Corrective Action Plans

Student Financial Aid Cluster – Special Tests and Provisions – GLBA Recommendation: We recommend the College finalize its written information security program to ensure its compliance with the GLBA Safeguards Rule along with appropriately managing its information technology and cybersecurity risks. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The College’s Information Technology department will amend the written program and policy to include all necessary aspects of GLBA compliance and IT management and cybersecurity risk. Names of the contact person responsible for corrective action: Gwen Pechan Planned completion date for corrective action plan: March 31, 2024

Student Financial Aid Cluster – Special Tests and Provisions – NSLDS Recommendation: We recommend that the College continue to enhance its policies and procedures regarding enrollment reporting including additional monitoring over the third-party service provider to ensure that reporting is 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 Office of the Registrar reports enrollment to NSLDS using the National Student Clearinghouse (NSC). The Registrar’s Office will collaborate with our Information Technology Department to identify and correct all students with erroneous program start dates. As recommended by CLA, the Registrar’s Office is reviewing its process for Clearinghouse submissions in collaboration with the Information Technology Department and Advising Office to ensure that the program-level enrollment effective dates are accurately reflected when a student submits a change of major. Names of the contact persons responsible for corrective action: Sheia Pleasant-Doine and Adam Doine Planned completion date for corrective action plan: May 3, 2024

2023-001: Incorrect Pell Disbursement - Student Financial Aid Cluster Assistance Listing Number 84.007, 84.033, 84.063, 84.268, Grant Period - Year Ended August 31, 2023 Condition Found During our student file testing we noted one student out of forty was not disbursed the correct Pell Grant. The student was enrolled as three-quarters time but was awarded as being a full-time student resulting in an over award of $574. We consider this error to be an instance of noncompliance relating to the Eligibility Compliance Requirement. This finding was repeated from last year, see Prior Year finding 2022-002. Corrective Action Plan Financial Aid Office will make sure to disburse the accurate Pell Grant amoutn according to the students' enrollment status. EWU will return the over awarded Pell to reflect the correct amount for the student. We have never had a finding for awarding full time Pell to a three-quarters attending student. This was an isolated incident. Responsible Person for Corrective Action Plan Director of Financial Aid Cesar Campos Implementation Date of Corrective Action Plan February 15, 2024

2023-002 Incorrect Direct Loans Disbursement Amount - Student Financial Aid Cluster Assistance Listing Number 84.007, 84.033, 84.063, 84.268, Grant Period - Year Ended August 31, 2023 Condition Found During our student file testing we noted two students out of forty were disbursed the incorrect Direct Loan amount. Based on the student’s enrollment status and need the students were over awarded $4,500 in Subsidized Loans and under awarded $4,500 in Unsubsidized Loans. We consider this error in awarding to be an instance of noncompliance of the Eligibility Compliance Requirement. Corrective Action Plan Financial Aid office will make sure the correct amount is awarded based on the student enrollment status and need of the student. EWU will make the proper adjustments to the Direct Subsidized Loan and Direct Unsubsidized Loan to reflect the correct amount foer the two students. Responsible Person for Corrective Action Plan Director of Financial Aid Cesar Campos Implementation Date of Corrective Action Plan February 15, 2024

Program: AL 93.658 – Foster Care Title IV-E; AL 93.658 – COVID-19 Foster Care Title IV-E – Allowability Corrective Action Plan: The Agency will update where necessary policies and procedures to ensure adequate documentation be maintained to support that expenditures are allowable and proper in accordance with State and Federal regulations. Contact: Andrew Keck Anticipated Completion Date: 6/30/2024

Corrective Action Plan As a corrective measure, the following will be carried out: 1. A procedure will be documented with instructions for making and completing transfers. 2. Students' transactions that require transfer between academic terms must be handled by the designated Collections staff, completing the entire transaction in the University system. 3. Once the transfer transaction is completed, it must be verified by the Enrollment Manager, ensuring that the debt collection process has been completed in compliance with the provisions of Title IV. 4. At the Central Office, a report with all transfers made during the academic year will be produced to review and monitor the correctness of the transactions.

Corrective Action Plan The Inter American University of Puerto Rico (IAUPR) will implement the following actions to strengthen compliance with the 30-day reglementary period for the R2T4 determination: 1. IAUPR will also prepare compulsory online or face-to-face training sessions which all full and part-time faculty will be required to take in August and January of each year. The training sessions will review grading policies and any other procedures required for compliance with Federal Regulations. The primary executives of each academic unit, through the Deans of Academic Affairs, will be responsible for ensuring and certifying to the Vice President of Academic and Student Affairs that all faculty participated in the training. 2. The Deans of Academic Affairs or their designees at each academic unit will monitor the entry of final grades in the Banner System and report any suspicious grades and suspected cases of noncompliance with Federal Regulations to the chairs of the academic departments for immediate follow-up and correction. 3. IAUPR will develop a course of action whereby a department chair or dean of academic affairs may correct or update a grade in the Banner System, based on the academic information available, when a faculty member is unable to do so because of a force majeure. 4. In recurrent cases of noncompliance, the primary executives of each academic unit will send a written communication to faculty that do not comply with established procedures and include a copy of the communication in the professors' academic/administrative files.

Finding 2023-001: Student Financial Assistance Cluster, Department of Education Programs Program Name: Federal Direct Student Loans CFDA Numbers: 84.268 Corrective Action Plan: The University will update written procedures to clearly identify a step to manually do enrollment testing following all conferral of degrees. For those regularly scheduled graduation periods and following the submission of both the degree and last of term enrollment files, we will randomly sample 10% of graduated students and manually verify their statuses. For degrees conferred outside of the regularly scheduled graduation periods, each record will be manually verified. This will ensure recorded graduation records will be verified within the National Student Clearinghouse to ensure alignment between degree history and enrollment history. The error was found to be a bug in the reporting software that happened in the current fiscal year. The University’s processes in previous years were correct as this error was not present. Completion Date: Estimated March 2024

Trinity University Corrective Action Plan June 30, 2023 Department of Education Trinity University respectfully submits that following corrective action plan for the year ended June 30, 2023. Brown Edwards 3906 Electric Road Roanoke, VA 24018 Audit Period: June 30, 2023 2023-001 Treatment of Title IV Funds when a Student Withdraws (Significant Deficiency), Department of Education, SFA Cluster Criteria: Returns of Title IV funds are required to be deposited or transferred into the SFA account or electronic fund transfers initiated to the Department of Education as soon as possible, but no later than 45 days after the date the institution determines that the student withdrew in accordance with 34 CFR Section 668.173(b). Condition: Nine of seventeen students selected for withdraw testing for the 2022-2023 academic year required a return of funds to the Department of Education. Calculation of R2T4 forms for two students were not completed when they were in fact due a refund. Action Taken: The University is modifying the withdrawal procedure to provide more specific rules and instructions related to R2T4 requirements and timeliness. A shared document has been created in order to identity and monitor students who have withdrawn and are due a refund to ensure that refunds are made in a timely manner. Responsible Party: Cathy Geier Contact Information: Vice President of Enrollment Services Office Phone: (202) 884-9545 Email Address: geierc@trinitydc.edu Expected date of correction: January 12, 2024

FINDING 2023-003: Pell Calculation Planned Corrective Action: The Director of Financial Aid has created a Summer Pell specific reconciliation report to ensure accurate Pell calculations. Additionally, a custom data field in our financial Aid operating system, PowerF AIDS, has been created to flag all summer Pell eligible students for manual review by both the Director and the Associate Director of Financial Aid.

FINDING 2023-002: Timely Reporting to NSLDS The Registrar and the Landmark College Database / Application Systems Analyst met with the National Student Clearinghouse (NSC) to address this issue. This discussion surfaced the information about how NSC schedules their files and the revelation that Covid pushed the NSC submission schedule back. As a result of the meeting, the NSC first of term file will revert to preCovid. Planned Corrective Action: The correction to reports by NSC should correct this error going forward

Finding No. 2023-003: Failure to Notify Recipients of Federal Direct Loan Disbursement CFDA Numbers: 84.268 Program: Student Financial Assistance Cluster Corrective Action: The University added a monitoring report to identify any communication failures for disbursement notifications. Implementation Date: June 10, 2024 Contact Person: Amanda Fijal

Finding No. 2023-004: Untimely and Inaccurate Reporting of Pell and FDL Data CFDA Numbers: 84.268 Program: Student Financial Assistance Cluster Corrective Action: A control will be added to loan set-up. Additional training was provided to staff monitoring loan reports. Implementation Date: June 10, 2024 Contact Person: Amanda Fijal

The Financial Aid Office concurs with the audit finding of the monthly SAS reconciliation requirement to be done internally was not in compliance. Whittier College Financial Aid Staff failed to send the SAS files monthly to our Accounting Department for reconciliation. As of September 2023, Whittier College Financial Aid Office has calendared a monthly reconciliation report to be sent to the Accounting Department to meet the guidelines set forth by the Department of Education. This reconciliation report will be sent monthly through out the calendar year. In the summer months of June and July we may not have any funds to reconcile, however, a report will be sent regardless for compliance. Person Responsible: Jesse Marquez, Associate Director and Information Specialist of Financial Aid Anticipated Completion Date: Implemented as of September 2023

The Office of Financial Aid concurs with the audit of Pell 15-day reporting finding. The Compliance is clearly stated the timeframe to send an original Pell Grant disbursement to COD is within 15 days of the date of disbursement. We also understand we have the ability to go back into the account and make an adjustment as needed. As of September 2023, Whittier College has reached out to our software vender Ellucian Banner to find a solution on how to avoid these incidents of not sending Pell Grant disbursements to COD in the timeframe allotted for compliance. We have now been given a new process that will solve this issue to ensure the Pell Grants are all originated on COD thus allowing the disbursements to be sent within the 15-day compliance timeframe. We will continue to reconcile the Pell Grants twice a month internally to ensure any issues get resolved, if any noted, in a timely manner. Persons Responsible: Jesse Marquez, Financial Aid Associate Director and Information Specialist; Julie Aldama, Financial Aid Director Anticipated Completion Date: Implemented as of September 2023

The Office of the Registrar concurs with the audit finding of delayed reporting which noted that while there is now a process to submit enrollment and graduation information to NSLDS in a timely manner, the team noticed that three students’ information was not reported to NSLDS within the 60 days required to transmit status change. Due to staffing changes and challenges, Whittier College failed to meet the reporting window indicated in the NSLDS November 2022 Enrollment Reporting Guide, which states, “At a minimum, schools are required to certify enrollment [status change] every 60 days[.]” As of September 2023, Whittier College has adjusted the transmission schedule of enrollment reports to the National Student Clearinghouse to meet the guidelines set forth by NSLDS. Whittier College will submit enrollment files to the National Student Clearinghouse on the 30th of every month, with the exception of the December end of term enrollment report, which will be submitted on the Friday before the last working day before the holiday break. Degree Verify reports will be submitted to the National Student Clearinghouse within two weeks of the conferral date of every term to ensure the timeliness of status change submissions to NSLDS. Whittier College will also correct error reports and resubmit within the 10 days indicated by NSLDS to ensure compliance. Person Responsible: Brianna Mendez, Student Data Specialist, Office of the Registrar Anticipated Completion Date: Implemented as of September 2023

We concur. The enrollment file reported to NSLDS is submitted on behalf of the District by the National Student Clearinghouse (NSC). Contact will be made to ensure NSC accurately reports these entries on our behalf.

Finding Number: 2023-002 - Inadequate Internal Control over Return of Title IV Funds Planned Corrective Action: The University agrees with the finding. The University has streamlined the process of R2T 4 to prevent delays in processing. This enhanced process creates a countdown report to prioritize R2T4 calculation when staff resources as strained. Contact person responsible for corrective action: Roberta Smith Anticipated Completion Date: 06/30/2023

Finding Number: 2023-002 - Inadequate Internal Control over Verification Requirements Planned Corrective Action: The University agrees with the finding. The Department of Education has removed the previously issued "suspension of verification," therefore internal controls and regular practices for verification have been put back in place. Contact person responsible for corrective action: Roberta Smith Anticipated Completion Date: 06/30/2023

Finding Number: 2023-001 - Inadequate Internal Control over Student Enrollment Reporting Planned Corrective Action: The University agrees with the finding. The responsibility of reporting enrollment has been transitioned to a centralized office on campus. Internal controls have been put in place to ensure enrollment is reported accurately/timely moving forward. Contact person responsible for corrective action: Roberta Smith Anticipated Completion Date: 06/30/2024

Reference: 2023-001 Reporting Finding: Forty-five students were identified during the audit where the disbursement date in the Common Origination and Disbursement (COD) system did not match the date the funds credited to the student’s account. Although the funds were credited within 5 days, the disbursement date in COD was not updated to reflect the actual date the funds credited to the student’s account and therefore did not meet the COD reporting rules. Contact Person: Julie Wickstrom, Assistant Vice President for Financial Assistance & Student Employment Corrective action: Boston University Financial Assistance has improved its quality controls to ensure these dates match and has taken steps to mitigate this reporting issue. To this end BU Financial Assistance is committed to the following action steps: 1. The COD disbursement schedule has been changed to only occur during defined business hours and only on defined days of the week (Monday and Wednesday). This change to the disbursement schedule allows BU to make sure the COD disbursement date is the same date as the federal financial aid credits to the individual student account. 2. Beginning with the 2024/2025 academic year, Boston University will transition from a homegrown mainframe system to PeopleSoft Campus Solutions. This system will allow us to more easily schedule jobs that ensure that the disbursement date in COD reflects the date the funds actually credit to the student’s BU student account. 3. Boston University will better utilize the COD reconciliation reports to monitor COD disbursement date inconsistencies with student account credits and make updates to COD when inconsistencies occur. This finding was also identified during a 2023 Department of Education Program Review and the corrective action plan was implemented at that time.

Contact Person: Susan Willard, Interim Director of Records Corrective Action: The College acknowledges the finding of certain students’ enrollment status changes were not reported timely or accurately to NSLDS in a timely manner to include the proper corrections to their enrollment status. The College experienced a glitch in its ERP system update that impeded the timeliness and made it difficult to retrieve students' data. This issue has since been corrected and the College is submitting the required data to the National Student Clearinghouse in a timely manner. Anticipated Completion Date: May 31, 2024

Contact Person: Donald Hollings, Controller Corrective Action: The Finance Office provided Financial Aid with the incorrect amount to report on the annual FISAP for 2022-2023. The amount reported was $22,069,69,744 rather than $19,859,744. The $22,069,744 was inverted and incorrect. The College will add another level of review before submitting the FISAP to mitigate this type of error. Anticipated Completion Date: May 31, 2024

Contact Person: Traci Veyl, Associate VP of Student Financial Services Corrective Action: The College acknowledges the findings. Corrective action has occurred. The Financial Aid Office has updated policies and procedures to include a new report of all federal student aid to be sent to the Finance Office after any disbursements or adjustments of student aid. This report will include Direct Loans, Pell and SEOG. Anticipated Completion Date: March 11, 2024

San Francisco AAP FY 2022/2023 Corrective Action Plan The Adoption Assistance Program (AAP) was selected as a major program in the City's FY 2022/23 single audit. The Auditor tested AAP's compliance with eligibility requirements. The audit sample consisted of 55 on-going active cases, and 5 intake samples for the Fiscal year 2022-2023 from a random sampling. Findings The Auditor tested a statistically valid sample of 60 participants selected from a population of 1,087 cases receiving benefits under the AAP program for the period of July 1, 2022 through June 30, 2023, the Period under review (PUR). The Auditor noted 7 case findings needing improvement. All case findings were from the on-going active case samples. All of the intake cases sampled were correct with no error. There were no findings found to have any dollar amount errors. The auditor identified the following issues: renewal checklists were not submitted with physical files on a consistent basis. It could not be verified that Supervisor reviews were done consistently on all reassessments as the checklists used by the caseworkers, were not consistently found in the case files. Response to findings The Family & Children’s Services Foster Care Eligibility (FCE) unit recognizes the need for improvements through the Auditor’s findings. Inconsistencies were in large part due to the circumstances of the COVID-19 Pandemic. We have changed our previous business practices to improve deficiencies and maintain program integrity. Root Causes - COVID-19 pandemic The pandemic’s restrictions significantly altered FCE’s traditional in-office schedules and business processes, prompting a significant shift towards remote work arrangements and digital transformation. FCE adapted quickly to these operations changes while trying to maintain employee safety. This transition necessitated the need for flexible working hours, increased reliance on virtual communication, implementation of new technologies, and business processes to streamline workflows. - Physical files o FCE, during the PUR of this audit, used physical case files. Digital case files offer many advantages that FCE wasn’t able to access, such as easier accessibility, improved organization capabilities through search functions, greater security measures to protect sensitive data from unauthorized access or loss, and better oversight capabilities. Overall, transitioning from physical case files to digital files will result in having files easily accessible and will increase effectiveness and efficiency. - Staffing issues During the PUR, there were a variety of staffing issues that included leaves, promotions, and shortages. These staffing changes significantly impacted the administration of FCE program benefits. Corrective Actions - Future Staff training o We have recognized the need to develop refresher training for staff that will provide a thorough understanding of our AAP business processes. These trainings will ensure that AAP case reassessments are processed uniformly across the program. By investing in the development of these refresher staff trainings, we aim to equip our staff with the knowledge and skills necessary to perform their roles effectively and contribute positively towards achieving our organizational goals. o Time frame to implement trainings will be no later than 6/1/2024 with completion by 10/2024. - Digital Files o FCE recognizes the need to move from physical case files to digital case files. The COVID-19 pandemic provided the catalyst to speed up the transition to digital files. With the change to digital imaged files, future case reviews and tasks completed by workers and supervisors can, and will, be done more efficiently and will provide the necessary oversight.  Imaging case files conversion project was created in 4/2023.  FCE is currently at 70% percent converted to digital case files since the implementation of CalSAWS (11/1/2023).  FCE plans to convert to 100% digital files by the end of June 30, 2024. - Systematic Reporting o Reports generated from CalSAWS and case tasking will help improve our program’s overall efficiency.  Effective 11/2023, implementation of new task reports generated from CalSAWS will aid staff with reminders of tasks and will improve overall case review.  CalSAWS provides unit Supervisors with reports of overdue, pending and future case actions needed, including AAP reassessments.  By June 30, 2024, FCE will provide unit Supervisors and staff with additional tools to support them with their case tracking and reporting. This includes developing detailed reports accessible through our eligibility system CalSAWS. The AAP Corrective Action plan will be administered by FCE Program Specialist Justin Hyun and overseen by Program Manager, Juliet Halverson.