Corrective Action Plans

Finding Number: 2022-001 Planned Corrective Action: Mid-East's Adult Education Financial Coordinator retired at the end of Fiscal Year 2021. As any new position, there was a learning curve and the new Financial Aid Coordinator received limited training with the former Coordinator. Consultants were hired to help, but this specific reconciliation process was not discussed. There has been a recent change in the Adult Education Director's position, and it is the intention of the new Director to eventually cross-train positions. This will assist in the future for a smoother transition between employees leaving and new employees hired. Since the finding, the Adult Education Financial Coordinator has established a checklist of items that need to be completed for each drawdown. This checklist will be placed in each drawdown folder. The Monthly Drawdown Reconciliation plan will include beginning with verifying with Common Origination and Disbursement Center (COD) School Summery report prior to the disbursement. Once the disbursement information is entered into Ed-Express and transferred to COD for the month review of the School Summary report, it will be reviewed to verify that the "Cash>Net Accepted & Posted Disbursements" matches the Achademix Drawdown Batch. Then, again when the disbursement funds are disbursed, a review of the COD School Summary report will occur. At any time, if a variance occurs, it will be addressed immediately. This plan of action went into place with the February 17, 2023 disbursement process. All documentation of any reconciliations will be kept in each drawdown file. The variance of the $866.00 occurred during the final drawdown of Fiscal Year 2022. As the reconciliation process was not in place, the variance was not discovered. As a new Fisca Year started, it was a new batch of funds, and the $866 variance was not discovered until the audit process. The variance was researched and corrected. The correction was located and corrected in Ed Express and had no monetary effect. The School Summary report from COD Cash>Net Accepted & Posted Disbursements" is at zero for 2021-2022, and documentation has been kept on that. The newly implemented checklist and process for reconciliation will prevent variances from happening in the future. Anticipated Completion Date: Currently in place and will continue. Responsible Contact Person: Thasia Shilling, Adult Education Financial Aid Coordinator

Pell Grant ? CFDA No. 84.063 Federal Direct Loans ? CFDA No. 84.268 Federal Supplemental Educational Opportunity Grants ? CFDA No. 84.007 Federal Work Study Program ? CFDA No. 84.033 Recommendation: We recommend that the University document completion of approval and reviews. Views of responsible officials: There is no disagreement with the audit finding. Action taken in response to finding: : Student Financial Services has worked with a consultant from Ellucian Colleague to help us produce monthly reconciliation reports that are directly integrated with Common Origination and Disbursement (COD) System to remain complaint with our regulatory requirement. This action was implemented due to this finding and to ensure compliance in the future. This will provide the needed documentation and approvals for reconciliation. Name of the contact person responsible for corrective action: Rachel Wendorf, Director of Student Financial Services Planned completion date for corrective action plan: In process

Pell Grant ? CFDA No. 84.063 Federal Direct Loans ? CFDA No. 84.268 Federal Supplemental Educational Opportunity Grants ? CFDA No. 84.007 Federal Work Study Program ? CFDA No. 84.033 Recommendation: We recommend the University reevaluate its procedures and review policies surrounding reporting status changes and other enrollment information to NSLDS to ensure timely and accurate reporting. Views of responsible officials: There is no disagreement with the audit finding. Action taken in response to finding: This finding is linked to the reporting errors that many schools seem to be experiencing with their clearinghouse program length reporting. While our program length for a bachelor?s degree is 60 months, the average completion time nationally is 5 years. In order to eliminate errors with aid eligibility, the Registrar set up an automated process that assigns the Anticipated Graduation Date for 5 years from the initial term of entry. NCU has followed this same process for the past 20 years, and it has never raised any concerns. This is a simple time-saving process that eliminates the need to update the Anticipated Graduation date manually for each student who does not graduate within 4 years prior to running the monthly enrollment reports for NSC. As a member of many national organizations, we continue to monitor this reporting challenge as a university to try to reconcile how to report program length for aid eligibility and program length for clearinghouse compliance. In addition, a quality check process is being developed to ensure graduation dates or enrollment timelines are reported accurately to NSLDS. This work is being completed in tandem with our Registrar?s Office who reports to NSLDS through the National Clearinghouse. Name of the contact person responsible for corrective action: Rachel Wendorf, Director of Student Financial Services Planned completion date for corrective action plan: In process

Condition The change in student status for 3 of 25 students tested was not reported to the National Student Loan Data System (NSLDS) timely when the students graduated after the end of the spring term. The University subsequently corrected the 3 student?s status dates in NSLDS. Additionally, management investigated further and identified a total of 255 students who were not reported timely. The University subsequently correct the students' status. Corrective Action Plan Corrective Action Planned: Situation: Incomplete files were sent to the Federal Clearinghouse. The degree transmittal files were incomplete due to an update to the MSOE operating and financial system, Jenzabar, in June that resulted in a loss of scripting that is used to create the file. Due to this loss of scripting, the file did not include names of graduates whose degree was conferred after the upgrade date. Remediation: MSOE IT recreated the scripting, ran a catch-up file, and submitted the file to the Clearinghouse. Ongoing Prevention: MSOE IT sends a copy of the file every week to the Registrar?s Office, who spot checks and samples the file to provide assurance of its completeness. Name(s) of Contact Person(s) Responsible for Corrective Action: Amy Liebl, Student Data Analyst, Registrar?s Office; Michael Timm, Applications Systems Analyst, Information Technology Anticipated Completion Date: September, 2022

2022-003 COD Reporting Recommendation: We recommend the College evaluate its procedures and policies around reporting Pell disbursements to COD to ensure that student information is reported accurately and timely. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Pell disbursements will be reviewed by the Student Aid Coordinator and then by the VP of Student Services to ensure accuracy and timeliness. Name(s) of the contact person(s) responsible for corrective action: Mariel Lee, Shannon Stoughton, Matt Payne Planned completion date for corrective action plan: This change will take place immediately.

Inaccurate and Untimely Return of Title IV Funds (R2T4) Planned Corrective Action: The implementation of the new student information system was completed in October 2022. This will assist in extracting timely data related to course drops and reporting LDAs. The Registrar has implemented a review of all data to ensure it is correct moving forward. Person Responsible for Corrective Action Plan: Derek Pritchett, Registrar and Jennifer Steed, Director of SFS Anticipated Date of Completion: Correction action steps are in place now and monitoring is ongoing.

Finding 2022-007 Federal Agency Name: Department of Agriculture Program Name: Community Facilities Loans and Grants FFAL #10.766 Finding Summary: The fiscal year 2021 audit report was requited to be submitted to the federal agency by September 30th, 2022. We did not provide the 2021 audit report within the timeframe requested by the federal agency representative. Responsible Individuals: Amanda Soesbe, Chief Finance Officer Corrective Action Plan: The CFO will send the audited financial statements to USDA by the deadline. Anticipated Completion Date: 9-30-2023

Finding 2022-002 Federal Agency Name: Department of Education Program Name: Student Financial Aid Cluster CFDA # 84.268 - Federal Direct Student Loans Special Tests and Provisions ? Return of Title IV Funds Finding Summary: 1 of 30 students tested for return of Title IV had a withdrawal determination date outside of the 30-day requirement. For a student who withdraws without providing notification from a school that is not required to take attendance, the school much determine the withdrawal date no later than 30 days after the end of the earlier of 1) the payment period or the period of enrollment, 2) the academic year, or 3) the student?s educational program. Responsible Individuals: Eric Schultz, Director of Enrollment and Marlene Seeklander, Director of Financial Aid Corrective Action Plan: The Registrar?s Office will take the following action: For all programs that have SOE/Internship/Clinical experiences, a roster will be generated, and the instructors will be required to verify that the student has been placed and is actively participating in the SOE/Internship/Clinical. Moving forward, this will be a reminder that is emphasized on a regular basis. At the instructor in-service sessions in August, the Director or Enrollment and Director of Financial Aid present a session which is a series of reminders and other important information that instructors need to know. While we already address the need to notify the Registration Office that a student is no longer attending, we plan to expand on that topic. We will include a slide with the audit finding as outlined so they can see the audit ramifications it has on LATC. We will also explain that this is an institutional responsibility, which includes all staff, all program instructors and all adjuncts. Anticipated Completion Date: Ongoing

2022-002 NSLDS Reporting Recommendation: We recommend the Organization reevaluate its procedure and review polies surrounding reporting status changes to NSLDS to ensure timely reporting as well as put a process in place to ensure the enrollment effective date reported to NSLDS is aligning with the organizations last date of attendance. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Financial Aid staff will utilize the most recent NSLDS Enrollment Reporting Guide, and the corresponding NSLDS Enrollment Reporting Guide Appendices in order to evaluate current procedures and improve upon where necessary in order to be in compliance. The guide and appendices will also be shared with the Registrar?s office for review. The Registrar?s Office and Financial Aid Office will work together to ensure both departments? tasks and processing concerning NSLDS enrollment reporting are done so in a timely manner. The data provided to Financial Aid staff will be reviewed uploaded to NSLDS within one week of receiving it from the Registrar to make certain the reporting is accurate and falling within the required timeframes. The Financial Aid staff and Registrar will revamp current reporting process to reduce risk on incorrect data being reported as well as to ensure all the correct data is being compiled and reviewed prior to reporting. Note: Due to late notification of 2020-2021 Audit Findings, we were unaware of deficiencies in our process, therefore; did not begin corrective action until near the end of 2021-2022 AY. Name of the contact person responsible for corrective action: Jennifer Haavisto Planned completion date for corrective action plan: 3/15/2023

Identifying Number: 2022-005 - USDOE Student Financial Assistance Cluster - Special Tests and Provisions: Students' Satisfactory Academic Progress Ineligibility Finding: The College disbursed funds within 30 days of the first day of class for 12 first year students out of 40 students tested. Name of Contact Person: Karen Overton, Director of Financial AidCorrective Action Plan: The College will create, follow, maintain, and monitor an appropriate satisfactory academic progress (SAP) policy that meets USDOE requirements. The USDOE requires all institutions to sustain an SAP policy that requires students to maintain a 2.0 GPA and successfully complete 67% of their educational program in order to be eligible for financial aid. Anticipated Completion Date: Beginning August 2022

Identifying Number: 2022-004 - USDOE Student Financial Assistance Cluster - Special Tests and Provisions: Early Disbursements to Students Finding: The College disbursed funds within 30 days of the first day of class for 12 first year students out of 40 students tested. Name of Contact Person: Karen Overton, Director of Financial Aid Corrective Action Plan: The College will not disburse any Title IV federal aid until after the first 30 days of classes each semester for all students. Faculty are required to take attendance. On the 30th class day, staff will submit attendance reports for all students. After a review of the reports, staff will only disburse aid for students who have been attending the College for the first 30 days per USDOE regulations. Anticipated Completion Date: Beginning August 2022

Identifying Number: 2022-003- USDOE Student Financial Assistance Cluster-Special Tests and Provisions: Exit Counseling Support Finding: The College could not produce support showing completed exit counseling or proof of an attempt to send exit counseling for 19 students that graduated/withdrew out of 40 students tested. Name of Contact Person: Karen Overton, Director of Financial Aid Corrective Action Plan: The College will provide and document exit counseling information ( or proof of an attempt to send exit counseling) to all graduated and withdrawn students. The College will maintain the evidence through email communication, certified mail receipts, and USDOE Common Origination and Disbursement (COD) reports.

Identifying Number: 2022-002 - USDOE Student Financial Assistance Cluster - Special Tests and Provisions: Enrollment Status Reporting Finding: The College did not report status changes for various students, primarily withdrawn students, within a timely manner as required. Name of Contact Person: Karen Overton, Director of Financial Aid Corrective Action Plan: The College will report status changes for all students, including withdrawn students, every 30 to 45 days which is required by National Student Clearinghouse and National Student Loan Data System (NSLDS). All faculty are required to take attendance. Faculty report excessive absence concerns to lcabscences@louisburg.edu. During the first seven days of classes all students who are identified as 'No Shows' will be reported to the Registrar's Office. After Census Day (the end of Drop/Add), students will be identified who have missed the equivalent of 14 class days per USDOE regulations. These students will be withdrawn according to USDOE regulations. This process will be initially completed in National Student Clearinghouse, per regulations, and then reconciled in NSLDS. Anticipated Completion Date: Monthly, beginning August 2022

Identifying Number: 2022-001 - USDOE Student Financial Assistance Cluster - Special Tests and Provisions: Borrower Data Transmission and Reconciliation Finding: The College was unable to produce the reconciliations for review. Name of Contact Person: Karen Overton, Director of Financial Aid Corrective Action Plan: Using the data files, provided by USDOE Common Origination and Disbursement (COD), the College will upload the files every month into CAMS to perform COD reconciliation monthly. A specific staff has been assigned to perform this task each month. Anticipated Completion Date: Monthly, beginning August 2022

Finding Number: 2022-002 Condition: The University initiated certain returns of Title IV funds after the required timing and, for other students, did not initiate certain returns. The University performed certain return calculations using inappropriate inputs. There were three errors that attributed to this finding: 1.Of the 60 students tested, there were 29 students with discrepancies between the date utilized in return to Title IV calculations and the date required to be utilized based on Federal regulations resulting in $5,990 in questioned costs. 2.Of the 60 students tested there were 18 students identified where the University had returned the funds untimely (45 days if student attended, 30 days if never attended). 3.Of the 60 students tested, there were 4 identified where no return to Title IV calculation was performed and therefore no return of funds until students were selected for testing for the audit resulting in $1,715 in questioned costs. Views of Responsible Officials and Corrective Action Plan - The University agrees with the finding. Planned Corrective Action: The procedures used to monitor, calculate, report, and return Title IV funds are being updated in the following ways to address the errors found and the cause of the errors: ?All procedures will be tied to FSA Handbook and regulatory guidance with references linked as appropriate. This will clarify the procedures being used for the return to Title IV process. ?Procedures will include updated regulations related to module courses. This will address the errors that were caused in misinterpreting these new regulations. ?Methodology for dates being used for end of semester and date of determination will be clearly documented for each semester along with the actual dates used. For non- modular courses, the end of semester date will be the Friday of final exam week. (This will be verified via guidance received from the ask regs function of NASFAA.) This will clarify the required deadlines for each semester. ?A new report generated from our Data Warehouse system will be used to reconcile all required returns for a given semester have occurred. This will address students who were also missed in the prior year process. Contact person responsible for corrective action: Brian Bell, Director Student Account Services Anticipated Completion Date: 10/31/2022

Finding Number: 2022-001 Condition: The University did not report certain students' status to NSLDS in an accurate and timely manner during the fiscal year. There were three errors identified that attributed to this finding. 1. Of the 40 students tested, there was 15 students who withdrew/graduated whose status change was not reported accurately to the NSLDS. Student withdrew or graduated and was reported but with an incorrect effective date. 2.Of the 40 students tested, there were 7 students who withdrew/graduated whose status changes were not reported to the NSLDS within 60 days. 3.Of the 40 students tested, there were 6 students who withdrew/graduated whose status change were not reported to the NSLDS. Views of Responsible Officials and Corrective Action Plan - The University agrees with the finding. Planned Corrective Action: Following guidance provided via Plante Moran and the Dept, of Education (2020-2021 desk file review and NSLDS direct support), we will be implementing the following changes effective Fall 2022 to address correct enrollment status change reporting by: ? Adopt the use of the published academic semester end date for enrollment reporting vs using the long-standing use of the SAP/SLCM 100 Date or end of a semester payment period. It was learned that published end of an academic semester, per the Academic Calendar, is expected to be reported for use in applicable enrollment compliance timing calculations. ? Registrars will update NSLDS with the actual status effective date when learned for all unofficial withdrawal or graduated statuses. This date will be the earliest date at which Registrars retroactively learns was the actual last date of attendance that created an enrollment status change. Our past practices did not update such students but used the end of the previous semester date (SAP/SLCM 100 Date) if a student was shown to be enrolled in the next upcoming semester. This corrective action will occur for all cases even if the student is not required to have a R2T4 initiated, due to having attended at least 60% of the semester. Students who officially withdraw, in part or total, during a given semester are found in our monthly enrollment reporting as last date of attendances are supplied at the time of formal withdrawal. ?Registrars will enhance or develop (if not already in place), in conjunction with SASUB, necessary control reports to ensure accuracy of identifying students who are unofficial withdrawals at the end of an academic semester and adjust staffing resources as necessary to account for critical time periods such as the period between CMU?s Fall and Spring semesters when the university is closed. This will be necessary due to using the published last date of the semester instead of the end of the payment period date that was used in prior years. ?Planned timeline to complete corrective actions is February 2023 to account for end of Fall 2022 grading processes and manual updating of NSLDS as necessary for identified unofficial withdrawals. ?Contact person responsible for corrective action: Keith Malkowski, Registrar ?Anticipated Completion Date: February 2023 following end of semester grading and subsequent student record updating per our Date of Determination process.

Identifying Number: 2022-001 Finding: During the course of testing, the University incorrectly calculated Pell grant on one student from a sample of 40, incorrectly calculated a Title IV refund on one student from a sample of 2, and did not complete a Title IV refund within 14 days on one student from a sample of 25. Corrective Action Taken or Planned: Wittenberg University's Office of Financial Aid has seen changes in staffing over the last two years with new employees having limited experience regarding student financial aid federal, state and institutional regulations. These changes have caused delays and misunderstandings related to Pell grant calculations and Title IV refund calculations. As of November 2021, one part-time financial aid employee was hired and in December 2021, the other open position (full-time status) was filled. With new employees being continuously trained and developed on federal, state and institutional guidelines, the Director of Financial Aid, or their designee, will review all calculations performed by employees moving forward. The institution will also implement reporting tools to ensure Pell, Title IV refunds, and other calculations are correct based on federal, state and institutional guidelines. Wittenberg University's Office of Student Accounts has also seen changes in staffing over the last two years with new employees having limited experience regarding accounts receivables and Title IV regulations. These changes have caused misunderstandings around Title IV refunds. The Office will implement new reporting tools where all credit balances on students' accounts will be reviewed and, if applicable, refunded at least once per week. The weekly reports and refunds will be monitored and reviewed by the Controller, or their designee, per week in consultation with the Office of Student Accounts. Completed Date: Fiscal year 2023

A control has been added to require a member of the accounting department to review the FISAP prior to submission

The Title IV withdrawal calculation was complete on COD, but the amount the student was eligible for was transposed when entered on the internal withdrawal calculation form. A secondary review will be done prior to adjusting federal funds in the College?s internal system. This process was implemented February 15, 2023, and the responsible college official is Tina Wiseman, Director of Financial Aid.

The Registrar?s Office will use the date the student confirms their intent to withdraw. If that isn?t available, then the last available date of attendance will be used. The College is not an attendance taking college according to its policy and procedures and that has been revised in the academic catalog. This process was implemented February 15, 2023, and the responsible college official is Tina Wiseman, Director of Financial Aid.

The Financial Aid Office has updated its internal procedures to ensure disbursements for first-time borrowers will not occur until after the 30 day delayed requirement. To ensure this procedure, the disbursement date has been calculated for 30 days after the first day of class for first-time borrowers on the Period of Enrollments (POE). This process was implemented October 1, 2022, and the responsible college official is Tina Wiseman, Director of Financial Aid.

The College has implemented a weekly review and refund of student account credit balances to maintain compliance with this requirement. This process was implemented August 22, 2022, and the responsible college official was Diane Bozarth, Chief Financial Officer, who retired January 6, 2023. The new responsible college official will be Julie Straus, Chief Financial Officer.

The district has entered into a contract with Huron Consulting Group to address the internal controls pertaining to returning funds and reissuing funds back to students. District Finance has been working closely with each College to return funds to the Department of Education. Queries have been created to identify returned checks which will be monitored on a regular basis to reverse financial aid disbursements and re-report changes to COD. Planned completion date for corrective action plan: March 31, 2023.

The District Administration & Records will perform a study of the current business processes to identify data discrepancies. The District will engage the Clearinghouse and review the applicable reporting procedures with the financial aid offices to ensure sound internal controls over reporting and updating of NSLDS enrollment data. Planned completion date for corrective action plan: June 30, 2023.

The district has entered into a contract with Huron Consulting Group to address internal controls pertaining to reconciliation of Title IV funds, R2T4 processing, award packaging and verification. Huron has created more robust packaging and disbursement rules to ensure only eligible students are awarded and paid. Additionally, the district has created business processes and procedures to improve internal controls over federal awards. While the cutoff date for the audit was missed for the 2021-2022 school year, corrective actions have been taken to ensure the reconciliation of Title IV funds and secondary reviews have been completed and are currently underway for 2022-2023. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Planned completion date for corrective action plan: June 30, 2023.