. To ensure the correct information is entered, the University will implement a secondary review of all R2T4 calculations. The primary R2T4 processor will enter all required information in the R2T4 calculation screen within Colleague, and then print the screen for review by a secondary member before the return is referred for processing. The primary processor and secondary reviewer will be required to sign off on the printed calculation sheet, verifying the accuracy of the information. The items that will be included as part of the secondary review will be the date of determination, enrollment status, last date of attendance, and institutional charges. Professional Judgment: The University will implement a Professional Judgment Committee. The committee will consist of at least one Financial Aid Counselor and the Director of Financial Aid. The committee will collectively review all the documentation for each case to make a final determination. Name of the contact person responsible for corrective action: Dustin Kummrow, Director of Financial Aid Planned completion date for corrective action plan: November 1, 2023

2023-002 Student Financial Aid Cluster – Assistance Listing No. 84.007, 84.033, 84.063, 84.268 Recommendation: We recommend that the University consider any NSLDS access and documentation requirements necessary to ensure compliance with the stated criteria. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: As part of the University winding down operations, and no longer providing educational services, University management will consider any modifications to the NSLDS access and documentation requirements necessary to ensure compliance with the stated criteria. Name(s) of the contact person(s) responsible for corrective action: Rachel Nielsen, Vice President of Finance and Administration Planned completion date for corrective action plan: July 31, 2024

Aggregate Loan Limits Planned Corrective Action: ·The financial aid leadership team (Director and Associate Director) will review the current awarding loan processes to determine where the deficiencies are to ensure this issue does not reoccur next year. ·The financial aid leadership team will review the setup to configure automation and minimize manual processes to catch student approach loan limits ·The financial aid team will review NSLDS when students are flagged for approaching loan limits to verify remaining eligibility. Person Responsible for Corrective Action Plan: Kary Tejeda-Executive Director of Financial Aid and Veteran Services, Elisa Fisher-Associate Director of Financial Aid Operations and Dr. Anthony Turner-Vice President of Enrollment and Marketing Anticipated Date of Completion: March 15, 2024

Inaccurate and Untimely Return of Title IV Funds (R2T4) Planned Corrective Action: The oversight of R2T4 will be performed by the Financial Aid team. Going forward all Return of Title IV will be processed in PowerFAIDS enabling the calculation to be completed and the funds adjusted at the same time. This should eliminate the late return of funds. Person Responsible for Corrective Action Plan: Kary Tejeda, Executive Director of Financial Aid and Veteran Services, Julie Hodge-Assistant Director of Compliance Anticipated Date of Completion: January 15, 2024

Views of Responsible Officials and Planned Corrective Actions – The University moved from an on-premise solution to a cloud environment in fiscal year 2022. This upgrade included a new reporting tool. The reports used to identify and send disbursement notifications were not working as expected, therefore notifications were not sent out in a timely manner. The Director of Financial Aid has created a process to ensure all students and parents receiving loan funds are being notified about their right to cancel their loans. This process will be run immediately after loans have been transmitted to a student's account. The letters will be emailed to the student and parent email address.

Views of Responsible Officials and Planned Corrective Actions - The Student Financial Services Office is notified by the Registrar's Office when a student has completed the withdrawal process. Once that notification has been received, the Director of Financial Aid will complete the return of Title IV funds worksheet on the Common Origination and Disbursement (COD) website and update Colleague accordingly. A letter will be sent to the student notifying them of the modification to their financial aid award. To ensure all withdrawn students receiving federal financial aid have been processed, the Argos Withdrawn Student report will be run monthly. Each student will be reviewed to see if federal financial aid was awarded and disbursed for the term in which they withdrew. If there is a student that still needs to be processed, the Director of Financial Aid will complete those steps immediately.

Views of Responsible Officials and Planned Corrective Actions – The Registrar's Office reports student enrollment status to the National Student Clearinghouse according to the predetermined reporting schedule based on our census dates. The University opened a case with the Clearinghouse's audit resource department to gather information on what may have led to reporting delays. The Clearinghouse has indicated there was an NSLDS outage between July 2022 and March 2023 which could have resulted in several delays, such as those noted in the audit. If future NSLDS outages are anticipated or known, the Registrar's Office will adjust our reporting practices accordingly. The Registrar's Office has created and made available a procedural guide to running and submitting reports to make sure program length and other data submitted is accurate.

Name of Responsible Individual: Jason Byrd, University Registrar Liberty acknowledges that there was one instance in which a student’s enrollment status was not reported within compliance timeframes. Additionally, Liberty recognizes that there were multiple months in the year in which there were repeat errors found in the SSCR error file. Corrective Action: Liberty University continues to work to ensure the enrollment reporting process is handled compliantly and within allowable timeframes. There were multiple errors that were proactively addressed with National Student Clearinghouse (NSC) as Liberty was unable to resolve them internally. This was one of the contributing factors in having multiple months of repeat errors as NSC did not resolve. We will continue to work with NSC to resolve timing issue that result in errors outside of compliance timeframes. Additionally, the Registrar’s Office will work with ADS Academics to review the standard report used through Ellucian’s Banner to report student enrollment status to NSC. The goal of this review will be to better identify the source of errors and reduce error count for future submissions. Finally, over the last year, Liberty’s Financial Aid Office has hired an employee whose primary focus will be to provide an additional Quality Control (QC) process for enrollment reporting. This employee will work collaboratively with the Registrar’s Office to ensure roster errors and student enrollment level changes are resolved and reported within the permissible timeframes. While this position has been filled, we have been limited by the U.S. Department of Education’s National Student Loan Data System (NSLDS), as they transitioned to a new system and reporting used for this QC process was not released until July of 2023 and was not functional until September 2023 due to run-time errors that went unresolved. Liberty reached out to the U.S. Department of Education on multiple occasions (Case# 220920-00436 and Case# 230718-000084) in order to obtain a working report. Anticipated Completion Date: March 2024

Finding 2023-002 Recommendation: We recommend that management consider applicable regulation guidelines and ensure that background functions are appropriately functioning for all applicable fund codes, particularly around mergers with other institutions. View of Responsible Officials and Planned Corrective Actions: The EFT or “Loan Notice” email runs through an integration maintained by the University’s Information Technology department that generates a Loan Notice email based on a student having a disbursement under a specific federal loan fund code in Banner, the University’s financial aid software. Following the merger of the University of the Sciences with the University, the University of the Sciences had a Temporary Provisional Program Participation Agreement in effect through December 30, 2022. As a result, the University disbursed federal loans for the University of the Sciences campus for this period utilizing a different federal loan fund code within Banner. The Financial Aid Office was unaware that the integration utilized fund codes to generate the Loan Notice email and as a result the integration was not updated to include the additional fund code being utilized. Therefore, students that received loan disbursements under this fund code for the summer 2022 and fall 2022 terms did not receive Loan Notice email. These students were sent general communications in the summer and fall about the timing of loan disbursements for each term, but these did not meet the federal requirements. During the spring 2023 term, all student loan disbursements were included under the same federal loan fund code and all students received the Loan Notice email. During the upcoming merger with Pennsylvania College of Health Sciences, federal loans for the Lancaster campus will be processed in the legacy financial aid system under the existing procedures for the spring 2024 and summer 2024 terms during the period in which the Temporary Provisional Program Participation Agreement is in effect. Federal loans will be processed as one institution, under the University’s federal OPEID, utilizing a single federal loan fund code, beginning in the fall 2024 term. In the future, anytime there is a change federal loan fund codes being utilized the University will review the background functions to ensure they are operating appropriately. Individual Responsible for Corrective Action: Elizabeth Rihl Lewinsky, Assistant Vice President for Financial Aid, 610-660-1346, lewinsky@sju.edu Anticipated Completion Date for Corrective Action: The planned Corrective Actions will be immediately implemented

Department of Education Bucknell University 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—FEDERAL AWARD PROGRAMS AUDITS Department of Education 2023-001 Federal Pell Grant Program – Assistance Listing No. 84.063 Federal Direct Student Loans – Assistance Listing No. 84.268 Recommendation: We recommend the University review procedures around sending correct information to the NSLDS. In addition, we recommend the University develop a process to help better oversee the submissions completed by the third-party servicer. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Bucknell is currently reviewing its existing process of reporting student enrollment data to the NSLDS. The University through its Registrar and Financial Aid Office will update current procedures to include a more thorough verification of third-party servicer submissions to the NSLDS. Name(s) of the contact person(s) responsible for corrective action: Tim Kracker, University Registrar and Erin Wolfe, Director, Financial Aid Planned completion date for corrective action plan: December 2023 If the Department of Education has questions regarding this plan, please call Elizabeth D. Stewart, Associate Vice President, Treasurer & Controller at 570-577-3108.

Corrective Action Plan: Upon suggestion of the Office of Registrar the University of Dallas will begin dual reporting to both the National Student Loan Clearinghouse (NSLC) and the National Student Loan Data System (NSLDS) every thirty days. The Office of Registrar will work with Information Technology to set-up and run the SFRSSCR from the Banner system as well as run the same reports for the NSLC on the same day and approximate time to ensure that timely reporting is completed for the University of Dallas. The Office of Financial Aid will in turn run the appropriate reports to ensure that such reporting is successful. The Financial Aid Office will request access for the Office of Registrar personnel to submit such reports to the NSLDS or, if necessary, perform this task on behalf of the Office of Registrar. The Office of Financial Aid will work with the Student Registrar to ensure such reporting is accurate by reviewing such data points as Enrollment Effective Date, Enrollment Status, Term Begin Date, Term End Date and Award Completion Date. Implementation: The responsible parties include the Office of Registrar, the Office of Financial Aid along with the staff of Information Technology at the University of Dallas. Anticipated date of implementation of February 2024, pending updates to the SAIG and Electronic Services for the Department of Education and schema updates from the Department of Education with full utilization by close of the Spring 2024 term.

Corrective Action Plan: While the student was not initially identified, the record was corrected within the appropriate term and the student received the full proceeds of their aid eligibility. The Office of Financial Aid will be notified of grade changes on a weekly basis, if applicable, by the Office of the Registrar who is responsible for documenting and recording corrections to grading. The Office of Financial Aid will recalculate, if appropriate, the student Satisfactory Academic Progress status and make any necessary awarding and disbursement updates to the student’s record. Implementation: The responsible parties include the Office of Financial Aid and the Office of the Registrar with initial submissions within the month of November 2023 and continuing forward until such further efficiencies have been identified.

Condition: The College did not submit accurate and timely notification to the National Student Loan Data System (NSLDS) of student status changes and program-level enrollment data. Corrective Action: Because of the breach at the Clearinghouse, the College intentionally delayed its submission to the Clearinghouse to ensure its student data would not be compromised. The College’s policies and procedures are adequate to meet the 60 day requirement for reporting student status changes under normal circumstances. The College has reviewed the misreporting of one student’s campus and program-level record information and has determined that this is a unique circumstance. However, to strengthen its policies and procedures, a new form is being developed to properly document the timing of student enrollment changes to the Registrar. The document will be retained in the student’s file. Person Responsible For Corrective Action: Deann Schloesser, Registrar Anticipated Completion Date: October 2023

We concur with the auditor’s finding. We will be completing a full audit of remaining Perkins files to ensure that all necessary documentation is accounted for and properly filed. Contact Person Responsible for Corrective Action: Carol Summervill, VP for Finance Anticipated Completion Date: Corrective action was started in October and will be completed by December.

We concur with the auditor’s finding. We have reviewed our processes related to the enrollment reporting of withdrawing students. The financial aid department has added a column in the tracking document to record the effective withdrawal date from NSLDS. On a weekly basis, the withdrawal dates from NSLDS will be compared to the withdrawal dates per the financial aid records to ensure the two dates are the same. Contact Person Responsible for Corrective Action: Andy Olsen, Director of Financial Aid; Rhianna Reed, Assistant Registrar Anticipated Completion Date: Corrective action was completed in October.

2023-002 Student Financial Assistance Cluster – Assistance Listing No. Various Recommendation: We recommend the College work with their consulting firm to review their documentation and ensure that there are documented safeguards for identified risks and the required documentation and practices are implemented. We also recommend reviewing the changes in the Gramm-Leach-Bliley Act (GLBA) regulations that were required to be implemented as of June 9, 2023. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The College engaged a consulting firm as our Virtual Chief Information Security Officer (vCISO) in 2022-23 to assist in compliance with the GLBA. The College’s work with our vCISO includes a comprehensive risk assessment of the College’s information security posture, a determination of identified risks, access to expert security resources to build an effective and measurable security program, and an evaluation of the controls protecting the external network. These action items began in the 2022-23 fiscal year and are ongoing in the 2023-24 fiscal year. The vCISO program includes virtual multi-year ongoing support. Name(s) of the contact person(s) responsible for corrective action: Harlan Jorgensen, Director of Computing Services Planned completion date for corrective action plan: June 30, 2024

2023-001 Student Financial Assistance Cluster – Assistance Listing No. Various Recommendation: We recommend the College review its reporting procedures to ensure that students’ statuses are accurately and timely reported to National Student Loan Data System (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: After being alerted to the finding, the Registrar changed the submission dates to the National Student Clearinghouse (NSC) to allow more time for the NSC to timely report to the NSLDS. The Registrar’s Office will notify the Business Office when files have been submitted to the NSC. The Business Office will periodically monitor the NSLDS system and alert the Registrar of their observations. Name(s) of the contact person(s) responsible for corrective action: Austin Nyhof, Registrar Planned completion date for corrective action plan: June 30, 2024

South Plains College will modify system generated reports to include all reportable status changes and resubmit enrollment reports in which errors were identified. The College will implement a process to monitor the accuracy of enrollment reporting for future submissions. The anticipated completion date for the corrective action plan is no later than May 31, 2024.

November 20, 2023 To Whom It May concern: Corrective Action Plan – finding number 2023-001 Overall responsible individual for implementation of plan – Amy Hoss, Senior Director of Financial Aid While most of the reporting discrepancies occurred during the Christmas and New Year holidays ensuring that students would receive their funding in a timely manner, Parker has put in place additional controls to ensure compliance is dependent on initial and monthly reviews. Amanda Etheridge, Academic Business Analyst, and Amy Hoss, Senior Director of Financial Aid, will review PowerFAIDS and ensure that disbursement dates are appropriate and accurate, 10 days prior to the start of a term, regardless of the calendar day. Parker University will ensure that Title IV funds disbursed via PowerFAIDS are applied to student accounts via Jenzabar and reported to COD the same day. Parker University will further enhance the monthly reconciliation process. Once SAS reports are received, imported into PowerFAIDS, and the reconciliation report is generated for the respective Title IV programs, the file will be reviewed for any discrepancies in dates between the reported To_COD_Disb_Date, From_SAS_Disb_Date, and To_Bus_Disb_Date. Rodica Calin, Senior Accounting Analyst, will identify students with discrepant dates and provide to Angela McFadden, Compliance Officer, for further review. If the Compliance Officer confirms a discrepancy, the Academic Business Analyst or Senior Director of Financial Aid will complete a second review and update the appropriate system (PowerFAIDS, Jenzabar, or COD). Parker University will complete this data review for September disbursements by December 15, 2023 and October disbursements by December 31, 2023. It will be a part of our updated reconciliation process for subsequent months.

Finding: 2023-001 Estimated Completion Date: Year Ended June 30, 2023 November 15, 2023 Pennsylvania College of Health Sciences is committed to meeting all regulatory policies and procedures related to student financial aid. Below are the changes that were implemented in March 2023 and communicated to all staff members involved with student financial services: 1. Require the Student Account Specialist to run the Batch Assign Transmittal Communication process in the student information system immediately following each transmittal of financial aid. This will ensure communication will occur within the regulated timeframe. 2. Request that the Student Financial Services Coordinator note when loan disbursement notification e-mails are sent and alert the Student Account Specialist if notifications are not pulling in communications. These steps are monitored by the Director of Student Financial Services to ensure all updates and communication are occurring in a timely manner and in compliance with all regulations.