Corrective Action Plans

Over Award Review and Correction Action Taken – Kansas Health Science Center (KHSC) Identifying Number: 2023-001 Finding: Eligibility – Determining Federal Direct Student Loan Awards Applicable Regulation: Per 34 CFR 686.203(b)(iii), in the case of a graduate or professional student for a period of enrollment beginning on or after July 1, 2012, the total amount the student may borrow for any academic year of study under the Direct Unsubsidized Loan program may not exceed $8,500. Per 34 CFR 685.203(c)(2)(v), the additional amount that a student described in paragraph (c)(1)(i) of this section may borrow under the Direct Unsubsidized Loan Program for any academic year of study may not exceed the following: in the case of a graduate or professional student, $12,000. Finding: During testing of eligibility, 7 out of 7 students selected for testing were over awarded Unsubsidized Federal Direct Loans. KHSC improperly awarded 61 out of 61 students Unsubsidized Federal Direct Loan in excess of the maximum amount for one academic year, amounting to [$4,445] per student, for a cumulative over award of [$271,146]. Summary: Prior to the commencement of the independent audit conducted for the fiscal year ended May 31, 2023, the institution discovered that it had over awarded Unsubsidized Federal Direct Loan funds to its students. Specifically, the institution awarded additional Unsubsidized Federal Direct Loan funds based on 12-month academic calendar instead of prorating the award based on a 10-month academic calendar. This error resulted in an over award of [$4,445] per student. The institution conducted a file review and refunded all amounts owed to the Federal Student Aid programs because of the file review. The institution also informed the auditor of this error. Corrective Action Taken or Planned: Once the above noted error was discovered, the institution conducted an audit of all student aid packages for students enrolled in the 2022-2023 academic year. It was determined that 61 current students had been over awarded by a net amount of $4,445, for a total of $271,146. Findings were compiled and a plan was created to return over awarded funds and communicate the error to students. The institution also consulted with the Department of Education to confirm its revised calculation was appropriate. The institution returned the funds between July 5-July 20, 2023. Further, the institution made students whole by forgiving any student balances that would have been paid by the over award amount. Emails were sent to all impacted students on July 3, 2023 notifying them of the error. The institution also subsequently notified students that any account balance that remained based on the reversal of the over award would be forgiven. Students who received an estimate financial aid award with the incorrect figures, but who had not yet received aid, were notified of the error and provided updated award information. To ensure this does not happen again the institution has updated their internal student finance audit to include a review of all aid eligibility in conjunction with the next year’s academic calendar for each class of students. Upon any determination that future aid should be prorated, calculation(s) will be completed and reviewed with leadership before implementation. An internal review and approval process will then be enacted and documented. The institution informed RSM of this error and the corrective actions taken. Contact Person Lawrence McGhee, Associate Vice President of Financial Aid, lawrencemcghee@tcsedsystem.edu Completion Date July 20, 2023

Student Financial Assistance Cluster – Assistance Listing No. 84.268 Recommendation: We recommend the University evaluate its policies and procedures around reporting student status changes to the NSLDS to ensure that all relevant information is being captured and reported timely in accordance with applicable regulations. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The University has evaluated its policies and procedures around reporting student status changes and will make the following changes to ensure proper data capture and timely reporting: Following the conclusion of a graduation cycle, the NSC Degree Verify extract will be verified via a cross-check with the BANNER ERP system information on degrees awarded to assure no one is missing or mis-reported. Further, the BANNER de-activation process (SHRDEGS) will be run for the proper semester parameters, so that the student record will reflect proper periods of activity and graduation for those who graduated. BANNER’s registration processor has been configured to update time status dynamically. No longer will there be any discrepancy between the status date in BANNER and the date reported to the NSC and subsequently to NSLDS. The NSC extract of enrollment data will be matched to a separate report of registered students for the given semester to assure that no one is being missed. Name(s) of the contact person(s) responsible for corrective action: Gerard J Donahue Planned completion date for corrective action plan: Completed and effective as of February 28, 2024

Student Financial Assistance Cluster – Assistance Listing No. 84.038 Recommendation: We recommend the University evaluate its procedures and policies around recordkeeping and record retention. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The University will generate a master list of all prior students with Perkins Loans. That master list will track location of files/documentation and provide the tracking to have all files secured all in one properly secured location. Name(s) of the contact person(s) responsible for corrective action: Michele McDevitt Planned completion date for corrective action plan: In progress as of February 28, 2024. A complete master list of students who received Perkins loans will be cross checked against the student’s actual file contained in fire proof cabinets, verifying each student’s master promissory note is on site. This process will be completed no later than August 1, 2024. If the United State Department of Education has questions regarding this plan, please contact Michele McDevitt at mmartin@lasalle.edu or 215.951.1651

Student Financial Assistance Cluster – Assistance Listing No. 84.007, 84.033, 84.038, 84.063, 84.268 Recommendation: We recommend the University evaluate its procedures and review policies in overseeing student credit balances to ensure that any credit balances as a result of Title IV aid are returned within the required timeframe. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The University will evaluate the current refund process and make revisions to process to ensure any credit balances of Title IV aid are returned within the required timeframe. The university’s goals is to automate the refund process to reduce the chance of human error, and placing the refund process on a schedule to ensure refunds are processed within the appropriate window of time. Name(s) of the contact person(s) responsible for corrective action: Michele McDevitt Planned completion date for corrective action plan: September 9, 2024 – first rounds of Fall 2024 refunds

Our Lady of the Lake University of San Antonio FY 2023 Single Financial Audit Finding Response Corrective Action Plan – Reconciliation of COD Monthly School Account Statement Compliance Finding: The Department of Education’s (DoE) School Account Statement (SAS), downloaded electronically from the Common Origination Destination (COD) website, was not being reconciling monthly as required by the Student Financial Aid/ Direct Loan Program. Criteria or Specific Requirement: Per the Student Financial Aid/ Direct Loan Program requirements with the DoE, every school is required to reconcile their SAS to their accounting system records at least monthly. This statement is issued to each participating school through the SAIG mailbox monthly. The auditors noted 34 CFR 685.102(b), 385.300(b), 685.301, and 303 as the compliance regulation. Cause of Noncompliance: It appears that the SAS was reconciled monthly per the compliance requirement in recent years, but with high turnover and periods of under-staffing in the Accounting department this procedure was changed to one that did not meet the above requirement. Although OLLU did regularly reconcile the accounting system records with reports from COD, it was not the official monthly SAS statement. OLLU’s modified procedures did not completely meet the compliance requirement but did offer some mitigating procedures. Institution Response: OLLU has already begun coordinating processes between its Accounting and Financial Aid departments to download the monthly SAS into the university’s system electronically, where Accounting will then reconcile the statement monthly as a part of its month-end close procedures. The Financial Aid Director will be responsible for ensuring that the statement is downloaded monthly as a part of the regular electronic data file transfer between OLLU and the Department of Education. The Senior Accountant in the Accounting department will generate the report in Colleague via the DRSS process and reconcile the SAS statement to cash records. The Director of Accounting and Reporting will review the reconciliation monthly.

2023-002 Student Financial Assistance Cluster- Assistance Listing Number: 84.063, 84.268 Recommendation: We recommend the University review its reporting procedures to ensure that students' statuses are accurately and timely reported to NSLDS as required by regulations. Explanation of disagreement with audit finding: There is no disagreement with the finding. Action taken in response to finding: The Office of the Registrar will continue to submit enrollment data to the National Student Clearinghouse via the current schedule. The Office of the Registrar will investigate and resolve any errors returned by the National Student Clearinghouse. After the enrollment data is transferred from the NSC to NSLDS a University representative will review the data in NSLDS for any discrepancies including cross-checking graduation files and complete withdrawals. Any inconsistencies will be discussed and timely resolved by the applicable units and officially updated in NSLDS and NSC respectively. The University will keep track of any changes manually made within the NSLDS or NSC database by university representatives, so that the student information system, NSC, and NSLDS records are in-sync. Name of the contact person responsible for corrective action: Dennis Koch, Associate Vice President of Financial Services Planned completion date for corrective action plan: 3/15/2024 If the Department of Education has questions regarding this plan, please call Dennis Koch at 309-667-3119.

2023-001 Student Financial Assistance Cluster- Assistance Listing Number: 84.007, 84.038, 84.063, 84.268, 84.379, 93.364 Recommendation: We recommend that the University review its procedures related to outstanding student refund checks to ensure they are being returned to the Department of Education after 240 days. Explanation of disagreement with audit finding: There is no disagreement with the finding. Action taken in response to finding: The Financial Services Division of the University (FSD) has implemented a new process to better track the status of student refund checks. After the first week of the month, all outstanding checks from the prior month are investigated in order to identify student refund checks that were the result of Title IV funds (e.g. January outstanding checks are reviewed after the first week of February). A representative from FSD will contact the borrower within 45 days of the original issuance date via email to inform them that the check remains outstanding and provide them with the option to EFT the funds directly to the student or void the check and reduce the borrowing with the Department of Education. The original check will remain valid for the 90 days stated on the face of the check. After 90 days, no additional communication will be made to the borrower. The check will be voided and borrowing will be updated with the Department of Education after 90 days of the original issuance, but prior to the 240 days allowed by the Department of Education. In additional to establishing a process to handle any future refund checks, the University.is also in contact with the Department of Education to provide process clarity on how to return funds related to refund checks for years where the financial aid year has been closed. Name of the contact person responsible for corrective action: Mark Young, Assistant Controller Planned completion date for corrective action plan: 2/29/2024

A plan has been developed to take corrective action regarding findings 2023-001 in our audit for the year ended May 31, 2023. Due to previous manual processes and significant staffing turnover in the Accounting and Financial Aid areas, this summer, we discovered some of the R2T4 calculations were missed. Once this was discovered, we went back through and ensured all the withdrawal calculations were done and funds returned, even though they were outside the compliance timeframe. While testing the return of Title IV funds from a sample, FORVIS noted that two students did not have a refund calculation completed in a timely manner. These findings had been discovered by SBU and corrected, and funds were returned earlier, but they were still outside the compliance timeframe, which required an audit finding. To address these issues, SBU employees have taken the following corrective measures: 1. We reworked the reporting process for withdrawals. All withdrawals now go to the Associate Provost regardless of campus or program. They are then processed by the Registrar’s Office and placed in a shared drive. Once there, they are reviewed weekly by the Financial Aid Office, and R2T4s are completed in a timely manner. This process no longer relies on a member of the Accounting Office to notify Financial Aid of a withdrawal. 2. R2T4 requests are completed by one Financial Aid staff member and verified and processed by another to ensure accuracy and reliability. 3. We have implemented an administrative withdrawal process to give campus and program directors the ability and authority to withdraw students who are no longer in attendance to limit the number of all Fs at the end of the semester. Sincerely, Terri Rogers Controller

Student Financial Aid – Aid – 84.268 – Federal Direct Loan Program, 84.063 – Federal Pell Grant Program Recommendation: We recommend a secondary review be done by someone other than the SFA Director to ensure disbursements and verifications are completed accurately and timely. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Director of Financial Aid will notify the Vice President of Operations of disbursements and verifications, and the Vice President will complete a secondary review. As this is the final year in which Lincoln Christian University will have academic operations, we believe this corrective action to be sufficient for the remainder of the year. Name(s) of the contact person(s) responsible for corrective action: Nancy Siddens, Director of Financial Aid. Planned completion date for corrective action plan: November 1, 2023.

Student Financial Aid – 84.268 – Federal Direct Loan Program, 84.063 – Federal Pell Grant Program, 84.007 – Federal Supplemental Educational Opportunity Grant Program, 84.033 – Federal Work-Study Program Recommendation: We recommend the review process for awarding be documented and retained as support for the review and approval process. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Director of Financial Aid will document each change to an award by printing a new award offer and saving to document tracking. As this is the final year in which Lincoln Christian University will have academic operations, we believe this corrective action to be sufficient for the remainder of the year. Name(s) of the contact person(s) responsible for corrective action: Nancy Siddens, Director of Financial Aid. Planned completion date for corrective action plan: November 1, 2023.

Views of Responsible Officials and Planned Corrective Actions - Drury University accepts this finding. • Upon discovery of a programming error within the enrollment report obtained from the Jenzabar system for transmission to the National Student Clearinghouse (NSC), the report was immediately corrected by the Registrar and rechecked prior to its transmission to NSC in October 2023. The Registrar has expressed confidence that the error is corrected but has set up additional system queries to be checked against the report to ensure accuracy prior to transmission of future reports. • Financial Aid Office and Registrar’s Office will review and compare actual enrollment and program information with the data reported in NSLDS after each submission. Any corrections will be made as soon as is practicable, but not later than 30 days after the discrepancy is identified.

View of Responsible Officials and Planned Corrective Actions – Drury University accepts this finding and has created a Corrective Action Plan (CAP). In all four cases identified in the finding, the late return of funds were for students who unofficially withdrew (ceased attending) and did not notify the institution. Henceforth, within 10 days of grades being posted at the end of each semester, Financial Aid will liaise with the Registrar’s Office to review all unearned F grades and determine if a return of funds is required. Additional automated tasks already have been created in the PowerFAIDs software that notify the Financial Aid Administrator (FAA) when a Return of Title IV Funds (R2T4) has been completed but not processed. The FAA will monitor R2T4 processing and returns to ensure that returns are processed within the required timeframe.

Saint Mary's believes that the switch to J1 and upcoming J1 software patch should solve the reporting issues. We anticipate that all students will be submitted to the Clearinghouse correctly, and will set up ad hoc reports to verify no students are missed. As for the NSC reporting correctly to NSLDS, we anticipate that the two entities have resolved the issues that they were having in communicating with each other. The Registrar's Office will ask the Financial Aid office to verify that students are being reported to NSLDS correctly. The Registrar's Office does not have access to NSLDS, but the prior Financial Aid Director did, so the current one should as well.

Untimely Returns of Title IV Funds (R2T4) Planned Corrective Action: We have engaged an outside vendor to provide knowledgeable staff augmentation to help us improve our processes and the timeliness of completing R2T4s. Additionally, we have planned supplemental training for our staff to complete R2T4s. Person Responsible for Corrective Action Plan: Cathy Morgan, Director of Student Financial Services Anticipated Date of Completion: March 1, 2024

Common Origination and Disbursement (C OD) Reporting Planned Corrective Action: We are working to put a double check process in place, and to understand which step in the internal aid process has the opportunity to ensure this date exactly matches the COD disbursement date. The team had not realized that the date must match exactly. We have engaged an outside vendor to provide knowledgeable staff augmentation to help us improve our processes and the timeliness of our disbursing of Title IV funds. Person Responsible for Corrective Action Plan: Cathy Morgan, Director of Student Financial Services Anticipated Date of Completion: March 1, 2024

2023-004 Treatment of a student who fails to receive a passing grade in any class (Significant Deficiency), Department of Education, Student Financial Aid Cluster. Criteria: An institution must have a procedure for determining whether a Title IV aid recipient who began attendance during a period completed the period or should be treated as a withdrawal. If a student who began attendance and has not officially withdrawn fails to earn a passing grade in at least one course offered over an entire period, the school must assume, for Title IV purposes, that the student has unofficially withdrawn, unless the institution can document that the student completed the period. In the absence of evidence of a last day of attendance, a school must consider a student who failed to earn a passing grade in all classes to be an unofficial withdrawal. Condition: From a population of 35 students that received all failing grades in a term, we tested five students and noted that documentation of the last date of attendance could not be provided for any of the students tested. Action Taken: The Provost’s Office has drafted a memo to faculty explaining the requirement to enter the last day attended for any student receiving a failing grade.  The Registrar’s Office has added this requirement to their routine reminders to faculty about entering grades.  The Clerk of the Faculty has agreed to bring this change in policy to the faculty to add to the Faculty Handbook in section 3.1.10 Reading Day, Final Examinations, and Course Grades.  Plan for auditing effectiveness of corrective action: The Register’s Office is turning on the requirement in Bannerweb (student system) that any F or NC grade cannot be entered in the system without a last date of attendance. An audit report will be able to be generated on this data. Responsible Party: Provost, Registrar, and Faculty, under the supervision of the Provost is responsible for implementing this corrective action plan and ensuring compliance. Point of Contact: Maria Rosales, Provost, mrosales@guilford.edu, 336-316-2205 Expected date of correction: April 2024

The University experienced staffing turnover in the financial aid department during the 2022-2023 aid year, resulting in certain established processes to go unfollowed. In March 2023, the University hired a full time on campus Director of Financial Aid, which has stabilized the department staffing. The Director has established clear roles and responsibilities so that established processes are not missed going forward.

The University experienced staffing turnover in the financial aid department during the 2022-2023 aid year, resulting in certain established processes to go unfollowed. In March 2023, the University hired a full-time on campus Director of Financial Aid, which has stabilized the department staffing. The Director has established clear roles and responsibilities so that established processes are not missed going forward. Additionally, the University has reviewed all procedures for identifying official and unofficial withdrawals, adding a new requirement for all faculty members to include a last date of attendance for all unsatisfactory grades input into our student information system. Additionally, job duties have been reallocated to ensure calculations on official and unofficial withdrawals and exit counseling communications are done on a timely basis going forward.

There is no disagreement with the audit finding. Corrections for this finding started in January 2023. Initial months selected were prior to that date. Additional months were provided, tested and complied. NCU will continue to do our monthly reconciliations in the same manner.

There is no disagreement with the finding. All program lengths have been corrected in our NSLDS reporting cycle. Unfortunately, the implementation went beyond the May 31, 2023, fiscal year. During a recent internal audit of 20 students we can now see the published length correctly reporting in NSLDS for all investigated students.

There is no disagreement with the audit finding. We have diligently reviewed our procedures and implemented robust measures to ensure strict adherence to the regulations governing Return of Title IV Funds. Our efforts have focused on establishing comprehensive double checks throughout the process to mitigate any potential errors or oversights. This includes enhanced annual training, dual verification process - every Return of Title IV fund calculation must now be calculated first by our Financial Aid Data and Reporting Analyst and then re-calculated and reviewed by the Executive Director of One Stop. We now have a robust documentation process for each return and prior to the end of the fiscal implemented internal audits of all withdrawn students. We are confident these measures will maintain compliance and ensure accuracy.

Christopher Cartmill, Director of Financial Aid, Telephone 716-375-7888. We are in agreement with the auditors' recommendation to ensure personnel involved with R2T4 calculations receive appropriate training and update the policies and procedures manaual to require formal review and approval of all R2T4 calculations. We have developed additional procedures to ensure institutionally scheduled breaks are being considered in determining a student's percentage of Title IV aid earned. The procedures include participation in training webinars and updates to the policies and procedures manual with detailed instructions on how to calculate the number of days in the semester and formal review and approval of all R2T4 calculations. The procedures also include secondary check by the Director or designate, of entered dates in the calculation set up. The training and updated policies and procedures were completed on September 14, 2023, effective with the Fall 2023 term and forward.

Corrective Action Plan: The College acknowledges that the noted three off-cycle disbursements did not meet the notification requirement. The College has evaluated its current procedures for releasing its financial aid notifications and identified system improvements that will result in notifications being sent prior to the disbursements being processed to ensure all requirements for this program are met. Timeline for Implementation of Corrective Action Plan: These process and system updates will be implemented before the end of fiscal year 2024.

The Office of Student Financial Aid will update their procedures to verify the proper aid is packaged and awarded based on the student status.

2023-004 Student Financial Assistance Cluster – 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: With one year until the program is fully sunset, we will continue to manage and safeguard the promissory notes that we have in our possession. We do not disagree that some MPNs were not able to be found, but with only 90 accounts remaining, we are confident that we have the grand majority of MPN’s needed to close the program in the near future. Name(s) of the contact person(s) responsible for corrective action: Michael Johnson, Controller Planned completion date for corrective action plan: March 1, 2024