Corrective Action Plans

Financial Statements Management?s Response and Planned Corrective Action: On identification of the issue, management confirmed that August 22, 2022 was the only date for which the notifications were not sent out properly. This issue resulted from a lack of sufficient staff and significant turnover around August 2022. Management promptly updated procedures and training to clarify to accounts payable personnel the correct parameters for the Direct Loan notifications and are working to put in place additional review controls. No further action related to the August 22, 2022 disbursements was considered necessary as students who received these disbursements would have received subsequent disbursements in which proper notification was sent. Corrective Action Plan Pages Finding Number: 2022-002 Federal Assistance Listing Number: 84.268 Federal Direct Loans Year Ended: August 31, 2022 Responsible Individual: Joanne Hammond Associate Comptroller Management?s Response and Corrective Action Plan: The College agrees with the finding and recommendation. There were no notifications sent out for direct loan disbursements on August 22, 2022. The College verified that this was the only day affected by reviewing each disbursement date related to the fiscal year 2022 and verifying inputs into the notifications were done correctly. The error was corrected the next day and notifications were appropriately sent since August 23, 2022. A list of all students who received Direct Loans on August 22, 2022 was obtained and reviewed, noting that this affected 909 students. Management promptly updated procedures and training to clarify to accounts payable personnel the correct parameters for the Direct Loan notifications and are working to put in place additional review controls. No further action related to the August 22, 2022 disbursements was considered necessary as students who received these disbursements would have received subsequent disbursements in which proper notification was sent. The above procedures have already been implemented.

Management?s Views and Corrective Action Plan 2022-001 ? Loan Disbursement Notifications Award Information Cluster: Student Financial Assistance Grantor: Department of Education Award Name: Federal Direct Student Loans Award Year: July 1, 2021 ? June 30, 2022 AL Number: 84.268 The University of Massachusetts acknowledges that some students did not receive their notifications informing them of the 30 day right-to-cancel for their Federal Direct Loans within the prescribed timeframe of no later than 30 days before, but no later than 7 days after the date of disbursement. The University has implemented an automated communication process with built in internal reviews that will ensure all borrowers are notified within the required timeframe. For further details regarding the corrective action plan, contact the Assistant Vice President and University Controller, Patrick Hitchcock, at phitchcock@umassp.edu.

Responsible Contact Person(s): Ida Witherspoon, Chief Financial Officer Corrective Action Planned: Send periodic e-mail reminders to program staff responsible for submitting FFATA data to the Federal Reporting Unit for submission to the federal government. Estimated Completion Date: 12/31/2023

The Business Director will establish Google Calendar reminders for upcoming due dates for expenditure reports. See full Corrective Action Plan on district letterhead.

Corrective Action Plan For the Year Ended May 31, 2022 Finding 2022-001 Assistance listing number(s), federal agency, and program name: 84.063, 84.007, 84.033, and 84.268; United States Department of Education (DOE), Student financial aid cluster. Finding type: Noncompliance and significant deficiency in internal control over compliance Statement of condition: Certain student records within the National Student Loan Data System (NSLDS) were identified with inaccurate data elements. Management's review of the enrollment reporting did not detect errors on certain student data elements. Context: Five students were identified with inaccurate data elements reported out of a total of 40 students tested. Cause: The preparer incorrectly input the student's status into NSLDS resulting in inaccuracies in significant Campus-Level and Program-Level enrollment data elements that ED considers high risk. The Institute?s internal control over compliance did not detect and correct the error. Effect: The Institute incorrectly reported certain Campus-Level and Program-Level records in NSLDS which is information that DOE considers high risk and the Institute?s internal controls over compliance did not detect and correct the errors. Recommendation: We recommend management review policies and procedures surrounding enrollment reporting submissions to ensure the accuracy of data elements reported to DOE. A review performed by an appropriate individual separate from the preparer prior to the submission of the enrollment reports to NSLDS may improve the accuracy of enrollment reporting. Status completed Corrective Action Management agrees with the finding. Through internal investigation, it was determined that the issue arose through National Student Clearinghouse (NSC), which reports the Institute?s data to NSLDS. Management will work with NSC to assure graduates are accurately reported as soon as possible within existing external systems. The changes to management?s enrollment reporting procedures will be added to the Institute?s NSC submissions procedure documentation. Contact Jean Weimer Registrar 414-847-3272 jeanweimer@miad.edu submitted 2/23/2023

2022-001 Student Financial Aid Cluster - Assistance Listing No. 84.268 Recommendation: We recommend the College reviews outstanding checks regularly to ensure funds are returned to the Department of Education before 240 days of the original disbursement attempt. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: MCC will implement a process to review outstanding checks on a timely basis which will allow time to contact student and reissue payment. If student can not be found, funds will be returned to the Department of Education either through COD or direct payment prior to the required 240 days. Name(s) of the contact person(s) responsible for corrective action: Lewis Hendrickson Planned completion date for corrective action plan: Prior to Fall 2023

FINDING 2022-004? COD Disbursement Dates Program Name: TEACH Grant Federal Pell Grant Program ALN and Program Expenditures: 84.379 ($9,410) 84.063 ($684,817) Award Number: P379T223315 P063P213315 Federal Award Year: July 1, 2021 to June 30, 2022 Questioned Costs: $-0- Condition Found: The Common Origination and Disbursement System (?COD?) disbursement date did not agree with the disbursement date on accounts for two of the three students receiving TEACH Grants and two of the thirty students receiving Federal Pell Grant funds in our sample. A total of four students were affected by this finding. Corrective Action Plan: The Student Financial Aid Director created a ticket with the third party administrator to have them correct the disbursement dates for the students in question in COD in November 2022. The corrections were made in December 2022. Going forward, the Student Financial Aid Director will verify the disbursement dates agree when the payments are made. Anticipated Completion Date: The corrective action was completed in December 2022. Contact Person: Cliff Bristow, Director of Financial Aid 405-912-9037

FINDING 2022-005 ? NSLDS Reporting Program Name: Federal Direct Student Loan Program ALN and Program Expenditures: 84.268 ($1,119,033) Award Number: P268K223315 Federal Award Year: July 1, 2021 to June 30, 2022 Questioned Costs: $-0- Condition Found: The incorrect enrollment status was reported to the National Student Loan Database System (?NSLDS?) for nine of the forty students selected for testing. Corrective Action Plan: Management agrees with this finding The Student Financial Aid Director corrected the enrollment status and withdrawal date for the students in question in November 2022. Procedures have been improved to ensure the information is communicated timely to the third-party servicer and that third-party servicer reports the changes to NSLDS timely. Anticipated Completion Date: The corrective action was completed in November 2022. Contact Person: Cliff Bristow, Director of Financial Aid 405-912-9037

FINDING 2022-002 ? Exit Interview Program Name: Federal Direct Student Loan Program TEACH Grant ALN and Program Expenditures: 84.268 ($1,119,033) 84.379 ($9,410) Award Number: P268K223315 P379T223315 Federal Award Year: July 1, 2021 to June 30, 2022 Questioned Costs: $-0- Condition Found: Nine of the forty federal student financial aid recipients in our sample did not complete or were not sent exit interview instructions to complete. Corrective Action Plan: Exit interview instructions were sent to the students in question in October and November 2022. Procedures have been improved to ensure an exit interview is completed when a student withdraws from the University. The process implemented is that a spreadsheet has been created that compares the enrolled credit hours for each student for the Fall -vs- Spring semester of the current Academic Year and the Spring -vs- Fall semester of the next Academic Year. This spreadsheet will identify which students should be receiving exit interview notifications, as well as, any student who needs to have NSLDS enrollment status updated. Anticipated Completion Date: The corrective action was completed in November 2022. Contact Person: Cliff Bristow, Director of Financial Aid 405-912-9037

Audit Finding Number: 2022-001-Enrollment Reporting: Management concurs with the finding. As noted by the auditors, a corrective action plan was established to ensure that timely enrollment data be coordinated between the Registrar's Office and the Financial Aid Office. This plan was developed in August 2022 along with additional corrective actions efforts to ensure that admission and financial aid data was internally audited prior to enrolling a student. As the audit was conducted, it was evident that the corrective action could not be examined for effectiveness and accuracy as the students examined were from periods prior to the implementation of the corrective action plan and then, as noted by the auditors, the government's NSLDS was not working from July 2022-February 2023, so records could not be shared. The corrective action plan was implemented when the HSLDS because available to submit reports in February 2023. Additionally, the Helms College Registrar, Director of Education and Compliance and Financial Aid Manager will complete free enrollment reporting training courses offered by the National Student Clearinghouse, and continue to submit the enrollment status reports to the National Student Clearinghouse according to the required reporting schedule. Luke Schultheis, Executive Vice President of Education 6/13/23

Incorrect Pell Calculations Planned Corrective Action: The University will establish additional controls over changes in enrollment status after the initial enrollment date and return of Title IV funds, including verification of enrollment status after the third week of initial enrollment and verification of enrollment status upon return of Title IV funds. Person Responsible for Corrective Action Plan: Roberta Martinez, Manager of Student Financial Services Anticipated Date of Completion: February 2023

Corrective Action Plan Responsible Official: Iman Riddick, Registrar and T.J. Snowden, Director of Financial Aid Anticipated Completion Date: Dec 15, 2022 Finding 2022-001: Enrollment Reporting and Documentation of Controls Views of Responsible Officials and Planned Corrective Action: Management agrees with the recommended corrective action for which the Institute immediately began to remediate. This relates to the National Student Loan Data System (NSLDS) site modernization resulting in NSLDS functionality/operational pauses that included the data flow from National Student Clearinghouse (NSC) to NSLDS. This issue has been resolved. The Institute has established a procedure to ensure this does not happen again. It should also be noted that as of December 2022, the Director of Financial Aid and Registrar have implemented procedures and controls to ensure that all required reporting to the NSLDS is performed accurately and in a timely manner. Each month?s enrollment data submission to National Student Clearinghouse by the Registrar will be reviewed by the Director of Financial Aid to verify the consistency of the data in NSLDS; The Director of Admissions and the Registrar will review submission of the 10 business days after the original submission and on the 14th of each month prior to the submission of the next batch of enrollment data to the National Student Clearinghouse. This will allow IWP to correct any inaccurate reporting and verify timely submissions to both systems, providing a preventive control in addition to the resolution of the NSLDS functionality pause.

Name of Responsible Individual: Melanie Mason, Director of Student Financial Aid Corrective Action: The University will transition from a manual review process to an automated electronic process utilizing a combination of both Informer and Colleague reports. The process will identify student loan distributions which exclude the appropriate communication code. Additionally, responsibility for all loan correspondence has been moved to the loan coordinator position to ensure completion. Anticipated Completion Date: March 31, 2023

Name of Responsible Individual: Melanie Mason, Director of Student Financial Aid Corrective Action: The University has implemented this Student Self Service component of Colleague. Beginning in academic year 2022-2023, this system was used by students for acceptance of all loan awards and distributions. Acceptance of the awards will be automatically captured by the system. The Associate Director of Financial aid will run weekly Informer and Blackboard system reports to confirm student withdrawal dates. The Associate Director will then calculate based on the withdraw date to ensure an accurate return of funds calculation. The Director of Financial Aid will verify all return of funds calculations performed by the Associate Director within the required time period. Anticipated Completion Date: July 1, 2022

Name of Responsible Individual: Melanie Mason, Director of Student Financial Aid Corrective Action: The University will transition from an entirely manual verification process to a hybrid automated electronic process utilizing a combination of both Informer and Colleague reports. These reports will focus on certain aspects of ISIR information such as Adjusted Gross Income and Taxes paid. Communication management rules will be validated by the Enrollment Management office. Anticipated Completion Date: March 31, 2023

December 1, 2022 U.S. Department of Education 400 Maryland Avenue SW Washington, DC 20202 Re: Corrective Action Plan Pacific School of Religion (PSR) respectfully submits the following corrective action plan for the year ended June 30, 2022. Audit period: July 01, 2021 through June 30, 2022 The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. Finding 2022-001 Enrollment Reporting Criteria: Title IV regulations (34 CFR 685.309(b)) require that upon receipt of an enrollment report from the Secretary, institutions must update all information included in the report and return the report to the Secretary: (i) in the manner and format prescribed by the Secretary: and (ii) within the timeframe prescribed by the Secretary. Unless it expects to submit its next updated enrollment report to the Secretary within the next 60 days, an institution must notify the Secretary within 30 days after the date the institution discovers that: (i) a loan under Title IV of the Act was made to or on behalf of a student who was enrolled or accepted for enrollment at the institution, and the student has ceased to be enrolled on at least a half-time basis or failed to enroll on at least half-time basis for the period for which the loan was intended; or (ii) a student who is enrolled at the institution and who received a loan under Title IV of the Act has changed his or her permanent address. Recommendation: The School should revise its procedures to ensure accurate enrollment information is sent to NSLDS with the required timeframe for all students. Corrective Action Plan: Procedural changes implemented by the school during the Spring 2022 semester that allow for more frequent and timely enrollment reporting will correct this type of enrollment reporting error going forward. In addition, school administration will update procedures to verify status start dates for any enrollment changes specifically match the student?s enrollment in the student information system. Sincerely, Natasha Lee Vice President for Finance and Administration

The Institute will examine the documented destruction date on other student related files related to federal compliance requirements to ensure accuracy of document destruction date.

Enrollment Reporting Student - Rodriguez Peria, Joan; ID #M00601823; Term 2022-13 Cause The student's Graduated (G) status was not reported to the NSLDS. The student's graduation application was dated December 2, 2021, but was not paid and submitted until February 12, 2022. The student's degree was certified in our Banner system on February 23, 2022. By the certification date, the "Graduate-Only" file transmissions to the Clearinghouse (NSCH) for the 2022-13 term had ceased. Once the file transmission for a term ceases, any cases has to be manually reported at NSLDS. Unfortunately, this case was not reported to NSLDS. Action Once the circumstances of this case were identified, the student's status update to a (G) Graduate in NSLDS has been intended several instances over the past few weeks and is still in process due to problems with the NSLDS modernized website. The Electronic Announcement ID: GENERAL-22-76 reports open issues with the NSLDS modernized website. Corrective Action Plan According to the Graduation Certification Calendar submitted to the registrars, we will develop a monitoring process to identify students certified as graduate past the certification deadline. These students will be referred to the registrars for immediate certification at the NSLDS and to the Management Compliance Office for verification at the NSLDS. Contact persons: Mrs. Patricia Alvarez, Ph. D. Associate Vice President of Academic Affairs Prof. Evelyn Aviles Institutional Director for Academic Affairs and Student Services

R2T4 Late Return Student Jean Morales Cruz; ID #E00542118; Term 2022-10 Cause This is an exceptional case where the student reinstalled the enrollment after a withdrawal process was processed. ? Student enrolled in course CMEM 0291, Section 51806 (EMS Internship) for a total of de 9 credits at the beginning of term 202210. ? On September 7, 2021, the professor indicated that the student had not been attending the course and a total withdrawal was processed, since this was the only course in which student was enrolled for the term. ? The R2T4 calculation was performed and the TIV award cancelled. ? Subsequently, on September 29, the Registrar's office received a certification of the student's attendance to the course and the student's enrollment was reinstalled and the financial aid re awarded. ? Upon finalizing the term, the professor annotated an administrative withdrawal (UW) for the student with the last date of attendance as of October 18, 2021. But the administrative withdrawal was not properly recorded due to previous R2T4 existing record on system and the TIV return not processed on a timely manner. Action Once the circumstances of this case were identified, the R2T4 was reprocessed on June 22, 2022 and the corresponding return of the 50% of the award was completed. Corrective Action Plan The San German campus established a procedure to reinforce the internal communication between the corresponding offices to ensure a proper process for any enrollment reinstalled after an R2T4 process was performed for the same period. 1. The Dean of Academic Affairs receives and signs the student's request for re enrollment in courses. He will submit the request to the Enrollment Manager for the reinstallation process. 2. The Enrollment Manager will evaluate the request and upon approval will run the RWOTIVE- Automatic Registration Reinstatement process. This process will cancel the previous student's withdrawal record, the financial aid adjustment and register the adjustments to the student's account. 3. Once these steps are completed, the Enrollment Manager will notify the Registrar to change the enrollment status in the system and reinstall the courses. 4. Once the Registrar has completed the process, the Bursars Office will validate the total enrollment costs and the Financial Aid Office will be notified for the processing of the financial aid. Also, the Institutional Financial Aid Office designed the report SWOBJAC (Reinstalled Students with Active Total Withdrawal) to identify any student who reinstalled enrollment and an existing R2T4 record is active in our system for the same period. The report will be generated automatically at the end of each week and sent to the Enrollment Manager to identify any pending case. Contact persons: Mrs. Vilma S. Martinez Acting Chancellor San German Campus Mrs. Glenda Diaz Maldonado Institutional Financial Aid Director

FINDING 2022-003? R2T4 Calculation Program Name: Federal Direct Student Loan Program Federal Pell Grant Program Federal Supplemental Educational Opportunity Grant ALN and Program Expenditures: 84.268 ($1,119,033) 84.063 ($684,817) 84.007 ($34,837) Award Number: P268K223315 P063P213315 P007A213421 Federal Award Year: July 1, 2021 to June 30, 2022 Questioned Costs: $26.85 (84.268) $97.40 (84.007) Condition Found: The Title IV funds were not returned timely for two of the forty students in the compliance testing sample. In addition, the R2T4 was not calculated correctly for two of the three students noted above. The incorrect number of days in the semester was used for both students. The remaining R2T4s calculated by the University were reviewed. Two additional R2T4s were not completed timely and one of the additional R2T4s was not calculated correctly. Federal Pell Grant funds returned for not beginning a module course were not excluded from the R2T4 calculation. Corrective Action Plan: Management agrees with this finding. ? For the first student in question, the R2T4 was completed timely, but the incorrect number of days was used in the R2T4 calculation. $26.85 of Federal Direct Loans were returned to the Department of Education in December 2022. ? For the second student in question, the R2T4 was completed and accepted late by the third-party servicer. In addition, the incorrect number of days was used in the R2T4 calculation. An additional $65.59 of Federal Pell Grant funds were disbursed to the student in December 2022. ? For the third student in question, the R2T4 was not completed timely and accepted late by the third-party servicer. The R2T4 was not completed until April 2022 which was more than forty-five days after the date of determination. ? For the fourth student in question, the incorrect Federal Pell Grant disbursed figure was used in the calculation. An additional $97.40 of FSEOG funds were returned in December 2022. In addition, the R2T4 was not calculated within 45 days of the date of determination, so the original funds were returned late. ? For the fifth student in question, the R2T4 was not reviewed and approved by the TPA within 45 days of the date of determination. The correct post-withdrawal disbursement was made in August 2022. Anticipated Completion Date: The corrective action was completed in November 2022. Contact Person: Cliff Bristow, Director of Financial Aid 405-912-9037

3) Finding 2022-003 ? Student Financial Assistance ? Enrollment Reporting Management?s Response: Management understands the importance of ensuring information is reported accurately and timely and the requirement to report to the NSLDS the enrollment status of students who receive federal funds. The College will review its controls and procedures to ensure that not only are status changes reported to the Clearinghouse, but also that the enrollment changes are reported appropriately from the National Student Clearinghouse to NSLDS. Views of Responsible Officials and Corrective Action: We will reassess controls, review these processes and implement controls, including multiple layers of review, to ensure that timely and accurate enrollment reporting is made. Furthermore, the reporting data was appropriately updated subsequent to the required timeframe. Name of Responsible Person: Mattavia Ward, Director of Admissions Implementation Date: Immediately

2) Finding 2022-002 - Student Financial Assistance ? Return of Title IV Funds Management?s Response: Management understands the requirements specific to calculating and returning unearned Title IV aid. Management acknowledges and agrees with the findings as presented. Views of Responsible Officials and Corrective Action: We will reassess controls, review these processes and implement controls to ensure that timely calculations and return of funds are made. Furthermore, the funds noted were sent back subsequent to year end. Name of Responsible Person: Jennifer O'Linger, Director of Financial Aid Implementation Date: Immediately

2022-001 Return to Title IV Recommendation: We recommend that the College review and implement procedures to ensure that withdrawals are properly communicated to all departments and processed timely. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: So that we do not have to rely upon other offices to notify the Financial Aid Office of students not returning, the College has developed a report to detect this condition. We ran the report and no additional students were found to be in this condition. At a minimum, this report will be run on a monthly basis. Name(s) of the contact person(s) responsible for corrective action: William Healy Planned completion date for corrective action plan: July 2022

Ecology Education, Inc. Corrective Action Plan For the Year Ended December 31, 2022 Finding 2022-001 Condition The School has not prepared written policies which could result in potential noncompliance. Corrective Action Taken or Planned Management is currently reviewing the 2022 compliance supplement (2 CFR PART 200, APPENDIX XI) which applies to most federal awards including USDA RD financing. Management understands this supplement is issued annually and can be obtained online. Specific review includes the matrix for federal programs on page 21, and details for ALN 10.766 (USDA Community facilities loans) which begins on page 275. Management has prioritized preparing written policies in direct alignment of the 2022 compliance supplement related to internal control and compliance with federal award requirements. The relevant compliance requirements for TES for 2022 for which policies are being drafted related to the USDA RD Community Facilities Program loan include reporting, reserve account funding, and minimum insurance and bonding coverage, per the agreement with USDA. Specific controls over compliance with these requirements will be documented.

Untimely Returns to Title IV (R2T4) Planned Corrective Action: We have trained and implemented processes to correctly determine period lengths and the earned and unearned percentages. We have increased the number of reports used to identify potential withdrawals. To correctly and timely process R2T4s, we outsourced the determination and calculation processes to a third-party vendor in November 2022 (this took longer than we anticipated). In March 2023, we were granted additional staffing resources and are in the process of hiring for those positions. To reduce the number of R2T4 calculations required, we also plan to switch from being an institution required to take attendance to a non-attendance taking institution for the 2023-2024 aid year. Person Responsible for Corrective Action Plan: Bryan Taylor, Associate Director of Student Financial Services Anticipated Date of Completion: May 2023