Corrective Action Plans

Finding 2022-014 Personnel Responsible for Corrective Action: Director of Financial Aid, James Green Anticipated Completion Date: June 2023 Corrective Action Plan: The calendar for 2022 - 2023 academic year has been updated to ensure the correct number of days are used for return of Title IV calculations.

Finding 2022-013 Personnel Responsible for Corrective Action: Director of Financial Aid, James Green Anticipated Completion Date: June 2023 Corrective Action Plan: The Financial Aid staff will ensure systems are setup to prevent the over award of federal financial aid. The financial aid counselor will prepare and award the student. Upon completion, the financial aid counselor will submit the file to the Director of Financial Aid for the second review. The University Financial Aid officers will undergo a series of trainings and certifications through the National Association of Student Financial Aid Administrators to assist with understanding aggregate limits for federal student aid.

Finding 2022-012 Personnel Responsible for Corrective Action: Assistant Comptroller - Brian Huggins Anticipated Completion Date: July 2022 Corrective Action Plan: The University has implemented a process to document all allowable costs prior to funds being draw down that will be prepared by a Senior Accountant, reviewed by the Assistant Comptroller and Comptroller for 2nd review, and sent to the CFO for final review and approval prior to requesting reimbursement/cash drawdowns from the Federal Government. Moreover, the University is implement a quarterly grant review process with the grant Principal Investigator to review grant expense allocations. G5 drawdowns will take the second Monday of each month.

Holy Family University respectfully submits the following corrective action plan for the year ended June 30, 2022. Name and address of independent public accounting firm: Baker Tilly US, LLP 1650 Market Street, Suite 4500 Philadelphia, Pennsylvania 19103 Audit period: June 30, 2022 The findings from the June 30, 2022 schedule of findings and questioned costs are discussed below. Finding 2022-001: Special Tests and Provisions - Gramm-Leach Bliley Act (?GLBA?) 84.268 Federal Direct Loan Program; 84.063 Federal Pell Grant Program, 84.033 Federal Work Study Program, 84.007 Federal Supplemental Education Opportunity Grant; 84.038 Federal Perkins Loan Program Recommendation: The University should perform and document an annual risk assessment to determine the University's specific risks relevant to protecting consumer nonpublic personal information. At a minimum, the University should have at least one risk statement aligned or referenced to each of the three required areas noted in the GLBA law at 16 CFR 314.4 (b). Finally, the University should identify and document at least one safeguard (i.e., control) for each of the risks identified and document in the risk assessment. Each control should be aligned or referenced to the risk(s) to which the safeguard applies. Action Taken: The institution acknowledges and understands the requirements set forth by the Gramm-Leach-Bliley Act (GLBA) and is in the process of selecting a qualified individual for the partner role. Our team is actively developing a timeline to ensure full compliance with GLBA by June 9, 2023. In order to prioritize our efforts, we have identified areas of risk and implemented risk-based priorities to strengthen our network security, including firewalls, email access with Multi-Factor Authentication (MFA), applications, and policies/procedures. As part of our compliance efforts, our team will conduct a risk assessment to address three areas of concern, including 1. employee training and management 2. information systems (including network and software design 3. as well as information processing, storage, transmission, and disposal), and detecting, preventing and responding to attacks, intrusions, or other systems failures. We will document safeguards for identified risks by June 30, 2023. Name(s) of Contact Person(s) Responsible for Corrective Action: Mark Green, Associate Vice President Institutional Effectiveness, IT, and Innovation Anticipated Completion Date: June 9, 2023 If there are any questions regarding this corrective action plan please contact Eric Nelson, Vice President for Finance & Administration, at enelson@holyfamily.edu.

2022-004 Eligibility ? Assistance Listing No. 84.063 Recommendation: We recommend the College design controls to ensure an adequate review process is in place to ensure compliance with reporting requirements. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Policy and Procedures of reporting deadlines and requires has been put into action by the director of financial aid. Name(s) of the contact person(s) responsible for corrective action: Grant Pollard, Director of Financial Aid Planned completion date for corrective action plan: 11/1/2022

2022-009 Eligibility ? Assistance Listing No. 84.268 Recommendation: We recommend the College design controls to ensure an adequate review process is in place to ensure compliance with reporting requirements. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Policy and Procedures of reporting deadlines and requires has been put into action by the director of financial aid. Name(s) of the contact person(s) responsible for corrective action: Grant Pollard, Director of Financial Aid Planned completion date for corrective action plan: 11/1/2022

2022-006 Special Tests and Provisions ? Assistance Listing No. 84.063, 84.268 Recommendation: We recommend the College design controls to ensure an adequate review process is in place to ensure compliance with reporting requirements. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The director of financial aid works with the third-party servicer to ensure accurate student programs and program beginning dates reported to NSLDS. The financial aid office cross-references program information within the student information system. Name(s) of the contact person(s) responsible for corrective action: Grant Pollard, Director of Financial Aid Planned completion date for corrective action plan: 11/1/2022

2022-005 Special Tests and Provisions ? Assistance Listing No. 84.063, 84.268 Recommendation: We recommend the College design controls to ensure an adequate review process is in place to ensure compliance with reporting requirements. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The director of financial aid works with the third-party servicer to ensure accurate and timely enrollment updates to NSLDS. Name(s) of the contact person(s) responsible for corrective action: Grant Pollard, Director of Financial Aid Planned completion date for corrective action plan: 11/1/2022

2022-003 Eligibility ? Assistance Listing No. 84.063, 84.268 Recommendation: We recommend the College provide additional resources to ensure all compliance requirements are met. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The director of financial aid reviews the funding estimate (award package) put together by the third party servicer and signs/e-signs it to document his review. Name(s) of the contact person(s) responsible for corrective action: Grant Pollard, Director of Financial Aid Planned completion date for corrective action plan: 11/1/2022

Incorrect and Late Returns of Title IV Funds (R2T4) Planned Corrective Action: Executive Director of Financial Aid has reviewed and updated policy and COD system set-up to ensure correct calculations. Executive Director of Financial Aid provided in-house R2T4 training specific to WBU for all staff as well as will ensure all pertinent staff responsible for R2T4 complete R2T4 training provided by FSA and purchased through NASFAA. Audit report is now generated weekly to identify students who have withdrawn and reviewed by appropriate staff to ensure timely R2T4 completions. Executive Director of Financial Aid is working with IT (and others) to integrate BlackBoard course activity data with PowerCampus for most accurate record of course attendance and last date of academically related activity for all students. This implementation is being piloted during Fall 2 session, with plans for full implementation for the Spring 2023 term. WBU has funded a Financial Aid Compliance Specialist position in the Office of Financial Aid. Once filled, this position with be devoted to internal audit and federal/state regulation compliance. Person Responsible for Corrective Action Plan: Christy Miller, Executive Director of Financial Aid Anticipated Date of Completion: January 2023

Concordia University Irvine An Educational Institution of The Luther Church - Missouri Synod Schedule of Findings and Questioned Costs June 30, 2022 Finding 2022-001: Significant Deficiency - Return of Title IV Funds Program: Federal Direct Student Loans Assistance Listing Number: 84.268 Federal Agency: U.S. Department of Education Federal Award Identification Number: P268K223683 Federal Award Year: June 30, 2022 Criteria: 34 CFR 668.22 requires that when a recipient of Title IV grant or loan assistance withdraws from an institution during a payment period or period of enrollment in which the recipient began attendance, the institution must determine the amount of Title IV grant or loan assistance that the student earned as of the student's withdrawal date in accordance with Federal regulations and return the unearned portion of the grant or loan funds to the Title IV programs as soon as possible but no later than 45 days after the withdrawal date. Condition/Context: In a sample of 15 students that withdrew during the fiscal year, the University did not perform the required return to Title IV calculations for four students who completed less than 49% of the payment period. For one additional student, a Title IV calculation was prepared, however the calculation was incorrect and an incorrect amount was returned. The sample was not a statistically valid sample. Cause: The University incorrectly interpreted the period of enrollment to be the one module and not the entire payment period for the withdrawal exemption for successful completion of 49% or more. The University's interpretation was made in May 2021 and therefore impacts students in the 21-22 award year as well as in the 22-23 award year through March 1, 2023 when the error in interpretation was confirmed. Effect: The University incorrectly calculated students as having completed more than 49% and therefore did not perform R2T4 calculations or return unearned loan funds to the Department. Additionally, some R2T4 calculations were incorrect based on the calculation using only the module not the days in the payment period. Questioned costs: Total questioned costs were $10,819 of Direct Student Loan funds. Recommendation: It is recommended that the University review interpretations, policies and procedures in place for withdrawals and R2T4 calculations to ensure that correct dates and institutional charges are being used. Management's Response: Upon discovery of the errors, the University reviewed the population of withdrawn students where the dates for one module were used versus the payment period. The University performed the additional or revised Title IV calculations for five students and returned additional funds. The $10,819 reported as questioned costs identified by the auditors has also been returned. The university will also review 2022-23 award year of when the 49% exemption or one module in a payment period, and make any R2T4 corrections. Anticipated completion date is May 1, 2023 Contact Lori McDonald at lori.mcclonald@cui.eclu or 949-214-3074

November 17, 2022 To: Chair of the Audit Committee From: Debra Martin, Vice President for Finance and Administration RE: Response to Baker Tilly Audit Communication ? Uniform Guidance Audit Findings Finding 2022-004: Nursing Student Loans Program: Nursing Student Loans (NSL) Assistance Listing Number (ALN): 93.364 Federal Agency: U.S. Department of Education Federal Award Identification Number: Unknown Federal Award Year: June 30, 2022 Criteria: U.S. Department of Education regulations require for a NSL loan, repayment must begin nine months after the student ceases to be a full-time or half-time student, except as required in 42 CFR 57.310(a). For NSL loans after November 13, 1998, the 10 ?year repayment period may be extended for ten years for any student borrower who, during the repayment period failed to make consecutive payments and who, during the last 12 months of the repayment period, has made at least 12 consecutive payments. Institutions must exercise due care and diligence in the collection of loans. Many institutions engage third-party servicers for billing, collection, and processing deferment and cancellation requests, although these institutions remain responsible for compliance. Institutions are required to timely convert loans to repayment, establish repayment plans, process cancellation requests, and service loans as required. Condition: Seven of seven students who were tested had errors. The University had difficulty providing a listing of students who entered repayment on their NSL during fiscal year 2022. ? For one student, selected from an initial listing that ended up not being correct, the system screen showed the student separated from the University on May 8, 2020, however, the student was not noted as graduated for reporting to the NSLDS or provided with exit counseling to establish the repayment plan. ? Two students were noted as missing from the final listing provided and the servicer screen showed their status as `in school?, however they should have been indicated as `in repayment?. For one of these students, the exit counseling was provided but the student did not complete/sign it and the University did not follow-up to ensure it was completed or the repayment plan established. ? For three students that had separated from the University, the dates differed between system screens and servicer screens and exit counseling. One of these students was provided exit counseling but the student did not complete/sign it and the University did not follow-up to ensure it was completed or the repayment plan established. ? For one additional student, the exit counseling was provided but the student did not complete/sign it and the University did not follow-up to ensure it was completed or the repayment plan established. The sample was not a statistically valid sample as the auditors ended up testing the entire population. Cause: The University?s processes are not ensuring that information for NSL students is correct in the University or servicer systems, or that exit counseling is being performed or repayment plans established. Effect: Students with NSL are not being converted to repayment timely with established payment plans that can result in loans not being repaid. Questioned costs: Not applicable Context: Not applicable. Recommendation: It is recommended that the University review policies and procedures in place to resolve issues in a timely manner to facilitate compliance with NSL regulations. Management?s Response: The University agrees with the recommendation and will review system, reporting functionalities and business processes contributing to these errors and implement corrective measures. Correction Action: The University will dedicate a Student Accounts staff to manage the loan program by providing addition policy training on processes and technology training with the third party loan processor. Student Account Staff will perform timely reconciliations on all Federal nursing loan programs with the external loan servicer to ensure the student?s status is accurate. We will be exploring the possibility of reporting directly to the NLDS.

November 17, 2022 To: Chair of the Audit Committee From: Debra Martin, Vice President for Finance and Administration RE: Response to Baker Tilly Audit Communication ? Uniform Guidance Audit Findings Finding 2022-003: Enrollment Reporting Program: Federal Direct Loan Program Assistance Listing Number (ALN): 84.268 Federal Agency: U.S. Department of Education Federal Award Identification Number: P268K221157 Federal Award Year: June 30, 2022 Criteria: Title IV regulations (34 CFR 685.309(b)) require that upon receipt of an enrollment report from the Secretary, institutions must update all information included in the report and return the report to the Secretary: (i) in the manner and format prescribed by the Secretary; and (ii) within the timeframe prescribed by the Secretary. Unless it expects to submit its next updated enrollment report to the Secretary within the next 60 days, an institution must notify the Secretary within 30 days after the date the institution discovers that: (i) a loan under Title IV of the Act was made to or on behalf of a student who was enrolled or accepted for enrollment at the institution, and the student has ceased to be enrolled on at least a half-time basis or failed to enroll on at least a half-time basis for the period for which the loan was intended; or (ii) a student who is enrolled at the institution and who received a loan under Title IV of the Act has changed his or her permanent address. Condition: Five of the twenty-five students who were tested had incorrect statuses, status dates or program information reported to NSLDS. One student was reported correctly as graduated on the campus level reporting but was not reported as graduated on the program level. Two other students that graduated were not reported as graduated on campus or program level reporting. Two students were reported with the status effective date on both the campus and program level reporting that did not agree to the University?s system support, subsequently for one student the registrar changed the system date noting it had not been updated in error. The sample was not a statistically valid sample. Cause: The University?s processes did not ensure accurate reporting to NSLDS. Effect: The accuracy of Title IV student loan records depends heavily on the accuracy of the enrollment information reported by institutions. If an institution does not review, update, and verify student enrollment statuses, effective dates of the enrollment status, and the anticipated completion dates, then the Title IV student loan records will be inaccurate. Questioned costs: Not applicable Context: Not applicable. Recommendation: It is recommended that the University review policies and procedures in place to resolve reporting issues in a timely manner to facilitate compliance with Title IV regulations. Management?s Response: The University agrees with the recommendation and will review system and business processes contributing to these errors and implement corrective measures. Correction Action: MSMU will add an additional enrollment and degree report to our current schedule of one per month. This will allow for more frequent enrollment reporting that will correct this type of enrollment reporting error going forward. In addition, Registrar?s Office will update procedures to verify status start dates for any enrollment changes to specifically match the student?s enrollment in the student information system. MSMU will continue to explore the possibility of reporting directly to the NSLD rather than having to abide by the Clearing House policies. In the meantime, when graduating a student Registrar staff will check to see if the student is currently enrolled at MSMU, and if they are not, the staff member will go to the Clearing House and manually mark that program as graduated with a G. The Registrar?s Office will have multiple staff members verify the degree data uploaded to the Clearing House.

November 17, 2022 To: Chair of the Audit Committee From: Debra Martin, Vice President for Finance and Administration RE: Response to Baker Tilly Audit Communication ? Uniform Guidance Audit Findings Finding 2022-001: Significant Deficiency - Return of Title IV Fund Calculations Program: Student Financial Assistance Cluster Assistance Listing Number (ALN): Various Federal Agency: U.S. Department of Education Federal Award Identification Number: Various Federal Award Year: June 30, 2022 Criteria: 34 CFR 668.22 requires that when a recipient of Title IV grant or loan assistance withdraws from an institution during a payment period or period of enrollment in which the recipient began attendance, the institution must determine the amount of Title IV grant or loan assistance that the student earned as of the student's withdrawal date in accordance with Federal regulations and return the unearned portion of the grant or loan funds to the Title IV programs as soon as possible but no later than 45 days after the withdrawal date. Condition: Two students of five students tested had incorrect/missing calculations. One student was disqualified during the term after the first 8 week session in the Associate Degree of Nursing and could not continue into the second 8 week session. The University did not note the disqualification and withdrawal timely and did not perform an R2T4 calculation as required and the $2,473.53 of direct loans calculated by the auditor was not returned. One student's number of days attended (numerator) was calculated incorrectly at 25 days but should have been 26 days and therefore $59.53 too much Pell was returned. The auditors noted that a total of four students withdrew from the Associate Degree of Nursing program from the population file provided, and two students were not selected by the auditors. The University reviewed these students and noted one student completed more than 60.01% although the auditors learned that the student was disqualified at the end of the first 8 week session and therefore should have had an R2T4 calculation and return, and one student the R2T4 calculation was performed, however the auditor noted the number of days attended (numerator) was calculated incorrectly at 51 days but should have been 52 days and included a negative amount of Pell grant that ?could have been disbursed?. The University noted that an estimated term end date of May 7, 2022 was input in the system and was not updated to the actual term end date of May 6, 2022. As this could impact all students who withdrew during the Spring 2022 term, the auditors noted 21 students in the population file provided who withdrew during spring 2022, and four of those students were noted as withdrawing before 60% and were not tested by the auditors. The University reviewed these students and noted two additional students with incorrect denominators used in their calculations, the auditor reviewed only the denominators for these students and agrees. The sample was not a statistically valid sample. Cause: The University?s controls surrounding completing timely and accurate refund calculations did not operate as designed and resulted in exceptions. Effect: The calculations of funds to be returned to the Department of Education did not occur or were incorrect. Questioned costs: Questioned costs of $2,301.70 (ALN No. 84.268), and $59.53 (ALN No. 84.063) were noted during testing. Context: Exceptions were noted for 2 of the 5 students selected for testing. There were a total of 33 students who withdrew during fiscal year 2022 that received Title IV aid. Recommendation: It is recommended that University personnel review the calculations generated by the University's software system to ensure they are timely and accurate. It is also recommended that the control structure be reviewed to ensure all student who withdraw during a term are identified in a timely manner. Management?s Response: The University will review withdrawal controls and procedures so that students who withdraw are identified and correctly processed in a timely manner. The University will also engage our software system Consultant to examine system settings to ensure accurate and timely Return of Title IV calculations occur. Further, management reviewed and performed the same recalculations for the remaining 28 students in the population. Of those, 24 had no findings or errors and the remaining only had a small amount of excess available Pell funding or loan eligibility. The Pell amounts were awarded and students with loan availability were notified and asked to respond if they wished to borrow the additional funds. All amounts were not material. Correction Action: The Registrar?s Office will provide the Financial Aid Office with final academic calendars in advance to ensure that proper start and end dates of academic periods are correct in the Financial Aid System. Multiple employees (as opposed to a single person) in the Financial Aid office will be tasked with confirming the accuracy of the calendar set-up in advance of the start of each semester. We have also reminded the Nursing department of timely communication of student disqualifications to the Registrar?s office to assist in recognizing students who may fall into this category. In addition to these steps, the University is exploring systematic changes in colleague that will split the ADN and ABSN programs into two separate 8 week sessions with separate start/end dates, as opposed to one 16 week semester that has two sessions within. An RT24 output report will now be automatically generated and reviewed by the Director of Financial Aid every two weeks. Furthermore, the University will apply the same refund calculation policy to ADN students who are academically disqualified, as we do all other student populations. This will ensure accuracy when determining the number days attended and earned amounts of federal aid when processing R2T4 calculations. The University will dedicate additional resources, staff and technology, to manage withdrawal notifications and to process then in a timely manner.

2022-001 - Non-compliance Specific steps to be taken to correct the situation (including a timetable for performance of the CAP) or reason why corrective action is not necessary (including disagreement with the finding): NTMA has recently adopted a new student financial management system that will assist in determining correct calculated awards and is a State of the art financial aid packing system. We are retiring Transcripts, a very antiquated system that was not set up to provide the error free outcomes required. Jenzabar Financial Aid, our new SMS, enacts group processing and direct data imports from the DoE, manages funds to and from the COD system. Flexibility to award using federal and institutional methodologies, automates COA calculations etc.. Jenzabar is a Financial Aid System built by financial aid people. It was set up in manner that is meant to be more compliant and more robust streamline process. It has automated the entire financial aid process. In addition, we are also considering the use of a servicer and requiring financial aid staff to take an additional continuing education and they will be attending virtual workshops that the DoE offers each year.

The institution does not dispute this finding. This was an isolated incident and no further instances of this nature occurred. There was a personnel change in the staff member responsible for completing refund calculations. The automated notice for this particular student's withdrawal had been sent to the prior employee, who by that time was no longer with the college. The new individual did not see the notice and was not aware that a refund calculation was required. There was a brief window when all notifications were switched to the new staff member, and this particular status change was processed during that transition. The refund has now been processed and all unearned aid for the term has been returned. We have two personnel trained on completing/reviewing R2T4 calculations to serve as a checks-and-balance within the department. This finding was reviewed with all staff members in the department to ensure compliance moving forward.

The institution does not dispute the finding. This was an isolated incident and no further instances of this nature occurred. There was a delay in processing the refund as the R2T4 was completed just before our holiday break. The staff member that handles the return in COD would have completed it upon return to the office in early January but then she was out of the office for longer than anticipated due to symptoms resulting from a positive diagnosis of Covid. Upon her return, she completed the refund and it posted to the ledger 19 days late. Each position within the department has now been cross trained so that any one staff member's extended absence does not impact the operation and our ability to maintain regulatory compliance. This finding as reviewed with all staff members in the department to ensure compliance moving forward.

The institution does not dispute this finding. This was an isolated incident and no further instances of this nature occurred. The staff member mistakenly thought that a PLUS denial from a prior academic year was for the academic year in question, thereby awarding additional Unsub for an independent student. Once the error was found, the ineligible Unsub amount was returned. Staff was provided proper training with respect to reviewing documentation to confirm accuracy of awards being packaged. This finding was reviewed with all staff members in the department to ensure compliance moving forward.

Return of Title IV (R2T4) Calculations Planned Corrective Action: The Office of Financial Aid and Scholarships will develop procedures to conduct secondary reviews of R2T4 calculations going forward to address any issues related to calculations. Responsible staff will continue to attend regular virtual seminars conducted by the Department of Education and national, regional, and state associations of financial aid administrators for ongoing training. The Director of Financial Aid and Scholarships will develop a working group to discuss current University policies related to attendance, roster drops, and withdrawals to improve reporting to ensure timely returns. The group will include representation from the office of Financial Aid and Scholarships, the office of the University Registrar, the office of the University Provost, and Anderson Central. Additionally, because the University has adopted Workday for its new campus-wide ERP the financial aid system of record has changed from PowerFAIDS. The Director will work with our outside consulting partner to develop reports and notifications necessary to ensure compliance since the delivered R2T4 process within Workday is not fully functional. Person Responsible for Corrective Action Plan: Director of Financial Aid and Scholarships, Michael Sapienza. Anticipated Date of Completion: Continuous process

Name of Responsible Individual: Sammara Evans, Director of Institutional Research Corrective Action: On March 21, 2023, Howard assigned Ms. Sammara Evans, the Director of Institutional Research, as the lead for quarterly and annual HEERF reporting. The areas with access to the information required to complete the quarterly and annual HEERF reporting have now been added to the Education Stabilization Fund (ESF) site as editors. This list of editors on the ESF site includes representatives from the Financial Aid Office, the Bursar?s Office, Enrollment Analytics and Grants & Contracts. These offices can now receive notifications regarding submission deadlines and have access to update the information for each report. Prior to the quarterly or annual report due date, the Director of Institutional Research will request the necessary information from each department and is aware of her responsibilities to do so. HEERF reporting responsibilities have been defined. Anticipated Completion Date: March 31, 2023

Name of Responsible Individual: Benjamin Carmichael, Compliance Officer and Roderick Johnson, Assistant Director for Compliance Corrective Action: There was one credit balance in the sample (from September 2021) that was not processed within 14 days. It was completed on the 20th day after the refund was created on the student?s account. Note that the record identified in the sample was during the time of the cyberattack. While this does not absolve Howard of demonstration of administrative capability, the bursar team could not have performed their function during this time. Anticipated Completion Date: December 31, 2021

Name of Responsible Individual: Roderick Johnson, Assistant Director for Compliance Corrective Action: The finance and financial aid divisions will collaborate to improve the internal controls that are in place to ensure there is a three-day turnaround for draws and refunds. The policies and procedures for cash management were updated in July 2022. Anticipated Completion Date: June 30, 2023

Name of Responsible Individual: Benjamin Carmichael, Compliance Officer Corrective Action: Loan disbursement notifications are now the responsibility of the Office of Financial Aid (Financial Aid). Notifications are now being sent out through Ellucian Banner (Banner) when a student has been awarded. The disbursement notification documentation is now electronic and does not require manual actions from Howard University employees to be completed. The following areas identified in the audit have been addressed: ? Notifications are immediately sent out electronically when the student is awarded, allowing Howard to meet the required notification timeline for notification. ? Each notification is addressed to the specific person (i.e., parent, student) who is responsible for paying back the loan. ? The name of the student, exact amount of the disbursement and the date of disbursement is generated on the notification as well. Bi-semester reviews have been completed by the Associate Director for Compliance (Financial Aid) to ensure the loan disbursement notifications are being generated in the required timeline and includes all federally required information listed above in each notification. Spring 2022, Summer 2022, and Fall 2022 reviews have been completed thus far with no significant issues identified. The policies and procedures for loan disbursement notifications were updated in April 2022. These will be reviewed annually. Anticipated Completion Date: April 30, 2022

Name of Responsible Individual: Benjamin Carmichael, Compliance Officer and Roderick Johnson, Assistant Director for Compliance Corrective Action: The Enrollment Reporting process is supervised by the Office of the Registrar (Registrar), which is responsible for providing enrollment reports to Howard University?s third-party servicer, National Student Clearinghouse (NSC), who then submits the report to the National Student Loan Data System (NSLDS). The departure of a key registrar personnel resulted in miscommunication and neglect of the enrollment reporting duties. The issue has since been remedied, but due to the time lag, will take an additional fiscal year for improvements to be observed. Anticipated Completion Date: March 31, 2023

See corrective action plan for chart/table.