Corrective Action Plans

2022-003 FINDING: FEDERAL PERKINS LOAN COHORT DEFAULT RATE TOO HIGH Corrective Action Plan: The University?s cohort default rate significantly improves on a year-to-year basis. As indicated in the finding, the University?s cohort default rate during the Fiscal Year 2022 (for borrowers who entered repayment during Fiscal Year 2021) was at 11.11%, meeting the 15% threshold. However, since the number of University borrowers who entered repayment during Fiscal Year 2021 were fewer than 30, the current cohort default rate calculation also included the University borrowers who entered into repayment and defaulted for the past three years, in accordance with federal regulations. The University will continue to closely monitor and communicate with students entering on default on a month-to-month basis, in addition to sending defaulted student loans to the Illinois State Comptroller?s Offset system. Responsible University Personnel: Villalyn Baluga, Associate Vice President for Finance; Linda Theres-Jones, Director/Chief Accountant. Anticipated completion date: Already implemented during FY 2020.

2022-002 FINDING: ENROLLMENT REPORTING Corrective Action Plan: The University reports enrollment status changes to the U.S. Department of Education?s National Student Loan Data System (NSLDS) through the National Student Clearinghouse (NSC), a third-party servicer. There is currently no mechanism for reporting students who were administratively withdrawn after the semester (the students registered for) ended until after the next reporting cycle to the NSC. The University will work with the NSC to determine a course of action to report these exceptions to NSLDS at the earliest possible date. Responsible University Personnel: Timothy Carroll, Registrar. Anticipated completion date: Summer 2023 Term.

Student Financial Assistance Cluster ? Assistance Listing No. Various Recommendation: We recommend the University review its procedures to ensure that key personnel changes are reported to the Department of Education in the required 10-day timeframe. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: CSP has made sure that more than the Financial Aid Director has the information to access the E-APP. We also put into place a secondary designated person for SAIG and other portals and process as able. Name of the contact person responsible for corrective action: Amanda McCaughan, SFA Director Planned completion date for corrective action plan: February 2023

Student Financial Assistance 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's Office has been working with National Student Clearinghouse since September 22, 2022, to review findings on error reports and how to resolve the specific errors. For example, Social Security Number not matching error was instructed to send a card via email and trying to identify a safe way to provide that student information instead of through an unsecured email inbox. We are actively working on the current error report for students who flag as NSLDS errors, even though the NSC data is accurate. NSC has verified that reporting is moving to NSLDS. The Registrar's team will keep all email communication to the NSC Audit team regarding error reporting. Name of the contact person responsible for corrective action: Lynn Lundquist, Registrar Planned completion date for corrective action plan: September 2022

Student Financial Assistance Cluster ? Assistance Listing No. Various Recommendation: We recommend the University review its reporting procedures to ensure the 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 audit finding. Action taken in response to finding: Registrar's Office reports enrollment data every 30 days to the National Student Clearinghouse. Registrar's Office individually updates student records to maintain compliance with the 60-day update in NSLDS. The Registrar's Office has been communicating with the National Student Clearinghouse since September of 2022 regarding timelines of NSC to NSLDS updates. NSC has confirmed that updated information has been reported in time. Registrar's Office has sought specific information regarding audit findings as reported information to NSC is within the timeline. Registrar Team has been reviewing Program and Campus Level information since September of 2022 as regulations had been newly modified. Name of the contact person responsible for corrective action: Lynn Lundquist, Registrar Planned completion date for corrective action plan: April 2023

Student Financial Assistance Cluster ? Assistance Listing No. Various Recommendation: We recommend that the University implement a review process as it relates to R2T4 calculations. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: CSP has created and started to use a report that pulls any student with a course withdrawal to verify no withdrawals are missed for an R2T4. A 2-step review has been put place, the first review to pull the data and complete the calculation and the second review with double check and return the funds. A CSP employee in the R2T4 review process registered and is currently attending the NASFAA U R2T4 course. Additional training for all FA staff on R2T4?s will be completed by May 31st. Name of the contact person responsible for corrective action: Amanda McCaughan, SFA Director Planned completion date for corrective action plan: Additional reports are already created; additional training will be completed by May 31st

The Director of Financial Aid will ensure that a process is created to identify students that are scheduled to graduate, withdraw, or drop below half-time in order for them all to complete exit counseling. Students will be notified at the time of withdrawal by phone, email, and a certified letter with the steps to complete the exit counseling.

The Office of Financial Aid has created a process where they will check Common Origination Disbursement (COD) to ensure that each student has a valid entrance counseling. Each counselor will also make a notation in the Financial Aid system that the student borrower's entrance counseling has been reviewed.

The Controller and Compliance Officers are working together to correct the previously filed reports to update the estimated total number of students at the institution that are eligible to receive Emergency Financial Aid Grants to Students under the CARES (a)(1) subprogram and the CRRSAA and ARP (a)(1) subprograms. Completion Date: April 2023 Contact Person: Tom Corley, Controller and Director of Fiscal Operations and Carrie Stevens, Associate Vice President of Compliance

Student Accounts Receivable, Controller?s Office, and IT are working together to develop more real-time reporting and tracking for student account refund balances to identify student accounts with refund balances that remain undistributed more than seven days after being created to prioritize those accounts for refund processing. Completion Date: June 30, 2023 Contact Person: Heather Long, Director Student Accounts

The Registrar and the IT department are working together to ensure timely and accurate data is being transmitted on a regular schedule to the Clearinghouse as needed. When date determination exceptions occur (e.g., degrees being conferred after initial reporting or withdrawal dates being retroactively determined for administrative purposes), the Registrar?s Office, IT, and Financial Aid will work together to determine the appropriate date adjustments needed to manually update the Clearinghouse with the correct information if needed as quickly as possible. Completion Date: June 30, 2023 Contact Person: Julie McAdoo, University Registrar

project Number: 21st Century - Project 553. Corrective steps: Procedures have been put in place to ensure employees are being paid in accordance with the District contracts with board approval. All extra duty contracts have been signed by the Varnum School Board. Completion date: 3-20-2023. Plan for monitoring adherence to the corrective action plan: The Varnum Schools Superintendent will monitor for compliance.

2022-003 Significant Deficiency: Exit Counseling (U.S. Department of Education, William D. Ford Direct Loan Program, ALN #84.268) Name of Contact Person: The Director of Financial Aid, Christin Mustard, is responsible for the corrective action for this finding. Exit counseling letters are generated by the Financial Aid Counselors, who report to the Director of Financial Aid. Corrective Action Plan: King University concurs with finding 2022-003, that exit interviews were not sent to students as required upon withdrawal from the university or dropping below halftime enrollment status. This functionality was handled by previous staff who are no longer with the university. These duties were not clearly assigned in our policies and procedures, which resulted in inconsistencies in sending out exit letters as required. We now have established clear policies and procedures to correct this finding. These are as follows: As part of the withdrawal process, the Financial Aid Counselors will send exit letters within the required timeframe upon receiving notification from the Office of Registration and Records that a student has withdrawn from the University. The counselors will also utilize the Daily Load Report and a series of selection sets to identify students who have dropped below halftime enrollment, and will send the exit letters as required by federal regulations. Anticipated Completion Date: The Financial Aid Office has reviewed all students who have withdrawn or dropped below halftime enrollment status in the 2021-22 and 2022-23 award years to ensure that exit letters were sent. This corrects these findings.

2022-004 Significant Deficiency: Awarding Eligibility (Federal Pell Grant Program, ALN #84.063) Name of Contact Person: The Director of Financial Aid, Christin Mustard, is responsible for the corrective action of this finding. Financial Aid packaging is performed by the Financial Aid Counselors, who report to the Director of Financial Aid. Corrective Action Plan: We concur there were instances where King failed to calculate/disburse Federal Pell Grant funds appropriately based on their updated Enrollment Status/EFC. We found that the Pell distribution fund was locked, which prevented the Pell recalculation when the higher ISIR transaction was loaded. In addition, there was not a report in place to alert the Financial Aid office of students enrolled in both traditional and modular courses. As a result, those students were not being identified/monitored effectively for enrollment changes. King is currently updating its policies and procedures to capture and monitor enrollment status of traditional students enrolled in a combination of traditional and modular courses. This will ensure that Pell Grant is awarded correctly based on enrollment status and modular courses for which the student verified. Additionally, we will ensure that Pell Grant award distributions are unlocked so that the Powerfaids system will update the Pell award amounts correctly according to EFC changes from subsequent ISIRs. Anticipated Completion Date: All Pell findings have been reviewed, and errors that could be corrected have been resolved.

2022-002 Significant Deficiency: National Student Loan Data System (NSLDS) Report (U.S. Department of Education, William D. Ford Direct Loan Program, ALN #84.268 and Federal Pell Grant Program, ALN #84.063) ?Did not supply status updates to NSLDS in a timely manner. Name of Contact Person: The Director of Registration and Records, Whitney Cleland, and the Director of Institutional Research and Assessment, Jason Thead, are responsible for the corrective action plan for this finding. Corrective Action Plan: King University uses the National Student Clearinghouse to report enrollment changes to NSLDS. Effective Fall 2022, King University will submit enrollment data uploads to the National Student Clearinghouse at least every 30 days. The first of term submission will occur within 21 days of the start date of the term. Monthly enrollment reporting will correspond with module drop/add periods and will occur no later than 10 business days after a module drop period ends, per the Academic Calendar. Additionally, and as a part of the enrollment submission process for the National Student Clearinghouse (NSC), which provides data to NSLDS, an exception report is generated for each enrollment file prior to submission. This exception report is verified and remedied before data is submitted to NSC. Once data is submitted to NSC, an error report is generated from the NSC system. For any students who have status or level changes, the Director of Institutional Research and Assessment verifies all dates with an internal report, called the Enrollment Analysis by Course report, to ensure dates are accurately reported to the NSC. This report is also used by the Office of Financial Aid to ensure withdrawal dates are consistent. This internal report and process ensures that the dates used for all offices are the same, which remedies any communication issues between offices. Additionally, notices are sent by Financial Aid for adjustments to withdrawal dates, which are corrected in our database management system (DBMS). These additional steps allow the DBMS to accurately and collectively capture all applicable students, and the exception and error reports allow the institution to ensure the correct information is reported. We believe a portion of the untimely reporting to NSLDS is a result of the reporting delays between the National Student Clearinghouse and NSLDS, as documented in GENERAL-22-64 beginning July 25, 2022. The Dear Colleague letter and subsequent updates describe issues with enrollment functionality, which affected enrollment reporting. King conducted a review on a sample of students and found that students were reported correctly to the Clearinghouse but were not appearing in NSLDS. A more frequent enrollment schedule should remedy this issue. We also attribute these delays to changes in leadership/staffing during that timeframe. The enrollment reporting steps were outlined by the prior Registrar when this process transitioned to the Office of Institutional Research, but this staffing transition could have resulted in inaccurate data being captured and reported during a window of time in Fall 2021 (when the reporting responsibility transitioned). Additionally, it was discovered that incorrect coding in the CAMS database management system (DBMS) was causing exclusions based on a missing field. These exclusions began in Summer 2021 due to added majors that were not correctly created. Anticipated Completion Date Per above, effective Fall 2022, enrollment data is now uploaded to the National Student Clearinghouse at least every 30 days. Furthermore, the missing fields in the DBMS have been remedied, and the institution is working with NSC and NSLDS to correct previously misreported records by February 2023.

2022-001 Significant Deficiency: National Student Loan Data System (NSLDS) Report (U.S. Department of Education, William D. Ford Direct Loan Program, ALN #84.268 and Federal Pell Grant Program, ALN #84.063). Incorrectly reported student enrollment status. Name of Contact Person: The Director of Registration and Records, Whitney Cleland, and the Director of Institutional Research and Assessment, Jason Thead, are responsible for the corrective action plan for this finding. Corrective Action Plan: King University uses the National Student Clearinghouse to report enrollment changes to NSLDS. Effective Fall 2022, King University will submit enrollment data uploads to the National Student Clearinghouse at least every 30 days. The first of term submission will occur within 21 days of the start date of the term. Monthly enrollment reporting will correspond with module drop/add periods and will occur no later than 10 business days after a module drop period ends, per the Academic Calendar. Additionally, and as a part of the enrollment submission process for the National Student Clearinghouse (NSC), which provides data to NSLDS, an exception report is generated for each enrollment file prior to submission. This exception report is verified and remedied before data is submitted to NSC. Once data is submitted to NSC, an error report is generated from the NSC system. For any students who have status or level changes, the Director of Institutional Research and Assessment verifies all dates with an internal report, called the Enrollment Analysis by Course report, to ensure dates are accurately reported to the NSC. This report is also used by the Office of Financial Aid to ensure withdrawal dates are consistent. This internal report and process ensures that the dates used for all offices are the same, which remedies any communication issues between offices. Additionally, notices are sent by Financial Aid for adjustments to withdrawal dates, which are corrected in our database management system (DBMS). These additional steps allow the DBMS to accurately and collectively capture all applicable students, and the exception and error reports allow the institution to ensure the correct information is reported. We believe a portion of the untimely reporting to NSLDS is a result of the reporting delays between the National Student Clearinghouse and NSLDS, as documented in GENERAL-22-64 beginning July 25, 2022. The Dear Colleague letter and subsequent updates describe issues with enrollment functionality, which affected enrollment reporting. King conducted a review on a sample of students and found that students were reported correctly to the Clearinghouse but were not appearing in NSLDS. A more frequent enrollment schedule should remedy this issue. We also attribute these delays to changes in leadership/staffing during that timeframe. The enrollment reporting steps were outlined by the prior Registrar when this process transitioned to the Office of Institutional Research, but this staffing transition could have resulted in inaccurate data being captured and reported during a window of time in Fall 2021 (when the reporting responsibility transitioned). Additionally, it was discovered that incorrect coding in the CAMS database management system (DBMS) was causing exclusions based on a missing field. These exclusions began in Summer 2021 due to added majors that were not correctly created. Anticipated Completion Date Per above, effective Fall 2022, enrollment data is now uploaded to the National Student Clearinghouse at least every 30 days. Furthermore, the missing fields in the DBMS have been remedied, and the institution is working with NSC and NSLDS to correct previously misreported records by February 2023.

In response to Federal Award Finding 2022-002, updates to the National Student Loan Data System (NSLDS) will occur monthly to reflect Federal Financial Aid enrollment status changes and include the following procedures: 1) Financial Aid Coordinator will review enrollment roster on NSLDS monthly for accuracy, print and sign monthly report. a. A monthly enrollment report will be pulled and cross-referenced with NSLDS Certification Report by additional Student Services staff member. b. If student data is missing or incorrect, the Financial Aid Coordinator will contact NSLDS to address. Missing or incorrect data will be reported to the Student Services Coordinator and Director in writing. 2) Financial Aid Coordinator will identify due dates to ensure compliance for 15 day window for reporting and maintain a calendar noting load dates to ensure deadlines are met. 3) Financial Aid Coordinator will submit monthly report to Student Services Coordinator for review. 4) Instructors will receive additional training addressing submittal of timely withdrawal forms. 5) Student enrollment status change will be updated upon receipt of student withdrawal form. Copies of the withdrawal form and status change will be placed in student's financial file. 6) Student Services Coordinator will review withdrawal form and status change documentation for reporting accuracy and timeliness, sign and date copy of status change form. Data between FOCUS Postsecondary Student Data System and NSLDS will be compared to ensure accuracy. The procedures noted above will ensure timely updates and accuracy in the National Student Loan Data System. The Financial Aid Coordinator will finalize all edits.

Management Views and Corrective Action Plans 2022-001- Reporting on the Fiscal Operations Report and Application to Participate ("FISAP") Point of Contact- Robert Friedman, Director of Student Finance, (646-592-6255) Management agrees with the current year finding, which is related to the prior year finding, and the recommendations to enhance controls to include a reconciliation process, to ensure completeness and accuracy of the FISAP. In addition, management will process a request to make the necessary corrections through the COD website and follow the procedures for submitting changes onto the FISAP. The University's Controller's Office or its designee in conjunction with the Office of Student Finance will perform a review of the FISAP reconciliation prior to filing. We believe this finding will be rernediated prior to the University filing the September 2023 FISAP after completing a full reconciliation of the Perkins fund and through collaboration with the Perkins Portfolio office.

Finding 2022-008 Corrective Action Plan: In our effort to enhance our ability to access older Perkins Loan records, we will engage our information technology consultants to research our information collection system. Currently our ability to access older Perkins Loan records is restricted due to system constraints. The findings from this engagement will be recorded and memorialized for the record. Anticipated Completion Date: June 30, 2023

Finding 2022-004 Corrective Action Plan: The Financial Aid division has revised its compliance process to ensure the effective administrative and internal control oversight of the notification of the Direct Loan disbursements. As a part of this revised compliance process, students receiving financial aid while attending one or more other institutions will be ?singled out? for a detail review in accordance with the National Student Loan Data System (?NSLDS?) Student Transfer Monitoring Process. The Director of Financial Aid will perform periodic reviews to ensure the new process is being effectively executed in a timely and accurate manner. An internal review will be performed Spring 2023 with the Director of Financial Aid, Data Coordinator and neutral third party selected from another division within the University (documentation of these compliance tests will be memorialized for the record, June, Oct, Feb). Anticipated Completion Date: June 30, 2023

Finding 2022-007 Corrective Action Plan: To enhance the internal controls over the applicable compliance requirements of the enrollment reporting requirement to ensure that all status changes are submitted to the NSLDS website within the required timeframe, the Registrar?s office in coordination with the Information Technology Division will develop a ?flag based? process to capture and review all enrollment status changes on a monthly basis. This new reporting process will enhance the Registrar?s ability to review and accurately submit timely notifications to the National Student Loan Data System (?NSLDS?). These monthly reviews will be recorded and memorialized for the record. Anticipated Completion Date: June 30, 2023

Finding 2022-003 Corrective Action Plan: The University has made the necessary changes to the staff and to the review process including, but not limited to, the hiring of both a Senior Financial Aid Counselor and a Director of Transfer Students. The new Director of Transfer Students will have the necessary access/ability to generate the information and update the system to improve the University?s capability to monitor requirements of Title IV aid to ensure enhanced compliance. This will eliminate the challenge created by multiple financial aid counselors being assigned the responsibility for initiating the process, generating the information, and updating the system on a weekly basis. In addition, the Director of Financial Aid will receive alerts when the process has been completed, and perform periodic reviews, using sample populations, to ensure the process is being done timely and accurately. As this is a repeat finding, the University?s corrective action plan is being implemented immediately?Spring 2023. An internal review will be performed using Spring 2023 data with the assistance of the Director of Financial Aid, Director of Transfer Students and a neutral third party selected from another division within the University (documentation of these compliance tests will be memorialized for the record, June, Oct, Feb). Anticipated Completion Date: June 30, 2023

The University will revise processes to ensure that notifications are received as required by the Code of federal regulations. 1) Perform a review of (implement enhancements to) current processes to ensure appropriate notification to students.

The University will review processes to ensure that adequate internal control exists to mitigate risks related to collection of required verification documents are collected. 1) Ensure that staff are trained on the required verification documents to be collected. 2) Perform periodic review of student files to verify completeness of records.

The University will perform a risk assessment that is inclusive of the requirements outlined in the GLBA.