Corrective Action Plans

Name of Responsible Individual: Sarah Christoffersen, Interim Director of Financial Aid Corrective Action: An incorrect date was used to process one student’s Return of Title IV (R2T4) calculation. Training has been provided to financial aid staff in properly performing the R2T4 calculations and a report is being run several times a month to identify possible data entry errors in R2T4 calculations. Anticipated Completion Date: Completed

Name of Responsible Individual: Sarah Christoffersen, Interim Director of Financial Aid Corrective Action: The majority of the certification delays were one day late. Corrective action has been taken. The financial aid office is working jointly with the registrar’s office to report enrollment information via the National Student Clearinghouse (NSC) which will facilitate more timely reporting of future enrollment status changes to NSLDS and reporting of all significant data elements to NSLDS. Reporting to NSC by the University Registrar’s Office has begun. Anticipated Completion Date: Completed

Name of Responsible Individual: Sarah Christoffersen, Interim Director of Financial Aid Corrective Action: This finding affected a mere 2 of 40 records tested. Corrective action has been taken. The financial aid office has set up daily disbursement record submissions through its financial aid processing system, Jenzabar Financial Aid, which will simplify the process and prevent reporting delays. Anticipated Completion Date: Completed

Name of Responsible Individual: Ruth Casper & Stephanie Furlough Corrective Action: The University Financial Aid Office has restructured the disbursement process as noted below: • Staff members will be retrained on the importance of timely reporting and record compliance. • A disbursement and documentation process will be created to track, manage and reconcile the disbursement requests sent to COD. This process will aidin recognizing approved disbursements, rejected requests, and posting of disbursements. • The disbursement and reconciliation log will be reviewed by the Asst. Vice President for Student Financial Services as well as the Asst Vice President for Analytics & Audit. Anticipated Completion Date: The disbursement procedures will be monitored on an ongoing basis.

The enrollment reporting issue specifically relates to the integrated BS/PharmD degree program. The University's primary operating system, Jenzabar, reports concurrent enrollment status for P1 students and students who have graduated from the bachelor's degree component of the program. Since the National Student Clearinghouse's (NSC's) system automatically overrides the graduation data in the University's Jenzabar report without notifying the University, a two-step corrective action plan has been initiated. The modified reporting process to improve internal controls consists of the following steps: 1. Upload the initial Jenzabar enrollment reporting into the NSC system which will show full-time enrollment for both the bachelor's degree and the PharmD program; 2. File a second report reflecting the date of completion of the bachelor's degree for all students in the integrated program to remedy the NSC system override of graduation data in the initial Jenzabar report; and 3. Conduct a manual verification of graduation data in the National Student Loan Data System to ensure complete, accurate and timely reporting of graduation information from NSC. The modified reporting process is expected to be fully implemented at the conclusion of the 2023-2024 academic year in conjunction with completion of commencement, which is scheduled to occur in May 2024.

Criteria: Regulations require the Institution ensure exit counseling is conducted with each Direct Subsidized Loan or Direct Unsubsidized Loan borrower and graduate borrower shortly before the student borrower ceases at least half-time study. Exit counseling must be conducted within 30 days after the school learns the student borrower has withdrawn from school or failed to complete the exit counseling [34 CFR 685.304(b), (1) & 34 CFR 674.42(b)]. The University concurs with this finding and will adhere to the corrective action plan. Corrective Action: The audit for FY22 was not finalized until June 27, 2023. The plan date for correction for this finding was December 31, 2023. Therefore, the plan was not realized due to the timing of completion of the FY22 audit. Now that the FY23 audit is completed, the Registrar will email exit counseling materials as an attachment to the email or send a email containing URL or hyperlink which will take the student directly to the Exit Counseling page on StudentAid.gov. Responsbile Person(s): Doreen Dixon, Registrar ddixon@vuu.edu 804 257-5845. Robert Merino, Executive Director jrmerino@vuu.edu 281 795-6190. Planned Date of Completion of Corrective Action: December 31, 2023.

Criteria: Under the Pell grant and ED loan programs, Institutions are responsbile for timely enrollment reporting to the NSLDS whether they report directly or via a third-party servicer such as the National Student Clearinghouse (NSC). Enrollment reporting in a timely and accurate manner is critical for effective management of the programs. Enrollment information must be reported within 60 days whenever enrollment status changes for students unless a roster is submitted within 60 days. These changes include reductions or increases in attendance levels, withdrawals, graduations, or approved leave-of-absence. The University concurs with this finding and will adhere to the corrective action plan. Corrective Action: The audit for FY22 was not finalized until June 27, 2023. The plan date for correction for this finding was December 31, 2023. Therefore, the plan was not realized due to the timing of completion of the FY22 audit. Now that the FY23 audit is completed, the Registrar and Information Technology will ensure monthly reporting to the National Clearinghouse. In addition, the Registrar will determine the root cause is corrected and enrollment is reported correctly. These procedures will become part of the Registrar's Standard Operating Procedures. Responsbile Person(s): Doreen Dixon, Registrar ddixon@vuu.edu 804 257-5845. Kofi Jack, Chief Information Officer kjack@vuu.edu 804 257-5709. Planned Date of Completion of Corrective Action: December 31, 2023.

Criteria: Institutions are required to report all Direct Loan (DL) disbursements and submit required records to the Department of Education's Common Origination and Disbursement (COD) which is a web-based system for processing, storing and reconciling DL financial aid data. Each month, the COD provides Institutions with a School Account Statement (SAS) date file which consists of a Cash Summary, Cash Detail and (optional at the request of the school) Loan Detail records. The school is required to reconcile these files to the Insitution's financial records ("DL Reconciliations"). While the University has made significant improvements in this reconciliation process and that of the other related federal award programs, there are still unreconciled differences in all three major federal pass-through program's reonciliations as noted in the financial statement audit. However, for FY23, these differences netted to an immaterial difference overall and were no adjusted / passed during the financial statement audit. However, differences still remain, and the reconciliation process still needs to be improved upon. The University concurs with the audit finding and will adhere to the corrective action plan. Corrective action: The Student Financial Aid activity was reconciled among the Registrar, Financial Aid, and Business Offices as of June 30, 2023, at detailed (student) level. Monthly reconciliations will be maintained effective July 2023. Responsible Person(s): Robert Merino, Executive Director of Financial Aid jrmerino@vuu.edu 218 795-6190. Planned Date of Completion of Corrective Action: December 31, 2023.

The University did not timely disburse a Pell grant to an eligible student within the payment period. Corrective Actions Taken or Planned: Run the pending Pell Grant report weekly and investigate any returning corrections that were delayed by CPS such as this case. Anticipated Completion Date: August 1, 2023 Contact Person: Julie Haack

The University did not accurately or timely report enrollment changes to the National Student Loan Data System (NSLDS). Corrective Actions Taken or Planned: Based on these circumstances of a reported status being overwritten by a monthly update, we will do a random audit of all reported withdrawn students to make sure the correct status has flowed through to NSLDS from NSLC Anticipated Completion Date: December 1, 2023 Contact Person: Julie Haack

Condition: The Institution does not have evidence that exit counseling was provided to students who withdrew or graduated as required by 34 CFR 682.604. Planned Corrective Action: The Iliff School of Theology has contracted with a professional, third-party processing company to administer its student aid programs. The school has also ensured that this third-party processor is properly coordinated with the registrar’s office to meet federal requirements for exit counseling when status changes are processed. Contact person responsible for corrective action: Jason Warr, VP for Business, Controller Anticipated Completion Date: May 2024

Condition: The Institution does not have a documented Direct Loan quality assurance program. Planned Corrective Action: The Iliff School of Theology has contracted with a professional, third-party processing company to administer its student aid programs. The school will coordinate with this third-party processor to ensure that there is a documented quality assurance program that is regularly exercised for compliance purposes. All documentation will be maintained. Contact person responsible for corrective action: Jason Warr, VP for Business, Controller Anticipated Completion Date: May 2024

Condition: Our audit procedures identified an instance where the Institution could not locate evidence that the required R2T4 calculation under federal regulation was completed. The total aid disbursed to this student was $5,125. Planned Corrective Action: The Iliff School of Theology has contracted with a professional, third-party processing company to administer its student aid programs. This third-party processor is adequately skilled to complete Return of Title IV calculations and includes an established review process for quality control. All documentation will be maintained. Contact person responsible for corrective action: Jason Warr, VP for Business, Controller Anticipated Completion Date: May 2024

Condition: The Institution does not reconcile institutional records with Direct Loan funds received from the Secretary of the U.S. Department of Education and the Direct Loan disbursement records submitted to and accepted by the Secretary of the U.S. Department of Education. Planned Corrective Action: The Iliff School of Theology has contracted with a professional, third-party processing company to administer its student aid programs who will ensure that direct loan reconciliations are conducted on a monthly basis in coordination with the business office. Contact person responsible for corrective action: Jason Warr, VP for Business, Controller Anticipated Completion Date: May 2024

Condition: Our audit procedures identified instances of inaccurate or untimely reporting of enrollment information to NSLDS. Planned Corrective Action: The Iliff School of Theology has contracted with a professional, third-party processing company to administer its student aid programs. The school has also ensured that this third-party processor is properly coordinated with the registrar’s office to meet federal requirements for NSLDS enrollment reporting. Contact person responsible for corrective action: Jason Warr, VP for Business, Controller Anticipated Completion Date: May 2024

Condition: Our audit procedures identified instances of MPNs not being properly maintained. Planned Corrective Action: The Iliff School of Theology has contracted with a professional, third-party processing company to administer its student aid programs. The school has also ensured that this third-party processor is properly reviewing MPNs to meet federal requirements. Contact person responsible for corrective action: Jason Warr, VP for Business, Controller Anticipated Completion Date: May 2024

Condition: The institution submitted a FISAP to the U.S. Department of Education that reported inaccurate information in several data fields within the report. In addition, there was no evidence that an individual other than the preparer reviewed the report. Planned Corrective Action: The Iliff School of Theology has contracted with a professional, third-party processing company to administer its student aid programs. Preparation and submission of the FISAP will be completed with coordination between the VP of Business and the third-party processor. This includes a quality review process for accuracy. Contact person responsible for corrective action: Jason Warr, VP for Business, Controller Anticipated Completion Date: May 2024

Condition: Due to the limited number of personnel within the Financial Aid Department, the director of financial aid is solely responsible for packaging, awarding, and disbursing to student accounts Federal Student Financial Aid (Title IV) as well as calculating return of Title IV funds for students who withdraw from the School to student accounts. The packaging of Title IV aid and the return of Title IV funds are complex calculations that are not formally reviewed by another employee. Planned Corrective Action: The Iliff School of Theology has contracted with a professional, third-party processing company to administer its student aid programs. This third-party processing company is structured to properly segregate financial processing and includes a quality review function. Contact person responsible for corrective action: Jason Warr, VP for Business, Controller Anticipated Completion Date: May 2024

Since August 2022, the Financial Aid Office has been responsible for enrolment reporting. The contract with the third-party vendor was terminated, and the process was reassigned to the Financial Aid Office. As of August 2022, the Financial Aid Office staff is required to update the roster monthly through the NSLDS website, no later than 15 days after receiving it. The Registrar’s Office generates a graduate student report at the end of each academic period, and the Financial Aid Office updates the student statuses on the NSLDS website.We commit to implementing the corrective plan for this finding by March 31,2025.

Management will be more vigilant and will review future filings before they are published.

The financial aid department has developed a Direct Loan workflow process in accordance with federal guidelines. Utilizing Colleague's software, the financial aid office can now accurately assess students' aid eligibility to ensure they are appropriately awarded. Colleague has Award Eligibility Critiera (AEC) rules invoked at transmittal to determine if the student is eligible to receive loan funds.

The Univesity implemented a comprehensive ERP software tool, Ellucian Colleague in FY2021 and FY2022 and hired more staff. The built-in internal control structure, which includes access to enrollment reports and data coupled with a complete reconciliation process with the Office of Financial Aid, Office of the Registrar and Student Account wills prevent this from recurring.

Return of Title IV (R2T4) Calculations Planned Corrective Action: Southwestern Christian University will provide more training and resources regarding the R2T4 process of modular withdrawals. Southwestern Christian University will have all R2T4's reviewed by a second financial aid staff member. Person Responsible for Corrective Action Plan: Rita Palmer, Director of Financial Aid/Fully Disbursed, Third­ Party Servicing Agreement Anticipated Date of Completion: Immediately

Credit Balances and Heightened Cash Monitoring 2 (HCM2) Compliance Planned Corrective Action: Southwestern Christian University will provide ongoing training to current staff as well as new staff on HCM1 and/or HCM2 compliance regulations with the Department of Education. SCU will have additional staff review student accounts for credit balances that would result from disbursements of Title IV Aid. Person Responsible for Corrective Action Plan: Rita Palmer, Director of Financial Aid Anticipated Date of Completion: Immediately

Audit Period: June 20, 2022 The finding from the June 30, 2022 Schedule of Findings and Questions Costs is discussed below. The Corrective Action Plan does not include the corrective actions for our discreetly presented component unit, Luna Community College Foundation (LCC Foundation). LCC Foundation does not have federal funds in excess of $750,000. The finding is numbered consistently with the numbers assigned in the schedule. FEDERAL PROGRAM INFORMATION: 2022-005 – Return of Title IV Funds (Other Non-Compliance) Funding Agency: U.S. Department of Education Title: Student Financial Assistance Cluster Assistance Listing Number: 84.007, 84.033, 84.063, 84.268 Award Year July 1, 2021 to June 30, 2022 Compliance Requirement: Special Tests and Provisions CONDITION: In our test work over the Return of Title IV funds, we noted the following noncompliance: In 3 out of 9 students examined totaling $1,733, the College did not return the funds to the Department of Education in the required 45 days after the withdrawal date of the student.CRITERIA: According to 34 CFR 668.173(b), return of Title IV funds are required to be deposited or transferred into the Student Financial Assistance account or electronic fund transfers initiated to the Education of Department as soon as possible, but no longer than 45 days after the date the institution determines that the student withdrew.QUESTIONED COSTS: None EFFECT: The College returned Title IV funds to the Department of Education later than the timeframe required by the program requirements. CAUSE: The College was late in sending the returned funds to the Department of Education for a few of our samples examined because the City of Las Vegas was under a fire emergency due to Calf Canyon/Hermit Peak Fire. Upon return to the College offices, it was noted some of the funds to be returned to the Department of Education had not been processed. RECOMMENDATIONS: We recommend that the College policies and procedures to ensure that it regularly checks any student withdrawals and ensure that they send the Return to Title IV funds within the 45 day requirement. MANAGEMENT’S RESPONSE: The College acknowledges the auditors' comments and has taken steps to address the findings. The college’s Financial Aid department has experienced key staff turnover. In FY23, the college contracted with Attain Partners, a third-party service provider, to enhance our policies and procedures, ensuring alignment with best practices and compliance requirements. Attain, with college staff, are conducting a thorough review of the processes used by the Registrar, Bursar, and Financial Aid Office to improve coordination and the timely reporting of R2T4s. RESPONSIBLE PARTY/TIMELINE TO CORRECT: The Return to Title IV (R2T4) policy and procedures will be updated as necessary to remain current, and all staff will be informed of any revisions. The Interim Vice President of Student Services and the Interim Chief Financial Officer, working with Attain contractors, will review and update R2T4 policies by September 30, 2024. Due Date of Completion: September 30, 2024 Responsible Party: Dr. Loretta Montoya If the U.S. Department of Education has questions regarding this plan, please call me at 505-235-1755. Respectfully, Loretta Montoya Dr. Loretta Montoya Interim CFO