Corrective Action Plans

The Department of Human Services (DHS) agrees with the finding in this report. The DCAS System is currently configured to receive the Title II benefit information via the SSA BENDEX periodic data match process. However, the Title II benefit information is shared with DCAS only when the benefit information with the SSA changes. In the scenario where a TANF benefit is certified on a new application, the BENDEX PDM process will not provide the Title II benefit information to DCAS. Hence, we have seen evidence of the data matches not happening up until the point when the benefit information recorded with SSA has changed. The SSA SolQi interface does provide a customer?s Title II and Title XVI benefit information at the time of the initial application, however, this interface in DCAS is configured as a verification interface. In other words, if the customer has reported income from the Social Security Administration, then the DCAS System uses the data match with the SolQi interface to verify the information reported. If a verification is outstanding on the reported benefit from the SSA, and the information received from SolQi matches, then DCAS system is configured to systematically resolve the verification. Hence, there has been evidence of the record received via SolQi, however, the record was not used to update the internal evidence which is used by the eligibility rules. DHCF DCAS teams are tracking system enhancements, logged in internal JIRA tickets ? DSM-3185 and DSM-3186 to enhance DCAS? interface with SolQi to leverage the interface at initial application and during the recertification process to ensure that the DCAS System has the most up to date income information from SSA to determine eligibility. These tickets are currently scoped for the FNS-AWL-CAP-5 releases planned for fiscal year 2024. See Corrective Action Plan for chart/table

The Financial Aid Office and the Registrar's Office will work closely together to resolve the NSLDS reporting discrepancies. We are currently in the process of hiring a Compliance Coordinator that will serve as a bridge between the Financial Aid Office and the Registrar's office that will monitor and audit the reporting process for errors and discrepancies monthly. From here, if there are any discrepancies or inconsistencies, the Financial Aid Office and the Registrar's Office will work together to understand any patterns that exist so that our processes can be reevaluated and tightened to ensure ongoing compliance. Based on the review of information from last year's similar finding (2021), it was determined after the fact that Webster University had both reported the enrollment information correctly and in a timely manner to the Clearinghouse, however, the Clearinghouse frequently reported glitches and outages that prevented reporting to NSLDS in a timely manner. Going forward the Compliance Coordinator will monitor enrollment reporting, as well as the timing of the Clearinghouse's enrollment reporting to NSLDS. If it is determined that enrollment reporting via the Clearinghouse continues to be discrepant, Webster University will explore other methods of reporting that are more conducive to timely and accurate enrolment reporting to NSLDS.

The District concurs with the auditor?s finding. The delay in the report submission is due to unusual circumstances and events during the fiscal year. We will communicate to the appropriate personnel the importance of providing requested documents and responding to auditor inquiries in a timely manner. See Corrective Action Plan for chart/table

2022-002 Eligibility ? Maintain good standing or satisfactory academic progress Contact: Jeffrey C. Straits Title: Chief Financial Officer Phone Number: (202)885-8684 Anticipated Completion Date- Done Corrective Action Wesley Theological Seminary will ensure that students maintain a good standing or satisfactory academic progress in order to be eligible for Federal direct student loans per the OMB Compliance Supplement. Wesley acknowledges that before the outsourcing of our financial aid processing, there was a breakdown in the seminary following policies, procedures, and controls, which allowed this error. The Seminary will review all policies and procedures related to this control and develop ways to strengthen these controls. Wesley will also complete a review of all active federal loans for the fiscal year 2022 to identify if there are further processing errors allowing loans to students without maintaining good standing or satisfactory academic progress to be eligible for Federal direct student loans. Wesley management will also implement quarterly testing of randomly selected student loan transactions. The testing will include the verification of eligibility for aggregate loan totals, good standing, and satisfactory academic progress. The results of this testing will be reviewed by the CFO and maintained by Wesley?s management. Status as of November 2022 Wesley Theological Seminary outsourced our financial aid processing in January 2022. The error found was processed by our internal Financial Aid Director before the outsourcing of financial aid. Wesley has reviewed our policies and procedures related to this issue. We will add to the policies and procedures that the CFO will also approve all appeals approved by the Financial Aid Committee for lack of a student?s adequate satisfactory academic progress. The CFO?s approval will also be maintained with the appeal records of the Financial Aid Committee. We completed the review of all students who received Federal financial aid in the fiscal year 2022. There were no other students with inadequate satisfactory academic progress other than the one previously identified by BDO. Our outsourced financial aid processor will ensure the review of satisfactory academic progress prior to processing a loan, as required in our policies and procedures. To verify ongoing compliance of our outsourced financial aid processor with our financial aid policies, procedures, and controls, we are adding a requirement of quarterly random testing of students? records for the verification of eligibility for aggregate loan totals, good standing, and satisfactory academic progress. Wesley management has completed the fiscal year 2023 first quarter review of random students? transactions, and we did not find any errors. The testing results were reviewed by the CFO and maintained by Wesley?s management.

2022-001 Eligibility ? Aggregate Loan Limits for Subsidized and Unsubsidized Loans Contact: Jeffrey C. Straits Title: Chief Financial Officer Phone Number: (202)885-8684 Anticipated Completion Date- Done Corrective Action Wesley Theological Seminary will ensure that the loans disbursed by the Institution are within the loan limits prescribed in the OMB Compliance Supplement. Wesley acknowledges that before outsourcing our financial aid processing, there was a breakdown in the Seminary following policies, procedures, and controls within financial aid, which allowed these errors. The Seminary will review all policies and procedures related to this control. We will also complete a review of all active federal loans for the fiscal year 2022 to identify if there are further processing errors allowing loans above the aggregate loan limits. Wesley management will also implement quarterly testing of randomly selected student loan transactions. The testing will include the verification of eligibility for aggregate loan totals, good standing, and satisfactory academic progress. The results of this testing will be reviewed by the CFO and maintained by Wesley?s management. Status as of November 2022 Wesley Theological Seminary outsourced our financial aid processing in January 2022. Wesley will ensure the work prepared by outsourced personnel is reviewed properly and such review is documented properly. All of the errors found were processed by our internal Financial Aid Director before the outsourcing of financial aid processing. We completed the review of all students who received Federal financial aid in the fiscal year 2022. There were seven students with awards over the aggregate maximum (including those previously identified by BDO). The total amount awarded over the per-person aggregate limit was $79,159. Our outsourced financial aid processor will ensure the review of total student debt prior to processing a loan, as required in our policies and procedures. Wesley management has reviewed our policies and procedures related to this issue. To verify ongoing compliance of our outsourced financial aid processor with our financial aid policies, procedures, and controls, we are adding a requirement of quarterly random testing of students? records for the verification of eligibility for aggregate loan totals, good standing, and satisfactory academic progress. Wesley management has completed the fiscal year 2023 first quarter review of random students? transactions, and we did not find any errors. The testing results were reviewed by the CFO and maintained by Wesley?s management.

Personnel Responsible for Corrective Action: Daniel Holt, Chief Financial Officer Anticipated Completion Date: June 30, 2023 Corrective Action Plan: The College will properly implement the February 2022 Information Security Plan and maintain effective internal controls, perform risk assessments, establish safeguards and document identified risks. The information technology office and security committee will ensure all activities are performed per institutional policy and generate reports for the institutional compliance committee and CFO for presentation to management.

Identifying Number: 2022-002 Finding: Students were never awarded and disbursed FDL funds and under awarded an disbursed FSEOG funds. Corrective Actions Taken or Planned: Students identified were awarded aid to cover the error on 6/30/22. All student enrollment is checked at the start of the term; however, our modular students are allowed to make schedule changes throughout the semester. A report has been generated to review enrollment changes weekly to properly update any necessary aid changes. Persons Responsible and Completion Date: Mark Freed, Director of Financial Aid, June 30, 2022

2022-001 Federal Work Study - Student Financial Aid Cluster Assistance Listing Number 84.007, 84.033, 84.063, 84.268, Grant Period - Year Ended June 30, 2022 Condition Found During our Federal Work Study testing, we selected eleven students and noted that one student was paid for hours they did not work. The College did not review federal work-study hours worked against class hours scheduled and timesheets to ensure the student was not working during a scheduled class and that they were paid for the correct number of hours. We consider this condition to be an instance of non-compliance to the Activities Allowed or Unallowed compliance requirement. Corrective Action Plan In addition to direct counseling with the supervisor and student workers partied to this practice, the Financial Aid and Human Resources offices implemented several steps to stress the supervisor?s responsibility for timesheet validation. The changes went into effect on August 5, 2022. The steps included: 1. Reviewed the Student Worker Employee Handbook and Student Worker Supervisor Handbooks to confirm that language exists addressing that students should not work during scheduled class time, and supervisors are responsible for reviewing timesheets before approval submission. 2. All Supervisors are now required to review and sign off on the Supervisor Student Worker Handbook annually. Human Resources will audit for compliance quarterly. 3. At the start of each new academic year, Financial Aid and Human Resources will host a ?Hiring a Student Worker Information? session for all supervisors. This year the session took place on September 1, 2022. This session stress timesheet reviews, among many other responsibilities. Responsible Person for Corrective Action Plan Mary Greenwood, Director of Student Financial Aid Services, will be the person responsible for this Corrective Action Plan. Implementation Date of Corrective Action Plan As of August 5, 2022, all phases of the Corrective Action Plan were implemented.

Views of Responsible Officials and Planned Corrective Action The HPU Office of Sponsored Projects (OSP) and Office of Financial Aid work to follow all federal reporting regulations and guidance mandated for the Federal grant & contract programs. For future programs, the Institutional Research, the Office of Sponsored Projects and the Financial Aid Office will generate the reports and will implement layers of review procedure to ensure that the reports are accurate, complete, submitted timely, and if needed, posted in HPU website. For the Institution portion, the Manager for Grants and Contracts will prepare the grant report and this report will be reviewed by the Assistant VP for OSP. For the student portion the periodic reports will be prepared by the staff of the Office of Financial Aid and will be reviewed by the Director of the Financial Aid office. The Business Office will perform a high-level independent review for completeness and accuracy. Finally, moving forward, all the files and documents that support the grant report will be retained. Person Responsible: Manager, for Office of Sponsored Projects & Assistant VP for Office of Sponsored Projects, Director of Financial Aid Targeted Correction Date: June 30, 2023.

Views of Responsible Officials and Planned Corrective Action The HPU Financial Aid Office works hard to follow all federal regulations and guidance mandated for the Title IV Federal Student Aid programs. In regards to the distribution of the Federal HEERF fund to HPU students, the HPU Financial Aid Director relied on reports from the SIS (Banner system), Institutional Research, and Accounts Receivable to determine students eligible for HEERF funds. The HPU Financial Aid Office and Office of Sponsored Projects worked hard, and diligently, to award funds to students and expend Institution portion based on the regulations that were provided at the time and not violating the intent of the program, as evidenced by there not being any non-compliance over allowability of costs charged to Federal HEERF fund. For future awards, the Principal Investigator with the assistance of the Office of Sponsored Projects will review diligently the expenditure to be sure the expenditures are within the allowability and terms and conditions of the federal awards. Both offices will work collaboratively so that the internal controls over allowability are strengthened and that the documentation will be strongly implemented and retained. For future programs, the HPU Financial Aid will work to strategically plan, organize, and disburse funds to students and expend Institution funds within the requirements mandated by the United States Department of Education, including strengthening our internal controls over compliance, and increasing the documentation and maintenance of documentation over our existing internal controls for compliance. Person Responsible: Manager, for Office of Sponsored Projects & Assistant VP for Office of Sponsored Projects, Director of Financial Aid Targeted Correction Date: June 30, 2023.

Contact person(s) responsible for corrective action - Amy Cavelier and Robert Wagstaff, Registrar?s Office Anticipated completion date ? August 31, 2023 Corrective Action The Registrar?s office will ensure proper controls and processes are in place to ensure program-level effective date information is properly and timely submitted to the NSLDS. Timeframe: June through August 2023 Responsible Parties: Amy Cavelier and Robert Wagstaff Goal: Registrar management and staff are working with the College?s Student Information Systems and IT departments to verify when and how the conflicting program-level effective dates were entered. At this point, we believe that the data originating from Jenzabar is correct. Discrepancies were created during the NSC error cleaning process, and data including those discrepancies were reported to the NSC and subsequently the NSLDS. Registrar?s Office management and staff are working with the NSLDS to obtain final student data reports which will be compared to the monthly student data files originally submitted to the NSC, prior to error correction, to identify the discrepancies and the cause of the data errors. The College is transitioning the enrollment reporting responsibility to another member of the Registrar?s Office. This transition will include formal training on the Jenzabar student information system, with a particular focus on NSLDS data reporting, as well as the NSC and NSLDS data submission processes. Our first Jenzabar training sessions have been scheduled for June 30 and July 7, 2023.

Student Financial Assistance Cluster ? Assistance Listing No. Various Recommendation: We recommend the Universities review their reporting procedures to ensure that students? statuses are accurately and timely reported to NSLDS and all errors are corrected within the appropriate timeframe as required by regulations. University of Maine at Fort Kent (UMFK) Condition: During our testing of 40 students, we noted five students at the University of Maine at Fort Kent (UMFK) whose campus enrollment date was not timely reported. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Registrar responsible for reporting campus enrollment during the year under audit left the position on August 15, 2022. The errors noted during the audit have been discussed with both the Interim Registrar and new Registrar to ensure understanding of and compliance with enrollment reporting requirements. In response to this finding, the new Registrar has worked very closely with the National Student Clearinghouse (NSC) to correct and update the required reporting dates through the next several terms. They have confirmed all dates in their calendar. The Director of Financial Aid now also receives reporting email notifications from the NSC as an internal control process for ensuring that reporting is occurring in a timely manner. Name(s) of the contact person(s) responsible for corrective action: Sara Best, Registrar for the University of Maine at Fort Kent Planned completion date for corrective action plan: Completed September 2022 University of Maine at Farmington (UMF) Condition: During our testing of 40 students, we noted for one student at the University of Maine at Farmington (UMF), the enrollment effective date did not match the enrollment effective date per UMF?s records. In addition, for one student, the program enrollment effective date did not match the program enrollment effective date per UMF?s records. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Immediate corrections to the reported dates were made upon notification of the finding. The Assistant Registrar runs the ?Student Clearinghouse File? report in its student system, MaineStreet, that transmits enrollment information to the National Student Clearinghouse (NSC). This reports both the enrollment effective date and the program enrollment effective date. In December 2021 the NSC implemented a new warning code series (1801 ? 1806) that kicks back any inconsistencies with the two dates as reported. To prevent similar errors in the future, a process has been implemented whereby the Assistant Registrar reviews these warnings and makes required corrections. UMF was previously sending a Degree Verify Report, which is a report run in MaineStreet, to the NSC three times a year for May graduates, August graduates and December graduates. We have changed our reporting timeline for graduates and are now sending the Degree Verify Report monthly to pick up any students who get cleared for graduation late. The Assistant Registrar who is responsible for reporting to the NSC is participating in the regular webinars provided by the NSC, to address reporting issues. Person responsible for corrective action: Lisa Beane, Assistant Registrar for the University of Maine at Farmington Planned completion date for corrective action plan: Completed July 25, 2022 University of Maine at Presque Isle (UMPI) Condition: During our testing of 40 students, we noted for two students at the University of Maine at Presque Isle (UMPI), the program enrollment effective date did not match the program enrollment effective date per the University?s records. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Registrar responsible for reporting campus enrollment during the year under audit left the position in July 2022. The errors noted during the audit have been discussed with both the Interim Registrar and new Registrar to ensure understanding of and compliance with reporting requirements. The new Registrar has updated policies and procedures regarding the reporting process and all reporting dates are confirmed in their calendar. The Director of Financial Aid now also receives reporting email notifications from the National Student Clearinghouse (NSC) as an internal control process for ensuring that reporting is occurring in a timely manner. In addition, the student records team at UMPI have received additional guidance and training from the NSC. Name(s) of the contact person(s) responsible for corrective action: Lisa Smith, Registrar for the University of Maine at Presque Isle Planned completion date for corrective action plan: Completed August 2022

Student Financial Assistance Cluster ? Assistance Listing No. Various Recommendation: We recommend the University evaluate its procedures and policies around reporting disbursements to COD to ensure that student information is reported accurately and timely. University of Maine at Presque Isle (UMPI) Condition: During our testing at the University of Maine at Presque Isle, we noted one Pell disbursement that was not reported within the required 15 days and two Pell disbursements where the disbursement date per COD did not match the disbursement date per the student?s account. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Following the May 2022 retirement of the staff member responsible for this task, we implemented a weekly process to ensure timely reporting to COD, as well as timely resolutions to any issues encountered in sending these files. We also trained additional personnel to send these files and identify/resolve issues in the files and to have a documented internal control process to track the sending, receipt and error resolution process of COD files. Name(s) of the contact person(s) responsible for corrective action: Connie Smith, Director of Financial Aid for the University of Maine at Presque Isle Planned completion date for corrective action plan: July 1, 2022 - We implemented the new weekly process as described above to ensure files are sent and issues are resolved in a timely manner. March 1, 2023 - All staff responsible for this new process have been trained to send and review these files.

Upon discovery of the over award, funds were returned for the student immediately. Moving forward, the Financial Aid team will implement a review process at the beginning of each term that will identify students nearing aggregate loan limits to ensure students are not over awarded.

Both the Financial Aid team and Student Accounts team have developed a weekly disbursement and posting schedule. A cut off time for processing will be implemented to ensure both dates are aligned and to accommodate any file response import delays.

We recommend the University review its reporting procedures to ensure that roster file submissions are reported timely to NSLDS as required by regulations.

The University contracted with National Student Clearinghouse (NSC). In the prior year, we identified a data exchange issue between our institution and NSC. We have now resolved that issue.

Springfield College June 30, 2022 Finding 2022-001 Fiscal Operations Report and Application to Participate Corrective Action Planned The Corrective Action Plan (CAP) has three components. First, the Director of Financial Aid will conduct additional training with the staff from the processing unit. The training will review the field in the financial aid management system that must be updated and the importance to the FISAP. This training is scheduled for the week of November 14, 2022. Second, we implemented a work-flow task in our financial aid management system to notify the financial aid counselor to review the academic grade level flag for each term the student is enrolled. This component was implemented on November 3, 2022. Third, prior to submission of the FISAP the Director will develop a report to detect academic grade level inaccuracies. The anticipated completion date for this component is September 2023. Person Responsible for Corrective Action Plan Troy A. W. Davis Anticipated Completion Date September 2023

Condition: There was lack of documentation related to disbursement notices and exit counseling for nine out of thirty-four students tested. Criteria: According to ?668.165, before an institution disburses title IV, HEA program funds for any award year, the institution must notify a student of the amount of funds that the student or his or her parent can expect to receive under each title IV, HEA program, and how and when those funds will be disbursed. Additionally, according to ?682.604, a school must ensure that exit counseling is conducted with each loan borrower and graduate either in person, by audiovisual presentation, or by interactive electronic means. Cause: The College was unable to locate the documents for the students as a result of transitioning softwares. Effect: Certain documentation for disbursement notices and exit counseling was lost during the transition of the College's software. Context: During the compliance audit testing of ALN 84.268 and ALN 84.379, it was determined that documenation to confirm delivery of disbursement notices and performance of exit counseling could not be provided for certain students selected for testing. Recommendation: We recommend all required documentation be backed up to support compliance with certain requirements. View of Responsible Officials and Planned Corrective Action: The College is currently working with their IT department to make sure that all types of communication includes copying the financial aid department email to make sure the College has support for all communications to prevent this in the future.

Finding 2022-003: Policies and Procedures Related to Packaging Student Financial Aid ? SFA Cluster (significant deficiency) Corrective Action: Lyon College has two employees in the Financial Aid office. We do have a process in place to review the packaging of new student aid (FTFT and TXFR), though it is very manual, and requires both FA employees to be involved (in order to separate duties). It is still not foolproof. Our current software will not prevent us from overpackaging subsidized loans in our manual packaging process, but we can run a report to check and see if the field marked `Awards to Report as Need-Based? is greater than the field marked `Original Need?. If any are found, we can make the necessary adjustment. In the packaging of returning students ? the larger group of students - we do not have a review process in place. We will review to see if we can find a practical way, with our current limited personnel, to implement a review process for returning student award packages. The overpackaged student was simply a human keystroke error. Sub (remaining need) was calculated to be $4,484 and we input $4,884, a transposition. This was a returning student who likely did not get reviewed, and we also failed to pick it up in the process described below, comparing original need to awards marked as need. Our current software will not prevent us from overpackaging subsidized loans in our manual packaging process, but we can run a report to check and see if the field marked `Awards to Report as Need-Based? is greater than the field marked `Original Need?. If any are found, we can make the necessary adjustment. The other student was underpackaged with subsidized loans. In this case, the student was packaged on 7/15 based off of the only FAFSA we had available at that time, received on 6/29. On that FAFSA, the student had an EFC of $28,180, and no need. Therefore, all loans ($7,500) were packaged as unsubsidized. A PLUS loan denial came in the next day and the additional $5,000 was also packaged as unsubsidized. On 8/4, a revised FAFSA came in showing an EFC of $5,119. No adjustment was made to reclassify part of the loans as subsidized based on the `need? shown on the revised FAFSA. The Financial Aid Office believes that running the comparison report mentioned above on a regular basis will help us to find over-packaged need-based loans that we either made a mistake on during our initial packaging process, or due to a revised FAFSA that created additional need. Proposed Completion Date: The FAO will begin running the `Original Need vs. Aid Packaged As Need? Report on a monthly basis, and most importantly, in August immediately before aid is originated and disbursed.

Finding 2022-002: Policies and Procedures Related to Withdrawals ? SFA Cluster (significant deficiency) Corrective Action: The ?Timely Reporting? issue resulted from a misunderstanding in the Registrar?s Office regarding the requirements of what had to be reported and by when. We have discussed this issue with that office?s personnel and established procedures designed to prevent it from happening in the future. The ?Funds Not Returned Timely? reflects continued improvements resulting from policies already established to enhance compliance with attendance reporting and tracking of those reports by the Registrar and Financial Aid Offices. The College will continue to reinforce compliance with the attendance monitoring and reporting policy, as well as refine procedures for active monitoring of those reports by these two offices. In particular, the process of evaluating whether students who are on the two-week absence report in any one class are in fact at risk of falling out of enrollment status overall. Proposed Completion Date: June 30, 2023

October 14, 2022 U.S. Department of Education 400 Maryland Avenue, SW Washington, D.C. 20202 Re: Corrective Action Plan Finding 2022-001: Federal Direct Student Loan Enrollment Reporting Program: Federal Direct Loan Programs Assistance Listing Number (ALN): 84.268 Federal Agency: U.S. Department of Education Federal Award Identification Number: P268K22059 Federal Award Year: June 30, 2022 Condition: For 3 of 25 students included in our sample, the enrollment status of withdrawn were reported late (61 days after the determination date of separation). The sample was not a statistically valid sample. Corrective Action Plan Management agrees with the finding, and is committed to strengthening its procedures to avoid similar issues in the future. Beginning in September 2022, a second Registrar?s Office staff member will complete an additional review of the National Student Clearinghouse status for all students withdrawing after a particular semester. This secondary review will be completed at the end of January and at the end of June in order to ensure the 60 day reporting period is met. Nathan Engle Controller

2022-001: Reporting Management?s view and corrective action plan Management concurs that FISAP for the Federal Perkins Loan program contained incorrect amounts for ?Cash on hand and in depository? as of 6/30/22 and 10/31/22. The misstatements were due to clerical errors and insufficient review prior to submission. Management will implement an enhanced review process to validate all amounts reported on the FISAP prior to submission. Implementation date: July 2023 Ronald Keller Vice President for Finance & Controller

2022-003: Enrollment Reporting Management?s view and corrective action plan Management concurs with the findings regarding the delay and insufficient graduation reporting to NSLDS. The University Registrar is aware of the 6-day delinquency in reporting for summer term due to the timing of the degree awards for the May graduates on the East Falls campus. Degree audits will be checked to ensure are awarded in a timely manner. We also will work with NSC to ensure all enrollment reporting schedules are updated in accordance with the academic calendar of the appropriate branch, limiting any issue with the 60-day certification date during our Summer term, as all other terms have been reported correctly. This will happen every semester on a 4?6 week basis, in tandem with enrollment report submissions. This will resolve the 60-day certification issue. Academic Services makes every effort to report clean enrollments accurately and on time. However, we continue to find inconsistencies with the NSC transmissions to NSLDS and are aware of the need for additional oversight of the NSC process as well as the development of a process to audit NSC transmissions to NSLDS. This will also aid in the elimination of reporting errors between NSC and NSLDS, as in the case of the three graduation records. The Office of Academic Services is working to identify resources to address the above action plans. Implementation date: July 2023 Raelynn Cooter Vice Provost for Academic Infrastructure and Effectiveness

Finding 2022-001: Enrollment reporting Condition: For 5 out of 25 students tested for NSLDS reporting, it was noted that these students were not reported within 60 days as required for all schools participating in Title IV aid. Crowe had management perform an independent analysis in order to quantify the total number of students with enrollment reporting issues due to the 5 identified as part of our testing. Through further testing procedures performed and analysis performed by management it was noted that a total of 38 students were not reported timely to the NSLDS. Recommendation: We recommend that the University enhance its review and monitoring of the enrollment reporting to NSLDS to ascertain accuracy and timeliness of the submission. Views of Responsible Officials Management agrees with the finding related to enrollment reporting. Management has taken steps to change the process, adding review of filings by the Office of the Registrar, Financial aid, and Institutional Research. Additionally, a calendar has been created for future reporting dates of enrollment reports and degree conferral reports to be filed with the National Student Clearinghouse. Corrective Action Plan Management is developing a new process for reporting student enrollments. The Office of Institutional Research will review the specifications for reporting from the National Student Clearinghouse (NSC) and National Student Loan Data System (NSLDS) to ensure that the proper data is being reported. The Office of the Registrar will develop an annual calendar of filing dates for enrollment and graduation reports. Reports will be generated by Institutional Research and upon approval of the Registrar submitted to the NSC. Any errors in reporting will be remediated by the Registrar. And the Financial Aid Office will verify that reports sent to the National Student Clearinghouse are accurately reported to the National Student Loan Data System, by auditing both systems with assistance from the Office of institutional Research and Office of the Registrar. This process will be in place by February 2023.