Corrective Action Plans

Finding No. 2022-001: Financial Aid Administration ? Control Deficiency Federal Agency: U.S. Department of Education CFDA Number and Title: 84.063 ? Federal Pell Grant Questioned Costs: $ - Responsible Individual: Jodie Kuba, Director of Financial Aid Nikki Chun, Div. of Enrollment Management, Vice Provost for Enrollment Management Date Action Taken: August 1, 2022 Due to staff following the 45-day timeframe for the Return to Title IV Calculation, staff did not take into account the 30-day requirement to return funds when it could not be confirmed if a student academically attended the course(s). To ensure compliance with federal aid regulations, the Financial Aid Services office will work with the Office of the Registrar to confirm academic attendance as needed and complete the return to Title IV calculation within 30 days.

2022-007 Finding: Exit Counseling Not Completed ? Edwardsville Campus Response: We agree. SIUE Student Financial Aid has reintroduced a Banner process which runs simultaneously with the current bi-monthly process, in order to notify students of exit counseling requirements at the earliest possible time. Corrective Action Plan: Implemented. Specifically, we are running exit counseling reports more frequently and comparing exit requirements from Banner process to in-house process to create a job that runs exit counseling through production control. We will continue to work with the appropriate office for assistance on how to ensure the appropriate flag gets checked to ensure the proper results. Contact Person: Jeremy Baker (SIUE Student Financial Aid Associate Director) Anticipated completion date: October 31, 2022

Corrective Action Plan The Union College Economic department chose to change the Classification of Instructional Programs (CIP) code to more accurately reflect the degree requirements of this particular major. The CIP code change process is typically applied at the start of a new academic year, but in this case, the College felt that it was necessary to do so immediately. The National Student Clearinghouse (NSC) was consulted to be sure that students would, in fact, graduate in the new CIP code without negative impact to their program. As a result of this late semester change, a number of Economics majors were manually corrected in the NSC and reported as graduated with the new CIP code. In the future, Union will adhere to its standard timelines and processes for curricular changes, as the ?ad-hoc? nature of such changes are difficult to manage. Upon further pressure for resolution, the NSC has now provided instructions regarding how to resolve the students reporting issues. A new file will be transmitted to the National Student Loan Data System (NSLDS) in early March, once further updates are received and processed by the NSC. Union College will review the NSLDS database to confirm accurate reporting once the file has been submitted. Union College will also perform self-audits to ensure our processes are efficiently capturing enrollment changes and that the NSC and NSLDS reports agree and are accurate beginning with the March 2023 enrollment period.

2022-002 Student Financial Assistance Cluster ? Assistance Listing No. Various Recommendation: We recommend the University review the procedures surrounding PELL and TEACH awarding to ensure the proper cost of attendance is used so that amounts awarded do not exceed calculated financial need and awards are proper. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The University returned the ineligible Pell and Teach funds to ED. The University has implemented new processes, which include, but are not limited to, a second review of all student packages for the aid year. Prior to the start of each semester, the student package will be reviewed for subsequent ISIRS, grade level, and enrollment statuses, to ensure the Pell and Direct Loan eligibility is awarded correctly. Prior to awarding TEACH grants, the student package will be checked for the ATS (agreement to serve) and counseling. For continuing students, we will check the cumulative GPA from the prior year to ensure students are meeting the cumulative GPA of 3.25 to receive TEACH for the subsequent award year. Additionally, we have added new TEACH aid components to our student information system (SIS) to include the ATS (agreement to serve) and counseling. Student(s) will not receive any TEACH grant until they have met all three requirements. Lastly, campus based funds will be reviewed once a semester for need, and eligibility requirements. Name(s) of the contact person(s) responsible for corrective action: Lisa Stone, Director of Financial aid, Sean Corcoran, Associate Director of Financial Aid and Joyce Hatch, Financial Aid advisor. Planned completion date for corrective action plan: Fall 22

2022-001 Student Financial Assistance Cluster ? Assistance Listing No. Various Recommendation: We recommend the University reevaluate its procedures and review policies surrounding reporting status changes and other enrollment information to NSLDS to ensure timely and accurate reporting. We also recommend the University review its reporting procedures to ensure all errors are corrected with the appropriate timeframe as required by regulations. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding. The process described in the corrective action plan in response to 2021-001 was developed and implemented in August of 2022. This was after the close of FY22. Therefore, the process had no bearing on the FY22 SFA audit. We believe the effects of the new process will be reflected in the FY23 SFA audit. To recap the corrective action plan from 2021-001: Training with the National Student Clearinghouse (NSC) online reporting system was implemented. A consequence of the training was that the Associate Director of Institutional Research (ADIR) acquired the necessary knowledge of how to manually change program enrollment dates in the NSC online system to correspond to the University?s internal records. The ADIR continues to adhere to the master calendar for reporting to ensure timeliness. Name(s) of the contact person(s) responsible for corrective action: Lisa Stone, Director of Financial Aid, Eric Tompkins, Associate Director of Institutional Research and Jeff Phillips, AVP of Institutional Effectiveness. Planned completion date for corrective action plan: Fall 2022

Finding ? Special Tests and Provisions: Enrollment Reporting ? Federal Direct Student Loan Program, Assistance Listing Number 84.268; June 30, 2022 Award Year; U.S. Department of Education Criteria or Specific Requirement Enrollment information, including the effective date of separation from the institution, must be accurately reported within 30 days whenever attendance changes for a student, unless a roster will be submitted within 60 days. The changes include reductions or increases in attendance levels, withdrawals, graduations, and approved leaves-of absence. It is the institution?s responsibility, as a participant in the Title IV aid programs, to monitor and report these changes to the National Student Loan Data System (?NSLDS?). (NSLDS Enrollment Reporting Guide September 2021, and 34 CFR 685.309(b)) Condition Of the 40 students selected for enrollment reporting testing, two students within the sample were reported to NSLDS outside the maximum 60-day window. This was not a statistically valid sample. Views of Responsible Officials and Planned Corrective Actions The School concurs with the finding. The School intends to report student status changes at year end. Names of Contact Person Responsible for Corrective Action: Anne Marie Martorana, Chief Financial Officer Anticipated Completion Date: December 14, 2022

AUDIT PERIODS: 7/1/21 TO 6/30/22 - A. COMMENTS ON FINDINGS AND RECOMMENDATIONS - FINDING 2022-001 - OVERAWARDED FEDERAL DIRECT SUBSIDIZED LOAN: DURING THE AUDIT, IT WAS NOTED THAT ONE STUDENT WAS OVERAWARDED A SUBSIDIZED LOAN. IT WAS RECOMMENDED THAT THE SCHOOL RETURN $762 IN SUBSIDIZED LOAN TO THE DEPARTMENT. THE INSTITUTION AGREES WITH THE FINDING. B. ACTIONS TAKEN OR PLANNED FINDING 2022-001 - STUDENTS ARE MANUALLY PACKAGED. ALTHOUGH THE CORRECT AMOUNT OF LOAN WAS PACKAGED $2,825, THE FACT THAT THE STUDENT WAS IN THE FINAL SEMESTER OF HIS PROGRAM WAS MISSED AND THE LOAN WASN'T PRORATED. THE LOAN WAS REALLOCATED IN THE CORRECT AMOUNTS OF $2,062 FEDERAL SUBSIDIZED LOAN AND $763 FEDERAL UNSUBSIDIZED LOAN THE SAME DAY WE WERE MADE AWARE OF THE ERROR. LOAN DISBURSEMENT REPORTS WILL CONTINUE TO BE MONITORED FOR STUDENTS - WITH SPECIAL EMPHASIS ON THOSE WHO ARE IN THE FINAL SEMESTER OF THEIR PROGRAM TO CONFIRM THAT THE LOAN ALLOCATION IS CORRECT.

2022-002: Incorrect Pell Disbursement - Student Financial Aid Cluster Assistance Listing Number 84.007, 84.033, 84.063, 84.268, Grant Period - Year Ended August 31, 2022 Condition: During our student file testing we noted two students out of forty were not disbursed the correct Pell Grant. For the students the wrong Pell chart was used resulting in an under award of $150 for each student. We consider these errors to be instance of noncompliance relating to the Eligibility Compliance Requirement. Corrective Action Plan: East-West University will correct the two students to reflect the correct Pell Grant, in addition we will also be implementing check and balance system to ensure the correct Pell Grant is disbursed. Responsible Person for Corrective Action Plan: The Director of Financial Aid Cesar Campos will be the person for the corrective action plan. Implementation Date of Corrective Action Plan: 02/16/2023

Finding 2022-001 - Non-Compliance with Timely and Accurate Student Enrollment Change Submissions to the National Student Loan Data System (NSLDS) Grantor: U.S. Department of Education Program Name: Student Financial Assistance Cluster Award Names: Federal Pell Grant Program and Federal Direct Loan Program Award Year: 7/1/2021 - 6/30/2022 Award Number: Not applicable Assistance Listing Numbers: 84.063 and 84.268 Rensselaer agrees with the finding and in concurrence with the recommendations has developed and is implementing the following corrective action plans: Rensselaer?s Registrar?s Office is working with Rensselaer?s IT Department (?EIS?) to validate the logic of the data parameters included within every enrollment file. Validation will include ensuring all student status changes are reported in the enrollment file, including retroactive changes even if the student is not enrolled in the current semester. Rajni Soharu, the Institute?s Registrar, is responsible for implementing this corrective action plan by March 31, 2023. As of the date of this report, the Registrar?s Office is now fully staffed and employees are trained on the student status change requirements and system usage. Additionally, Rensselaer?s Student Success Office will now communicate changes in student enrollment information to the Registrar?s Office in real-time through a shared file. The shared file will be updated by the Student Success Office as soon as they receive any new approved leave of absence or withdrawal information from Student Health Services or other departments. The Registrar?s Office will update the student?s enrollment information within the student information system within three business days of the change reported and ensure the student?s status change is timely and accurately submitted to the National Student Clearinghouse. Rajni Soharu, the Institute?s Registrar, in collaboration with members of the Student Success Office are responsible for implementing this corrective action plan by January 31, 2023. Eileen McLoughlin Vice President for Finance and CFO

Corrective Action Plan Audit Finding Reference: 2022-002 Planned Corrective Action: In response to audit finding 2022-002, the current policy requires a master promissory note (MPN) to be stored in a locked, fireproof safe. We acknowledge there may have been gaps in internal controls during the 1970s and 1980s resulting in the missing MPN. Since 2005, MPNs are electronically signed and maintained by ECSI, our third-party servicer. During 2022, Trinity submitted 154 loans to the Department of Education (DOE) for assignment. While the University did not have an MPN for nine of these loans, the DOE accepted all but one loan based on additional documentation provided in lieu of an MPN. To determine potential future exposure, the University reviewed paper files for the 25 borrowers with loans disbursed prior to 2005 and found only three additional borrowers with a missing MPN. If the University were required to purchase these loans from the DOE, the estimated purchase amount would be less than $30,000. Date of Remediation: October 2022 Contact Person Responsible: Clara Wells

CORRECTIVE ACTION PLAN February 8, 2023 Juniata College respectfully submits the following corrective action plan for the year ended May 31, 2022. FINDING 2022-001 Corrective Action Taken: The Controller & Chief Financial Officer, in response to the finding of the incorrect rounding in the return to Title IV calculation, reviewed the FSA Handbook and communicated the finding with both the Director of Student Financial Planning and the Bursar. As a result, the Bursar updated the calculation spreadsheet to ensure that the calculation was rounding to three decimal places for the current academic year. The Senior Leadership Team was also apprised of the finding. Name of Contact Responsible for Corrective Action: Karla D. Wiser, CPA Anticipated Completion Date of Corrective Action: August 18, 2022

View of Responsible Officials Condition A We concur. The department received the notice of non-cooperation on 9/14/21 and did not enter the non-cooperation until 9/29/21, which was beyond the 10-day time frame. The case should have then been confirmed to impose the sanction on or before 9/24/21. This resulted in the client being over issued by approximately $222.37. Condition B We concur. The sanction for non-cooperation with Child Support was entered in error as Child Support did not issue a non-compliance. This resulted in the client being under issued by approximately $446.50 Follow-up We will be informing all supervisors of the specific errors found during the audit. We will also require supervisors to include these topics at their next staff meeting. In addition, individual emails will be sent to the staff involved with the errors and provide guidance. Anticipated Completion Date: N/A Contact Person: Karyl Provost

2022-003 NSLDS Reporting Recommendation: We recommend the University review its reporting procedures to ensure that students? statuses are accurately 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: please see below Name(s) of the contact person(s) responsible for corrective action: Elizabeth Vestal, Registrar. Planned completion date for corrective action plan: December 31, 2022 with continued auditing after. Four areas of deficiency have been identified within our current enrollment reporting process. Specifically, 1) the university did not correct errors within ten days, 2) the program begin date reported to NSLDS (National Student Loan Data System) does not match the university?s records, 3) the student?s program enrollment effective date is incorrectly reported to NSLDS and 4) status changes were not certified and/or received within sixty days. In response to your findings, the Registrar?s Office has created a plan of action to remedy the errors. The enrollment reporting process has new leadership at the university. The findings from the new audit team will be corrected. The corrections will require the university to change current behaviors, practices, and reports. Findings two and three are connected to the program start date entered into Colleague. Currently, when processing a program add or change in Colleague (student information system), the program start date defaults to the first day of the month of the start of the term. In the past admissions and advising have been instructed to enter the upcoming term date as the program start date in the SACP (Student Academic Program) screen of Colleague. Unfortunately, this is not being done consistently and several teams have reverted to using the default date and the issue was not identified prior to reporting. The following outlines the proposed corrective action plan: 1) New and re-entry/re-admit students, program changes, or change of residency a. Effective for student programs starting in Fall 2 2022, the program start date in Colleague will match the start date of the upcoming term or end date of prior term. The operator will manually correct the default date to mirror the first day of the start term or end date of prior term in Colleague. i. If there is a potential issue with the date of the upcoming term, the Registrar?s Office must be consulted prior to committing to an alternate date. 2) Active continuing students a. Phase 1: The Fall 1 2022 census report will be used to generate a list of all currently active students. Each student will be manually reviewed to verify the program effective start date reflects the start of term at the university or start of term for the next declared program/major. Although the start date of a program change is not required to match the start of term for enrollment reporting purposes, this will eliminate processing confusion and increase consistency. i. The first phase of corrections will be completed by October 24, 2022. b. Phase 2: Prior census reports will be used to capture students who had been active in terms from Summer 1 2021 to Fall 1 2022. The program effective start dates will be reviewed and corrected as needed. i. The second phase of corrections will be completed by December 31, 2022. 3) Communication a. Issue a Registrar Communication memorandum (RegCom) outlining the new expectations for assigning the program effective start date, auditing schedule, and implications of errors to the following within the university, by October 24, 2022. i. Registrar team ii. Admissions operations iii. Deans, Chairs, and Program Directors iv. Campus success coaches, faculty advisors, and coordinators v. Center directors and staff 4) Inactive students (have not attended since Summer 1 2021) a. The program effective start date of students who have not been active at the university since the Summer 1 2021 term will be reviewed and updated upon re-entry/re-admit to the university (See bullet 1 above). 5) Report/Audit a. Coordinate with the Department of Information Technology (DoIT) to create a SQL report to pull student information from Colleague, including the student?s start term and declared program effective start date. b. The Registrar?s Office will audit the report weekly to ensure all dates are compliant and accurate prior to generating the enrollment file. 6) Colleague functionality a. Explore the possibility of amending the default date assigned by Colleague. i. This is restricted by the capabilities of the SIS. If unable to amend, we would continue with manual process noted above. Findings one and four relate to the timing of file submission and correcting roster errors. The Registrar will review the university?s reporting procedures and schedule to ensure that student statuses are accurately reported through the servicer to NSLDS within sixty days and errors are corrected within ten days. To do so, the Registrar will: 1) Establish an annual schedule to report student statuses every thirty to sixty days. a. Attention will be given to term dates, withdraw deadlines, as well as weekends and calendar holidays. 2) Create a sub-schedule of timing for correcting errors. This schedule should account for days necessary for the servicer and NSLDS to process the data. 3) Audit the SCHER5 and other reports weekly to ensure any remaining errors are corrected within ten days. By taking the above actions, Saint Leo will have processes in place to establish and maintain procedures to reasonably achieve compliance with NSLDS regulations providing timely and accurate data and audit the effectiveness of our data collection and reporting procedures. The university, specifically the Registrar?s Office, is committed to submitting complete, accurate, and timely enrollment data for Saint Leo University students.

2022-002 Return to Title IV Recommendation: We recommend the University review the R2T4 requirements and implement procedures to ensure the R2T4 calculations are using the correct amount of term days and are completed accurately. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Report is being created that will allow staff to compare R2T4 manual data entries against source data. Discrepancies will be researched and corrected within 5 business days. Report will be generated weekly and reviewed by the manager over this area. Name(s) of the contact person(s) responsible for corrective action: Brenda Clark, Director of Financial aid Planned completion date for corrective action plan: Implementation of new quality control R2T4 report planned for October 24, 2022.

This letter is in reference to the following audit finding reference. The enrollment status change was not appropriately reported for three students out of a sample of forty. In each instance, the University of Bridgeport notified the National Student Clearinghouse of the student graduating from the University, but the student?s enrollment status had not been properly updated within the system. The University of Bridgeport has a reconciliation process in place to verify that student?s enrollment status is checked after submitting batch rosters to the National Student Clearinghouse, however the process failed to identify these exceptions. The university of Bridgeport?s proposed corrective action is as follows: 1. The Office of the Registrar will take over Clearinghouse reporting responsibilities from Information Technology. 2. The Office of the Registrar will submit to Clearinghouse enrollment and DegreeVerify files. 3. IF, exceptions are received back from the Clearinghouse, the corrections will made by The Office of the Registrar and with support from Information Technology if needed. 4. Corrections to the file are then sent to Financial Aid. 5. Financial Aid will then submit the corrections to the National Student Loan Database System. 4. These procedures will be recorded in a comprehensive manual. Anticipated Completion date: October 1, 2023 Name of Contact Person: Melissa Quinlan, Ph.D. Vice President of Institutional Effectiveness and Student Systems Carmen Rosa University Registrar Sincerely, Melissa Quinlan, Ph.D. Vice President of Institutional Effectiveness and Student Systems

Audit Finding Reference: Finding 2022-002 Disbursements to or on Behalf of Students Planned Corrective Action: Based on this finding, we will implement a new process starting with the summer 2023 semester. Disbursement notifications will be sent weekly. Name of Contact Person: Kristen Piscioneri Anticipated Completion Date: April 23, 2023 Please feel free to contact me with any questions regarding the corrective action plan. Kristen Piscioneri Director of Financial Aid Operations

RE: Finding 2022-001 Disbursements to or on Behalf of Students Corrective Action Plan: Based on the finding, we implemented a new process to ensure email addresses are populated in the financial aid system, PowerFaids, prior to disbursement. In addition, we incorporate a mix of manual reviews of files as well as an exception report that we run immediately after any disbursements to ensure all notifications have been processed. In addition, our new processes aim to notify students the following business day, but will now always ensure notification within the 7 days allowed under the regulations. Person Responsible for Corrective Action Plan: Name: Bonnie Soltz-Knowlton Title: Assistant Vice President of Financial Aid Anticipated Completion Date: January 11, 2023

2022-002 COD Dates Not Reflecting Actual Disbursement Dates Planned Corrective Action: All 21-22 batch disbursement dates will be checked within COD. Any dates that do not match will be updated to match with the date the funds were disbursed as recorded in Populi. To prevent this in the future when the finance office receives funds and posts them on student accounts in Populi the financial aid office will manually mark each disbursement in Populi to sync and send them to COD. This will cause the disbursements COD status to change to pending in Populi while it processes, when the status changes back to accepted the Populi and COD disbursement data will align. Once updates process with COD each disbursement will again show as accepted a PDF of the disbursement batch will be saved in our files which displays that the awards are synced with COD. We will perform a spot check of the disbursements within each batch by looking up individuals in COD and verifying that the disbursement date updated in the sync from Populi. Person Responsible for Corrective Action Plan: Anna Bergh, Financial Aid Director Anticipated Date of Completion: January 1, 2023

Identifying number: 2022-002 Finding: There are allowable costs such as a benefit allocation and supplies in which there was no formal approval of the cost. Corrective actions taken or planned: Additional levels of review will be added to verify the allowable cost have been approved. Contact person: Steve Schuring, CFO Date of completion: June 2023

Identifying Number: 2022-001 Finding: There were two individuals that did not have a service planning conference within 5 business days of the individual admission date. Corrective Actions Taken or Planned: Additional levels of review and monitoring over compliance with the contract will be put in place. Contact person: Steve Schuring, CFO Date of completion: June 2023

Finding Number: 2022-001 ALN, Federal Agency, and Program Name - Student Financial Assistance Cluster-Federal Direct Student Loan Program ALN 84.268 Condition: The College was not sending notifications meeting the required criteria during the year. Planned Corrective Action: The College has updated notifications to include the required elements beginning in the Fall 2022 semester. Contact person responsible for corrective action: Nicole Hatter Anticipated Completion Date: 11/22/2022

View of Responsible Officials: Management concurred with the finding and has implemented procedures to review the information shared between College of the Ozarks and the NSLDS.

Corrective Action for Audit Finding Background: We tested a sample of 25 students, 13 graduates and 12 withdrawals, for proper compliance with enrollment reporting requirements. We found that the enrollment reporting for the change in status of the 12 withdrawal students were completed within the appropriate timeframe and the withdrawal date per the NSLDS enrollment detail matched the withdrawal date per the student?s academic file. Of the 13 graduates tested, 11 of the students had completed their required courses as of their respective graduation dates and their status change dates were properly reported to the NSLDS. Of the 13 graduates tested, 2 of the students had not completed their required courses as of their standard graduation date; and although they had subsequently completed their test/work and were marked as graduated in the student?s academic file, the change in their statuses was not reported to the NSLDS within the 60-day timeframe. Audit Finding: The Citadel failed to timely report the students? status change in its reporting submission to the NSLDS. Corrective Actions: The Registrar's Office will submit degree files to the Clearinghouse every 30 days for 3 months after the end of the term to help ensure we are able to update the graduation status of student?s whose degrees are awarded after the graduation date. Members of the Registrar's Office will update the Clearinghouse for individuals by hand those students whose graduation takes place after the 3-month period. Keith Gauvin Registrar (843)953-6964 kgauvin@citadel.edu

Finding number: 2022-001 Federal agency: U.S. Department of Education Program: Student Financial Assistance Cluster AL #?s: 84.063, 84.268 Award year: 2022 Corrective Action Plan: Management concurs with audit finding 2022-001 and are planning the follow: 1. Four of the student statuses were linked to students with no earned credit in the Fall 2022 or Spring 2023 semester. Bunker Hill is re-evaluating the walk-away reporting process. In addition, the College will specifically monitor students in NSLDS who are viewed as a walk-away. 2. The one graduated student not reported was due to the student having a second active program. Students with double majors will now be reviewed separately during reporting. This will ensure students graduating from just one of their two majors are reported correctly. Timeline for Implementation of Corrective Action Plan: Effective immediately Contact Person Susan Martin, Registrar, Academic Records Jake Deehan, Business Analyst Melissa Holster, Executive Director of Student Financial Services

Finding 2022-001: Return of Title IV Funds Federal Program: Student Financial Assistance Cluster, Federal Direct Student Loan Program, Federal Pell Grant Program Federal Agency: U.S. Department of Education Pass-Through Entity: Not Applicable Assistance Listing Number: 84.268, 84.063 Federal Award Year: June 30, 2022 Corrective Action Taken The University?s Interim Financial Aid Director, Stephanie Schrift, has required all Student Financial Services staff to attend virtual trainings on the return of Title IV funds process in April 2023. In addition, Stephanie Schrift (Interim Director) will process all R2T4s via COD's calculator and Elizabeth Susick (Assistant Director) will verify and sign off on the calculations once complete. This will provide a two-step validation procedure for all R2T4 returns.