Corrective Action Plans

REPORTING Fairmont State University, West Virginia State University, Bluefield State University, West Virginia Northern Community College, West Liberty University, Southern West Virginia Community and Technical College, Pierpont Community and Technical College, Concord University, Mountwest Community and Technical College, and Glenville State University Assistance Listing Number 84.425E, 84.425F, 84.425J, 84.425M Fairmont State University (FSU) response In regard to the Annual Reporting of HEERF, the Controller will work with the Financial Reporting Manager to ensure the annual data is accurate and reflects the data reported on the quarterly reporting for the same period. The Controller will perform data entry of all required fields in the annual submission website. Once complete, an email will be sent to the CFO for final review and approval. The CFO will provide email correspondence that the review is complete and the reporting is approved for submission. The CFO will submit the annual report via the reporting website. This action was implemented January 2023. West Virginia State University (WVSU) response WVSU developed and documented an internal control procedure to ensure compliance of HEERF Reporting. This procedure includes a dual review and sign off process by Business and Finance before the report is posted to WVSU?s website. This review includes ensuring accurate forms are being used for reporting. Additionally, screen captures are saved to provide a date/timestamp of when the report was made public. The control was implemented on or before July 1, 2022. Bluefield State University (BSU) response BSU has strengthened internal controls over reporting of HEERF funds to assure that the posting to the University website in a timely manner is documented in writing. BSU posted all reports to the University website on or before the filing deadline. However, we did not receive written documentation from our IT department to document the timely posting. We have revised our internal control procedures to ensure that that we receive and retain documentation of the posting date. BSU inadvertently used incorrect terminology to describe some of the emergency grants to students made from the Student Portion of HEERF funds. The reports selected for testing were for the Student Portion of funds that was reported in a narrative format. The revised reporting form issued by the Department of Education combines the reporting of Student, Institutional and HBCU funds on one standard form. This will eliminate these types of errors in subsequent reporting. West Virginia Northern Community and Technical College (WVNCC) response WVNCC is aware to include the total amount of grants distributed, the estimation of students to receive a grant and the total amount of students to receive the grant from the calculations used to issue Emergency Financial Aid Grants. In addition to reporting the method used to determine award amounts to students prior to the awards being disbursed, WVNCC will also include the method used in future reporting. As an added layer of review, WVNCC will include a third report reviewer from Student Accounts to verify the number and dollar amount of awards disbursed to be included in the report. This action was implemented in January 2023. West Liberty University (WLU) response As of January 2023, federal drawdowns are reconciled and reviewed prior to the drawdown. The signature of the Controller or CFO is on each drawdown with the date of review and approval. The drawdown is then completed usually on the same date as the review and approval. Southern West Virginia Community and Technical College (SWVCC) response SWVCC has enhanced its procedures surrounding the preparing, updating, and reviewing of quarterly and annual reports for the HEERF Education Stabilization Fund (and all other federal awards). The information utilized to prepare the reports is now dated and saved for future reference. The individual compiling the report documents the date the report is completed and submits it to the reviewer. The reviewer documents the date of review and any adjustments made to the report. The review is completed before the report is posted to the institution?s website and all documentation will be maintained for audit review. These procedures are in place as of January 2023. Pierpont Community and Technical College (PCTC) response PCTC?s staff and administration have reviewed the reporting requirements for HEERF funding to ensure quarterly and annual reports are accurate and timely. All staff involved in the reporting process, which includes the offices of Financial Aid, Registrar and Finance, have been directed to document and retain all source data used in the reporting process. A documented review process was put in place in October 2022 to ensure review by a supervisor and a final review by the Vice President of Finance and Administration/Chief Financial Officer or the Comptroller. Evidence of the review process is demonstrated through sign offs and/or e-mail communications. Concord University (CU) response Beginning with the December 2022 quarterly reporting, the coordination and approval of all reports will continue to be documented electronically. Additionally, the level of review/approval for the generated reports prior to posting will also be documented, and all work orders requesting the public posting of approved reports will include a cited reminder of the federal posting deadline for grant compliance. This additional information in the requested work order will ensure all parties involved are aware of and meet the required posting deadline. These steps were taken for the December 2022 Institutional Portion (CFDA #84.425F) quarterly reporting and resulted in a timely posting. The Student Aid Portion (CFDA #84.425E) final reporting occurred during fiscal year 2022. Mountwest Community and Technical College (MCTC) response For student reporting ? Q4 FY2021 and Q3 FY2022 there were no student reports prepared for these quarters. MCTC submitted OMB Control Number 1840-0849 with no expenditures reflected for HEERF I, II, or III Student Portion for FY21 Quarter 4 and FY 22 Quarter 3. All funds were fully expended by the end of FY 22 Quarter 2. Although there were no HEERF Student Portion funds expensed during the Quarters in question, MCTC has acknowledged that the language on the website should have been updated to disclose all funding as awarded and final. As a response to the finding, MCTC will develop a Quarterly Reporting schedule for posting on the website to capture all awarding activity from HEERF I, II, and III from point of initial receipt of HEERF funds through the grant end period, June 30, 2023. For Institutional Reporting ? Q4 FY2021 institutional report was not posted timely within the 10-day reporting requirement. This occurred before the PY corrective action plan was implemented. A corrective action plan was submitted on February 17, 2022 and all subsequent quarterly reports have been submitted timely. Glenville State University (GSU) response GSU implemented and strengthened internal controls surrounding the reporting for both HEERF II and III in February 2022. GSU has created and filled the position of Director of Grants Compliance. This new Director has direct oversight and assurance of GSU?s compliance with all grant reporting requirements. The Director will prepare and maintain a ?Master? checklist for all grants received by GSU. The checklist will be monitored and updated as reporting or compliance steps are met by the Director. The Director will coordinate with the relevant personnel with reporting or compliance responsibility over the grant to ensure the compliance expectations are met timely.

SPECIAL TESTS AND PROVISIONS ? DISBURSEMENTS TO OR ON BEHALF OF STUDENTS Pierpont Community and Technical College (PCTC) Assistance Listing Number 84.007, 84.033, 84.038, 84.063, 84.268, 84.379, 84.408, 93.264, 93.342, 93.364, 93.925 PCTC?s standard procedure for disbursement letters is to have the Information Systems Specialist (ISS) provide letters for review to the Director of Financial Aid before mailing. This was either not done by the ISS or overlooked by the Director. The process has been reviewed and communicated to the current Information Systems Specialist as well as the Assistant Director of Financial Aid. The Assistant Director of Financial Aid is authorized to review letters in the absence of or instead of the Director. This action was implemented January 2023.

SPECIAL TESTS AND PROVISIONS ? BORROWER DATA TRANSMISSION AND RECONCILIATION Pierpont Community and Technical College and West Virginia State University Assistance Listing Number 84.007, 84.033, 84.038, 84.063, 84.268, 84.379, 84.408, 93.264, 93.342, 93.364, 93.925 Pierpont Community and Technical College (PCTC) response Beginning July 1, 2022, PCTC has updated the monthly reconciliation process. The Direct Loan School Account Statement (DLSAS) reports from Common Origination and Disbursement (COD) are downloaded by the 10th of each month, as before, by the Information Systems Specialist (ISS). The reports are now provided to the Assistant Director of Financial Aid (Asst.) and then reconciled to both Banner paid and COD approved Direct Loan disbursements. Reports verifying reconciliation are then completed and saved by the Assistant Director of Financial Aid and reviewed by the Director of Financial Aid for completion and accuracy. PCTC will maintain the documentation of the DLSAS statements each month and the reconciliation report along with evidence of said review. West Virginia State University (WVSU) response After each weekly disbursement, the Financial Aid Technician requests a Year-to-Date SAS Disbursement Detail on Demand Report from COD. The report is compared with the disbursement data within Banner and a COD/Banner Comparison Report is generated. The comparison report is sent to the Associate Director of Financial Aid and Director of Financial Aid to correct and document any discrepancies and if necessary, refers to the monthly DLSAS reports to verify resolution to any found discrepancies. The monthly DLSAS report is reviewed each month by the Director of Financial Aid to confirm consistency between fund disbursement and drawdownsreturn of payments by the Fiscal Office. The Director of Financial Aid and Business and Operations Manager both sign off weekly confirming accuracy. Effective August 2022, policies and procedures have been updated so any corrections applied will be documented, dated and saved by the Associate Director of Financial Aid and/or Director of Financial Aid.

FINANCIAL REPORTING Pierpont Community and Technical College and West Virginia State University Assistance Listing Number 84.007, 84.033, 84.038, 84.063, 84.268, 84.379, 84.408, 93.264, 93.342, 93.364, 93.925 Pierpont Community and Technical College (PCTC) response PCTC?s Assistant Director of Financial Aid (Asst.) will take screen captures of both Banner and the Common Origination and Disbursement (COD) for a monthly reconciliation of the Federal Pell Grant program. Screen captures will be printed, and comparisons will be made by the Asst. All necessary adjustments will be performed to student accounts by the Asst. or Director of Financial Aid (Director) until balanced. The Asst. will sign as an approval on reconciliation documentation and provide to the Director for review and approval. The completed monthly reconciliation information will be retained in the completed reconciliation information file on the shared drive. This process has been implemented as of July 1, 2022. The updated procedure will ensure timely processing of all federal Pell grants to students and updates in the COD system. West Virginia State University (WVSU) response Effective January 2022, WVSU reports information to COD daily. Originations and fund adjustments are imported and exported Monday through Friday for students who meet eligibility requirements by the Financial Aid Technician and the import reports are reviewed by both the Technician and a FA Administrator with corrections being made to any errors and/or rejections. The disbursement process of applying aid to student's accounts occurs weekly throughout the semester after enrollment hours have been confirmed. The disbursement process in Ellucian Banner is completed by the Financial Aid Technician and funds are applied to student's accounts. The Director of Financial Aid proceeds to review the disbursement roster to confirm accuracy of fund sources, fund amounts and enrollment hours after the disbursement process has finished. The Financial Aid Technician sends the disbursement files to COD after the disbursement roster has been reviewed, and loads the response files the following morning. The load response files are reviewed by the Associate Director of Financial Aid and Director of Financial Aid to confirm acceptance. Both the Director of Financial Aid and Business and Operations Manager will sign off weekly confirming accuracy. Policies and procedures were updated August 2022 so that any corrections applied will be documented, dated and saved by the Associate Director of Financial Aid and/or Director of Financial Aid.

FISCAL OPERATIONS REPORT AND APPLICATION TO PARTICIPATE Fairmont State University, West Virginia State University, and West Virginia School of Osteopathic Medicine Assistance Listing Number 84.007, 84.033, 84.038, 84.063, 84.268, 84.379, 93.264, 93.342, 93.364, 93.925 Fairmont State University (FSU) response As of January 2023, the Financial Reporting Manager will complete Part II of the Fiscal Operations Report and Application to Participate (FISAP) submission. The Controller will review and compare with audited financial statements to ensure the correct amounts are recorded prior to approval and submission by the institution. West Virginia State University (WVSU) response This finding was a result of inaccurate reporting. The dollar amounts used for tuition and fees in the original calculation were incorrect. The supporting documentation was updated after submission of the FISAP to include correct numbers. To prevent this from occurring in the future, a dual review will be required for all reporting data. The Office of Financial Aid and Scholarships will verify the Federal Work-Study (FWS) and Supplemental Education Opportunity Grant (SEOG) fund allocations are identified correctly on the FISAP, in regard to transfer of funds, to accurately reflect the allotted fund amounts and amounts paid to student accounts in Banner. These changes were made effective March 2022 and reflected in the FY22 FISAP. West Virginia School of Osteopathic Medicine (WVSOM) response Internally generated reports used to prepare the FISAP from WVSOM?s management system have been modified to ensure accuracy and clarity of the data. Procedures are in place for a secondary review of the report prior to submission.

SPECIAL TESTS AND PROVISIONS ? ENROLLMENT REPORTING Fairmont State University, Blue Ridge Community and Technical College, Pierpont Community and Technical College, West Virginia State University, and Marshall University Assistance Listing Number 84.007, 84.033, 84.038, 84.063, 84.268, 84.379, 93.264, 93.342, 93.364, 93.925 Fairmont State University (FSU) response The Appeals committee has updated policies and procedures to include the Business Analyst and the Registrar on the email communication list when a retroactive drop that changes enrollment status and/or a retroactive withdrawal is approved. FSU will identify the steps necessary at the National Student Clearinghouse to update the student?s status because this status update will be after the term has ended. FSU has put this plan into action already and will begin cleaning up retroactive drops and withdrawals from here on out. Blue Ridge Community and Technical College (BRCTC) response BRCTC provided training in October 2022 to appropriate staff members on the proper maintenance of record retention. Pierpont Community and Technical College (PCTC) response PCTC?s procedures to Title IV refunds were updated in January 2023 to enhance communication between the Financial Aid and Finance offices to ensure Finance has a copy of the student letter and additional Finance Office staff now have access to the Return to Title IV (R2T4) tracking sheet. The R2T4 tracking sheet is monitored by both the Financial Aid and Finance staff to ensure all refunds are returned within the required 45-day time period. The Director or Assistant Director of Financial Aid also review the return of aid calculations to ensure accuracy. West Virginia State University (WVSU) response Effective January 2022, WVSU utilizes the National, Student Clearinghouse (NSC) to update student?s enrollment and its effects on student?s direct loan and Pell statuses. Thorough edit checks of student data for each semester will be produced by IT on a regular basis. The Office of the Registrar, in coordination with Admissions, Dual Enrollment, and other contributors of student data, will make sure these errors are corrected. Special focus will be placed on resolving these errors before each enrollment file is produced. (Initial Data Integrity, First Check). On or around the 25th of each month, IT will produce the NSC enrollment file. Each time the file is produced, the file will be sent to the Registrar for review to ensure accuracy of the data being pulled from Banner. Registrar sends approval for upload to NSC. (Process Integrity, Second Check) The file will be uploaded to the NSC by IT, ensuring NSC received the appropriate number of records. The data will then be reviewed and any discrepancies in the data, when compared with past data, will be resolved in a timely manner. The Registrar, as the ultimate steward of student enrollment data, has taken full responsibility for resolving NSC errors. The NSC process makes sure these errors are resolved before the data is reported to the NSLDS, it is the responsibility of the Registrar to make sure these are resolved with accurate data. (Data Integrity, Third Check) After resolution of errors, the NSC will perform a final review of data before sending to the National Student Loan Data System (NSLDS). This will be reported on the NSLDS Reporting tab of the Enrollment Reporting screen in the NSC website. If data is satisfactory, the submission will be marked with "Congrats. No Errors!" by the originator "CH" (Clearinghouse). The NSC sends emails whenever these items are updated. It is the responsibility of the Registrar to review and resolve any errors in a timely manner. (Data Integrity, Fourth Check) The enrollment data is then submitted to the NSLDS. After NSLDS reviews the data, any errors will be reported back through the NSC in the same manner as NSC errors. Resolution of these errors is of special importance and will be given top priority. The NSC sends emails whenever these items are updated. It is the responsibility of the Registrar to review and resolve any errors in a timely manner. (Data Integrity, Fifth Check) Marshall University (MU) response As approved by Faculty Senate and the President, the 2023 academic calendar has been adjusted so that MU?s summer semester is now one long term with parts of term within it. This calendar revision more closely resembles the current fall and spring semesters. Now that summer is one term with parts of term within, this will allow MU to report enrollment to the National Student Clearinghouse on a multiple report date submission schedule throughout the summer term.

SPECIAL TESTS AND PROVISIONS ? RETURN OF TITLE IV FUNDS West Virginia State University, Pierpont Community College, Bluefield State University, New River Community and Technical College, and West Liberty University Assistance Listing Number 84.007, 84.033, 84.038, 84.063, 84.268, 84.379, 93.264, 93.342, 93.364, 93.925 West Virginia State University (WVSU) response Effective January 2022, a weekly report of complete withdraw students is generated and an initial review and calculations are performed by a Financial Aid Administrator. A second review of the student?s record and calculations are then completed a second time by the Associate Director of Financial Aid or the Director of Financial Aid. After the second review is complete, the initial reviewer will update the student account accordingly and perform any Return of Title IV (R2T4) funds needed. The second reviewer will confirm that updates are accurate. Both the initial and second reviewer will sign off on R2T4 calculation documentation for the student's file. Pierpont Community and Technical College (PCTC) response Communication between the Financial Aid and the Finance offices will be enhanced to ensure Finance has a copy of the student letter and additional Finance Office staff now have access to the return of Title IV (R2T4) tracking sheet. The R2T4 tracking sheet will be monitored by both the Financial Aid and Finance staff to ensure all refunds are returned within the required 45-day time period. This process was implemented in January 2023. Bluefield State University (BSU) response In January 2023, BSU implemented controls to perform the Return of Title IV (R2T4) withdrawal and calculation to ensure that records comply and that return of R2T4 funds are within the required time frame of 45 days. Controls include the review of ?Permit to Withdraw? forms to ensure they are completed with all signatures of the offices involved and the sign-off of R2T4 calculations. All reviews will occur within the time frame of 45 days by the Interim Financial Director along with Business Office and Accounting. In December 2022, the Interim Financial Aid Director spoke with the Registrar and the Financial Aid Counselor in separate meetings regarding the late submission of withdrawal forms and performing the R2T4 calculations. The Registrar understands they must submit the completed withdrawal forms to the Financial Aid office the same day they are completed by her office. When the forms are received by Financial Aid an R2T4 will be completed within the same week of receipt and sent to the Business Office if a return of Title IV Aid is required. The Business Office will then review the calculations and perform the necessary repayment of Title IV Aid to the Department of Ed, utilizing the refund process through G5 within the required 45 day timeline. All adjustments to the students account will be made within the same time frame. New River Community and Technical College (NRCTC) response The Registrar's office will request the error report from IT. At that point the Registrar?s office will work on correcting the errors on the report. The Registrar?s office will request IT to run the error report again to make sure all errors are clear. Once all errors are clear from the report the Registrar?s office will request IT to send the enrollment report so that it can be submitted to the National Student Clearinghouse (the Clearinghouse). Once the enrollment report is received from IT someone in the Registrar?s office will upload the report in the Clearinghouse. The Registrar?s office will make sure the Clearinghouse report is submitted by the due date and errors sent by the Clearinghouse are corrected in a timely manner. The Registrar's office will run a random selection of 20 students from the National Student Loan Data System (NSLDS) to make sure students are correct in the Clearinghouse, which will be done at least 50 days out from the time students were initially reported. IT and someone in the Registrar?s office will sign off on these processes when the report is run, when the report is reviewed, and once the report is sent. The Registrar's will run the Failure Irregular Withdrawal report daily, instead of weekly to ensure all students who have not attended classes are taken out within a timely manner as soon as they are reported by the instructors. These procedures were implemented in August 2022. West Liberty University (WLU) response When the Registrar Office is recording and entering data for Withdrawal (WD) students, a review and approval process has been implemented to ensure dates and information are entered accurately and timely.

INTERNAL CONTROL ? PAYROLL Department of Health and Human Resources (DHHR) Assistance Listing Number 93.558, 93.658, 10.557 For the condition whereby a timecard for the WIC program was not approved by a manager in the automated payroll system, the DHHR Office of Human Resources Management (OHRM) received confirmation from the manager that the timecard was accurate. However, the confirmation was not obtained until after the state?s independent auditors inquired about the timecard. To enhance the controls and improve the documentation surrounding timecard approvals in general, the OHRM has instructed their payroll processors to use a log to note any issues with timecards prior to signing off on the timecards within the automated payroll system. The log will be shared with timekeepers and managers in the field (i.e., the various DHHR bureaus and offices throughout the state). The timekeepers and managers in the field will be required to note resolution of the issues directly on the log. If there are any unresolved issues remaining after signing off on the timecard in the system, the issues will be documented along with the manager?s actions. The ultimate goal is to obtain management approval for every timecard, whether such approval is documented directly within the automated payroll system prior to sign-off or documented outside of the system after sign-off. As is always the case, if adjustments to a timecard are necessary after the sign-off process, the OHRM will utilize their ?OHRM-36 Kronos Time & Leave Correction" form. When deemed necessary, the log and any related documentation will be shared with the state?s independent auditors during fieldwork for the West Virginia Single Audit. The anticipated date for completion of the log and the procedures related thereto is February 10, 2023. For the condition whereby the payroll system was unavailable due to a ransomware attack, the OHRM switched to a manual timekeeping system immediately after the attack and developed processes and controls related thereto. However, as the state?s independent auditors indicated, the OHRM did not maintain adequate documentation related to the controls and the precision of the controls in all instances. Accordingly, the OHRM is working on a contingency plan to document the steps to take in the event of another ransomware attack or any other incident that causes the automated payroll system to be unavailable. The anticipated date for completion is March 31, 2023.

DHHR INFORMATION SYSTEM AND RELATED BUSINESS PROCESS CONTROLS Department of Health and Human Resources (DHHR) Assistance Listing Number 10.551, 10.561, COVID-19 10.561, 10.542, 93.558, COVID-19 93.558, 93.568, COVID-19 93.568, 93.575, 93.596, COVID-19 93.575, 93.658, 93.659, 93.767, 93.775, 93.777, COVID-19 93.777, 93.778, COVID-19 93.778, ARRA 93.778 Enhancing the Quality Control process (by adding other programs to the overall scope and expanding the populations for sampling to include payments that have case data that is initiated and approved by the same person as well as case data that is entered by one person without another level of approval) would prove costly for the DHHR due to the additional staff throughout the DHHR that would be required to accomplish such a task. Although enhancing the Quality Control process is still a possibility, upon further discussions within the DHHR, it was determined that prior to considering such an enhancement, the Bureau for Social Services, Bureau for Family Assistance, and other DHHR units should work together to perform the following: outline the existing internal controls over payments by payment type or program, determine the number of payments per month whereby one employee initiates and approves a payment (in relation to the population of all payments) and conclude on the risk of those payments being improper. Management can then identify areas of focus to conclude on the adequacy of the internal controls and make revisions to policies and procedures, if necessary. In short, although there are existing controls in place, the controls have not been documented and communicated to the State?s independent auditors in an effective manner.

2022-001 Student Financial Assistance NSLDS Enrollment Reporting Recommendation: We recommend the College continue to follow the corrective action plan as it relates to enrollment and program status reporting to NSLDS to ensure all status changes are reported timely with the correct effective dates. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: A cross-disciplinary group of institutional staff meets to discuss and continue remediation efforts. The Director of Enrollment Services obtains and reviews internal data reports to inform further assessment. Once the review of specific cases was completed, the Director of Enrollment Services performed a full file review for the 21-22 year, making changes necessary as a result of that review. The Director of Enrollment Services engaged in a review of policy and procedures and individuals responsible for enrollment reporting to the NSLDS including, but not restricted to, 1) review of the institution?s data in the BANNER system; 2) the institution?s set up and interface with the National Student Clearinghouse, and 3) internal staff policy and procedure for staff engaged and responsible for enrollment reporting to the NSLDS for the institution. The Director of Enrollment Services consults with personnel and continues to assess appropriate protocols. In addition, the Director of Enrollment Services directs personnel on needed training including, but not restricted to, FSA conference sessions, FSA Training portal suite pedagogy, and the National Student Clearinghouse Academy. Name(s) of the contact person(s) responsible for corrective action: Renee Ojo-Ohikuare, Director of Enrollment Services. Planned completion date for corrective action plan: June 30, 2023 If the Department of Education or the Office of the Secretary of Higher Education have questions regarding the documented plans above, please call Evens Wagnac at 973-877-3040.

Finding 2022-001 Enrollment Reporting Views of Responsible Officials The University agrees with the auditor?s findings and recommendations. Corrective Action Plan The University has implemented additional training for this compliance requirement to ensure that changes in enrollment status are recorded correctly in the system and reported accurately. Additionally, the University will resolve status change discrepancies and review status change reporting output monthly to ensure that changes are reported accurately. Implementation Date Immediate Individual(s) Responsible Yvonne Harwood, Vice President of Institutional Effectiveness and Becky Wilson, Assistance Vice President of Financial Assistance

Corrective Action: (SSS): SSS will verify student?s low-income levels for those with a FAFSA on file by having the University?s Financial Aid Department confirm that the student?s income is low-level per the Student Aid Report and FAFSA University?s Financial Aid Department confirm that the student?s income is low-level per the Student Aid Report and FAFSA. The EFC that is listed at $0 is information that is derived from the institution?s Financial Aid Department that is uploaded into Banner once the department verifies the information which comes from the FAFSA and parent/student taxes. (TS): Students in question were offered allowable activities (e.g., tutoring, career/college exploration) by TS program staff. However, these eight students elected to forgo involvement in permissible activities. During the audited period, the former TS program director retired and a new program director was hired. There was no overlap between the former and new program director. The TRIO Tracking Specialist reviewed, signed, and initialed documents in the absence of the TS Director. The applications audited show evidence of the initials of the TRIO Tracking Specialist which was intended to provide evidence of internal program control. Timeline of Corrective Action: 1. The above processes will be put in place by December 31, 2022. 2. A review of related TRIO grant processes and eligibility requirements for students currently involved in the programs will be conducted by June 30, 2023. 3. In addition to the above steps, the Roswell campus is in the process of reviewing the job description for a grants director to oversee federal grants. This position would include oversight of compliance with federal rules, regulations, guidelines, and campus policies. The ENMU-Roswell Campus HR office reviewed the grants director job description and started the process of posting this position on October 24, 2022. It is anticipated this position will be filled by January 31, 2023. 4. Additional compliance discussion sessions and grant requirement reviews for the involved TRIO grant program directors will take place in November 2022 with the campus senior leadership. Responsible Party(ies): Roswell Campus; Assistant Vice President of Student Affairs

Corrective Action: Management agrees that students were not properly reported to the Clearinghouse or NSLDS again and that all of the proposed corrective action in FY 21 did not occur. The registrar did not utilize NSLDS access until October 2022 and was not able to verify the submissions. Timeline of Corrective Action: Immediate. The registrar now has access to NSLDS as well as the Clearinghouse and has established procedures to verify the submission after every upload. The Financial Aid and Registrar Offices have agreed to meet quarterly to review submissions and to include Roswell offices in the meetings too. Responsible Party(ies): Registrar; Portales Campus

Management?s Corrective Action Plan: The University acknowledges the finding and the recommendation from Moss Adams regarding improving procedures. Finding-2022-001 Special Tests and Provisions-Enrollment Reporting-Significant Deficiency in Internal Controls Over Compliance Improved Process of Protocol: The University will implement corrective action during November 2022 related to the filing of the NSLDS report. This will include updating monthly reporting to National Student Clearinghouse when responding to NSLDS roster files rather than every other month. Additionally, the department has revised paperwork for graduating students to ensure status are processed in a timely manner by the Registrar. Contact Person Responsible for Corrective Action: Raquel Munoz. Registrar Anticipated Completion Date: November 2022

Views of Responsible Officials and Corrective Action Plan We concur. Admissions and Records is aware of this issue and the impact that is has on the NSLDS reporting and will implement a business practice that includes a collaboration with Financial Aid and Academic Affairs to address this matter. Additionally, Admissions and Records will work with Academic Affairs to implement a district policy to enforce faculty drops by the established deadlines. Lastly, a recent update was applied to our Banner ERP system on November 13, 2022, to address a known defect that prevented faculty from dropping students by the class census date and W deadline.

Finding No. 2022-002 - Title IV Credit Balances The missing of the fourteen-day deadline by one day was an outlier caused by new staff lacking an understanding of how to calculate the timeframe when a holiday is involved. All staff involved in the refund process have been retrained in the regulations that must be followed. Rogen Miller, Bursar, is responsible for this corrective action plan which has been implemented.

Finding No. 2022-001 ? Enrollment Reporting The University is in the process of correcting the 64 students that were identified as withdrawn instead of graduated. The University is reviewing the data submitted for the May, July and August 2022 conferral dates for the same issue. It should be noted the NSLDS system cannot be updated at this time which is beyond the control of the University. The University has experienced turnover in the Registrar?s Office and will provide additional training to all staff to ensure the reporting requirements are fully understood. The University will review its processes and internal controls as recommended above and make revisions as needed. Sharon Brewer, Interim Registrar, and Michelle Kalis, Provost will be responsible for the implementation of the above process review and implementation of process enhancements, if any, as well as training all appropriate staff within the Registrar?s Office. This work will be completed no later than December 31, 2022. Sharon Brewer, Interim Registrar, will be responsible for ensuring NSLDS is updated within two weeks of the system accepting updates.

Student Financial Assistance ? Assistance Listing No. Various Recommendation: We recommend the College review its procedures to ensure controls are in place and operating effectively. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Clarkson College has reviewed Cost of Attendance procedures and starting July 2022, to include all monthly reconciliations related to Pell, Direct Loan, SEOG and FWS along with G5 drawdowns are annotated and reconciled in conjunction with the Controller?s Office. Awarding procedures as well as R2T4 procedures were reviewed as well. The employee responsible for this finding is no longer associated with the college. Name(s) of the contact person(s) responsible for corrective action: Nan Merz Planned completion date for corrective action plan: July 2022

Student Financial Assistance ? Assistance Listing No. Various Recommendation: We recommend the College review its reporting procedures to ensure the students' statuses and effective dates are accurately reported to 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: Financial Aid established a procedure in July 2022 for one FA staff person to work with the Registrar each time enrollment is/was reported. All errors are cleared in the allowed timeframe. The employee responsible for this finding is no longer associated with the college. Name(s) of the contact person(s) responsible for corrective action: Nan Merz Planned completion date for corrective action plan: July 2022

Student Financial Assistance ? Assistance Listing No. Various Recommendation: We recommend the College review the R2T4 requirements and implement procedures to ensure the R2T4 calculations are using the correct number of break days and are accurately completed. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Clarkson College reviewed the R2T4 requirements and has implemented procedures to ensure R2T4 calculations are using the correct days. FA staff have completed NASFAA R2T4 training. The employee responsible for this finding is no longer associated with the college. Name(s) of the contact person(s) responsible for corrective action: Nan Merz Planned completion date for corrective action plan: July 2022

Student Financial Assistance ? Assistance Listing No. Various Recommendation: We recommend the College evaluate its procedures and policies around reporting 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: Clarkson College has reviewed procedures and starting July 2022, all disbursements reported to COD are reported within the 15-day timeframe. The employee responsible for this finding is no longer associated with the college. Name(s) of the contact person(s) responsible for corrective action: Nan Merz Planned completion date for corrective action plan: July 2022

2022-002 Student Financial Aid Cluster ? (a) Federal Supplemental Educational Opportunity Grant (b) Federal Work Study Program (c) Federal Perkins Loan Program (d) Federal Pell Grant Program (e) Federal Direct Student Loans (f) Teacher Education Assistance for College and Higher Education Grants, Assistance Listing No. (a) 84.007 (b) 84.033 (c) 84.038 (d) 84.063 (e) 84.268 (f) 84.379 ? Year Ended June 30, 2022. Condition: In one of the 40 student files tested (2.5%), Subsidized and Unsubsidized Direct loans we not properly awarded. The College under awarded the student $5,500 in Subsidized loans and over awarded the student by $5,500 in Unsubsidized loans. Corrective Action Plan: Jayne Schreck has reviewed the student?s file and the circumstances surrounding the instance of non-compliance. The college does have systematic policies and procedures in place to properly evaluate a student?s file and determine the proper levels of Subsidized and Unsubsidized Loan. The systems used did calculate the loan split properly as documented in the student?s paper file. The error was a human error caused when keying the amounts and codes into the computer system. Jayne has asked her staff to split duties whenever possible. For example, one person may calculate the package but a different person should key the information into the computer system. Human error is human error, it can happen, but having two sets of eyes on each file might help to minimize the risk of error. Responsible Person for Corrective Action Plan: Jayne Schreck, Associate VP for Student Financial Planning Implementation Date for Corrective Action Plan: September 2022

2022-001 Finding Frontier Nursing University (the University) did not report 1 student who withdrew to National Student Loan Data System (NSLDS) in a timely manner. Summary The University does not have a control in place to ensure students who withdrew from the University are reported timely to NSLDS. Views of the University and Planned Corrective Action The University agrees with this finding and summary. The University did not have sufficient control measures in place to ensure that every student?s change in enrollment status was reported to NSLDS in a timely manner. To improve the University?s Title IV regulatory compliance and to ensure that all changes in students? enrollment status are correctly reported to NSLDS in a timely manner, the Director of Enrollment Management and Financial Aid will continue to report a withdrawn student directly to NSLDS within 30 days of a student withdrawing from the University and the Associate Director of Financial Aid will review NSLDS once notification of a students? withdrawal has been received to ensure the withdrawn status has been reported timely. Responsible Parties: Rainie Boggs, Director of Enrollment Management and Financial Aid and Andrew Dezarn, Associate Director of Financial Aid Estimated Completion Date: August 15, 2022.

Finding 2022-002 Federal Awards Findings and Questioned Costs Condition The change in status for three of twenty-five students tested was not reported to the National Student Loan Data System (NSLDS) within 30 days or included in a response to a roster file within 60 days. The change in status information for five of twenty-five students tested did not agree between the campus level and program level enrollment detail. The date for the change in status for eleven of twenty-five students tested did not agree to the University?s records. The total number of students impacted is thirteen due to students being included in multiple categories as noted above. Corrective Action Plan Doane University staff is changing our process for enrollment reporting. Auditors have provided a copy of the NSLDS Enrollment Reporting Guide which staff will refer to for specific guidance in case questions arise. Errors noted in the Single Audit for the period 7/1/2021-6/30/2022 will be adjusted to reflect data noted in the schedule relative to this finding. Name(s) of Contact Person(s) Responsible for Corrective Action: Denise Ellis, Registrar, Doane University. Anticipated Completion Date: April 30, 2023 CFO February 27, 2023

Finding 2022-003 Condition Various key student financial assistance processes, such as monthly Direct loan reconciliations and drawdowns of federal funds, have been performed, but there is no evidence of documented reviews. In addition, it was noted that the servicer?s internal control report for the Perkins Loan Program was not reviewed. Corrective Action Plan Corrective Action Planned: In the fiscal year starting July 1, Doane University has implemented or changed processes to ensure management review and documentation of the review is saved. Name(s) of Contact Person(s) Responsible for Corrective Action: Julie Heyen, Controller Anticipated Completion Date: September 30, 2022 CFO February 27, 2023