Corrective Action Plans

Contact Person(s): Shanell Tilo, Financial Aid Officer Dr. Emilia Le?i, Dean of Student Services Dr. Letupu Moananu, Vice President of Academics, Community, and Student Affairs Explanation and specific reasons for disagreement with the audit finding or that corrective action is not required (if applicable): No disagreement Corrective actions taken/planned: The Financial Aid Coordinator (control #1, with FA Officer as alternate) has been assigned to transmit the bi-monthly Enrollment Report roster. The control #1 reviews the roster and performs data entry, status updates and submission by the 15th of the reporting month. On the 1st of every nonreporting month, control #1 will review and report any enrollment status changes before the 15th. Counselor III (control #2) is assigned to monitor and spot check the status updates on NSLDS after the 25th of every month to internally audit the submissions. The policy will ensure all student changes in status are identified, updated and submitted timely and accurately. ASCC FAO participates in Federal Student Aid (FSA) training and conferences regarding NSLDS updates, changes and functionality. FAO also subscribes to the Weekly Knowledge Center Updates from FSA Partner Connect. ASCC is a member of the National Association of Student Financial Aid Administrators (NASFAA). All of these resources provide access and education in the process of enrollment reporting and compliance, as well as responsibilities and consequences of inaccurate reporting. Controls (#1 and #2) shall be included accordingly in the job descriptions of the Financial Aid Coordinator and Counselor III as well as the Financial Aid Standard Operating Procedures for consistency in compliance and reporting. Graduates: Students who graduate will be updated into NSLDS within one week after graduation. Official / Unofficial Withdrawal: All Withdrawals must then be reported to NSLDS within 45 days. Anticipated completion of the corrective action is expected by June 2023.

2022-002 Enrollment Reporting to NSLDS Planned Corrective Action: Admissions department and registrar department will provide a list of all non-true freshman to the financial aid department. The financial aid department will run NSLDS reports to determine if students have utilized financial aid in the past. Each student that has received aid in the past will be reported to NSLDS whether they utilize any federal aid at ABU or not. Person Responsible for Corrective Action Plan: Laurel Bartlett- Admissions Director, John Rocha- Financial Aid Director, Janie Taylor- VP of Academic Affairs / Registrar Anticipated Date of Completion: Spring 2023

Incorrect and Untimely Return of Title IV Funds (R2T4) Calculations Planned Corrective Action: The registrar's office will identify students that withdraw or are withdrawn & only have one class remaining. A committee meeting will follow and determine appropriate action. The committee will determine if the student can pass that last class or if student plans to drop that last class as well. The committee will consist of Peggy Smith, Janie Taylor, and John Rocha. At the end of each semester ABU will run a 0-credit report. The report will ensure all unofficial withdrawals are followed up with R2T4s when warranted. Person Responsible for Corrective Action Plan: Peggy Smith-VP of student affairs, John Rocha- Financial Aid Director and Janie Taylor- VP of Academic Affairs / Registrar Anticipated Date of Completion: Spring 2023

Identifying Number: 2022-001 Finding: Three student?s enrollment changes were not reported to the National Student Loan Data System (NSLDS) within the 60 day timeframe for the School?s reporting on the roster file submissions. Corrective Actions Taken or Planned: MHSL has hired an outside consultant through Agilyx to create a new enrollment report that will more accurately track and report the enrollment statuses for all students. MHSL will be using this report starting Fall 2022. The Director of Financial Aid now completes enrollment reporting. For each report, students will be selected by Director at random to manually review. Assistant Director of Financial Aid will also select a group at random to review for accuracy. This way both the person who runs the report and a person who does not will review a random sample of students. Also, additional scheduled date for enrollment reporting have been added to the school transmission schedule including j Term and summer. This will prevent late reporting over the summer. Contact Person: Lynn LeMoine ? Dean of Students; Katie Kuehl ? Registrar; and Nick Anderson ? Financial Aid Director. Anticipated Completion Date: Fall 2022

Finding 2022-003 ? Short-Term Program Placement Rate Condition The College cannot demonstrate compliance with the gainful employment placement rate of 70% calculation for the short-term program at a post-secondary vocational institution. Cause The financial aid office did not follow-up on the gainful employment of students. Currently the FAO does not manage the Short-Term Program Gainful Employment Requirement at the campus level. That process is managed by the campus. Corrective Action Taken or Planned City Colleges currently has two short term programs: ? Computer Numerical Machining (Daley College, Wright College) The Financial Aid Office will work with campus leadership to develop a gainful employment reporting process at Daley College and Wright College for short term programs. The reporting structure will include an outreach protocol to be completed and reported on currently enrolled during End of Term Processing for each semester. Contact Person: Associate Vice Chancellor, Financial Aid & Scholarships ? Richard Hayes Anticipated Completion Date: January 2023

Finding 2022-002 ? Return of Title IV Funds ? Enrollment Reporting Condition ? For two out of sixty students tested (3%) who withdrew from City Colleges, the students? withdrawal date reported to the National Student Loan Data System (NSLDS) for campus level and program level did not match the institution?s records. ? For one out of sixty students tested (2%) who withdrew from City Colleges, the student?s withdrawal date reported to the National Student Loan Data System (NSLDS) for campus level and program level did not match the institution?s records. The student?s status change at the campus level and program were not reported to the National Student Loan Data System (NSLDS) within the 60 day requirement. ? For two out of sixty students tested (3%) who withdrew from City Colleges, the students? status change at the campus level and program level were not reported to the National Student Loan Data System (NSLDS) within the 60 day requirement. ? For nine out of sixty students tested (15%) who withdrew from City Colleges, the students? status change at the campus level and program level was never reported the National Student Loan Data System (NSLDS). ? For six out of sixty students tested (10%) who withdrew from City Colleges, the students? status change at the program level was never reported the National Student Loan Data System (NSLDS). ? For one out of sixty students tested (2%) who withdrew from City Colleges, the student?s status change at the program level was not reported to the National Student Loan Data System (NSLDS) within the 60 day requirement. ? For one out of sixty students tested (2%) who withdrew from City Colleges, the student?s status change at the campus level was not reported to the National Student Loan Data System (NSLDS) within the 60 day requirement. ? For four out of sixty students tested (7%) who withdrew from City Colleges, the students? withdrawal status reported to the National Student Loan Data System (NSLDS) for campus level and program level did not match the institution?s records. Cause The Academic Systems & Registrar Office does not have an effective system in place to ensure all official student status changes are reported to the lender in a timely manner. Corrective Action Taken or Planned The enrollment reporting functions are housed in the college?s registrar office and separate from financial aid. An enrollment file is generated at the district level and uploaded quarterly. The Registrar?s Office & Financial Aid Office will create a weekly meeting to update its enrollment reporting procedures and create a reconciliation process to ensure all students are reported to NSLDS. Contact Person: Associate Vice Chancellor, Academic Systems ? Laura Clark. Associate Vice Chancellor, Financial Aid & Scholarships ? Richard Hayes Anticipated Completion Date: January 2023

LAKE LAND COLLEGE COMMUNITY COLLEGE DISTRICT NO. 517 MATTOON, ILLINOIS CORRECTIVE ACTION PLAN FOR CURRENT-YEAR AUDIT FINDINGS FOR THE YEAR ENDED JUNE 30, 2022 CORRECTIVE ACTION PLAN Finding No. 2022-001 ? Internal Controls over Student Financial Assistance Special Test and Provisions Condition: A. During compliance testing of ?Special Tests and Provisions ? Return of Funds? we noted that for eight (8) out of twenty five (25) students tested the College utilized the incorrect semester end date for the Spring 2022 semester. B. During the compliance testing of ?Special Tests and Provisions ? Eligibility? we noted that one (1) student out of forty (40) students tested the College utilized the 2020-2021 Pell payment schedule versus the 2021-2022 Pell payment schedule. Plan: A. The College will develop internal controls to ensure that the correct semester dates are utilized for the return of funds calculation to determine the amount of the Title IV assistance earned by the student. B. The College will establish procedures to ensure their software is utilizing the current Pell payment schedule. Anticipated Date of Completion: Immediately upon learning of the deficiency. Contact Person Responsible for Corrective Action: Jennifer Hedges, Director of Financial Aid and Veteran Services 98

The following is the process the College will implement to review, update and verity student disbursements as well as document retention to be in compliance with Title IV laws and regulations. 1. Once Title IV is approved in Campus IVY the following processes will be taken: a. Amount listed on student funding estimate will be sent to COD for approval b. Approval will be imported c. Amount will then list projected to pay in campus IVY d. Once the date that is listed arrives, Campus IVY will create a batch and send to the school for review and authentication e. The student accounts office reviews student transcripts to make sure eligible amounts are being requested f. Changes are made if students account sees a change in request vs schedule. g. Once review is complete, student account sends the batch back to campus IVY to release for payment. h. Once campus IVY releases for payment i. Campus IVY generates a document ?Disbursement Notification? and sends to the students email on file. j. The disbursement notification is housed in the student profile under ?notifications? for retrieval when needed. This corrective action plan will allow Community Christian College to be in compliance with Title IV laws and regulations regarding disbursements to or on behalf of students.

Corrective action plan to ensure enrollment reporting is completed timely and accurately 1. The admissions team sends a list of all enrolled students 2. Financial aid will manually enter the student?s information into campus IVY 3. Campus IVY updates the student?s status in NSLDS every 30 days. 4. If a student withdraws from Community Christian College, financial aid will manually update the student status into campus IVY 5. NSLDS is updated upon completion of the withdrawal This process will ensure that Community Christian College updates enrollment statuses for every student timely.

View of Responsible Officials and Corrective Action Plan 1. Campus IVY will aid with the data collection for the FISAP 2. Campus IVY will run a disbursement report showing how much FA was disbursed prior year and record 3. Campus IVY will run ISIR report to show eligible applicant and record 4. School will run population report out of populi and record 5. Campus IVY will run a report to show the amount of FSEOG disbursed prior year and record 6. Once all data is collected, a comparison year to year will take place 7. A comparison of student population as well as amount used 8. The result will allow the school to determine the amount of FSEOG is needed for upcoming year. This correction action plan will allow Community Christian College to report FISAP figures properly with supporting documentation.

The following is the procedure that the College will be implemented to ensure that student withdrawal calculations are performed accurately and returned within 30 days: 1. The registrar will send a list to financial aid of all students that have dropped by end of day every Thursday of each week. a. The list will include date of determination (DOD) and last date of attendance (LDA) of each student b. DOD will be within 14 days of student LDA 2. Upon receipt of the list financial aid will complete the following for each student: a. Gather student?s current ledger card b. Gather student?s current Transcript c. Complete a cover sheet which indicated the current loan period of the student. d. Financial aid will send over items to 3rd party processor in order for R2t4 calculation to be completed (Campus IVY) no later than Wednesday of the following week by end of business day. 3. Campus IVY will complete the R2T4 3-5 business days upon receipt and conduct the following: a. If a refund is required- campus IVY will schedule the refund, update student account and send to school. b. School (student accounts) will review the refund, update student account and monies will be placed in the operations account and sent back to G5. c. If a refund is not required based on the R2T4 results, Campus IVY will notate the student account. This corrective action plan will allow Community Christian College to complete the drop process for each student within 30 days from LDA.

Corrective Action plan to the College will implement a process to review, update, and verify student eligibility requirements. The following is the process to review, update and verify student eligibility requirements: 1. Financial Aid Rep assist student with completing FAFSA 2. Financial Aid Rep pulls NSLDS to make sure loan amounts and grants are not used up. 3. NSLDS print out is uploaded to campus IVY 4. Once the FAFSA summary is in Campus IVY and the funding is created, the usage amount is shown. 5. Once loan and Pell amounts are sent to COD and approved 6. Campus IVY will send a batch with student loan and Pell amounts to the school to be reviewed. 7. The student accounts office will then review the student loan and Pell amount against the student schedule. 8. Based on course load/scheduled credits the student account will update the amounts on the batch 9. Student accounts will ok the batch once corrections to eligibility are made and send back to Ivy for payment.

Corrective Action Plan December 16, 2022 Cognizant or Oversight Agency for Audit Labette Community College respectfully submits the following corrective action plan for the year ended June 30, 2022. Name and address of independent public accounting firm: Jarred, Gilmore & Phillips, PA, P.O. Box 779, 1815 S Santa Fe, Chanute, Kansas 66720. Audit period: Year ended June 30, 2022. The findings from the December 16, 2022 schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. Finding: 2022-001 ? Special Tests and Provisions ? Return of Title IV Funds Condition: The date of the institution?s determination of a student?s withdrawal is the date the student began the official withdrawal process or the date of the student?s notification, whichever is later. During our testing of the withdrawn students, it was noted that Labette Community College did not use the correct determination date when calculating the return of Title IV funds. Recommendation: Policies and procedures should be written and additional training should be understanding of the institution?s date of determination of a student?s withdrawal. Views of responsible officials and planned corrective action: New staff continue to be trained and are learning the rules and regulations with Title IV Funding. We have also added this to a R2T4 checklist staff use to ensure there are no more errors when reporting the date of the school?s determination on the R2T4. If the Oversight Agency for Audit has questions regarding this plan, please call Leanna Doherty, Vice President of Finance and Operations, at (620) 820-1231. Sincerely, Labette Community College Labette Community College

Responsible Individuals: Lori Herrick, CPA, CFE - Associate Vice President of Finance Dr. Eric Gumm - Registrar and Director of the First-Year Program and Academic Development Center Finding 2022-001 Federal Agency Name: U.S. Department of Education Program Name: Student Financial Assistance Cluster CFDA #84.063, 84.268 Finding Summary: In accordance with 34 CFR sections 690.93(b)(2), 682.610, and 685.309(i), Federal Regulations state that institutions are required to report enrollment information. Out of a sample size of 25 students, there were 19 students identified as not having an incorrect Program Enrollment Effective Date and 3 students in which the update for enrollment status was not timely. Corrective Action Plan (CAP): ACU has identified the source and cause of the variance in the program enrollment effective date. The variance is due to the time stamp associated with certain actions within the Banner reporting system. Immediate implementation of system process to change the time status upon the appropriate enrollment change has corrected this error and the timely reporting of status changes. Anticipated Completion Date: The updated procedure was implemented by the beginning of Fall 2022. Responsible Parties: Dr. Eric Gumm is the responsible party as the University Registrar. He will oversee the execution of the corrective action plan. J Rodriquez is the Assistant Registrar and the responsible part for the implementation and execution of the corrective action plan.

Return of Title IV (R2T4) Calculations Planned Corrective Action: Our process for identifying unofficial withdrawals has been to nm a report through our Workday software to identify students who had unearned credits in a semester at the conclusion of that semester, after the grade due date. We would then reach out to the individual professors of the courses to determine if each student completed the semester or if they had unearned credits because they ceased attending at some point during the semester. If they ceased attending, we would determine if a Return of Title IV (R2T4) Calculation was needed and would complete it if necessary. In preparing for the Al 33 audit, the auditor requested: "If you have online or modular students, please provide a list of students who earned 0 credits or no showed in at least one of the online classes or modules from the registrar." While pulling together the list of students to send to the auditors, we determined that the repo11 we were using to identify unofficial withdrawals did not include students who had No Credit (NC) grades or Incomplete (I) grades. It was only pulling Failed (F) grades. In addition, the report only included students who had received F grades in all the courses for the semester; it did not include students who received 0 credits in one of the modules. The report was corrected and should enable PLNU to identify all the students who need to be reviewed going forward. In addition, we have added to our process instructions to run this report after the grades for module I are due, and after the grades for module 2 are due, rather than at the end of each semester. This will ensure that we catch any unofficial withdrawals in a timelier manner and will allow us to meet the 45-day deadline for any possible returns that must be made. Person Responsible for Corrective Action Plan: Jamie Asche, Director of Financial Aid Anticipated Date of Completion: 11/30/2022

Name of Responsible Individual(s): Stacey Brackett, University Registrar Corrective Action: The University has modified reporting practices to SSCR in order to meet Federal Regulations 34 CFR 690.83(b)(2), 34 CFR 682.610 and 34 CFR 685.309. The Office of Academic Records will report student enrollment to SSCR on the 15th of every month (or the following business day if the 15th falls on a weekend, holiday or scheduled university closure). This plan will allow for reporting from SSCR to NSLDS to meet the 60 day timeline for student status change. The University has also strengthened report criteria to ensure that all current program and major detail are provided to SSCR. Anticipated Completion Date: 12/31/2022

Name of Responsible Individual(s): Courtney Thompson, Director of Financial Aid Corrective Action: The University has reviewed current practices related to withdrawal/R2T4 calculations. As a result, the University will enhance current policy and procedures to better support staff in the proper calculation of return of Title IV funds requirements. These enhancements will include but are not limited to; additional staff training and periodic secondary review. The Office of Financial Aid will also work with the Office of Academic Records to document substantiated last dates of attendance for withdrawing students. Anticipated Completion Date: 5/31/2022

2022-003 Incorrect Direct Loans Disbursement Amount - Student Financial Aid Cluster Assistance Listing Number 84.007, 84.033, 84.063, 84.268, 84.038 Grant Period - Year Ended June 30, 2022 Condition Found During our student file testing we noted four students out of forty were not disbursed the correct Direct Loans award. Based on the student?s enrollment status and need, the College over awarded Direct Loans to the students by $2,993. We consider this to be a significant deficiency relating to the Eligibility Compliance Requirement. Corrective Action Plan Due to the institutional policy, we have updated our process to check and recalculate all loans for the current semester in the following semester by the census date. Responsible Person for Corrective Action Plan Jeremy Hurse ? Director of Student Financial Services Deborah Beck ? Associate Director of Student Financial Services Implementation Date of Corrective Action Plan 01/16/2023

2022-002: Missing Exit Counseling Documentation - Student Financial Aid Cluster - Assistance Listing #s 84.033, 84.007, 84.063, 84.268, 84.038 - Grant Period - Year Ended June 30, 2022 Condition Found During our student file testing, we noted three students out of forty did not have documentation in their file that exit counseling was sent thirty days after the student withdrew from the College. We consider the missing exit counseling to be an instance of non-compliance with the Eligibility Compliance Requirement. Corrective Action Plan We have updated our process to check for any students who have withdrawn from the institution. After speaking with the registrar?s office, we are creating a report that will provide us with the withdrawal date so we may begin notifying students of their requirement for exit counseling. Responsible Person for Corrective Action Plan Jeremy Hurse ? Director of Student Financial Services Deborah Beck ? Associate Director of Student Financial Services Implementation Date of Corrective Action Plan 01/16/2023

Federal Perkins Loans ? Assistance Listing No.: 84.038 Recommendation: We recommend that the University implement a procedure to ensure that all necessary MPNs are retained in accordance with the federal regulation. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: All Perkins funds were audited in FY21 and we acknowledge that there are some files with missing MPNs. All the files have either been purchased from DOE or are currently receiving active payments. If payments do not remain current, we assign these loans to DOE after one year. There is no opportunity to recreate MPNs on these old loans, so no corrective action is possible. Name of the contact person responsible for corrective action: Michelle Hegarty, CFO Planned completion date for corrective action plan: December 2021

Student Financial Aid Cluster ? Assistance Listing No.: Various Recommendation: We recommend that the University review their policies surrounding federal grants and ensure a review process is in place to ensure that all necessary compliance requirements are met. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Registrar will be taking over all submissions going forward to ensure timely and accurate responses. Name of the contact person responsible for corrective action: Kris Ragozzino, Registrar Planned completion date for corrective action plan: May 1, 2023

Student Financial Aid Cluster ? Assistance Listing No.: Various Recommendation: We recommend reviewing the components of the enrollment roster file to ensure the correct effective date is reported correctly for both the "Campus Level" and "Program Level". Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: We report directly to the National Student Clearing house and rely on their punctuality in forwarding our report to NSLDS. On an institutional level, graduation processes have been modified to include secondary verification of graduate files. Monthly audits are performed to monitor report results. If errors are discovered during the audit, updates will be made to the report prior to sending to the National Student Clearinghouse and the report will be corrected. Lastly, when a new employee accidently makes an error, the staff is re-educated in student drop and withdrawal business rules to prevent further communication lapses regarding student enrollment. Name of the contact person responsible for corrective action: Kris Ragozzino, Registrar Planned completion date for corrective action plan: Already in place.

Name of Responsible Individual: Terri Grice, University Registrar Corrective Action: Although the Registrar?s Office has experienced turnover in leadership and staff roles in recent years, the remaining staff has adapted and taken on additional duties, as needed. This past summer, the office regained their sense of stability with the hiring of a staff member and a Registrar. The office is continuously cross-training all team members so duties are cross-checked, shared by at least two team members, and completed in a timely manner. The reports used by this office will be reviewed on a frequent basis to ensure information is being reported as it was intended. Team is also meeting with other departments to ensure information is shared consistently which will ensure accurate reporting to Clearinghouse and other agencies. Anticipated Completion Date: April 3, 2023 for five (5) audit findings/ Training will be continuous throughout the year.

Name of Responsible Individual: Brian K. Blackburn, Director of Financial Aid Corrective Action: A system error prevented scheduled Pell disbursements from taking place on the appropriate day thus creating a discrepancy in the timing of reporting. This discrepancy created the need for all disbursements to be verified manually and during the time needed to complete verification of the disbursement, the University was out of compliance. New reports have been created to ensure that all scheduled disbursements have disbursed within the University system and in the COD system and are accurately reported within the 15 calendar days as required. In the case of the identified student and their Direct Loan disbursement, the student's Unsubsidized loan was inadvertently disbursed with required documents missing. The University has put in to place a series of reports and measures that ensures a loan will not disburse if a student is missing required documents or is not in one of Powerfaids "Ready to Disburse" statuses. Anticipated Completion Date: March 7,2023

Name of Responsible Individual: Brian Blackburn, Director of Financial Aid Corrective Action: The University has assigned a Financial Aid Staff member to more closely monitor the NSLDS Transfer Monitoring List that comes in from NSLDS on a monthly basis and coordinate with the Registrar's Office to ensure that all information is updated in a timely manner. Additionally, we have put in place a new policy that Title IV aid will not be paid until after the end of the Drop/ Add period of any given semester. Anticipated Completion Date: March 22, 2023