Corrective Action Plans

1. Review the necessary submission dates required by ISBE. 2. Submit expenditure reports regardless if financial activity occurred. 3. Place several reminders one week prior to the end of the quarter to ensure timely reporting. See the full Corrective Action Plan included with the reporting package.

Finding: The University incorrectly calculated Federal Direct Subsidized Loan funds for one student resulting in an under award. Corrective Actions Taken or Planned: The Associate Director of Student Financial Aid reviews each student?s need-based aid to correctly calculate the amount of Direct Subsidized Loan each student should receive, with the TEACH Grant being treated as non-need-based aid. In addition, the Associate Director of Student Financial Aid will reassess a student?s calculation when summer term is awarded. The internal policies and procedures have been updated to ensure the need-based calculations are properly performed and reviewed. Person Responsible: Sara Sroka (ssroka@dbq.edu) Anticipated completion date: 10/19/2022

Finding: The University did not timely or accurately report enrollment changes to the National Student Loan Data System (NSLDS). Corrective Actions Taken or Planned: The Registrar?s Office submits a monthly report to the National Student Loan Clearinghouse. For a brief period of time the process for this was inconsistent. After a review of the procedures the issue has been fixed. Also, to ensure withdrawn dates during the semester are being reported on a timely basis Financial Planning will manually enter dates of withdrawn students to National Student Loan Data Systems (NSLDS). Students who have withdrawn at the end of the semester will be manually entered and monitored closely by the Registrar?s Office who will adjust reporting schedule to ensure timely reporting of withdrawn dates. Person Responsible: Sara Sroka (ssroka@dbq.edu) Anticipated completion date: 10/19/2022

See corrective action plan for chart/table.

As part of the assignment of Perkins Loans, we noted that the assignment process required the submission of original promissory notes for each loan to be assigned. As a result, the University began collecting and digitizing its historic loan records to maintain copies for retention and compliance purposes. The assignment process is currently underway and is required to be completed by June 30, 2023. The University is on track to meet that federal imposed deadline. Quinnipiac University agrees with the finding. A small percentage of the remaining loans to be assigned originated over 10 years ago. As it relates to this finding, we were unable to locate promissory notes for six students with loans originated 10 to 30 years ago. Due to their age, we believe the finding may be related to office moves and departmental reorganizations over the years. As a result of this finding and the federal assignment process in general, Management and Financial Aid have performed a comprehensive review of the remaining student records waiting to be assigned for completeness. As a result of this review Management and Financial Aid have identified all loans that are missing original promissory notes. As part of the assignment process, in lieu of original promissory notes alternative documents supporting the existence of these loans have been provided to the Perkins loan assignment processor. Any loans that are not accepted during this appeals process will be purchased by the University at the conclusion of the assignment process, which is planned to be completed by June 30, 2023. If the Office of Management and Budget have questions regarding this plan, please reach out to Stephen Allegretto, the Associate Vice President for Finance and Controller, who is responsible for ensuring this corrective action plan is implemented, at 203-582-7962.

FINDING 2022-001 Contact Person Responsible for Corrective Action: Colby Shank Contact Phone Number: 317-921-4765 Views of Responsible Official: Ivy Tech Community College disputes this audit finding. The College has an effective internal control system to ensure compliance with requirements related to the Special Tests and Provisions ? Return of Title IV Funds compliance requirement. The College previously determined that the Return of Title IV Funds (R2T4) is high-risk due to the large number of transactions, the College?s modular term-based system, and the manual nature of R2T4 calculations. Therefore, a robust quality control review process was implemented. College personnel regularly monitor the error rates and nature of errors discovered through the quality control review to identify, correct, and eliminate calculation errors. The claimed errors outlined in Finding 2022-001 relate to the interpretation of how a correction recalculation is determined. In correction calculations, aid previously returned as a result of the initial calculation in the 2021-2022 academic year was considered no longer disbursed and was included in the correction calculation as ?aid that could have been disbursed.? In certain scenarios, this can result in different return amounts than if the aid had been included in the calculation as ?aid disbursed.? In the absence of explicit guidance on how to handle these scenarios within the Federal Student Aid Handbook, College interpretation and precedent has been to treat aid previously returned under the original calculation as aid that could have been disbursed. Volume 5, Chapter 2 of the 2021-2022 Federal Student Aid Handbook states that ?any undisbursed Title IV aid for the period that the school uses as the basis for the R2T4 calculation is counted as aid that could have been disbursed.? Ivy Tech confirmed this interpretation as valid via a third-party financial aid expert who facilitated a discussion with a representative of the USDOE. This USDOE representative confirmed the accuracy of the calculation and the alignment with the Federal Student Aid Policy Implementation and Oversight Directorate. During this discussion, the representative stated that the results of the original calculation could not be ignored, and that including aid that is no longer disbursed as ?aid that could have been disbursed? is the proper way to perform a correction calculation. The auditors state the College should have performed the following actions: ?The College should have considered the original amount of aid to be returned that had already been posted to each student?s account. The College should have posted the additional amount of aid to be returned to the students? accounts based upon the net difference between the original calculation and the corrective calculation performed for each student.? This methodology would have produced inaccurate return amounts under the interpretation of guidance from Federal Student Aid from which the College was operating during the review period. Only posting the ?net difference? between the original calculation and the correction calculation would have resulted in too few funds being returned to Federal Student Aid for many calculations during the review period. Specifically, a difference in return amounts occurred when the amount of unearned charges (institutional charges for the period multiplied by the percentage of unearned Title IV aid) was less than the calculated amount of Title IV aid to be returned. Under the R2T4 calculation formula, the amount of unearned charges can effectively create a ?cap? on the amount of Title IV aid to be returned by the school. At Ivy Tech Community College, this cap is most often reached when students receive disbursements of federal student loans prior to withdrawing. Because a relatively small percentage of Ivy Tech students receive federal student loans, most correction calculations performed during the review period by Ivy Tech under our interpretation of the guidance resulted in accurate return amounts. This issue only impacted a subset of students who received a correction calculation during the review period. Description of Corrective Action Plan: Upon receiving new guidance from the Chicago/Denver regional office of Federal Student Aid, Ivy Tech has modified the way in which it performs R2T4 correction calculations. Aid returned as a result of the original calculation will remain in the correction calculation as ?aid disbursed? instead of ?aid that could have been disbursed.? The College is no longer following prior guidance received by an expert consultant, a representative of Federal Student Aid that advised the College to include aid that has already been returned as ?aid that could have been disbursed.? The calculation change will be monitored for correctness through the College?s previously established internal controls and quality assurance process for the R2T4 process. Financial aid staff have been trained on the calculation change. Ivy Tech will review all students during the review period who received a correction calculation and will cover with institutional aid any federal grant aid that otherwise would not have been returned under the new guidance from Federal Student Aid. Anticipated Completion Date: 3/31/2023

Corrective Action Plan for the Year Ended June 30, 2022 Finding 2022-004: Significant Deficiency - Non-compliance with Reporting Requirements for Disbursements Condition/Context: For 2 of 25 students selected for testing, the disbursement dates did not agree between the student?s institutional account and the data reported to COD. The students had disbursements that were later refunded. It was noted that the students were disbursed without a valid MPN on file, resulting in students being disbursement that were not eligible at the time of disbursement. The College ultimately obtained the signed valid MPNs and then re- disbursed the funds, as a result the student account original disbursement date and the COD disbursement date differ. Actions Taken: To ensure that this problem does not recur for 2022-2023, disbursement rules have been instituted in Colleague that would prevent funds disbursing if a student hasn?t completed an MPN. The frequency of exports from Colleague to COD has been increased. In addition, Direct Loan and Pell rejects are being corrected each week so that if funds are disbursed and a Colleague or COD error is received, the disbursement is corrected and re- exported before the 15-day time limit. Name(s) of Contact Person Responsible for Corrective Action: Joseph Gilchrist, Interim Financial Aid Director Anticipated Completion date: June 30, 2023

Corrective Action Plan for the Year Ended June 30, 2022 Finding 2022-002: Significant Deficiency ? Direct Loan Reconciliation Condition/Context: The College was not able to provide the three monthly reconciliations for November 2021, February 2022, or April 2022 when requested for the audit in the summer of 2022. The Institution noted that the reconciliations had not been performed timely, and subsequently the Institution had a consultant complete these reconciliations. The auditors were unable to obtain evidence of or confirmation from the Institution on if review of the reconciliations occurred. The sample was not a statistically valid sample. Additionally, the College discovered that Direct Loan reconciliation hadn't been done correctly in the past due to staff turnover. A consultant was given the task of doing a complete 21-22 reconciliation in June 2022. This consultant discovered 16 students had been awarded $177,816 in error. The cause of this was that rules had not been setup correctly in Colleague, and consistent reconciliation by correcting Colleague and COD errors wasn't completed in a timely manner. The auditors obtained the listing of students awarded incorrectly. Actions Taken: For the $177,816in direct loans incorrectly disbursed that was identified, SMC returned the loans and replaced with institutional aid for the impacted students. Beginning with July 2022, the Assistant Director/Systems Specialist reconciles direct loans every month. The Executive Director of Financial Aid and the VP of Enrollment Management review these reports at the end of each month. In addition, a system adjustment has been implemented for 2022-2023 to ensure reconciliation is done monthly. The Assistant Director/Systems Specialist utilizes Colleague variance reports that tract Direct Loans disbursed year to date, the number that COD (Servicer for U.S. Department of Education) has approved, and the students that make up the variance, if any. In addition, COD and Colleague errors that occur during the import/export of Direct Loans to and from COD are corrected on a consistent basis. Reconciliation documentation is then forwarded to the Executive Director for review. Name(s) of Contact Person Responsible for Corrective Action: Joseph Gilchrist, Interim Financial Aid Director Anticipated Completion date: June 30, 2023

Corrective Action Plan for the Year Ended June 30, 2022 Finding 2022-005: Significant Deficiency - Education Stabilization Fund ? Higher Education Emergency Relief Fund - Reporting Condition/Context: For three of the four quarterly reports selected for testing, two for the student portion and one containing both institutional and student portion reporting, the auditors noted that some of the information reported did not agree to the support provided, two of those reports also did not agree to the drawdowns from G5, two of those reports had required information missing, and two of those reports were posted late. ? Student portion report - for quarter three of calendar year 2021 the amount of emergency grants to students of $1,133,392 did not agree to the underlying support of $1,078,437 or drawdowns from G5 of $954,932. The number of eligible students and the number of students who received an emergency financial aid grant were missing from the report. ? Student portion report - for quarter four of calendar year 2021 the amount of emergency grants to students of $1,745,664 did not agree to the underlying support of $1,735,664 or drawdowns from G5 of $1,902,140. The number of eligible students was missing from the report. The report was posted to the Institution's website on January 24, 2022 after the required deadline of January 10, 2022. ? Combined report - for quarter one of calendar year 2022 the amount of emergency grants to students of $405,000 was reported for the institutional portion of HEERF but should have been for the student portion, the same amount was also reported for the institutional portion as covering student outstanding account balances and lost revenue. The report was posted to the Institution's website on July 8, 2022 after the required deadline of April 10, 2022. The report for quarter two of calendar year 2022 report was not submitted timely and was in process during the audit and therefore, was not selected for testing. The annual report had several items that did not agree to the underlying support. How many students received HEERF emergency financial aid grants, amount disbursed directly to students for emergency financial aid grants, amount of grants disbursed to students from all HEERF funds, total institutional funds used did not include amounts for room and board refunds that were reported in quarterly reporting during calendar 2021. Action Taken: The staffing changes in the Business Office and the Financial Aid office resulted in learning curves for the new employees regarding how to report expenses for HEERF. Saint Mary?s reached out to the Department of Education and alerted them to the late filing of the reports and received acknowledgment of the late filings. SMC has since filed reports which have properly accounted for all funds spent that were awarded through the HEERF program. The only report still needed is the annual report for 2022 which will be filed in a timely manner. This has been noted on our calendar with enough time to be properly filed. Name(s) of Contact Person Responsible for Corrective Action: Susan Collins, VP for Finance and Administration Anticipated Completion date: March 2023

Corrective Action Plan for the Year Ended June 30, 2022 Finding 2022-006: Significant Deficiency ? Control Environment Condition/Context: It was noted during the audit, that there were gaps in the internal control structure of the College, that was no longer adequate to ensure compliance with federal regulations and compliance requirements. Action Taken: The staffing changes in the Business Office and the Financial Aid office resulted in learning curves for the new employees. Both offices have started projects to document procedures so that when turnover occurs, there is a blueprint in place to assist the new employees. SMC will also review the internal controls in place for federal reporting to determine how they can be strengthened. Name(s) of Contact Person Responsible for Corrective Action: Nicole Yu, AVP/Controller and Joseph Gilchrist, Interim Financial Aid Director Anticipated Completion dates: Documenting procedures is on ongoing project. Revised internal controls for federal reporting will be in place by June 30, 2023.

Corrective Action Plan for the Year Ended June 30, 2022 Finding 2022-003: Significant Deficiency - Enrollment Reporting Condition/Context: Of 25 students tested, the status date for one student selected was not reported accurately on the campus level reporting in National Student Loan Data System (NSLDS). The College used the degree conferral date of 8/20/2021 rather than the end of the term/last date of attendance of July 4, 2021 that was used for reporting program level information for this student, and consistent with how other students were reported. Additionally, for two students, reporting at the program level was late, not within 30 days or included in a response to a roster file or within 60 days. The students were reported as graduated effective August 20, 2021 with the earliest certification date of October 31, 2021 at the campus level and December 3, 2021 at the program level. Action taken: In order to ensure compliance in 2022-2023, the Office of the Registrar has increased the degree of reporting frequency to National Student Clearinghouse (NSC), so as to meet the 60-day requirement in NSLDS. It has also have gained access to the National Student Loan Data System to monitor alignment with information submitted by SMC to NSC. Name(s) of Contact Person Responsible for Corrective Action: Tracey Donaldson, AVP and Registrar Anticipated Completion date: June 30, 2023

Corrective Action Plan for the Year Ended June 30, 2022 Finding 2022-001: Significant Deficiency- Return of Title IV Funds Condition/Context: During the audit it was noted that the College provided a list of students that withdrew during the fiscal year and this differed from data that was reported internally to the Audit Committee on the number of students that withdrew in Fall 2021 and Spring 2022 (through April). The number of students that withdrew, the number of student?s that required an R2T4 calculation and the amount of the return all varied. The auditors discussed this with management who confirmed that the list provided to the auditors was complete and that the information reported to the Audit Committee was incorrect. From the withdrawal population the College did provide, a sample of 9 students were selected for testing for return of Title IV funds, of which 5 students did not require Title IV refunds and 4 students did require Title IV refunds. For the population of students with Title IV refunds, the calculations and refunds for 3 students were performed late, and for 1 of those students the calculation was also incorrect (excluded SEOG funds from the calculation). For the 3 students with refunds that were late, 100% of their Title IV funds were returned and then later re- disbursed before the R2T4 calculation and return occurred. Actions Taken: Subsequent to the 2021-2022 single audit fieldwork, SMC had a Financial Aid Services consultant review all R2T4 cases and 1 additional error was identified requiring the return of an additional $17.00. In the future, all R2T4 refund calculations will be performed by the Assistant Director/Systems Specialist who has received substantial training. In addition, the Assistant Director?s refund calculations will be reviewed by the Executive Director of Financial Aid for accuracy. System adjustments have also been made so that if funds are reversed they are re-disbursed at the amount the student is eligible for after the R2T4 calculation is completed. Name(s) of Contact Person Responsible for Corrective Action: Joseph Gilchrist, Interim Financial Aid Director Anticipated Completion date: June 30, 2023

Finding No. 2022-001 The University verified the internal processes to this report and verified the operating system manual used by the University from the report. After this assessment on May 5, 2021, the University is review and amended the procedure for identifying students who met the graduation requirements. This procedure was done with the purpose of ensuring sent this report in the time required according by the regulations. This procedure is effective from fiscal year 2021 - 2022, as notified in the action plan for last year. As a result of the implementation of this process, the number of students was reduced by fourteen (14), from 16 to 2 compared to last year. This represents a reduction, of fifty-six percent (56%). In addition, to what has been previously explained, training and retraining will continue for all offices and departments that involved in the process established by the University. On the other hand, the University will continue to monitor the process by conducting internal audits to guarantee compliance with regulations in this matter.

Prior Year Finding Number: 2022-001 Fiscal Year in Which the Finding Initially Occurred: 2022 Federal Program, CFDA Number and Name: U.S. Department of Education, Student Financial Assistance Cluster ? CFDA 84.268, Federal Direct Student Loans; CFDA 84.063, Federal Pell Grant Program; CFDA 84.007, Federal Supplemental Educational Opportunity Grants Condition: The University did not accurately report a student status change to the NSLDS in a timely manner. Of the 40 students selected for enrollment reporting testing, the status change for 1 student was not accurately reported as withdrawn within the required 60-day period. Planned Corrective Action: The cause of the error has been found and the University has implemented additional controls to ensure that student graduation status is reported in a timely manner. Contact person responsible for corrective action: Diane Praet, Registrar Anticipated Completion Date: 12/31/2022

The office of the Registrar will work with the academic administration to increase faculty education on the importance of timely reporting on non-attendance, to include a presentation at Faculty Orientation. Additionally, communications to all faculty will be sent at the census period and mid-point of the term, reminding them of the attendance policy and reporting requirements. Lastly, Division Chairs and Vice President of Academic Affairs will be sent a list of non-compliant reporting faculty for follow-up at week 3 and week 9.

Finding No. 2022-001 - Internal Controls over Student Financial Assistance Special Tests and Provisions Condition: During the compliance testing, we noted the following exceptions: ? During the compliance testing of ?Special Tests and Provisions ? Return of Funds? we noted that one (1) student calculation used the incorrect institutional charges in the calculation and one (1) students funds were not sent back to the Department of Education within the required 45 day time frame. ? During the audit of the Federal Student Assistance Cluster we noted one (1) instance where the income tax reported on the Institutional Information Record (ISIR) did not match the information on the student?s income tax transcript. Plan: The Financial Aid Office has revised the worksheet used for Return of Funds calculation to include separate lines for tuition, fees, and books instead of only the aggregate total. The Financial Aid Specialist is training to perform the Return of Funds calculations. Going forward, when the Specialist performs the calculations, the files subsequently will be reviewed by the Director of Institutional Compliance and Research. When the Director of Institutional Compliance and Research reviews the R2T4 files for accuracy, she will also pull up the student?s file in COD to verify the amount has been transmitted. The Director will print the page for the R2T4 binder. This way the Director will quickly be able to see if a file has not been transmitted to COD. The Financial Aid Office staff has been retrained on separating tax information when a student (or parent) filed jointly and is now divorced, which was the case in the noted error. The staff will now leave the percentage to all decimal places in the calculator before multiplying it by the taxes paid. This will remove the chance for error due to rounding. Anticipated Date of Completion: Immediately upon learning of the deficiency. Contact Person Responsible for Corrective Action: Amy Epplin, Director of Institutional Compliance & Research

Management?s Response The UPR concurs with this finding. To address the situation and take corrective actions, a meeting was held at the Vice Presidency for Academic Affairs and Research on March 15, 2023 with registrars of the eleven (11) units of the UPR System. The following actions were proposed as corrective actions: ? Registrars were instructed to attend a Federal Student Aid workshop on March 28, 2023, on Loan Servicing, Enrollment Reporting, and the National Student Loan System. ? Professors will be oriented on the importance of taking and reporting attendance timely. ? All campuses must use the NEXT System (student data platform developed internally) to report partial and total withdrawals, as well as the attendance report. (We noted that the units that are using NEXT System did not have findings). For the five students of RUM and RCM the UPR was unable to provide information from NSLDS; the search on the website displayed ?Search returned 0 students. No matching students records found?. On December 9, 2022 RUM contacted NSLDS Customer Service Center by e-mail. They later received an e-mail informing the case was closed without further explanations. Also, NSLDS issued electronic announcements confirming problems with the implementation of their new website. On the other hand, RUM was able to provide evidence to auditors that they reported the status change of all students to the Clearing House on time. Responsible Person or Office: Executive Vice President for Academic Affairs and Research. Timeline: June 2024

BSMH has implemented enhanced policy and procedures to assist with managing data and enrollment reporting. The procedures include an enhanced review by the Registrar of the student data reports prior to NSLDS submission to ensure no omissions. The contact for this finding is Mark McKellip, Registrar, Mark.McKellip1@mercycollege.edu.

Satisfactory Academic Progress Planned Corrective Action: To receive financial aid students must maintain a cumulative grade point average (GPA) of 2.0 (?C?) or better, or be in a SAP-Probation program to recover their GPA. Pillar College academic standards require a student to have a minimum of a 2.0 cumulative Grade Point Average (GPA) to graduate. Degree seeking students will be evaluated for Satisfactory Academic Progress (SAP) on an annual basis. Pillar College is dedicated to helping students succeed academically and progress to graduation and is therefore committed to identifying students who may be struggling. Satisfactory Academic Progress is measured by three components: 1) The student?s cumulative grade point average (CGPA), 2) The student?s rate of progress toward completion (ROP), and 3) The maximum time frame (MTF) allowed to complete the academic program. (150% for all programs.) All students who receive financial aid at Pillar College are required to meet qualifying Academic standards. The student must maintain Satisfactory Academic Progress (SAP). If a student?s cumulative GPA falls below a 2.0, the student will be placed in Suspension Pending and must appeal to remain in school. Upon review of the appeal, the student will be placed on SAP Probation for the following semester/year and directed to the Academic Resource Center (ARC) for mandatory tutoring sessions through registration into ARC-090 SAP Remediation, a pass/fail course for SAP students. For the LEAD Program, the GPA benchmark is 2.5 to remain in the program. The probationary status permits the student to continue in college while working with the Academic Resource Center (ARC) to address deficiencies and take corrective action for improvement. The student may continue to receive Title IV and State Financial Aid so long as they are adhering to their SAP Remediation Plan. The student must use the SAP Remediation Form while on SAP Probation (available from the ARC). An assessment of current enrolled students? degree progress will occur mid-July. If the SAP standard is not being met, the student will be placed on SAP-Probation. It is possible to continue to receive Financial Aid while on SAP-Probation if the student?s ?Academic Plan? is being followed, and grades are improving. If a student does not adhere to the ?Academic Plan?, they may be moved to SAP-Suspension, and removed from the financial aid program. Aid will also be suspended for the semester if credit hours attempted fall below the credit hour criteria. Pillar College financial aid office, the Academic Resource Center (ARC) and the registrar?s office met to discuss and update the Satisfactory Academic Policy (SAP policy), implementing the changes in the current fiscal year. These changes are reflected in the Pillar College Catalog. Due to upgraded student services systems the process is functioning more effectively and efficiently. As stated before, an assessment of current enrolled students? degree progress will occur mid-July. The registrar, financial aid, and the Academic Resource Center (ARC) will meet together as a team two days after the report is published to discuss the results. Students will be notified individually through phone calls and emails to make an appointment with the Academic Resource Center to create a self-evaluative plan to increase their GPA. The ARC will upload the plan into the student services system and monitor the student?s progress by direct contact with the student. It will be noted in the student services system under the individual student?s account if a student does not respond to the notices, phone calls or emails that are sent. The student will be put on academic hold and will not be able to enroll in the new semester. Person Responsible for Corrective Action Plan: Betzi Schroeder, Financial Aid Office Anticipated Date of Completion: current

Inaccurate and Untimely Returns to Title IV Planned Corrective Action: Pillar College changed the R2T4 policy in the catalog and created an R2T4 form to monitor the process. Our operating system, Anthology, has been upgraded to include automatic triggers. The automated system alerts financial aid, the third-party servicer and the registrar to process and critique the effects of the student?s official and/or unofficial withdrawal. Three specific processes have been created and are combined under ?Withdrawal Process Flow Charts: Official, Unofficial and Non-Returning Student?. After analysis the financial aid office and third-party servicer determine the potentiality of funds to be returned to Title IV in a timely manner. Person Responsible for Corrective Action Plan: Betzi Schroeder, Financial Aid Officer Anticipated Date of Completion: current

Enrollment Reporting to NSLDS Planned Corrective Action: The college will continue to process the semi-monthly NSLDS reporting through the SIS and undertake spot checking 10% of the reported students after each enrollment reporting submission is completed to ensure accurate enrollment reporting. The errors will be fixed, and the type of errors will be tracked to modify the SIS as needed. Person Responsible for Corrective Action Plan: Brian Schroeder, Registrar Anticipated Date of Completion: current

2022-002 Federal Direct Loan Reconciliations Assistance Listing Number: 84.268 Criteria According to 34 CFR 685.300(b)(5), the school must, on a monthly basis, reconcile institutional records with Direct Loan funds received from the Secretary and Direct Loan disbursement records submitted to and accepted by the Secretary; Condition The University did not perform the monthly reconciliations over direct loans. Context We requested a selection of reconciliations out of the 12 required and were informed that only a year-end reconciliation was performed. Cause The reconciliations were not performed due to the University being short-staffed. Effect Direct loan discrepancies may not have been identified and resolved in a timely manner due to the lack of monthly reconciliations. Questioned Cost There were no questioned costs related to this finding. Recommendation We recommend that the University perform direct loan reconciliations monthly to ensure that discrepancies are properly addressed in a timely manner. Planned Corrective Action Existing fiscal staff will now have more bandwidth to help with monthly analysis and accounting close protocols with student services staff. Implementation Date Effective date: 7/1/23 for fiscal year 2024. Responsible Personnel Arlene Cash Interim Vice President for Enrollment Management awcash@ndnu.edu

CORRECTIVE ACTION PLAN Finding 2022-001 Federal Agency Name: U.S. Department of Education Program Name: Student Financial Assistance Cluster ALN: 84.063 and 84.268 Finding Summary: University of Mary Hardin-Baylor (?UMHB?) had three conditions that led to NSLDS reporting discrepancies for five students. Cause 1: A system report used for NSLDS reporting incorrectly included the end of a student?s enrollment term instead of the date of official withdrawal communication. Cause 2: UMHB did not adjust the NSLDS transmittal calendar when UMHB?s academic calendar was modified for an earlier start date. Cause 3: A system report used for NSLDS reporting did not include withdrawal dates for students that had unofficially withdrawn. Responsible Individuals: Trent Bridges, Director of Data Quality & Institutional Analytics Bethany Chapman, Institutional Research Coordinator Corrective Action Plan: Related to Causes 1 and 3: UMHB will review all the coding on system reports used for NSLDS reporting to assess accuracy and completeness of the data based on any changes in business practice and make updates to system reports as necessary. UMHB will update its internal process to document any required special handling of records based on system limitations. UMHB will reassess system report and processes used for NSLDS reporting prior to the beginning of each fall and spring semester. Related to Cause 2: UMHB has adjusted its NSLDS submission schedule according to our new academic calendar with the first of term submission occurring on the census date. UMHB will establish a schedule to include more frequent submissions throughout the term. Additionally, UMHB will run a withdrawal report twice a month and manually adjust enrollment status to ensure these students are reported as withdrawn correctly to NSLDS. Anticipated Completion Date: September 15, 2022

Reference Number 2022-001 Identification: 10.766 United States Department of Agriculture (USDA), Community Facilities Loans and Grants Cluster, Noncompliance Finding/Significant Deficiency, Reporting Compliance Requirement. Corrective Action Plan: The Medical Center will make improvements to its reporting process to include reporting its fidelity bond coverage. The Medical Center will also seek guidance from the USDA as to the fidelity bond coverage limits and who can complete the certification of records on behalf of the Medical Center. We will implement these items as directed by our USDA representative. Anticipated completion date: The Medical Center will implement these improvements immediately which will be effective for its next annual reporting checklist that is due 60 days after calendar year end. Dean Ohmart, CFO Phone: 660-747-2500 E-mail: dohmart@wmmc.com

Sacred Heart University Corrective Action Plan Year ended June 30, 2022 Finding 2022-001: Significant Deficiency and Noncompliance: Special Tests and Provisions ? Enrollment Reporting Corrective Action Planned Sacred Heart University has implemented a corrective action plan which involved collaboration with our enterprise resource provider, Ellucian, the Registrar?s Office, and the Department of Information Technology (IT). Sacred Heart University acknowledges that published program lengths reported on National Student Loan Data System (NSLDS) records did not conform with reporting requirements. The University?s ERP, Ellucian, provided instruction on updating the code for programs with ?years to complete,? which enabled the IT department to identify and correct existing active programs. To prevent future errors the Registrar?s Office can access the mnemonic (screen) to code new program records in ?years to complete.? Sacred Heart University processed and submitted the first two branches, 00 and 81, on 3/24/23, and Clearinghouse took steps to update the records. Sacred Heart University acknowledges incorrectly reporting the Graduated status effective date as the last day of classes instead of the last day of final exams at the NSLDS program level for two students sampled during our FY22 Federal Single audit. The University has amended its procedures to avoid potential errors causing nonconformities. The updated procedures will ensure the utilization of the last day of final exams as the Graduated status effective date at the program level and strengthen the review of the graduate file before submitting it to the Clearinghouse. Sacred Heart University acknowledges incorrectly reporting the student program begin date for one student sampled during our FY22 Federal Single audit. The University reported the student in the incorrect branch, discovered the error upon graduation, and moved the student to the correct branch. As a result of the branch correction, the University reported to the NSLDS the start date of the student?s last trimester instead of the actual program start date. The Registrar?s office, working with the Clearinghouse, is taking steps to correct the branch reporting which will fix the reported program start date for this particular student. The University is amending its procedures to prevent further noncompliance. The Registrar?s office is amending the report used to ensure students are selected and reported in the correct branches. The Registrar is also enhancing the report to include data identifying potential erroneous reporting before enrollment data is reported to the Clearinghouse. Contact Person(s) Responsible for Corrective Action Angela Pitcher, University Registrar Lori Jo McEwan, Senior Systems Analyst Anticipated Completion Date April 25, 2023