Corrective Action Plans

2022-001 Student Financial Assistance Cluster ? Federal Assistance Listing No. 84.038 Recommendation: We recommend the University evaluate is procedures and policies around recordkeeping and retention. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Management have reviewed their policies and procedures in regards to recordkeeping and retention of Perkins loan documents. Assigned and Retired Perkins loans are maintained in a locked, fireproof container in the Bursar office. The repayment schedules are electronically kept in our borrower files in Heartland ECSI. In addition, the Perkins loan program expired September 30, 2017. Name(s) of the contact person(s) responsible for corrective action: Diane Purcell, Bursar Senior Accountant, (860) 768-4361 Planned completion date for corrective action plan: March 2023

Finding 2022-001: Direct Loan Reconciliation Finding Type: Internal control over compliance ? Significant deficiency and noncompliance Federal Program title and Assistance Listing Number: Federal Direct Student Loan (84.268). Criteria: In accordance with 34CFR ?685.300 (b)(5), a school must, on a monthly basis reconcile institutional records with Direct Loan funds received from the Department of Education and Direct Loan disbursement records submitted to the and accepted by the Department of Education. Condition: During the audit, AFI was unable to provide evidence that the reconciliations were performed on a monthly basis. Context: AFI disbursed $8,050,495 in Federal Direct Student Loans during the year. Questioned Costs: None Cause: AFI did not maintain the documentation to support compliance with 34CFR ?685.300 (b)(5). Effect: AFI was not able to demonstrate compliance with 34CFR ?685.300 (b)(5). View of responsible officials and corrective actions taken or planned: The Institute has performed monthly reconciliations. However, the reconciliations were not kept on file for every month, particularly those with little to no activity. Accordingly, the Institute agrees on the finding. AFI has updated its procedures to retain documentation on all reconciliations that are performed on a monthly basis, and going forward, the Institute is implementing a formal second review process, with a new hire to support this long-term. Individuals responsible for corrective action: Robin Bailey-Chen, Director, Financial Aid 323.856.7764 Anticipated completion date: October 1, 2022

2022-002 Student Enrollment Reporting June 30, 2023 The University agrees with the finding. The University?s procedures between multiple departments lacked a collaboration on the timing of reports to NSLDS via NSC for degree confirmations. This procedural change has been identified and will be implemented moving forward. In addition, adequate procedure changes have also been identified as it relates to program-level reporting and will be implemented to ensure compliance. The contact person for this corrective action plan is Shannon Sutton, Interim Vice President for Finance and Administration. She can be reached by calling (309) 298-2073 or at the following address: Vice President for Finance and Administration Office Western Illinois University Sherman Hall 200 1 University Circle Macomb, IL 61455

Finding 2022-003 ? Special Tests and Provisions ? Enrollment Reporting Previously, some withdrawals were delayed as the result of electronic forms stalling within the workflow process. The Office of Records and Registration has met with the consultants and revised the process so that Records and Registration and Financial Aid is alerted immediately when a Term Withdrawal is submitted. Withdrawals are processed within 24 hours of receipt. Faculty will be trained to ensure the timeliness of them reporting students who have not been attendance so the student?s status will be updated expeditiously so they will be reported correctly. The Office of Records and Registration is working with Academic Affairs to hire staff who will be responsible for Enrollment Reporting and NSLDS. We will also report monthly to the National Student Clearinghouse in an effort to capture any changes in students? enrollment status. Anticipated Date of Completion: Corrective action completed as of the date of this report. Contact: Marie McNear Director Records and Registration mmcnear@alasu.edu 334.229-4312 The Office of Financial Aid works closely with the Office of the Registrar to ensure that all withdrawn students from the University are reported to the Clearinghouse on a monthly basis. Once the students are withdrawn and the report is generated to the Clearinghouse, the Registrar?s Office will submit a copy of those monthly reports to the Office of Financial Aid. Anticipated Date of Completion: September 30, 2023 Contact: K. Michael Francois Associate Vice President for Student Affairs/Financial Aid kfrancois@alasu.edu 334.229.4826

Finding 2022-001 ? Special Tests and Provisions ? Individual Program Compliance ? Federal Work Study Programs The Office of Student Financial Aid has hired a Federal Work Study Coordinator. The responsibilities of the coordinator are as follows: ? Determine eligibility ? Award the student for the year ? Ensure that the student has a federal work-study contract prior to starting work ? Student and supervisor must sign a work-study responsibility contract ? Student is assigned a work-study job placement ? Student enters their time into TimeClock Plus (TCP) ? Ensures the student time is correct by doing a monthly audit o Audit to ensure that the student doesn?t work more than 20 hours nor that the student works during the class schedule ? Submit information to payroll for processing Anticipated Date of Completion: Corrective action completed as of the date of this report. Contact: K. Michael Francois Associate Vice President for Student Affairs/Financial Aid kfrancois@alasu.edu 334.229.4826

Corrective Action Plan Monday, February 20, 2023 Harrisburg Area Community College respectfully submits the following corrective action plan for the year ended June 30, 2022. The findings from the June 30, 2022 audit report dated February 20, 2023 schedule of findings and questioned cost are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. Agency: U.S. Department of Education Audit Period: July 1, 2021 ? June 30, 2022 Name and Address of independent public accounting firm: Smith Elliott Kearns & Company, LLC, Certified Public Accountants & Consultants 804 Wayne Avenue Chambersburg, Pennsylvania Finding Type: Student Financial Aid Cluster: Significant Deficiency in Internal Control over Compliance and NonCompliance Internal Control Type: (please choose the type per the finding) o Material Weakness(es) ? Significant Deficiencies Audit Finding No.: 2022-003 Federal Program: (per Finding) Student Financial Aid Cluster Compliance Requirement: (per Finding) Activities Allowed or Unallowed and Eligibility Audit Finding Title/Statement of Condition: (copy from audit findings documentation) Significant Deficiency in Internal Controls over Compliance and Noncompliance 34 CFR 668.32-a student is eligible to receive Title IV, HEA (Higher Education Act) program assistance if the student is a regular student enrolled, or accepted for enrollment, in an eligible program at an eligible institution. Auditor Recommendation: (copy from audit findings documentation) We recommend that the College contact the U.S. Department of Education to review the programs in question and determine what additional programmatic changes may be necessary, if any, to ensure the student financial aid program is in compliance with federal regulations. 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). This finding was resolved in April 2022. Below are some of the specific steps the College took (and will continue) to correct the situation. o Identified an approved program and/or degree that aligns with each former pre-program student?s academic goal. Currently enrolled students moved to approved programs and degrees listed on the College?s ECAR. ? It is also important to note that the program(s) do not have a selective separate admissions process. o Removed the pre- or p-coded programs from Banner to ensure this error does not occur in the future relative to auto packaging. o Updated the admissions welcome/acceptance letter to inform new student about the selective/competitive (i.e., Nursing, Dental Assisting, etc.) entry programs and their next steps. o Conducted semesterly tests to ensure no currently enrolled students are coded under ?pre? or ?p-coded? programs. The next test is scheduled for October 2022. o Updated the financial aid policies and procedures manual and checklists. o Provided and will continue to provide professional development opportunities to financial aid employees. Anticipated Completion Date: Done Name(s) and Title(s) of contact person(s) responsible for correction action: Dawn K Mull Director, Financial Accounting & Reporting Harrisburg Area Community College dkmull@hacc.edu

Corrective Action Plan Monday, February 20, 2023 Harrisburg Area Community College respectfully submits the following corrective action plan for the year ended June 30, 2022. The findings from the June 30, 2022 audit report dated February 20, 2023 schedule of findings and questioned cost are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. Agency: (Federal Agency per Finding) U.S. Department of Education Audit Period: July 1, 2021 ? June 30, 2022 Name and Address of independent public accounting firm: Smith Elliott Kearns & Company, LLC, Certified Public Accountants & Consultants 804 Wayne Avenue Chambersburg, Pennsylvania Finding Type: (per Finding) Student Financial Aid Cluster: Significant Deficiency in Internal Control over Compliance and NonCompliance Internal Control Type: (please choose the type per the finding) o Material Weakness(es) ? Significant Deficiencies Audit Finding No.: 2022-004 Federal Program: (per Finding) Student Financial Aid Cluster Compliance Requirement: (per Finding) Reporting Audit Finding Title/Statement of Condition: (copy from audit findings documentation) Significant Deficiency in Internal Control over Compliance and NonCompliance Institutions are required to report enrollment information under the Pell grant and direct loan programs via the National Student Loan Data System (NSLDS). Auditor Recommendation: (copy from audit findings documentation) We recommend that the College contact the student to obtain a copy of their social security card to confirm the name and number to correct this situation. The College should also review its internal procedures to ensure controls are in place to timely identify reporting discrepancies and make corrections as necessary 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). ? The College contacted the student (via email) on Jan. 16, 2023, to verify their information. The student did not respond. ? The College sent a follow up communication on Feb. 13, 2023. ? If the student does not respond by close of business this week (Friday, Feb. 24, 2023), then a member of the Registration and Records unit will contact the student via phone. ? If the student does not respond, a hold will be placed on the student account. The student will not be able to perform any transition until the requirement is met. *The case in question is a unique situation in which the College does not know if the student provided the wrong SSN to HACC or the previous institution, and there is no way that the College would have known that information prior to the reject from the National Student Clearinghouse. At this point the College does not know if the student provided the wrong information to HACC or their prior institution because the student has not responded to the College?s outreach. Moving forward, the College plans to contact students immediately AND place a hold on their accounts (immediately). In most cases, the holds prompt students into action that they would not otherwise take. Anticipated Completion Date: In process Name(s) and Title(s) of contact person(s) responsible for correction action: Dawn K Mull Director, Financial Accounting & Reporting Harrisburg Area Community College dkmull@hacc.edu

Student Financial Assistance - Cluster - Federal Pell Grant Program; Award ID No. P063P210331, 2021 - 2022 Federal Award Year Identifying Number: 2022-005 Audit Finding: The University was required, as a result of the Focused Program Review (OPE ID: 00301200) (FPR) regarding the University?s participation in the ?Pell for Students Who Are Incarcerated? experiment (Second Chance Pell), to complete a full file review (enrollment status, effective dates and reporting dates) of all National Student Loan Data System (NSLDS) enrollment reporting for the 2019-20 and 2020-21 award years and update and correct errors identified. Corrective Actions Taken or Planned: Management concurs with the finding. The Registrar?s Office has performed a review of its policies and procedures and has revised them accordingly to ensure timely, accurate and complete submissions to the NSLDS. The determination of the review was that the enrollment effective status data field required correction in the NSLDS Enrollment History system. Since the restoration of the NSLDS system in November 2022, the Registrar?s Office has been correcting the data.

Student Financial Assistance - Cluster - Federal Pell Grant Program; Award ID No. P063P210331, 2021 - 2022 Federal Award Year Identifying Number: 2022-004 Audit Finding: The University did not have an established policy and procedure to ensure that the University consistently applied the regulations regarding payments of Pell if a student?s program crossed over an award year. Corrective Actions Taken or Planned: Management concurs with the finding. In April 2022 a formal policy and procedures addressing the awarding of the Pell Grant has been established to ensure compliance including staff training.

Student Financial Assistance - Cluster - Federal Pell Grant Program; Award ID No. P063P210331, 2021 - 2022 Federal Award Year Identifying Number: 2022-003 Audit Finding: As part of Schneider Downs testing of the origination records, we noted within a sample of 25 transactions, there were three records that had differences between the Common Origination and Disbursement (COD) data and the University?s data for their verification status codes. Corrective Actions Taken or Planned: Management concurs with the finding. Once management was made aware of the unresolved variances of verification codes, the variances were corrected immediately. Upon discovery in August 2022, the Student Financial Aid Office immediately implemented additional controls and training of staff to ensure that these issues do not reoccur.

Student Financial Assistance - Cluster - Federal Pell Grant Program; Award ID No. P063P210331, 2021 - 2022 Federal Award Year Identifying Number: 2022-002 Audit Finding: As part of the audit for the 2021- 2022 Federal award year, Schneider Downs determined that the University used the same determination for the payment period for those students who had been awarded Pell grants that it had been using in the periods for which the U.S. Department of Education (ED) conducted the Focused Program Review (FPR). In addition to the population of students who are participating the Second Chance Pell program, the University also identified additional students, that when using ED?s interpretation of the Code of Federal Regulations (CFR), the University used a payment period that did not reflect enrollment in a nonstandard instructional term program. Corrective Actions Taken or Planned: Management does not concur with the criteria of this finding due to a disagreement with the interpretation of the regulations included in ED?s Final Program Review Determination (FPRD) and has appealed the finding as stated in the following paragraphs. Management followed the direction received from the ED Reviewers during the FPR exit interview on September 24, 2021, stating the University should not change its practice for the Second Chance Pell students enrolled in their respective instructional program nor the calculation using Formula 1 for the payment period until the Program Review Report (PRR) is received. The PRR was received on January 3, 2022, which was after the summer and fall 2021 semesters and just weeks prior to the start of the spring 2022 semester. Moreover, pursuant to the Higher Education Act ?498A(b), the University was entitled to an opportunity to review the PRR and within 60 days of receipt, submit a response for ED?s review prior to their preparing a final determination. The University submitted its response to the PRR on March 11, 2022. The University disagrees with the determinations in the FPRD and is vigorously defending itself against the ED interpretation of the regulations, the findings and the proposed financial assessments. The University filed an appeal of the findings and the associated financial assessments contained in the FPRD on October 24, 2022, and submitted a brief in support of the appeal on January 22, 2023, to the ED Office of Hearings and Appeals within the guidelines as prescribed by the Higher Education Act ? 487(b)(2) and U.S.C. ? 1094(b)(2). Effective with the fall 2022 semester term and each fall and spring terms thereafter, the Second Chance Pell students enrolled in their respective instructional programs have a fifteen (15) week standard instructional term and the payment period qualifies for calculations utilizing Pell Formula 1.

Responsible Individual(s): Ron Anderson, Associate VP of Student Financial Services Finding 2022-002 Federal Agency Name: Department of Education Program Name: Student Financial Aid Cluster CFDA No.: Various Finding Summary: 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 and must return the amount of Title IV funds for which it is responsible as soon as possible but no later than 45 days after the date of the institution's determination that the student withdrew. During 2022, three students that withdrew during the period of enrollment required a refund of funds. These returns of Title IV funds were not made within the 45 day period required. Corrective Action Plan (CAP): The University will partner with the Registrar?s Office to determine students who have withdrawn from Lipscomb and need to have Federal Title IV funds returned. These returns will be tracked in a spreadsheet, calculated within the Student Information System, and returned through Common Origination and Disbursement within the regulated 45 days. Anticipated Completion Date: The procedures will be implemented for the 2022-2023 Financial Aid Year. Responsible Parties: The Return to Title IV process will be done by staff in the Financial Aid Office as assigned by the Director and monitored by the Associate VP of Student Financial Services.

Responsible Individual(s): Ron Anderson, Associate VP of Student Financial Services Finding 2022-001 Federal Agency Name: Department of Education Program Name: Student Financial Aid Cluster CFDA No.: Various Finding Summary: In accordance with 34 CFR Sections 685.102(b), 685.301, and 303, each month, the Common Origination and Disbursement system provides institutions with a School Account Statement (SAS) data file which consists of a Cash Summary, Cash Detail, and (optional at the request of the institution) Loan Detail records. The institution is required to reconcile these files to the institution's financial records. Since up to three Direct Loan program years may be open at any given time, institutions may receive three SAS data files each month. During fiscal year 2022, only three of the twelve monthly reconciliations were completed due to a system conversion and turnover in the financial aid department. Corrective Action Plan (CAP): The University will implement procedures to reconcile the Common Origination and Disbursement system to the University?s financial records for Direct Loans monthly. This task will be completed in the Financial Aid Office as assigned by the Director of Financial Aid and monitored by the Associate VP for Student Financial Services. Reconciliations will be completed for each month with disbursements, staring with the 2022-2023 Financial Aid Year. Anticipated Completion Date: The procedures will be implemented for the 2022-2023 Financial Aid Year. Responsible Parties: The monthly reconciliation will be done by staff in the Financial Aid Office as assigned by the Director and monitored by the Associate VP of Student Financial Services.

Aggregate Loan Limits Planned Corrective Action: I) We will ensure our automated process for verifying Direct Loan eligibility is functioning properly in Powerfaids (financial aid software). We will ensure that we are capturing all aggregate loan limits and are verified when a student is clo e to or at their aggregate limits. In addition, we will review our automated processing when FAFSAs come into the financial aid department to identify the correct people who need to be reviewed. 2) Counselor will go in and reviews NSLDS information and verifies loan eligibility and corrects if needed. 3) Counselor determines proper loan amount and adjusts the loan limit if student is eligible for funding Person Responsible for Corrective Action Plan: Dr. Anthony Turner, Vice President of Enrollment and Marketing Anticipated Date of Completion: 12/17/2022

Finding Number: 2022-007 Condition: The Seminary did not maintain appropriate documentation to substantiate the allowable charges on the students ledger account to identity whether credit balances were created and required additional documentation from the student to hold the credit balance. Planned Corrective Action: The Seminary will no longer be holding any credit balances for students. Any Title IV aid that is disbursed for 23-24 and creates a credit balance will be refunded to the student within 14 days of disbursement. Contact person responsible for corrective action: Vu Huynh Anticipated Completion Date: 07/31/2023

Finding Number: 2022-003 Condition: Of the 16 students who received disbursements selected for testing, the Seminary did not notify 11 students or parents, as applicable, that received direct federal loans within the required 30 days. Planned Corrective Action: Financial Aid Director has already set up a disbursement notification email to be sent out of the new financial aid management system (JFA). Shortly after Title IV disbursements are made, the Director will send out the disbursement notification to any group of students who have had aid disbursed. Each time a disbursement is made, these notifications will be sent to the necessary students. These notifications will be documented in each students? records. Contact person responsible for corrective action: Ashley Schreiner Anticipated Completion Date: 07/31/2024 (to be completed throughout 23-24 academic year)

Finding Number: 2022-005 Condition: The Seminary was unable to support that required records were retained for outstanding Perkins loans. Planned Corrective Action: Garrett has finalized the closeout of the Perkins Loan program (except for the audit final step, which is to be conducted as part of the 2022 audit. The Seminary has purchased the loans that were not accepted by the Department of Education. Contact person responsible for corrective action: Ashley Schreiner Anticipated Completion Date: 08/25/2023

Finding Number: 2022-008 Condition: The Seminary did not have the appropriate procedures and controls in place to file an accurate and timely Fiscal Operations Report and Application to Participate ("FISAP"). Planned Corrective Action: Financial Aid Director plans to have the FISAP completed and submitted by the required deadline of September 29th, 2023. The Seminary will implement an independent second review of the FISAP, where the supporting records will be included. Contact person responsible for corrective action: Ashley Schreiner Anticipated Completion Date: 09/29/2023

Finding Number: 2022-006 Condition: The Seminary did not have controls in place to identify and document the students who have withdrawn and the applicability of performing a return of Title IV funds. Planned Corrective Action: Financial Aid Director has created a spreadsheet to document detailed student information for withdrawals to include withdrawal date, whether federal funds were received, date R2T4 was calculated, if/how much unearned aid was returned, date processed, and any helpful notes for each student. Registrar will continue to email Financial Aid with any withdrawal details. Contact person responsible for corrective action: Ashley Schreiner Anticipated Completion Date: 07/31/2024 (to be completed throughout 23-24 academic year)

FINDING 2022-002 ? Special Tests and Provisions ? Borrower Data Transmission and Reconciliation: Condition/context: The University did not have effective internal control in place that would provide reasonable assurance that the University complied with federal regulations, and the University did not complete reconciliations for all of 2022 except March 2022. Cause: Management did not have an established policy and procedure for borrower data transmission and reconciliation. Further, the process was not completed in the noted months due to turnover in the position responsible for performing the monthly reconciliation. Corrective Action Plan: Due to significant turnover in the Financial Aid Office, management has outsourced its financial aid function to a third party. This partnership will ensure monthly loan reconciliations are performed on time and approved by the CFO. Responsible person: Sarah Stooksberry / Cindy Farrington Planned completion date: Completed as of the date of this letter.

FINDING 2022-004 ? Special Tests and Provisions ? Enrollment Reporting: Significant Deficiency in Internal Control Over Compliance Condition/context: An exception was noted whereby the status change of 1 graduated student selected for testing was not reported to the NSLDS. Cause: Due to turnover in the position responsible for performing the manual reporting process reporting was completed when the responsibility was assigned to a new employee. Corrective Action Plan: Due to significant turnover in the Financial Aid Office, management has outsourced its financial aid function to a third party. This partnership enables us to improve our attention to detail and increase our internal controls over compliance matters. Responsible person: Sarah Stooksberry / Cindy Farrington Planned completion date: Completed as of the date of this letter.

FINDING 2022-003 ? Special Tests and Provisions ? Disbursements: Significant Deficiency in Internal Control Over Compliance Condition/context: For one undergraduate student selected, federal student aid was disbursed, creating a credit balance that should have been refunded to the student within the 14-day requirement. Cause: Due to turnover in the position responsible for monitoring credit balances and disbursement date compliance requirements, individuals performing the responsibility could not perform the task according to the required timeframes. - Corrective Action Plan: Due to significant turnover in the Financial Aid Office, management has outsourced its financial aid function to a third party. This partnership enables us to improve our attention to detail and increase our internal controls over compliance matters. It also enables the financial aid function to communicate effectively with the accounting office and ensure disbursements and refunds are processed timely and in accordance with the Department of Education rules and regulations. Responsible person: Sarah Stooksberry / Cindy Farrington Planned completion date: Completed as of the date of this letter.

FINDING 2022-001 ? Eligibility: Significant Deficiency in Internal Control Over Compliance Condition/context ? The University did not have effective internal control in place to ensure ISIR flags had been cleared. Cause ? Individuals responsible for awarding and packaging students were unaware of the requirement to clear ISIR flags. Corrective Action Plan: Due to significant turnover in the Financial Aid Office, management has outsourced its financial aid function to a third party. This partnership enables us to improve our attention to detail and increase our internal controls over compliance matters. Responsible person: Sarah Stooksberry / Cindy Farrington Planned completion date: Completed as of the date of this letter.

Cluster name: Student Financial Assistance Cluster Assistance Listings numbers and names: 84.007 Federal Supplemental Educational Opportunity Grants 84.033 Federal Work Study Program 84.063 Federal Pell Grant Program 84.268 Federal Direct Student Loans Chris Wodka Anticipated completion date: June 30, 2023 The District agrees with the finding. The District worked with the SIS Vendor to improve the accuracy of Enrollment Reporting out of the SIS. Initial reviews of the reporting have been positive, however close monitoring will continue to ensure proper compliance.

Cluster name: Student Financial Assistance Cluster Assistance Listings numbers and names: 84.007 Federal Supplemental Educational Opportunity Grants 84.033 Federal Work-Study Program 84.063 Federal Pell Grant Program 84.268 Federal Direct Student Loans Chris Wodka Anticipated completion date: June 30, 2023 The District agrees with the finding. After reviewing the student in the finding, the District re-processed the Return of Title IV calculation. The one student record was updated and resulted in an amount of $275 to be returned to the student by offsetting their current balance with the District. The District will fund the reimbursement with institutional funds. During the fiscal year ending June 30, 2023, the District continued to enhance the monitoring of refunds processed. The District plans to begin exploring the use of the SIS to calculate Return to Title IV based on compliance requirements. The District will continue to strengthen our policies and procedures surrounding Return to Title IV compliance requirements.