Corrective Action Plans

Finding 2022-001 ? Special Tests and Provisions ? Enrollment Reporting (Student Financial Assistance Cluster) Contact Persons: Diana Dimas, Registrar?s Office Cristen Alecia, Office of Financial Assistance Current Status: Correction of this finding is in-progress. Anticipated Completion Date: December 31, 2023 Condition: The University of the Incarnate Word did not accurately or timely report student status changes to the NSLDS for 6 out of 60 students selected for testing. Identification of Repeat Finding: 2021-001, 2020-001, 2019-002 While the condition reported above is considered a repeat finding, it is important to note that the errors are different this year and that these findings are not a reflection of the university ignoring previous findings or failing to make changes, but rather a reflection of the complexity of enrollment reporting. There were no inaccurate or untimely attendance level changes, and the official withdrawals were reported accurately and timely. In this year?s errors, we had a student who graduated outside of a normal conferral date, causing them not to be reported during our normal degree conferral report to NSC. The Registrar?s Office is putting changes in place to either eliminate out-of-cycle conferrals, or increase the number of conferral and reporting dates to effectively capture all graduates. We know that only 6 students were caught up in this out-of-cycle graduation, as it was a specific exception for the School of Osteopathic Medicine, and is not a wide-spread issue. We had two unofficial withdrawals reported later than 60 days ? at 69 and 70 days. While the withdrawal and the changes were processed timely, the timing of the roster from NSLDS compared to the submission to NSC caused the report not to be acknowledged until after the 60 days had passed. The Office of Financial Assistance is researching the option of manually reporting unofficial withdrawals outside of the monthly reporting cycle in order to eliminate this problem. The Registrar?s Office will review the roster and NSC submission schedules to see if changes need to be made in order to better align reporting dates. We had three students inaccurately reported as withdrawn for the summer semester. These students were at least half-time in the preceding Spring and the following Fall, and therefore were not required to be reported as withdrawn. The Office of Financial Assistance and the Registrar?s Office will work together to research options in Banner and with NSC. It may be necessary to create a separate withdrawal code to identify summer withdrawals that should not be reported as withdrawn, and create a report to monitor the fall enrollment for these students in case they later withdraw from Fall and transition to a withdrawal which must be reported. The Banner system alone does not allow for the complicated logic mandated for summer reporting in the NSLDS Enrollment Reporting Guide. Our offices will continue to work in partnership to resolve these enrollment reporting issues. Cristen Alicea Director Office of Financial Assistance 210.805.1238 gimenez@uiwtx.ed www.uiw.edu/finaid Diana Dimas Associate Registrar Registration and Technology Office of the Registrar 210.832.5484 dimasd@uiwtx.edu www.uiw.edu

Instructors will do a better job communicating to the Registrar of student course drops and reporting LDAs. The Registrar has implemented a review of all data to ensure it is correct moving forward. Our third-party financial aid processer, FAME, has agreed to review all r2T4 forms going forward for accuracy.

Finding No. 2022-002 Enrollment reporting Cluster: Student Financial Assistance Cluster Grantor: Department of Education Award Name: Federal Direct Student Loans Award Year: July 1, 2021 ? June 30, 2022 Award Number: Not applicable Assistance Listing Number: 84.268 The College agrees with the finding noting that this exception is an unusual occurrence as a result of improper recording of the leave status in Colleague, the student information system. The record in Colleague should have had hiatus data entered on April 11, 2022, the date in which the College was aware of the student?s enrollment change, which would allow the change in enrollment information to be queried and transmitted to the National Student Clearinghouse (?NSC?) in in the May 17, 2022 submission. As this hiatus data was not updated, the student?s enrollment record was reported as enrolled at that time, which is attributed to an error in data entry of the multiple fields required in Colleague to reflect a leave from the College. The student?s transcript was correctly marked as ?W? as of April 8, 2022. However, the effective date was not correctly reported to the NSLDS. Management is in the process of correcting the effective date reporting to the NSLDS. The College has since implemented Workday Student, the College?s new student information system, in August of 2022. New business processes for entering student leaves have been documented and staff have been trained. The Office of Student Affairs initiates the leave process and a system process prompts records, financial aid, and billing to review the student record. The leave is updated within the student information system once all of the relevant offices have completed their processing. Training was done as a part of the implementation and testing process. The NSC enrollment reporting in Workday is automated. Jesse Barba, Director of Institutional Research and Registrar Services, is responsible for the implemented corrective action plan.

Finding No. 2022-001: Review of Return of Title IV Funds calculation Cluster: Student Financial Assistance Cluster Grantor: Department of Education Award Names: Federal Pell Grant Program, Federal Supplemental Educational Opportunity Grants, Federal Direct Student Loans Award Year: July 1, 2021 ? June 30, 2022 Award Number: Not applicable Assistance Listing Numbers: 84.063, 84.007, 84.268 The College agrees with the finding noting that a business control process was in place for a review of all Return of Title IV aid calculations, however, the College did not retain documentation evidencing this review. The College confirmed none of the Return of Title IV aid calculations selected had errors and the control was working as it was designed. The control is taken seriously and both training and oversight of personnel performing return of title IV calculations is exercised. As of March 31, 2023, the review will be noted on the change sheet at the time of award revision with the signature stamp in Perceptive Content (imaging and workflow software). Gail Holt, Dean of Financial Aid is responsible for implementing this corrective action plan.

Individuals Responsible for Corrective Action Plan: Eileen F. Doyle, Associate Vice President of Student Financial Services, (914) 633-2483 Corrective Action Plan: In this instance, there was a manual intervention which caused a loan to credit to the student account. A decision was made to leave the credit but not refund as a motivation for the student to complete the required Entrance Counseling. The student subsequently completed the Entrance Counseling when the loan credit was reversed. As soon as the Entrance Counseling was completed the loan was recredited and the refund was processed within the appropriate timeframe. The individual who made the decision to not refund is no longer with the University. Staff have been trained that, unless the borrower has completed all requirements, loans cannot be credited to an account and the ?do not refund? option is not an appropriate tool in such an instance. Anticipated Completion Date: Completed.

Individuals Responsible for Corrective Action Plan: Eileen F. Doyle, Associate Vice President of Student Financial Services, (914) 633-2483 DJ Arndt, Registrar, (914) 633-2520 Corrective Action Plan: Iona University?s Registrar?s office updated the Holiday Calendar schedules in PeopleSoft, the Student Information System, to ensure that institutionally scheduled breaks of 5 or more consecutive days are properly reflecting weekend days. These updates will be used to accurately calculate the percent of a term attended and federal aid earned for federal aid recipients who withdraw from the University during a term as part of the Return to Title IV aid mandatory calculations. The calendar entries will be made by the Associate Registrar and reviewed and approved by the Registrar during the academic year set up process each academic year. Anticipated Completion Date: Completed.

Emmanuel College Audit Response Finding number 2022-001 from the 2022 audit has been copied below with the management response and corrective action plan provided. EMMANUEL COLLEGE SCHEDULE OF FINDINGS AND QUESTIONED COSTS JUNE 30, 2022 Condition: Out of a sample of 108 students there were 20 who withdrew. We decided to test all 20 of those students as it related to return of Title IV funds. Return of funds were sent in by the required date except for two instances. One was late due to the Thanksgiving Holiday. The school was closed on that Thursday and Friday, so the funds were not submitted until the following Monday. This was not a big deal; however, the other instance was simply late by 4 days and no Holidays were involved. Cause: Simply an oversight in which the date simply slipped by them. Effect: The Department of Education received the transferred return of funds 4 days later than they were required to be deposited into the SFA account. Recommendation: College management should design and implement procedures to ensure that there are checks and balances to make sure that when a student withdraws and the return of funds are calculated that the required return date is flagged and sent to whomever is responsible for submitting those funds to the SFA account. Management Response and Corrective Action Plan: Financial Aid personnel will utilize a built in Return to Title IV funds feature of the financial aid software, PowerFaids, to function as a quality assurance measure for Accounting Office staff. The PowerFaids function archives the date of withdrawal and calculates the deadline for return of funds. This feature will allow for quality assurance reports to be pulled no less than a week before the deadline so that Financial Aid staff can serve as an accountability partner for accounting staff in ensuring funds are returned in a timely fashion and in compliance with all federal guidelines. Contact Responsible for Corrective Action: Donna Quick, Vice President for Enrollment, 706-245-2872

Name of Responsible Officials: Margherite Powell, Director of Financial Aid. The Policy and Procedures manual has been updated to reflect the following updated process: The Financial Aid Office has implemented measures to ensure students/parents that have Title IV loans disbursed are sent loan disbursement notifications via Colleague once a loan disbursement has been made. The process is done via Colleague each day and captures all Title IV loan disbursements made for the previous day. The notifications are processed via the ST-PCB process in Colleague, which sends a system generated loan disbursement notification to the student/parent. Processes are being worked on with the Information Technology department to generate a copy of the notification and to put in place a paper notification if no parent email is provided.

Name of Responsible Officials: Carlos Chaves, Business Office Manager. The Business Office processes student refunds within 14 days after a Title IV credit balance appears on a student?s account. At least once per week, the Refunds Coordinator generates a refund report (ARTM) which lists students with credit balances. The University?s policy is that all refunds are processed via ACH (direct deposit), and all students are required to provide their bank account information. Communication is sent to students throughout the semester reminding them to sign up for direct deposit. To ensure that all students receive their refunds by the required 14 days, a paper check is issued to students missing banking information. Checks are sent to the mailing address on file. Communication will continue to be sent to all students encouraging them to sign up for ACH refunds. However, refunds are processed timely even if the banking information is not available. The Policy and Procedures manual has been updated to reflect this process.

Name of Responsible Officials: Carlos Chaves, Business Office Manager. The Business Office has implemented measures to ensure that Perkins Promissory Notes are identified, stored, and accessible during their repayment and collection period. In addition to the current filing system, the Business Office will utilize management software for ease of access and recording. To ensure that all remaining promissory notes are kept in accordance with Department of Education regulations, the Business Office will: ? Record all incoming promissory notes internally and externally. ? Promissory notes created prior to 2013 will be made digitally accessible through Perceptive Content, a secure content management system. Access to these promissory notes will only be accessible by parties with authorized access. ? Promissory notes created after 2013 will continue to be made available through Heartland ECSI?s third party filing system. ECSI records paid, completed, cancelled, and retired promissory notes that were created after 2013. ? In accordance with the Perkins Assignment and Liquidation Guide from the Department of Education (EA ID: General-21-53), all accounts with promissory notes unable to be located will be written off and/or purchased from the Department of Education prior to the end of FY 2023. The Policy and Procedures manual has been updated to reflect this process.

To Whom It May Concern: Midland University Single Audit Report: Corrective Action Plan - Year ended May 31, 2022 Finding 2022-002 ? NSLDS Enrollment Reporting Condition/Context: For 6 of 25 students tested, the status effective date or program was reported incorrectly or the student was not reported to NSLDS. ? Two students' withdrawn dates reported to NSLDS did not agree to the support provided from the University's system. Additionally, one of these student's enrollment status was reported incorrectly as full time not 3/4 time. The University subsequently corrected these students? records in NSLDS and the auditor viewed the screen prints with the corrections. ? One student's graduated date reported to NSLDS did not agree to the support provided from the University's system, however the University believes the date reported to NSLDS was correct and the system's date was incorrect. ? One student's full time status effective date was reported incorrectly as January 10, 2022 not August 30, 2021. The University subsequently corrected the student?s record in NSLDS and the auditor viewed the screen print with the corrections. ? One student was incorrectly not reported to NSLDS when they attended and had Title IV loans during 2021-22. The University subsequently corrected the student?s record in NSLDS and the auditor viewed the screen prints with the corrections. ? One student's status dates reported to NSLDS for campus level January 10, 2022 did not agree to the support provided by the University's system of April 4, 2022. The University subsequently corrected the student?s record in NSLDS and the auditor viewed the screen print with the corrections. The sample was not a statistically valid sample. Corrective Action Plan The University has made all corrections to the identified records. The University is reviewing its current processes and evaluating if additional review controls need to be put in place to ensure timely and accurate NSLDS data.

To Whom It May Concern: Midland University Single Audit Report: Corrective Action Plan - Year ended May 31, 2022 Finding 2022-001 ? Title IV Credit Balances Condition/Context: For 4 of 25 students tested, the credit balance was not resolved in compliance with the regulations, the student?s Title IV credit balances on their accounts were held and applied to future charges without student or parent authorization. The first student?s Title IV credit balance was $759 of Direct Loan funds, the second student?s was $3,702 of Direct Loan funds, the third student?s was $390 of Direct Loan funds and the fourth student?s was $2,850 of Direct Loan funds and $943 of Teach Grant funds. The sample was not a statistically valid sample. Corrective Action Plan The University agrees with the finding. The occurrence of Title IV credit balances occurs primarily with graduate program students. A review is being conducted of current internal control processes and evaluating what additional reporting is capable within the student information system to assist in identifying these Title IV credit balances in a more timely manner. Title IV credit balances are being monitored during the Spring 2023 terms and new procedures will be put in place for the Fall 2024 term.

FY 2022 SFA Audit Corrective Action Plan Audit Firm: RSM US LLP 30 S Wacker Drive, Suite 3300 Chicago, IL 60606 Audit Period: 1/1/2022 ? 12/31/2022 Comments on Findings and Recommendations: Finding 2022-001 ? Error in Reporting for NSLDS Finding: Herzing University did not properly report the student enrollment change for a student who received federal student aid to the National Student Loan Data System (NSLDS). Condition: The University did not report a student?s Program-Level or Campus-Level enrollment status change to NSLDS. Out of the 60 students tested, we noted 1 student (1.7%) whose status change at the Program-Level and Campus-Level was not reported to NSLDS. Action Taken: In this instance, the student identified was withdrawn from the University and was correctly reported to NSLDS as such through our standard enrollment reporting processes. The student then subsequently re-enrolled at the University in the subsequent academic period becoming an Active student, and then withdrew again prior to our next standard enrollment reporting process occurring (one month after the previously reported withdrawn status). At the point of the second standard enrollment reporting timeframe, the student status was once again withdrawn, therefore an update did not occur to their enrollment status. Our process did not have a mechanism to identify the student changing statuses in between those reporting periods so that the active enrollment status was reported and then changed back to withdrawn versus simply staying at a withdrawn status. In August 2022, Herzing University updated our enrollment reporting policy to send in enrollment reporting biweekly instead of monthly. This was done to ensure that each student?s enrollment status was accurately reported as soon as possible and to prevent issues that occur from delays in proper enrollment statuses being reported to NSLDS. This update inherently decreased the likelihood that status timing issues would occur given the condensed timeframe for reporting. In addition, as of May 1st, 2023 Herzing University has developed and implemented an exception reporting process that will identify any student that has status updates that occur but reverts back to the original status within the timeframe of the two enrollment reporting periods. Using the student identified in this finding as an example, if the student is at a withdrawn status at the first enrollment reporting period, then moves to an active status immediately after that but then withdraws again within that 2 week window and therefore goes back to a withdrawn status in the subsequent enrollment reporting period, while our standard reporting would still show the student withdrawn for both standard enrollment reporting timeframes, the exception report will flag that student for review since a status change occurred in between the two withdrawn statuses being reported out. Upon review of the exception report, all relevant status progressions will be correctly reported to NSLDS. The required corrective action for Finding 2022-001 listed in the SFA audit for the period 1/1/2022 ? 12/31/2022 was completed on 5/1/2023. The person responsible for completion of the corrective action was Kevin McShane, Vice President of Financial Aid & Compliance.

AUDIT FINDING Finding 2022-001 Late Return to Title IV (R2T4) MANAGEMENT'S COMMENTS ON FINDINGS AND RECOMMENDATIONS We concur with the auditor?s finding and identification of a deficiency in our internal controls. MANAGEMENT'S CORRECTIVE ACTION PLAN We will enact stronger controls to ensure that all R2T4s are returned in a timely manner. EMPLOYEE/ DIVISION RESPONSIBLE Financial Aid Director TIMELINE AND ESTIMATED COMPLETION DATE Immediately

AUDIT FINDING Finding 2022-002 NSLDS Status Reporting Error MANAGEMENT'S COMMENTS ON FINDINGS AND RECOMMENDATIONS We concur with the auditor?s finding and identification of a deficiency in our internal controls. MANAGEMENT'S CORRECTIVE ACTION PLAN We will enact stronger controls to ensure that all future enrollment reporting is submitted timely. EMPLOYEE/ DIVISION RESPONSIBLE Financial Aid Director TIMELINE AND ESTIMATED COMPLETION DATE Immediately

It was brought to our attention that we are unable to update our third transmittal to NSC due an uploading error with Jenzabar. Once we were notified of this error, we began communicating with NSC to find an alternative route to submit the third transmittal. The third transmittal was submitted but we later learned that the file was rejected. Unfortunately during that time, the notification of the error message was inadvertently overlooked due to the challenges we were faced with during the recovery period of Hurricane Ida. To mitigate this from occurring in the future, we have discussed changing how and when our enrollment transmittal data will be reported. Furthermore, we had participated in training and scheduled additional training opportunities with Jenzabar to create an errorless transmittal process.

During the Fall 2021 semester, the late disbursement of funds was the result of staff being displaced as a result of Hurricane Ida in which the University started on time but had to stop due to the hurricane and its impact. Several staff members were also impacted, and the departments were working short staffed, which filtered into the Spring 2022 semester whereby there was an increase in the reduction of staff within the Office of Business and Finance.

It was brought to our attention that we are unable to update our third transmittal to NSC due an uploading error with Jenzabar. Once we were notified of this error, we began communicating with NSC to find an alternative route to submit the third transmittal. The third transmittal was submitted but we later learned that the file was rejected. Unfortunately, during that time, the notification of the error message was inadvertently overlooked due to the challenges we were faced with during the recovery period of Hurricane Ida. To mitigate this from occurring in the future, we have discussed changing how and when our enrollment transmittal data will be reported. Furthermore, we had participated in training and scheduled additional training opportunities with Jenzabar to create an errorless transmittal process.

Corrective Action: The two students whose information was not reported within 60 days was due to an internal failure to report the status change by the Financial Aid and Registrar's Office. The one student whose effective date varied between program and campus level stems from system limitations, as the process to report this status change on the program level but not the enrollment level, as required by NSLDS, is a manual process. The University continues to refine the manual process required for reporting this type of status change. For the four students who never had their graduation status reported to the NSLDS, Management noted one actual failure to report and three instances where the status change was reported to the Clearinghouse, but not reflected on NSLDS. The University is working with the Clearinghouse to understand what went wrong and how to prevent it in the future. The University is in the middle of implementation of a new student information system which is expected to improve this and other processes. Implementation is anticipated to be complete by July 2023.

Finding 2022-006 Federal Agency Name: Department of Education Program Name: Education Stabilization Fund ALN 84.425 Finding Summary: The College provided emergency grants to students with the student portion of the HEERF funding, but the College could not provide evidence that the student met the definition of ?eligible student?. The emergency grants were used to relieve the delinquent student accounts. There were 5 students identified in our testing that were not ?enrolled in an institution of higher education on or after the date of the declaration of the national emergency (March 13, 2020).? It appears the 5 students were not enrolled at the College on or after March 13, 2020, and the College did not obtain evidence that the students were enrolled on or after this date at another institution of higher education. Responsible Individuals: Courtney Judah, Director of Institutional Effectiveness Corrective Action Plan: Ongoing training was conducted with Enterprise Management Software support to develop reporting and process steps to prevent reporting errors and improve accuracy for student?s assistance. Prevention to include creation of reports for awards pending and detailed disbursement and reconciliations schedules. Develop ongoing student intervention processes to identify student with emergency financial need. Student Funding Committee formed that processes request includes verification of enrollment, number of credits, and financial aid standing. Committee includes representatives from Financial Aid, Advising, Foundation, and the Business Office. The College has entered into an agreement with a third-party financial aid provider to service and administer financial aid awards, reporting and reconciliation. Contracted services include award packaging, document collection and compliance review, disbursement logs, direct flow of federal funds, account reconciliation and exit process. The added third-party support reduced workload on Financial Aid and allowed for a more proactive engagement with student emergency funding needs. Contacted Department of Education grant administrator for guidance on program requirements and compliance. Completed and will continue to participate in ongoing Department of Education training. Anticipated Completion Date: June 30, 2023

Finding 2022-004 Federal Agency Name: Department of Education Program Name: Student Financial Assistance Cluster ALN 84.007, 84.033, 84.063, 84.268 Finding Summary: During our testing, we noted 42 instances out of 182 disbursement transactions tested where the disbursement date per the College?s records and the processing date at COD was outside the mandatory 15-day reporting window. In addition, we noted 52 instances out of 182 disbursement transactions tested where the disbursement date per the student?s record and the disbursement date per COD did not agree. Responsible Individuals: Axel Hernandez, Director of Financial Aid Corrective Action Plan: Continue to identify and resolve Enterprise Management Software (ERP) issues that result in disbursement delays. The College has entered into an agreement with a third-party financial aid provider to service and administer financial aid awards, COD reporting and reconciliation. Contracted services include award packaging, document collection and compliance review, disbursement logs, direct flow of federal funds, account reconciliation and exit process. Ongoing training was conducted with ERP support and third-party disbursement software support to develop reporting and process steps to prevent reporting errors and improve accuracy in reporting in identifying student?s assistance needs. Prevention to include creation of reports for awards pending and detailed disbursement and reconciliations schedules. Anticipated Completion Date: Ongoing

Finding 2022-003 Federal Agency Name: Department of Education Program Name: Student Financial Assistance Cluster ALN 84.007, 84.033, 84.063, 84.268 Finding Summary: During our testing over the NSLDS reporting requirements, we noted that 27 enrollment status certifications out of 151 enrollment certifications tested were not reported to NSLDS in the required timeframe. In addition, it was noted that 57 enrollment statuses out of 151 enrollment statuses tested did not agree to the enrollment status that was submitted to NSLDS. Responsible Individuals: Mary Martin, Registrar Corrective Action Plan: Enrollment reporting is the responsibility of the Columbia Gorge Community College (CGCC) Registrar. Reporting of enrollment information in a timely manner for the year ended June 30, 2022, was impacted by the implementation of a new Student Information System (SIS) in May 2021. The SIS included significant changes to student record procedures and a new enrollment reporting process. In response to the Enrollment Reporting Finding for the year ended June 30, 2022, the Registrar continues working to mitigate any issues negatively impacting enrollment reporting by: ? working with the Vice President of Student Services and Director of Financial Aid to establish internal checks and balances to ensure reporting is being done in a timely manner; ? working with SIS system support staff and internal IT staff to promptly address technical issues and/or other issues impacting enrollment reporting; ? working with National Student Clearinghouse representative to ensure reporting schedule meets required timeframes; ? consistent review of enrollment files prior to submission to ensure correct student enrollment statuses and program information are being reported; ? prompt resolution of reporting errors; ? identifying and training of additional staff on enrollment reporting. Anticipated Completion Date: Ongoing

Finding ? Eligibility ? Federal Direct Student Loan Program Assistance Listing Number 84.268 and Federal Pell Grant Program Assistance Listing Number 84.063; June 30, 2022 Award Year; U.S. Department of Education Criteria or Specific Requirement The annual maximum loan amount an undergraduate student may receive must be prorated when the borrower is enrolled in a program that is shorter than a full academic year; or enrolled in a program that is one academic year or more in length but is in a remaining period of study that is shorter than a full academic year. (2021 - 2022 Student Financial Aid Bank Book, Volume 3, Chapter 5, Page 3-160, 34 CFR 685.203(a),(b),(c)) The amount of a student's Pell Grant for an academic year is based upon the payment and disbursement schedules published by the Secretary for each award year. (2021 - 2022 Student Financial Aid Handbook, Volume 3, Chapter 3, Page 3-68, 34 CFR 690.62) Condition Of the 40 students selected for eligibility testing, two students within the sample were incorrectly awarded aid based upon their specific circumstances. This was not a statistically valid sample. Views of Responsible Officials and Planned Corrective Actions The University concurs with the finding. The University will implement periodic quality control checks to ensure student aid is being appropriately calculated and awarded based upon relevant student enrollment and financial information. Names of Contact Persons Responsible for Corrective Action: Joan Romano, Registrar and Anne-Marie Caruso, Assistant Vice President/Director of Financial Aid Anticipated Completion Date: October 24, 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, three 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 University concurs with the finding. The University will continue to remain vigilant in its oversight over timely communication of enrollment reporting detail to NSC and from NSC to NSLDS. Names of Contact Persons Responsible for Corrective Action: Joan Romano, Registrar and Anne-Marie Caruso, Assistant Vice President/Director of Financial Aid Anticipated Completion Date: October 24, 2022

2022-003 Student Financial Assistance Cluster ? Federal Assistance Listing Nos. 84.063 and 84.268 Recommendation: We recommend the University review its policies and procedures on reporting enrollment information to the NSLDS to ensure that all relevant information is being captured accurately and reported timely in accordance with applicable regulations. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The University will work towards adjusting policies and systems to ensure more timely and accurate reporting to NSLDS. This will include working with representatives at NSLDS and the Clearing House to ensure transmission of data is happening more frequently and accurately. Changes have also been made on how long after the close of semester we will allow a retroactive medical withdrawal. The timing of this will help ensure more timely reporting. Name(s) of the contact person(s) responsible for corrective action: Natalie Durant, Registrar Planned completion date for corrective action plan: May 2023