Corrective Action Plans

Finding 2023-004 Federal Agency Name: U.S. Department of Education Program Name: Student Financial Assistance Cluster ALN: 84.007, 84.033, 84.063, 84.268 and 84.379 Finding Summary: Unauthorized credit balances: In the event that a Title IV aid disbursement results in a credit balance on a student’s account, the University is required to disburse the funds to the student within 14 days of the disbursement, unless the student or parent has authorized the retention of a credit balance. Five students who received Title IV aid resulting in a credit balance on their accounts did not receive a disbursement of the funds within 14 days of the disbursement. The University did not have an authorization from the student or parent to retain the credit balance. Responsible Individuals: Shawnta Clark, Director of Student Accounts Corrective Action Plan: We agree with the auditors’ findings and recommendations. Credit balance reports will be pulled twice weekly (Monday and Wednesday) to ensure federal funds credits are timely disbursed on designated check run days. A management review procedure will be added for monitoring credit balance reports. Anticipated Completion Date: December 22, 2023

College Work Study – Assistance Listing No. 84.033 Recommendation: We recommend the College implement policies to review all student award packages at the start of the academic year to ensure no overawards exist. View of responsible officials: There is no disagreement with the audit finding. Action taken in response to finding: The Federal Work Study (FWS) earnings are tracked in the payroll department and reported to Student Financial Services (SFS) on a monthly basis. In November 2022, Union College hired a new Payroll Accountant who failed to provide FWS earnings to SFS after her hire date. Had SFS been notified of the actual amount the student earned, the department would have increased the award. The Controller in the Accounting office is aware of the lack of competence in this position, and took steps to ensure this finding does not come up in future years. A new Payroll Accountant was hired in October 2023. The new employee has many years of higher-education experience, including work with financial award packages. The Controller believes this will be a positive change for the Accounting office, and believes this finding will be eliminated in FY24. Name(s) of the contact person(s) responsible for corrective action: Steve Trana, VP for Financial Administration Planned completion date for corrective action plan: October 31, 2023

Perkins Promissory Notes – Assistance Listing No. 84.038 Recommendation: We recommend that the College put a procedure in place to ensure that all students have a promissory note prior to disbursing of funds. Also recommend a procedure be put in place to ensure proper record retention documenting the completion of promissory note. View of responsible officials: There is no disagreement with the audit finding. Action taken in response to finding: The process Union College follows to ensure promissory notes are signed is coordinated through Student Financial Services (SFS). SFS determines eligibility of awards and adds them to the student financial package. Once a loan has been accepted SFS has the student sign the promissory note. The loan is disbursed once the paperwork has been completed and reviewed. Perkins loans followed this procedure in the time they were available. The Perkins program is no longer active so there are no new promissory notes going forward. Student accounts is currently reviewing student files to ensure promissory notes, or documentation deemed appropriate by the Department of Education, are available for the Perkins loans that will be assigned to the Department of Education. Unfortunately, previous employees did not keep accurate records; this was brought to light when a new employee took over student accounts in August 2021. While the new employee has worked hard to track down all MPNs, we know that there are some that will never be found. As a result, this will likely be a repeat finding until all Perkins Loans are assigned or liquidated. It is our hope that this process will be completed by May 31, 2025. Promissory notes or documentation will be retained until the loans are either assigned or liquidated. Name(s) of the contact person(s) responsible for corrective action: Steve Trana, VP for Financial Administration Planned completion date for corrective action plan: We hope to assign or liquidate all Perkins loans by May 31, 2025. Until then, it is likely that this will be a recurring item on our corrective action report.

Corrective Action Plan: Federal Direct Loan exit interview information was sent to the students in question in August 2023. Procedures will be improved to ensure Federal Direct Loan exit interviews are completed or information is sent to students when they cease enrollment at the University. Anticipated Completion Date: The corrective action was completed in August 2023. Contact Person: Tasha Young, Staff Accountant 816-425-6151

Finding 2023-001 The University found the disbursement notifications that were scheduled to be made during a 45 day period, using our automated process, failed to transmit and therefore some borrowers did not receive the required notifications for Direct Loan funds. Response The University subsequently notified these students or parents following the identification of the error on November 16, 2022. As a result of the error in the automated process, a population of borrowers did not receive timely written notice of their right to cancel their Direct Loans until after the 30 day notification requirement ended. Corrective Action The disbursement notification process is run manually after each disbursement file is transmitted to the Student Accounts Office. Staff continue to work with the IT department to work towards making this an automated process. Status Corrected, November 16, 2022 Responsible Official Anne Tabor, Executive Director of Financial Aid

Finding 2023-002 The Return to Title IV calculations completed during Fall 2022 semester were based on the incorrect number of days in the term because it did not include the Thanksgiving break. Response Upon review, we were required to correct calculations for 25 students for Fall 2022. We reviewed Spring 2023 as well and that resulted in correcting calculations for another 7 students. Corrective Action We made sure the 2023-2024 academic year has been set up correctly to avoid these issues in the future and noted in the procedure to review breaks when setting up the new academic calendar each year in PowerFAIDS. Status Corrected, June 29, 2023 Responsible Official Anne Tabor, Executive Director of Financial Aid

The Institute agrees with the comment and has developed a plan to correct the finding. The Institute has examined the documented destruction date on the other student related files related to federal compliance requirements to ensure accuracy of the documented destruction date.

The institution does not dispute this finding. There was a change in personnel within the Registrar’s Office whereby proper training was not given to the staff member responsible for notification of enrollment changes to the Financial Aid department. This impacted the two students that were under-awarded Pell. Upon learning of this finding (and after disbursing the aid that was properly due), the issue was brought to the attention of senior leadership. The Registrar now sends out an electronic communication for all enrollment changes along with a document requiring signature from multiple departments (including Financial Aid). The Financial Aid department is also generating a weekly report that tracks all status changes from the prior week in order to make proper aid adjustments in a timely manner.

The institution does not dispute this finding. There was a change in personnel within the Registrar’s Office whereby proper training was not given to the staff member responsible for notification of enrollment changes to the Financial Aid department. This impacted the two students that were under-awarded Pell. Upon learning of this finding (and after disbursing the aid that was properly due), the issue was brought to the attention of senior leadership. The Registrar now sends out an electronic communication for all enrollment changes along with a document requiring signature from multiple departments (including Financial Aid). The Financial Aid department is also generating a weekly report that tracks all status changes from the prior week in order to make proper aid adjustments in a timely manner.

Finding Number: 2023-001 Federal Assistance Listing Number: 84.038 Federal Perkins Loan Program Year Ended: June 30, 2023 Responsible Individual: Christine Banewicz Director of Student Accounts Management’s Response and Corrective Action Plan: The College agrees with the finding and recommendation. For students whose Perkins loans were paid off, the College did not return the original or a true and exact copy of the note to the borrower, or otherwise notify the borrower in writing that the loan was paid in full. The College will take corrective action with their third party service provider, University Accounting Services (UAS) to send the required communications to students with loans that have been paid in full. The College also plans to contract with UAS to send these communications to borrowers as the loans are paid off going forward. The above procedures have already been implemented.

Drake University respectfully submits the following corrective action plan for the year ended June 30, 2023. Audit period: July 1, 2022 to 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 No findings to report. FINDINGS—FEDERAL AWARD PROGRAMS AUDITS Department of Education 2023-001 Student Financial Assistance Cluster – Assistance Listing No. Various Recommendation: We recommend the University reevaluate its procedures and review policies surrounding reporting status changes to NSLDS to put a process in place to ensure the student status changes are being reported timely. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Subsequent to the final submission of the enrollment file to the NSC, the Registrar’s Office will manually update the enrollment status in the NSC for any student whose enrollment status was determined to have changed immediately upon the discovery of that change. This ensures that the enrollment status is updated for “unofficial withdrawals”, since the University’s date of determination that the student withdrew occurs after the end of the spring semester and often after the submission of the first enrollment file for the next semester. Prior to the 60-day reporting deadline (starting at the school’s date of determination that the student’s status changed) the Assistant Director for New Student Programs will verify that the enrollment status change is correctly reflected in NSLDS. In addition, the Financial Aid and Registrar’s Offices are exploring reports that are available from NSLDS to assist in identifying any discrepancies between University and NSLDS records. Name(s) of the contact person(s) responsible for corrective action: Kevin Moenkhaus, Associate Registrar Planned completion date for corrective action plan: September 30, 2023. If the Department of Education has questions regarding this plan, please call Ryan Zantingh at 515-271-3048.

Inaccurate and Untimely Return of Title IV Funds (R2T4) Planned Corrective Action: A new administrative withdrawal procedure has been created to ensure that Title IV is both timely and accurately returned to the Federal Government in the case of an official / unofficial withdrawal from the university. A shared Office365 document was created to track the number of days in each segment of the withdrawal process. The Student Financial Services (SFS) Representative initiates the process upon notification of withdrawal from the Registrar. Appropriate documentation is gathered at the time of withdrawal to establish the correct timeline for the potential return of Title IV funds. The SFS Representative then determines if an R2T4 calculation is required. If an R2T4 calculation is required, the SFS Representative will assign the task to the Student Loan Processor or the Director of Student Financial Services. The Student Loan Processor and Director of Student Financial Services will use Microsoft Outlook, as prompted by the shared Office365 document, to assign “due dates” for both the R2T4 calculation as well as the return of funds to COD to ensure compliance. The Director of Student Financial Services and the Chief Student Finance Officer will perform a weekly review of the shared Office365 document to confirm the accuracy of R2T4 calculations and the required timeline of the return of Title IV funds. A secondary review by a financial aid representative with the appropriate level of experience will ensure that internal controls over such processes can operate effectively and achieve compliance. Person Responsible for Corrective Action Plan: David Burney, Chief Student Finance Officer Anticipated Date of Completion: Implemented August 21, 2023

Corrective Action Plan 2023-002: The University concurs with the finding and has provided corrective action through correcting the identified errors and adding additional review of the R2T4 calculations. Anticipated Completion Date: June 2023 Contact Person: Reta George, Director of Student Financial Services

Regarding student status change reporting, we identified a primary issue as the cause of late reporting this year for 32 of the 33 issues identified by our auditors. Upon review, we have determined changes that will prevent future instances of late reporting. As would be known to the federal government, a website and database conversion of the National Student Loan Data System (NSLDS) made enrollment reporting unavailable to schools for most of the academic year. One consequence to this was that the National Student Clearinghouse (NSC), transitioned away from what they refer to as a mid-month roster response. It was not known to us that the NSC was not regularly submitting mid-month response files to NSLDS after enrollment reporting resumed in January of 2023. Our monthly enrollment SSCR file is scheduled to be sent to the NSC on the first of each month. Our scheduled graduation date is the end of April or start of May, so we typically send an updated graduated student list around the middle of May. We were delayed from submitting this until the first week of June. The data submission was too late to be caught by the June 1st SSCR sent by NSLDS, but we expected that it would be sent by the mid-month file sent by NSC to NSLDS around June 15th. This would have kept us within 60 days for reporting. However, since NSC did not conduct mid-month reporting in June, the data we submitted indicating graduations that occurred at the end of April/start of May sat until July 1st with NSC and it was not sent to NSLDS within 60 days. Conversations we have had with the NSC since this discovery assured us that they have resumed mid-month reporting as of July, 2023. Additionally, our analyst with the NSC assured us they would track our transmission schedule to know if data is refreshed and current at the time of their responses to the first of month SSCR files they receive from NSLDS. When the data we send comes through after a scheduled SSCR file has been processed, they will reach out to inform us of a mid-month roster being sent. To provide accountability toward this, we will make it our process to check with them on whether a mid-month roster will be sent also. When NSC does not expect to send mid-month files automatically, we will order an ad-hoc enrollment report from the NSLDS website. We experimented with this process in recent months when we became aware of this issue with mid-month reporting and found it successful. In discussion with NSC and NSLDS, we inquired as to whether we should simply increase the frequency of our NSLDS SSCR to twice per month. For the majority of the year, this is not necessary. It was a unique situation this year in that mid-month reporting had ceased following the NSLDS Enrollment Reporting being offline for half or our academic year. For one additional student in the sample, an error was found with our student information system not updating the effective date of their enrollment change. Our software vendor was asked about the conditions of this error. They had made a modification to the reporting logic early on this past year, and this logic has proven to be inaccurate. The issue was not apparent through most of the year because enrollment reporting was not being conducted because of the previously mentioned NSLDS website transitions. Upon learning of the error, our software vendor updated their logic and has issued a patch that will correctly update the enrollment status effective date. All corrective actions will be fully implemented by October 31, 2023.

Finding 2023-002 Enrollment Reporting Views of Responsible Officials The University agrees with the auditor’s findings and recommendations. Corrective Action Plan The University has identified an issue that delayed identification and reporting of changes in student enrollment status for reporting on this NSLDS component for a small group of students. In response, internal report parameters will be updated to capture timely data and resolve this error. This report is provided to the Registrar who is responsible for reporting the change in enrollment status to NSLDS. The Registrar will be responsible for correcting the reporting error that was identified. Implementation Date Immediate Individual(s) Responsible Yvonne Harwood, Vice President of Institutional Effectiveness and Sonja Dixon, Registrar

For the executive bonuses, the Academy will award a blanket bonus based on a review from the executives' team members and manager, which provides feedback on overall leadership and communication skills associated with the teams being managed by the AAC executives. The review will not include any datea regarding attaining certain metrics related to recruitment and attaining any financial aid goals

Action Plan for Enrollment Reporting Audit Finding 2023-001 Issue - It was discovered that there was a Colleague system update that occurred that caused the Standard Reporting Flag to change from Yes to No, which resulted in inaccurate reporting to NSC. For all terms that a student can attend, the flag must be set to Yes for the reporting to be accurate. The following action plans will be put into place, to ensure that reporting is accurate: Action Plan 1 - A self-audit will be completed monthly when National Student Clearinghouse enrollment reporting is completed. This self-audit is to verify the students' enrollment status is accurate. To verify the accuracy, a sample of students will be pulled from the self-audit who have withdrawn, graduated, or had enrollment changes. Action Plan 2 - Admissions and Records and Financial Aid will work closely with the IT department any time there is a Colleague system update to fully comprehend the implications of the system update and how that could impact reporting and documented procedures.

Identifying Number: 2023-005 Finding: The College did not apply the appropriate clock to credit hour conversion formula for certain applicable financial aid eligible programs. The College also did not have sufficient evidence of controls being in place to ensure compliance with this requirement. Corrective Action Planned: Moraine Valley Community College will evaluate all certificates that are standalone programs. Financial Aid will receive a list of these programs and work with IT to identify students enrolled in those programs. Financial Aid will also update our policies and procedures to ensure that all clock to credit hour conversion formulas are being applied and documented per Uniform Grant Guidance (34 CFR 688.8). Anticipated Completion Date: June 30, 2024 Responsible Person: Tasha Campbell, Director of Financial Aid campbellt68@morainevalley.edu

Identifying Number: 2023-001 Finding: For eight out of ten students tested (80%) who withdrew from the College, the students' status change at the campus level and program level was not reported to the National Student Loan Data System (NSLDS) within the 60-day requirement. Corrective Action Planned: Enrollment Services staff have created a shared logbook that will track and compile NSC transactions. This logbook is saved to a shared drive with access given to appropriate staff, VP of Student Development and Dean of Enrollment Services. Additionally, any extended gaps in reports being verified, submitted and/or responses by either College staff or NSC staff will be followed up with by the Assistant Dean of Enrollment Services and logged in the NSC logbook for audit purposes. Anticipated Completion Date: June 30, 2024 Responsible Person: Tasha Campbell, Director of Financial Aid campbellt68@morainevalley.edu

Corrective Action Plan for Finding 2023-001 - The University experienced turnover in the Institutional Research position that attributed to the reporting errors. The University will provide additional training and monitoring to ensure that information reported to the National Student Loan Data System (NSLDS) is timely and accurate. The University also has a team represented by personnel from the Financial Aid office and Registrar's office that are evaulating our third-party agent assisting with enrollment verification reporting to the NSLDS, and the University will make a change in that relationship if warranted. The corrective action is currently in process and is being coordinated by Michelle Otwell, Assistant Professor and University Registrar; Breanna Yarbrough, Assistant Professor and Director of the Center for Assessment, Research, Effectiveness & Enhancement (CAREE); Linda Pynes, Director of Financial Aid. The corrective training will be completed immediately and monitoring will be an ongoing activity. The decision on whether to make a change in the agent assisting with transmitting data to the NSLDS will be made before May 31, 2024.

The Director of Financial Aid reviewed all students who had withdrawn and determined that only two were impacted. These two students' refund calculations were reviewed and corrected, and appropriate funds were returned. The dates used in the R2T 4 calculation for the upcoming year have been reviewed by the Director of Financial Aid to verify the proper number of days will be used in the Title IV Refund calculations. The Assistant Registrar will review the academic calendar each semester to be used in the R2T4 calculations. The University implemented these procedures for the Fall 2023 semester.

To prevent future errors and oversight in the preparation and review process, hard copies of the documents used to prepare the FI SAP will be cross-checked and verified by the Student Financial Aid Director. The documentation of the review then will be re-verified by the Vice President of Business & Finance. The University implemented these procedures for the FI SAP due October 1, 2023.

Enrollment Reporting to National Student Loan Data System (NSLDS) Planned Corrective Action: A review is being completed by the Registrar’s Office to determine if something is in the student record that may prevent a student from being reported correctly. If a common factor can be determined, then it will be corrected. Until then, Enrollment reporting to NSC will be reviewed twice. Follow up will be done regarding last date of attendance reporting for those students who do fail to complete the semester. Person Responsible for Corrective Action Plan: Karen LaQuey, Director, Student Financial Aid Director; Wendy McNeeley, previous Registrar; Kristina Penland, Registrar Anticipated Date of Completion: 12/12/2023

Amberton University will strengthen the internal controls related to NSLDS reporting and provide additional training to ensure data is reported accurately to ensure proper compliance with the established guidelines. The University is also beginning to work with the National Student Clearinghouse in the reporting of enrollment information.

Amberton University will strengthen the internal controls related to notifying students of the requirement to complete Exit Counseling and will provide additional training to ensure proper compliance with the established guidelines. Additional steps have been implemented to provide notification of exit counseling to students.