Corrective Action Plans

Condition: One out of three (33.3%) students selected for testing in the Spring, was disbursed a post-withdrawal disbursement without a notification being sent to authorize the loan disbursement. This was a result of the withdrawal for this student being completed late. We consider this finding to be an instance of noncompliance in relation to Special Tests and Provisions. Statistical sampling was not used in making sample selections. Corrective Action Plan: It is important to note that the entire 2021/2022 award year was processed by 3rd party servicer, Fully Disbursed. The current Financial Aid staff at Blackburn College started in October of 2021 but the processing was conducted by Fully Disbursed as they were under contract with Blackburn College for all 2021-2022 processing and packaging until August 2022 at the completion of the summer semester. The Financial Aid Office has increased controls over post-withdrawals disbursements in several ways: Establishing updated policies and procedures for disbursing funds after a student withdraws. The policy includes guidelines for determining how much aid a student is eligible for based on their withdrawal date and the specific requirements for disbursing funds; Regularly reviewing and analyzing post withdrawal disbursement data to identify any patterns or discrepancies that may indicate fraud or abuse. This includes a review of the financial records and transactions associated with each disbursement, as well as a review of the documentation that supports these transactions; Working closely with other departments within the College, including Registrar?s Office and the Business Office, to ensure that any changes in a student?s enrollment status are properly communicated and documented. By taking these steps, the Financial Aid Office will ensure that post-withdrawal disbursements are made in accordance with federal regulations and institution policies, and that these funds are used only for their intended purposes. Responsible Person for Correction Action Plan: Alexis Brown, Director of Financial Aid Implementation Date for Corrective Action Plan: Fall 2022

Condition: The College did not timely and accurately complete refund calculations in the Fall. In review of the Fall 2021 calculations the number of days in the break were not calculated correctly, resulting in the incorrect days in all Fall 2021 return of Title IV funds calculations. As a result of the incorrect number of days, the amounts of Title IV amounts returned for all withdrawn students were incorrectly calculated for 6 out of the population of 11 (54.5%) Fall withdrawal calculations. A sample of Spring withdrawal calculations identified no errors. We consider this finding to be a material weakness in relation to Special Tests and Provisions and is a repeat finding shown in Section IV of this report as prior year finding 2021-004. Statistical sampling was not used in making sample selections. Corrective Action Plan: It is important to note that the entire 2021/2022 award year was processed by 3rd party servicer, Fully Disbursed. The current Financial Aid staff at Blackburn College started in October of 2021 but the processing was conducted by Fully Disbursed as they were under contract with Blackburn College for all 2021-2022 processing and packaging until August 2022 at the completion of the summer semester. The Financial Aid staff at Blackburn Colleges understands that when calculating Return of Title IV funds, it is important to carefully review and accurately count the number of calendar days in the payment period. Currently, we review the College Academic Calendar for all vacations periods and ensure that any periods that are 5 or more days in length are added when setting up the School Calendar Profile in the R2T4 screen each academic year. This will help to make certain that all relevant dates are properly documented and that we are using the correct formula for calculating R2T4. Responsible Person for Correction Action Plan: Alexis Brown, Director of Financial Aid Implementation Date for Corrective Action Plan: Fall 2022

Condition: The College did not report actual loan disbursement dates to the Common Origination and Disbursement (COD) system for 23 of the 40 students in the sample (57.5%). We consider this condition to be a material weakness in internal control over compliance relating to the Eligibility compliance requirement and is a repeat finding shown in Section IV of this report as prior year finding 2021-003. Statistical sampling was not used in making sample selections. Corrective Action Plan: It is important to note that the entire 2021/2022 award year was processed by 3rd party servicer, Fully Disbursed. The current Financial Aid staff at Blackburn College started in October of 2021 but the processing was conducted by Fully Disbursed as they were under contract with Blackburn College for all 2021-2022 processing and packaging until August 2022 at the completion of the summer semester. The Financial Aid Office must emphasize the importance of accurate record-keeping in financial transactions. As a department we will continue to work closely with the Business office to ensure that every drawdown is properly documented and matches the corresponding dates and amounts. Additionally, we will continue to perform monthly reconciliations to ensure that any discrepancies are identified and addressed promptly. This process helps to minimize errors and maintain transparency in our overall financial aid operations. Responsible Person for Correction Action Plan: Alexis Brown, Director of Financial Aid Implementation Date for Corrective Action Plan: Fall 2022

Condition: Two of the 40 student files (5%) we examined, we noted the students were not properly awarded Direct loans. Further, we noted two of the 40 students (5%) were not properly awarded Pell. Corrective Action Plan: It is important to note that the entire 2021/2022 award year was processed by 3rd party servicer, Fully Disbursed. The current Financial Aid staff at Blackburn College started in October of 2021 but the processing was conducted by Fully Disbursed as they were under contract with Blackburn College for all 2021-2022 processing and packaging until August 2022 at the completion of the summer semester. The Financial Aid Office at Blackburn has evaluated and revised policies and procedures to ensure students receive the proper amount of Title IV Aid. Reconciling each month is necessary to ensure we catch any and all discrepancies that may occur. We will continue to utilize all available software to assist with packaging and that will allow all financial aid, including Title IV funds, to be reviewed frequently by both the Director of Financial Aid and the Assistant Director of Financial Aid. Responsible Person for Correction Action Plan: Alexis Brown, Director of Financial Aid Implementation Date for Corrective Action Plan: April 2023

Finding 2022-006: Direct Loan Reconciliation ? Material Weakness and Noncompliance Condition: Documentation that the required monthly School Account Statement (SAS) reconciliations were not completed for any of the three monthly tested for the year ended June 30, 2022. Responsible for the Plan: Janet Davidson, Director of Financial Aid Dennis Zeh, Director of Financial Operations Planned completion date: June 30, 2023 Corrective Action Plan: To ensure compliance with the Direct Loan Reconciliation requirements the college will adopt the following procedure. ? On a regular basis the Financial Aid Assistant/Loan Officer will process disbursements of direct loans using Powerfaids. This process will include sending files back and forth through CPS to update the Common Origination and Disbursement (COD) site as well as processing files to Jenzabar to make awards to student accounts. The Financial Aid Assistant/Loan Officer will be responsible for resolving any rejects that are returned through CPS into Powerfaids to ensure that all disbursements are approved and accepted in COD. ? At the beginning of the month the Financial Aid Assistant/Loan Officer will send the Director of Financial Aid the SAS report from CPS. ? The Director will pull the FA transactions from Jenzabar for the previous month and compare it to the COD disbursements to ensure the records match. The Director will prepare the reconciliations detailing the disbursements and drawdowns from COD as well as the disbursements and drawdowns reflected in Jenzabar. The Director will identify any discrepancies. ? Upon completion of the Reconciliation the Director of Financial Aid will review with Financial Aid Assistant/Loan Officer and the Director of Financial Operations ? Additionally, the DFO will ensure that independent reconciliations are performed from the General ledger back to AR Student accounts, this adds an essential third component on the FA review process to enable our identification of funds that are in scope for return but have been incorrectly posted or otherwise not available to the FA reconcilers under the proper AR accounts.

Finding 2022-009: Eligibility-Significant Deficiency and Noncompliance Condition: For three of the twenty-five students selected for testing, the Pell Award calculation was not correctly performed, and the students did not receive an adequate amount of Pell Award for the period under audit. Responsible for the Plan: Janet Davidson, Director of Financial Aid Planned completion date: June 30, 2023 Corrective Action Plan: To ensure compliance with eligibility requirements the college will adopt the following procedure: ? The Financial Aid Assistant/Loan Officer will review the daily registration changes report to determine the students enrollment status for each term and then set the appropriate class load in Powerfaids in the POE screen. ? Powerfaids uses that class load screen and the Pell payment schedules to determine the students pell grant award. ? The Director of Financial Aid will work with IT/IR to create a report that details the pell load in Powerfaids to match it against current credit load in Jenzabar to ensure that the student has the appropriate credit load in Powerfaids and the appropriate Pell awards are disbursed.

Finding 2022-004: Disbursements to or on Behalf of Students ? Material Weakness and Noncompliance Condition: For 13 of the 25 students selected for testing, a credit balance was late being paid back to the student, a waiver was not obtained, and the College is on the reimbursement payment method. For one of the 25 students selected for testing, disbursement was made to the first time student prior to 30 days after the first day of classes. Responsible for the Plan: Janet Davidson, Director of Financial Aid Dennis Zeh, Director of Financial Operations Planned completion date: June 30, 2023 Corrective Action Plan: To ensure compliance with the disbursement to or on behalf of student the college will adopt the following procedures: ? The Financial Aid office will create disbursements transactions through Powerfaids and transmit those to Jenzabar creating FA and LO transactions. ? To ensure that first time borrower disbursements are delayed until after 30 days from the first day of classes the college will adjust our disbursement dates for all students to be after the 30 th day of the term. ? The Business Office will review and post the FA and LO transactions on a daily basis. ? The Business Office will review all FA and LO transactions for any disbursements that might be for a prior term that could potentially result in a Title IV credit balance. ? The Business Office will prepare a refund list weekly (that will be generated by the weekly posting of FA, LO transactions as well as CG, MS and any payments received) to ensure that credit balance are distributed to students in a timely manner. ? Monthly General Ledger reconciliations on student AR accounts are implemented and will facilitate our capture of issues timelier and assist with the identification of adjustments when needed.

Finding 2022-005: Return of Title IV Funds ? Material Weakness and Noncompliance Condition: For two out of two students selected for testing, their return was not submitted within the required 45-day window. Responsible for the Plan: Janet Davidson, Director of Financial Aid Dennis Zeh, Director of Financial Operations Planned completion date: June 30, 2023 Corrective Action Plan: To ensure compliance for the Return of Title IV Funds requirements the college will adopt the following procedure: ? The Director of Financial Aid will review the Registration Changes Made by Date Report for the appropriate term on a daily basis to find any students who dropped to zero credits. ? These students will be reviewed to determine if they have any Title IV grants or loans that have been disbursed or could have been disbursed for the payment period. ? For students who have Title IV aid that was disbursed or could have been disbursed for the payment period the Director will complete the R2T4 calculation and determine the amount of aid if any that needs to be returned to the appropriate grant or loan program. ? The Director of Financial Aid will notify the Financial Aid Assistant/Loan Officer of the amounts that need to be returned. The Financial Aid Assistant/Loan Officer will make adjustments to the student aid and process FA transactions to the Business Office. In addition, the Financial Aid Assistant/Loan Officer will process adjustments to the loan or grant program through Powerfaids to the COD system. ? The Director of Financial Aid will ensure that this process is completed within 30 days of the date the student dropped to zero credits. ? The Business Office will process return requests within 48 hours of submission ? Monthly General Ledger reconciliations on student AR accounts are implemented and will facilitate our capture of issues timely and assist with the identification of adjustments when needed.

Name of Responsible Individual: Jenn Hall, Director of Financial Planning and Sara Benes, Associate Director of Financial Planning Corrective Action: The Financial Planning Office has reviewed the loan disbursement notification process to ensure that notices are sent in a timely manner to needed recipients. After a review of the 2021-2022 award cycle, it was determined that an application ID was missing from the Direct PLUS Loan file that prevented the disbursement notification from being issued to the Parent borrower in some instances. Internal controls have been put in place for the 2022-2023 award cycle and beyond so that this data element is accurately assigned. Anticipated Completion Date: December 31, 2022

Name of Responsible Individual: Jenn Hall, Director of Financial Planning Corrective Action: The Financial Planning Office has reviewed its policies surrounding FSEOG awarding and added additional quality control measures for the 2022-2023 award cycle so that FSEOG funding is provided solely to PELL recipients. Anticipated Completion Date: December 31, 2022

Name of Responsible Individual: Jenn Hall, Director of Financial Planning and Kristi Furr, Controller Corrective Action: The University Business Office and Financial Planning Office will review the institutional refund policies and put the proper controls in place to disburse Title IV credit balances to students/parents in the required timeframe. Anticipated Completion Date: December 31, 2022

Name of Responsible Individual: Jenn Hall, Director of Financial Planning Corrective Action: The Financial Planning Office has reviewed the verification policies and added a supervisory review process and internal audit of verification records. Additional staff training will be provided to help team members identify potential instances of noncompliance. Anticipated Completion Date: December 31, 2022

CORRECTIVE ACTION PLAN December 6,2022 Oversight Agency: U.S. Department of Education Mifflin County Academy of Science and Technology respectfully submits the following corrective action plan for the year ended June 30, 2022. Name and address of independent public accounting firm: Young, Oakes, Brown & Co, PC 1210 13th St. Altoona, PA 16601 Audit Period: 07/01/2021-06/30/2022 The findings from the 06/30/2022 schedule of finding and questioned costs are discussed below. The findings are numbers consistently with the numbers assigned in the schedule. FINDINGS - FEDERAL AWARD PROGRAMS AUDIT U.S. DEPARTMENT OF EDUCATION 2022-001 Education Stabilization Funds ALN 84.425E & 84.425F Recommendation: We recommend that the Academy implements procedures to ensure compliance with this regulation to ensure all information on the website is correct. Action Taken: As a result of the above referenced finding, the Academy has implemented the following policy for future reporting requirements. In order to ensure compliance with CARES Act public reporting, the Business Manager will review all reports prepared by the Supervisor of Adult Education prior to posting on the website beginning with the next quarterly report due by January 10, 2023. If the U.S. Department of Education has questions regarding this plan, please call Jenaya Mellinger 717-248-3933. Sincerely Yours

Summary: The University of Dallas contracted with Forvis to provide an opinion on the state of the University of Dallas compliance with the Single Audit standards. In providing such assessment the entity found that the institution was not in compliance with a matter that was not material in nature but need correction. The following is a Corrective Action Plan to address such deficiency. Reference Number 2022-001 Responsible Parties: James Huebner, UD Financial Aid and Marissa Darby, UD Registrar offices UD Financial Aid will request a copy of the Enrollment File Submission from the UD Registrar to ascertain that the appropriate formatting is performed from the UD Student Information System/Financial Aid Management System. (SIS/FAMS) Upon such assessment, UD Financial Aid in conjunction with UD Registrar will employ the expertise of the UD SIS/FAMS Systems Administrator, Blake Palmer, to ensure compliance with the file layout provided by the Third-Party Enrollment reporting agency the National Student Loan Clearinghouse. If such file layout cannot be corrected in the UD SIS/FAMS, then UD Financial Aid along with the UD SIS/FAMS Systems Administrator will report the specific error to the University?s ERP provider (Ellucian) for modification. To resolve the error while such modifications are being deployed the UD Financial Aid will employ the expertise of UD Institutional Effectiveness to edit such file to comply with the aforementioned format. UD Financial Aid will audit such records in the NSLDS system to ensure all data integrity end to end. The described process will be fully implemented by November 30, 2022. If the expertise of the University?s ERP provider (Ellucian) is needed to correct specific errors to execute a more automated process, the time frame may be extended to no later June 1st 2023.

Finding No. 2022 012: Special Tests and Provisions (Material Weakness) Federal Agency: U.S. Department of Health and Human Services AL Number and Title: 93.558 and COVID 19 ? 93.558 ? Temporary Assistance for Needy Families Award Number and Award Year: 1601HITAN3, 2001HITANF, 2101HITANF, 2201HITANF, 2021G990228 Condition We selected a non statistical sample of 14 participant files for testing out of a population of 138 participant files that were initially determined by the Title IV-D agency as not cooperating with the child support enforcement requirements. We noted 3 files did not contain any correspondence, notices, or documentation to indicate whether any follow up action, up to and including case closure and cessation of benefits, were performed. Views of Responding Officials: The Department agrees with the finding and will implement corrective action; however, notes the following: Based on my review of the selected cases, particularly the cases that were properly closed due to non-compliance with child support requirements, I found that the Processing Centers received hard-copy notifications from the Child Support Enforcement Agency (?CSEA?). The three cases indicated as having no closure notices, there were no hard-copy notifications found in the clients? electronic case files. The referrals to CSEA are done through an interface between the HAWI and CSEA's KEIKI systems. When a recipient is determined non-compliant by CSEA, the information is sent via the interface from KEIKI to HAWI in the form of a system-generated alert. This process worked well when application processing and maintenance of recipient cases were done in a case management method (e.g., each eligibility worker assigned to process applications and/or maintain a caseload of active cases). This method, eligibility workers would manage their caseloads and check for incoming alerts for cases assigned to them; these alerts would include the CSEA non-compliant alerts coming from KEIKI system. Workers were able to take appropriate and timely action in response to the alerts received. However, necessary changes were made to how applications and active cases are managed. The division stopped the case management method and converted to "task-oriented" processing statewide. Workers are no longer assigned to caseloads but are assigned to "tasks" such as processing applications, incoming documents/verifications, reported changes, six-month review and annual recertifications, etc. A case is not reviewed and worked in HAWI until a worker is prompted to do so, e.g., six-month review, annual recertification, change was reported by the household, or when a document pertaining to a case is received by the Processing Center such as hard-copy notice sent from CSEA indicating a client did not comply with child support requirements. When any one of these occur, then the worker who is assigned to that task will check for alerts for the case. Aside from that, recipient cases are not reviewed. So how the "alerts" were developed in HAWI no longer works for the way we currently process applications and maintain cases. We are unable to modify the HAWI system because we are currently developing a new eligibility system that will replace HAWI. Corrective Action Taken or Planned: We created an ad hoc report to identify Temporary Assistance for Needy Families Program (TANF) recipient cases that received the HAWI alert, ?REASON [Numeric Code]: CLIENT FAILED TO COOPERATE W/CSEU ON [mmddyyyy]?, generated by the interface with the KEIKI system. The report identifies cases by Case Number, Case Name, and assigned Processing Center. The program office will disseminate the list to the Processing Centers to take appropriate and timely action. The ad hoc report will be requested from the Department?s Office of Information and Technology (?OIT?) and disseminated monthly. Expected Completion Date: On-going Responding Official: Catherine Scardino, Benefit, Employment, and Support Services Division Temporary Assistance for Needy Families Program Administrator

Finding 2022-001 Condition Condition: The change in student status for 2 of the 25 students tested was not reported to the National Student Loan Data Systems (NSLDS) within 30 days or included in a response to a roster file within 60 days. However, these students were ultimately reported to the NSLDS. Corrective Action Plan The Office of the Registrar will work with the National Student Clearinghouse to adjust the reporting schedule to align more closely with the Goucher College Academic Calendar. This alignment should bring late reporting to zero. The goal is to have no findings in 2023. Name of Contact Person Responsible for Corrective Action: Darlene Anderson, Registrar Anticipated Completion Date: By the end of Spring 2023 semester, May 2023

2022-004 Perkins Promissory Notes - Assistance Listing No. 84.038 Recommendation: We recommend that the College put a procedure in place to ensure that all students have a promissory note prior to disbursing of funds. Also recommend a procedure be put in place to ensure proper record retention documenting the completion of promissory note. Views of responsible officials: There is no disagreement with the audit finding. Action taken in response to finding: The process Union College follows to ensure promissory notes are signed is coordinated through Student Financial Services (SFS). SFS determines eligibility of awards and adds them to the student financial package. Once a loan has been accepted SFS has the student sign the promissory note. The loan is disbursed once the paperwork has been completed and reviewed. Perkins loans followed this procedure in the time they were available. The Perkins program is no longer active so there are no new promissory notes going forward. Student accounts is currently reviewing student files to ensure promissory notes or documentation deemed appropriate by the Department of Education is available for the Perkins loans that will be assigned to the Department of Education. The assignment process will be completed by June 30, 2023. The remaining loan files will then be reviewed. Promissory notes or documentation will be retained until the loans are either assigned or liquidated. This review will be completed in FY24. Name(s) of the contact person(s) responsible for corrective action: Brandie Kolff van Oosterwyk, Controller Planned completion date for corrective action plan: FY24.

2022-002 Gramm-Leach-Bliley Act - CFDA No. Various Recommendation: We recommend that the College engage a third party or perform the risk assessment for the three areas required by the Gramm-Leach-Bliley Act and ensure that there are documented safeguards for identified risks. Views of responsible officials: There is no disagreement with the audit finding. Action taken in response to finding: Union College is developing a strategy to comply with the requirements of the Gramm-Leach-Bliley Act. Part of this process involves the consideration of contracting with a consultant to assist with the various aspects of implementing the policies and procedures necessitated by the legislation. We are actively in conversations with CLA regarding this project and are working towards having a substantive plan in place and operational for FY24. Name(s) of the contact person(s) responsible for corrective action: Brandie Kolff van Oosterwyk, Controller Planned completion date for corrective action plan: The goal date for this project to be completed is prior to the FY24 audit.

Finding No. 2022 009: Eligibility, Activities Allowed or Unallowed, Allowable Cost (Material Weakness) Federal Agency: U.S. Department of Health and Human Services AL Number and Title: 93.090 and COVID 19 ? 93.090 ? Guardianship Assistance Award Number and Award Year: 2101HIGARD, 2201HIGARD Condition We selected a non statistical sample of 60 case files which approximated $55,000 in monthly benefit payments, out of a population of approximately 380 case files which approximated $3.9 million in total annual benefit payments, for testing and noted exceptions in 17 case files as follows: ? Seven case files where the initial or modified guardianship/permanency assistance agreement was missing and therefore did not have any support for the amount of monthly assistance paid. ? Four case files where the ?difficulty of care? determination was missing and therefore did not have any support for the assistance amount paid. ? One case file where we were unable to determine if a child who attained the age of 14 was consulted regarding the kinship guardianship agreement. ? Three case files where the State, Federal Bureau of Investigation, and/or child abuse and neglect clearances were missing in the case files. ? Two case files where documentation regarding continuation of monthly subsidy payments after the child?s 18th birthday was missing. ? One case file where the supporting documentation regarding whether the State determined that the guardian/permanent custodian has a strong commitment to caring permanently for the child was missing. Views of Responding Officials: The Department agrees with the finding and will implement corrective action. Corrective Action Taken or Planned: 1. Child Welfare Service (CWS) will make a note in each specific case record identified in this audit explaining the audit findings, and secure missing/incomplete eligibility documents for cases identified in the audit. 2. The identified errors and the related corrective action step above will be reviewed by CWS Administrators, staff supervisors, and the Management Information Compliance Unit (MICU) within ninety days to ensure missing documentation has been secured and properly noted in record. ? Additionally, the MICU will complete a random Guardianship Agreement audit review approximately six months later. i. MICU will share random audit findings with CWS Administration. ii. CWS Administrators will take corrective action based on MICU audit findings. 3. CWS supervisors will ensure that line staff are familiar with these policies and procedures and monitor through individual supervision meetings and work product review. ? Staff with errors identified in this audit, during individual supervision meetings or through work product review will: i. Be given coaching/supervisory support to correctly complete documentation. ii. Be required to participate in refresher training on Title IV-E Foster Custody, which is offered three times a year with participation documented by Staff Development Office. ? All staff who manage payment-only cases will review a quarter of their cases each month with their supervisor, during monthly supervision. i. Each month a different quarter of their cases will be reviewed, so that all cases are reviewed three times a year. ii. During this review between the supervisor and the staff, documentation in the case file, as well as Child Protective Services System (CPSS) coding and payments, will be examined for completeness and accuracy. iii. Needed corrections will be made to the documents and/or CPSS, as identified in the monthly reviews. iv. If a supervisor notices consistent errors by a staff member in Guardianship Agreement documentation, they shall refer the staff to the Staff Development Office for refresher training. v. The supervisor shall document which cases were reviewed each month. 4. At the next Management Leadership Team meeting, CWS Branch Administrators will share with staff the results of this audit, explaining the direct correlation between documentation (or lack thereof) and financial penalties to the State. ? Reminder conversation about this audit and the importance of following current policies and procedures will be held during CWS weekly huddles. 5. As CWS implements this corrective action plan and monitors the results, the action steps proposed in one through four may be modified based on input from CWS Administrators and/or focus/exploration groups with line staff who complete this documentation. Expected Completion Date: May 31, 2023 Responding Officials: Kisha C. Raby, Social Services Division Program Development Administrator, Elladine Olevao, Social Services Division Child Welfare Social Services Manager, and Carolina Anagaran, Social Services Division Administrative Officer

Finding No. 2022 008: Eligibility, Activities Allowed or Unallowed, Allowable Cost (Material Weakness) Federal Agency: U.S. Department of Health and Human Services AL Number and Title: 93.659 and COVID 19 ? 93.659 ? Adoption Assistance Award Number and Award Year: 2101HIADPT, 2201HIADPT Condition We selected a non statistical sample of 60 case files which approximated $33,000 in monthly benefit payments, out of a population of approximately 2,500 case files which approximated $15.4 million in total annual benefit payments, for testing and noted exceptions in 38 case files as follows: ? 19 case files where the initial or modified adoption agreement was missing and therefore did not have any support for the amount of monthly assistance paid. ? 21 case files where the State, Federal Bureau of Investigation, and/or child abuse and neglect clearances were missing. ? Eight case files where the ?difficulty of care? determination was missing and therefore did not have any support for the assistance amount paid. ? Eight case files where documentation of a child?s special needs was missing. ? Eight case files where the supporting documentation regarding whether the State determined that the child cannot or should not be returned to the home of his or her parents was missing. ? One case file where documentation of monthly non-recurring expenses was missing. ? One case file where documentation regarding continuation of monthly subsidy payments after the child?s 18th birthday was missing. ? One case file where the final approval was granted to a household with an individual who was convicted of spousal abuse. ? Five case files where the adoption decree was missing from the case records. Views of Responding Officials: The Department agrees with the finding and will implement corrective action. Corrective Action Taken or Planned: Views of Responding Officials: The Department agrees with the finding and will implement corrective action. Corrective Action Taken or Planned: 1. Child Welfare Service (CWS) will make a note in each specific case record identified in this audit explaining the audit findings, and ? secure current modified adoption agreements for the nineteen missing documents, ? locate missing clearances for the twenty-one cases or re-run them if not located, Note: Not all clearances are secured prior to placement; Federal Bureau of Investigations (FBI) clearances come later and are NOT required prior to placement in a ?provisionally licensed? home. ? document the need precipitating Difficulty of Care (DOC) determination for the 8 records, showing how DOC was calculated. i. ensure that the written Adoption Assistance Agreement (AAA) matches the calculations and amount in the payment system or update/modify the AAA as appropriate, ? secure documentation of child?s special needs for the eight cases, noting categorical eligibility qualification as special needs for children adopted from foster care. Note: Hawaii is in the process of developing its new Comprehensive Child Welfare Information System (CCWIS) and plans to use this system to automatically code children in foster care as meeting the eligibility criteria for special needs. ? secure a copy of the court order which specified that the child should not be returned home, i.e., the order containing the ?contrary to the child?s welfare? language for the eight cases, ? document monthly non-recurring expenses in the missing case, ? document the reason for continuation of monthly subsidy payments after the child?s eighteenth birthday in one case, ? research/review and document why final approval was granted to a household with an individual who was convicted of spousal abuse. i. If review determines that AAA was inappropriately authorized, provide family with an adverse action notice discontinuing the AA and explaining the appeals process, ? Although adoption assistance is an incentive program with payment beginning prior to the finalization of an adoption, secure a copy of the five missing adoption decrees. Note: The adoption decree is NOT required for payment as the AAA must be entered prior to the finalization of an adoption. 2. The identified errors and the related corrective action steps proposed above will be reviewed by CWS Administrators, staff supervisors, and the Management Information Compliance Unit (MICU) within ninety days to ensure missing documentation has been secured and/or properly noted in record. ? Additionally, the MICU will complete a random AA audit review approximately six months later. i. MICU will share random audit findings with CWS Administrators. ii. CWS Administrators will take corrective action based on MICU audit findings. 3. CWS supervisors and Social Services Division (SSD) Staff Development Specialists will ensure that line staff are familiar with these policies and procedures through individual supervision meetings and work product review. ? Staff with errors identified in this audit, consistent errors identified during individual supervision meetings or through work product review will: i. be given coaching/supervisory support to correctly complete documentation, ii. be required to participate in refresher training on Title IV-E Foster Custody, which is offered three times a year with participation documented by Staff Development Office. iii. During this review between the supervisor and the staff, documentation in the case file, as well as Child Protective Services System (CPSS) coding and payments, will be examined for completeness and consistency. iv. Needed corrections will be made to the documents and/or CPSS, as identified in the monthly reviews. 4. In consultation with the Department of Accounting and General Services (DAGS), CWS will develop and implement a new AAA form which identifies payment amounts by age, informing families of the progression. This will eliminate the need for a new agreement when a child moves from one payment category to another, as they age. ? Should the standard AA amounts change, an addendum to this universal agreement will be sent to families noting the change(s). ? Once a new AAA form has been created, the Staff Development Office will update the AA training module to include this new form and offer the updated training in the regular training rotation. 5. At the next Management Leadership Team meeting, CWS Branch Administrators will share with staff the results of this audit, explaining the direct correlation between documentation (or lack thereof) and financial penalties to the State. 6. As CWS implements this corrective action plan and monitors the results, the action steps proposed in one through five may be modified, based on input from CWS Administrators and/or focus/exploration groups with line staff who complete this documentation. Expected Completion Date: May 31, 2023 Responding Officials: Kisha C. Raby, Social Services Division Program Development Administrator, Elladine Olevao, Social Services Division Child Welfare Social Services Manager, and Carolina Anagaran, Social Services Division Administrative Officer

Finding Number: 2022-004 Condition: Certain credit balances were not refunded to students within 14 days. Planned Corrective Action: Identify one or more additional staff members who can perform this function in the event of illness or absence, cross-train these individuals, and ensure permissions are granted, ensuring appropriate segregation of duties. Contact person responsible for corrective action: Matt Beattie, Mark Schroeder Anticipated Completion Date: February 28, 2023

Finding Number: 2022-002 (repeat finding) Condition: The student status changes for certain students with status changes were not reported accurately and/or within 60 days. Additionally, certain students were reported within correct effective dates. Planned Corrective Action: Enrollment Services is working with IT on an error report and ongoing review process to identify reporting errors for timely correction. Contact person responsible for corrective action: Dina DuBuis, Assistant Vice President, Enrollment Services and Registrar Anticipated Completion Date: February 1st, 2023

Finding Number: 2022-003 Condition: The University could not provide records to substantiate that the relevant criteria was complied with by the University in all cases. Planned Corrective Action: Train faculty to preserve and provide documentation related to reported last dates of attendance. This will be stored in the university?s enterprise document management system. Contact person responsible for corrective action: Dina DuBuis, Ann Elinski Anticipated Completion Date: February 15, 2023

Finding Number: 2022-004 Condition: Of the 40 students tested for NSLDS Enrollment Reporting, the University: -For 3 students, reported the status change with incorrect effective dates -For 2 students, reported the status change to NSLDS in an untimely manner Planned corrective Action: The new person hired as the Assistant Registrar for Special Programs and Compliance was officially hired on January 11, 2022. She has gone through training for both NSC and NSLDS. She is and will continue to work closely with Financial Aid related to status change dates and reporting data to the NSLDS. She is responsible for dealing with NSLDS error reports. Contact person responsible for corrective action: Noreen Ferguson, University Registrar Anticipated Completion Date: June 30, 2022. The responsibilities of this position are completed. There will be ongoing training as training sessions become available either through NSC or NSLDS.

Finding Number: 2022-003 Condition: Of the 21 students selected for Return to Title IV testing, the University: -For 4 of the students, utilized inappropriate withdrawal dates -For 2 of the students, inaccurately calculated returns -For 5 of the students, returned funds in an untimely manner -For 1 of the students, student authorization wasn?t obtained prior to crediting account for post-withdrawal disbursement Planned corrective Action: One Stop Center staff were retrained on September 7th on the process of backdating a drop/withdraw to the appropriate date. This training will continue to be ongoing to be sure they are aware and understand the importance of the backdating being accurate. An error report has been created that can identify if the last date of attendance is equal to the date the transaction took place. If students appear on this report further investigations will be done to determine if it is the accurate date to use. R2T4 calculations are always processed on students who withdraw without regard to percentage of time attended. The staff will continue to process R2T4 in Banner for withdrawn students who receive federal aid, with a secondary calculation using the COD online R2T4 calculator to confirm outcomes. The student found regarding post-withdrawal was an oversight. Notification letters will be mailed to students who are eligible for the Post Withdrawal disbursements requesting the student acceptance of offered aid. This area will also become a review item in our process to review R2T4 calculations weekly. Contact person responsible for corrective action: Noreen Ferguson, University Registrar Anticipated Completion Date: September 7, 2022. The error report is already developed and in use. The additional training will be ongoing.