Corrective Action Plans

2023-002 – Student Financial Aid Cluster – (a) Federal Pell Grant (b) Federal Supplemental Educational Opportunity Grant (c) Federal Work Study Grant (d) Federal Perkins Loan Program (e) Federal Direct Student Loans (f) Teacher education Assistance for College and Higher Education ALN No. (a) 84.063 (b) 84.007 (c) 84.033 (d) 84.038 (e) 84.268 (f) 84.379 – Year Ended June 30, 2023 Condition Found The College did not report graduate status changes within 60 days for ten out of twenty students (50%) tested. We consider this condition to be a material weakness of internal control over compliance relating to the Special Tests and Provisions compliance requirement. Corrective Action Plan The Registrar has updated its process to report the graduate status within 30 days of the end of each semester. Student Financial Services has set up an additional process to follow up with the Registrar at the end of each semester to ensure it has been completed. Responsible Person for Corrective Action Plan Fred Miller – Registrar Jeremy Hurse – Director of Student Financial Services Deborah Beck – Associate Director of Student Financial Services Implementation Date of Corrective Action Plan 10/11/2023

Special Test – Student Financial Aid Cluster Assistance Listing Nos. 84.007, 84.003, 84.063, 84.268 Recommendation: Recommend the design of controls to ensure an adequate documentation of control and review of student records to determine they are appropriately reflecting the proper status. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Moraine Park Technical College’s review of student record confirmed the record had the correct enrollment date in Financial Aid reported. Financial Aid reviewed and determined no Return to Title IV of financial aid was required. The student record in the National Student Loan Data System (NSLDS) was reviewed and updated to the correct enrollment date. The College has meetings planned with our ERP (Enterprise Resource Planning) vendor to determine possibility of automation of this manual process. Name(s) of the contact person(s) responsible for corrective action: Lynn Marquardt, Registrar and Enrollment Services Manager Planned completion date for corrective action plan: June 2024

Recommendation: We recommend the college implement procedures to strictly comply with the requirements of 34 CFR 690.83 and 34 CFR 685.309 as it relates to reporting enrollment information to the Department of Education. We further recommend the College follow the guidance provided in the NSLDS Enrollment Reporting Guide and stay abreast of new guidance as published by the Department of Education. Corrective Action Taken: The College will be taking extra measures to periodically review enrollment batches that are sent to the Clearinghouse, ensuring that they are being updated into NSLDS alongside any error reports that may be coming back from the Clearinghouse. This will help prevent any unknown or missed student enrollment report from the Clearinghouse to NSLDS. Anticipated Completion Date: Fall semester 2023 and ongoing

Lamar State College Orange Response and Corrective Action Plan to FY 23 Federal Financial Aid Audit Finding 2023-001 Enrollment Reporting Views of Responsible Officials The College agrees with the auditor's findings and recommendations. Corrective Action Plan The College has identified three issues that delayed identification and reporting of changes in student enrollment status for reporting on the NSLDS component. In response, the college will implement the following corrective actions: 1.The Registrar will review the error resolution reports provided by National Student Clearinghouse (NSC) to ensure the correct enrollment information is being reported to NSLDS within 60 days of the determination date. Implementation Date Immediate 2.An advisor drop code will be implemented effective Spring 2024. This code will trigger an email to the Records Office, and at that point the Records Office will determine the student's enrollment status and update to withdrawn in Banner when it is determined the student has withdrawn from the semester. This will ensure the correct enrollment status is reported to NSLDS within 60 days of the determination date. Implementation Date 1/16/2024 3. LSCO will ensure a subsequent term report is submitted any time a late award is processed. This will ensure the correct enrollment status is reported to NSLDS within 60 days of the determination date. Implementation Date Immediate Individual Responsible Summer Rather, Registrar

Audit for the 2022-2023 academic year. Enrollment Reporting Finding Compliance Requirement: Special Test and Provisions - Enrollment Reporting Criteria: The College is required to send changes in attendance levels, graduated, withdrew, dropped out, or enrolled changes to the NSLDS within 60 days of the change. Cause: The College had not reported changes for graduated students to the NSLDS as required with the time period to be in compliance with enrollment reporting requirements. Context: Of the nine students selected for testing in the annual audit, the college did not send changes related to four students whose status changed after graduation on May 8th, 2023 to the NSLDS system. Later the status was updated however, was outside of the 60 day requirement. Corrective Action Plan from College: Documentation of Graduation enrollment dates missing. This is submitted to Derrick Everhart, Director of Financial Aid by the College Registrar Brooke Millsaps. Update regarding processing of NSC Grad Only file for May 2023 Warren Wilson College has made multiple efforts to submit a May 2023 Grad Only file to the National Stud Clearinghouse but has been unable to due to our software not recognizing or pulling the files of the students who are documented as May 2023 graduates. We submitted an end-of-term file to the NSC which was certified on June 6, 2023. As of August 17, 2023, we have taken the following steps to try and remedy this: • Applied a script/patch provided by our software company (Jenzabar). This script failed to resolve the issue. • Manually edited all graduating student records for the NSC grad only file report. This manual input of information did not result in our ability to process a grad only file. • Consultation with IT Department and software consultants to determine what we can do to process and report this grad only file. Action Steps: Moving forward, if an enrollment file cannot be uploaded to National Student Clearing House for any reason by the College Registrar within the 60-day requirement, the Registrar will communicate with the Director of Financial Aid. A file with updated enrollment reporting of student records will be created from the Colleges reporting system. Those records will then be manually entered into the NSLDS system by the Director of Financial Aid to main­tain compliance with enrollment reporting requirements. Management Response: The Director of Financial Aid concurs with this finding and noted while the College out of compliance with the reporting timeframe, the College did make a substantial effort to complete the requirements and follow up with NSLDS and NSC to correct the students enrollment. Contact College personnel for corrective action. Derrick Everhart, Director of Financial Aid deverhart@warren-wilson.edu Brooke Milsaps, College Registrar bmillsaps@warren-wilson.edu

Management Response: Management agrees with this finding. To prevent this situation from occurring in the future, staff members will create a new academic record in our Student Information System (Jenzabar) for a student who graduates and enrolls in a subsequent semester. The new academic record will reflect the student’s non-degree status. A new academic record will prevent reporting conflicts between the student’s graduation status and subsequent non-degree enrollment status and therefore, will assist the college in reporting within the 60-day timeline. When a student changes enrollment statuses between regular monthly reports, staff members will continue to exercise the option to use the National Student Clearinghouse ad-hoc enrollment reporting so that the National Student Loan Database System receives timely enrollment updates. Contact Person: Betsy Henkel, Director of Financial Aid (henkelb@beloit.edu) Anticipated Completion Date: December 1, 2023

Condition: Expenditure reports were not filed in a timely manner. Recommendation: We recommend that steps are taken, including oversight by a second employee, to ensure that all quarterly expenditure reports are filed by the due dates. Management Response: Management will take the necessary steps to file all quarterly expenditure reports on time in the future. Anticipated Date of Completion: June 30, 2024

The Financial Aid Office and the Registrar's Office will work closely together to resolve the NSLDS reporting discrepancies. Based on the review information from last year's similar finding (2022), it was determined after the fact that Webster University had both repeated 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. The Clearinghouse continues to have system issues that delay reporting. Because the Clearinghouse is not able to consistently report accurate enrollment until their system challenges are resolved, the Financial Aid Registrar's Offices, with the assistance of IT and Enrollment Technology, will develop a mechanism going forward to establish more internal checks to compare against NSLDS data. One of these measures would include a monthly enrollment reporting audit to ensure timely and accurate enrollment information is provided to NSLDS.

2023-001 – Cost of Attendance Calculation. Auditor Description of Condition and Effect. Two students out of the 40 tested had an incorrect COA recorded in PowerFAIDS. The error was isolated to the population of students enrolled half-time at the College. The College determined that they did not properly update COA for the year. Subsequent to initial testing, the College adjusted the COA for the half-time students whose COA was not updated for the year. This condition did not result in any students being awarded an incorrect amount of Pell. As a result of this condition, the College was exposed to an increased risk that incorrect information would be used to determine students' Pell Grant award amounts. Auditor Recommendation. We recommend the College implement procedures to ensure the COA used to calculate each student's Pell Grant is updated for each academic year and reviewed by an independent official. Corrective Action. The College will evaluate and implement controls that will ensure Pell Grant Budget Cost of Attendance requirements are met. The Financial Aid Office will determine Cost of Attendance budget component amounts and School Administration will approve these amounts prior to the financial aid system and school website being updated accordingly each academic year. Responsible Party. Financial Aid Office and School Administration. Anticipated Completion Date. September 27, 2023

Condition: The University had one of the minimum safeguards written down within its information security program during the fiscal year. Planned Corrective Action: The University does have information security controls in place. While we have implemented these controls and safeguards, we acknowledge they are not documented in our formal policies. Our corrective action is to have these controls formalized and documented in the coming year. Contact person responsible for corrective action: Linda L Height, VP Finance Anticipated Completion Date: June 30, 2024

Condition: The University did not report certain students' status to NSLDS in a timely manner during the fiscal year Planned Corrective Action: The University Team will review status updates for all students that continue enrollment from one semester to another (May to Summer) to be sure their previous and new status both appear in NSLDS. All the students that were identified had continued with a new degree program in the summer, so the corrective action plan we are implementing will catch any issue before their new enrollment information is updated to NSLDS. Contact person responsible for corrective action: Noreen Ferguson, Registrar Anticipated Completion Date: December 31, 2023

Name of Contact Person Responsible for the Corrective Action Plan: Beth Young Corrective Action Plan: The College administration has met and is in the process of implementing controls and procedures to ensure that all Title IV funds are properly monitored and reviewed. Anticipated Completion Date: Fiscal year 2024.

Finding Reference Number: 2023-001 Initial Fiscal Year: 2023 Summary of Finding: Material Weakness: Gramm-Leach-Bliley Act (GLBA) (U.S. Department of Education, William D. Ford Direct Loan Program, ALN #84.268) Entity’s Corrective Action Plan Due to turnover within the IT Department, GLBA requirements were not communicated well to incoming staff or to the organization. Once GLBA requirements were discovered, a plan was developed to begin implementing GLBA controls and revise our security plan. The plan to bring the organization into GLBA compliance was developed for the 2023-2024 school year and was not in effect before this audit. The IT Department, and key stakeholders within the organization, are working to ensure GLBA compliance within the next year.. Anticipated Completion Date: September 21, 2023 Name and Title of Responsible Person: Luke Edwards, Director of IT.

Finding Reference Number: 2023-006 Initial Fiscal Year: 2023 Summary of Finding: Significant Deficiency: Exit Counseling (U.S. Department of Education, William D. Ford Direct Loan Program, ALN #84.268) Entity’s Corrective Action Plan Corrective Action Plan Summary: Once IT was made aware of the issues, we implemented changes to the process. The action code was discontinued, and our database administrator developed a custom database table used only for tracking Financial Aid communications. This custom table tracks the student’s organizational ID number, email address, communication code (EXIT for exit counseling emails), date/time the email was processed, and the status returned by the process used to send emails. Please note that this status only checks whether the process succeeded, it does not check whether the email was successfully sent. The Financial Aid Department is still copied in all emails sent at their main email address (currently FinancialAidTN@Johnsonu.edu). The Financial Aid Department has the responsibility to alert the IT Department if they are not receiving emails as expected. Once the IT Department has been alerted of an issue, the IT Department can start working to resolve the issue. For long-term reliability of communications, Johnson University has purchased and is implementing a new Financial Aid software platform. This will give us an opportunity to work towards reliable communications, not just reliable logging of process failures or successes. Anticipated Completion Date: September 21, 2023 Explanation: The corrective action plan was taken to resolve the prior year finding, helping to ensure that future dates are accurate. Name and Title of Responsible Person: Luke Edwards, Director of IT.

Finding Reference Number: 2023-005 Initial Fiscal Year: 2023 Summary of Finding: Significant Deficiency: Disbursement Notifications (U.S. Department of Education, William D. Ford Direct Loan Program, ALN #84.268) Entity’s Corrective Action Plan Corrective Action Plan Summary: Once IT was made aware of the issues, we implemented changes to the process. The action code was discontinued, and our database administrator developed a custom database table used only for tracking Financial Aid communications. This custom table tracks the student’s organizational ID number, email address, communication code (MAND for mandatory loan emails), date/time the email was processed, and the status returned by the process used to send emails. Please note that this status only checks whether the process succeeded, it does not check whether the email was successfully sent. The Financial Aid Department is still copied in all emails sent at their main email address (currently FinancialAidTN@Johnsonu.edu). The Financial Aid Department has the responsibility to alert the IT Department if they are not receiving emails as expected. Once the IT Department has been alerted of an issue, the IT Department can start working to resolve the issue. For long-term reliability of communications, Johnson University has purchased and is implementing a new Financial Aid software platform. This will give us an opportunity to work towards reliable communications, not just reliable logging of process failures or successes. Anticipated Completion Date: September 21, 2023 Explanation: The corrective action plan was taken to resolve the prior year finding, helping to ensure that future dates are accurate. Name and Title of Responsible Person: Luke Edwards, Director of IT.

Finding Reference Number: 2023-004 Initial Fiscal Year: 2023 Summary of Finding: Significant Deficiency: The University Did Not Timely Complete Return to Title IV Funds (U.S. Department of Education, William D. Ford Direct Loan Program, ALN #84.268, Federal Pell Grant Program, ALN #84.063) Entity’s Corrective Action Plan Corrective Action Plan Summary: When processing the R2T4s for these three students the Director looked at the current date on the form and processed them according to the current date and not the date of withdrawal. For these students due to the date difference went from being in the greater than 60% category where a R2T4 was not necessary to now needing one processed. The university has implemented an audit process where by the date entered can be more easily verified to ensure accuracy. This date and the withdrawal date or LDA are now added to a withdrawal form that is shared between departments so that any variance will be easily identified. Anticipated Completion Date: September 21, 2023 Explanation: The corrective action plan was taken to resolve the prior year finding, helping to ensure that future dates are accurate. Name and Title of Responsible Person: Rocky Christensen, Director of Financial Aid.

Finding Reference Number: 2023-003 Initial Fiscal Year: 2023 Summary of Finding: Significant Deficiency: Return to Title IV Funds (U.S. Department of Education, William D. Ford Direct Loan Program, ALN #84.268; Federal Pell Grant Program, ALN #84.063) Entity’s Corrective Action Plan Corrective Action Plan Summary: When setting the R2T4 dates in the system we had failed to count the Saturday and Sunday preceding the break period of five days or more. The university has addressed the issue for the future POE periods and implemented a three step verification process moving forward. The three step verification involves two additional staff verifying the dates in the system to ensure accuracy. Anticipated Completion Date: September 21, 2023 Explanation: The corrective action plan was taken to resolve the prior year finding, helping to ensure that future dates are accurate. Name and Title of Responsible Person: Rocky Christensen, Director of Financial Aid.

Finding Reference Number: 2023-002 Initial Fiscal Year: 2023 Summary of Finding: Significant Deficiency: Documentation Regarding Offer of a Post- Withdrawal Disbursement (U.S. Department of Education, William D. Ford Direct Loan Program, ALN #84.268; Federal Pell Grant Program, ALN #84.063) Entity’s Corrective Action Plan Corrective Action Plan Summary: The university was not documenting the PWD notification that happens with students as part of our exit process. While the university was completing this the lack of documentation has been addressed. The university now has the student verify receipt of this information on the withdrawal form. Anticipated Completion Date: September 21, 2023 Name and Title of Responsible Person: Rocky Christensen, Director of Financial Aid.

The Office of the Registrar recognizes the importance of both timely and accurate reporting of enrollment status changes for lenders and servicers of student loans to determine in-school status, deferments, grace periods, and repayment schedules, as well as the federal government’s payment of interest subsidies. Through our own data reporting and, in conjunction with the NSC, we are working to identify the affected students to correct their enrollment record statuses to graduated. We expect to make these corrections no later than January 12, 2024. Individuals with reporting responsibilities will engage in training through the NSC. An office audit will be conducted to assess areas for improvement. These actions will be completed by March 1, 2024. The College recently instituted additional conferral dates where graduated students will be submitted to NSC as batch files, thereby, substantially lessening the need to report as individual online updates.

U.S. Department of Education 2023-001 Student Financial Assistance Cluster – Assistance Listing Number: 84.007, 84.003, 84.038, 84.063, 84.268, 93.364 Recommendation: We recommend the College designate an individual to oversee the information security function and work to update the College’s written security program to ensure compliance with all standards. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The College recognized the need to improve their security program and data governance, and this was a catalyst in their decision to outsource the management of their Information Technology functional area. On July 15, 2023, The College engaged Ellucian as its Information Technology partner. Ellucian will be working, along with management, to develop a security program for the College. The College will be establishing appropriate data governance and security protocols and controls as part of the overall security program. The College anticipates having a security program written, approved, and employed by June 30, 2024. Name(s) of the contact person(s) responsible for corrective action: Tana Boone, Vice President of Finance and Administration Planned completion date for corrective action plan: June 2024

College Response: In November 2023, in conjunction with the College’s annual external audit, errors were identified in Cuyahoga Community College’s timely Return to Title IV funds. After careful internal review of the student records, all applicable corrections to student records were made to ensure compliance with federal regulations. All financial aid funds related to Return of Title IV funds had been returned to the U.S. Department of Education. In December 2023, the college completed a review of internal procedures and processes to mitigate untimely Return of Title IV funds in the future. Mitigation Strategy: The following process and procedural changes for the review of the Return of Title IV funds have been put in place to resolve the issue of late returns of funds as identified in the 2022-2023 external audit: 1. Retrained staff responsible for the Return of Title IV processing, including updates and revisions to the policies and procedure manual for this financial aid function to strengthen the internal quality check for manual review of the accuracy of returns 2. Identified and cross-train additional financial aid employees to support the high-volume financial aid process, including two team members to check and validate the timely processing and accuracy of the return of funds 3. Developed an enhanced report to compare completed calculations of the return of funds in Banner to the processed with the COD-generated report to verify the timely return of funds 4. Automated reports for Return of Title IV report to be delivered bi-weekly to the central mailbox, which will enable multiple employees to have access to the Return of Title IV reports and ensure more than one trained team member to timely process the return of funds to meet the 45-day federal requirement 5. Conduct a quality check of the Return of Title IV funds to assess the accuracy of the calculation and timely return of funds by conducting an internal Financial Aid Team review of 5-10% of the return of funds assessment every 60 days Anticipated Completion Date: 12/19/2023 Responsible Contact Person: Angela Johnson –VP of Enrollment Management

Finding 2023-002 Name of Responsible Individual: Cinnamon Bradley, Associate Dean of Student Affairs Corrective Action: We agree. We understand that status changes must be submitted, and errors must be corrected in the National Student Clearinghouse and NSLDS in a timely manner. We will review our procedures to ensure proper recording of these changes by NSLDS based on our submission to the National Student Clearinghouse. Additionally, we will implement the following processes: • An automated monitoring notification system that will alert us within the established timeframe of status changes to ensure accuracy in both third-party systems. • Change in our submission process to the National Student Clearinghouse from 30 days to occur weekly to ensure timely reporting to NSLDS. Additionally, all student records contained in the NSLDS for the Academic Term will be reviewed every month and the student roster will be reviewed weekly for accuracy in both third-party systems. Anticipated Completion Date: March 1, 2024

2023-001 – Pell Grant Calculation. Auditor Description of Condition and Effect. The Uniform Guidance states that the College must determine the maximum scheduled award a student would receive based on their Expected Family Contribution (EFC) and Cost of Attendance (COA) using the payment schedule provided by the U.S. Department of Education. Students must be awarded on the basis of a COA comprised of allowable costs assessed to all students carrying the same academic workload. COA must be prorated for students who are attending less than an academic year, or who are less than full-time in a term-based program. As a result of this condition, the College was exposed to an increased risk that incorrect information would be used to determine students' Pell Grant award amounts. Auditor Recommendation. We recommend the College implement procedures to ensure the COA and EFC used to calculate each student's Pell Grant is updated for each academic year and reviewed by an independent official. Corrective Action. In the spring of each year, the College Financial Aid Department will establish the Cost of Attendance (COA) necessary for Pell student eligibility, in addition to the Educational Financial Contribution (EFC) for the following fiscal year. Once these are calculated and established, the head of the Business Office will review the calculations, discuss, and approve. Once they have been approved, the appropriate information will be entered into the Financial Aid software system. Responsible Party. Director of Financial Aid and Head of the Business Office. Anticipated Completion Date. June 30, 2024.

Management acknowledges that there was an error in the amount of Pell awarded to the student. Cleveland Institute of Art is in the process of calculating the number of students affected by the issue and reconciling any differences. The College is also reconfiguring the systems to ensure that this issue does not continue. The financial aid office will import on a regular basis the credit hour update/create student update into Powerfaids using the data integration from J1 table to load credit hours onto the student record until the Pell recalculation/census date. The financial aid office will continue to share with the Registrar’s office the Financial Aid credit hours update report that shows hours not contributing to the program so they can correct the coding on specific coursework into the appropriate “trees.” Powerfaids only imports hours contributing to the program. At the beginning of the semester, and prior to disbursing aid, the financial aid office will look for enrollment discrepancies and reconcile hours in their system with a registration report from the Registrar’s office. On the census date, which is defined as day 15 of the term, the financial aid office will lock down the enrollment hours on the student record after reconciling the hours on the student record with the hours on the Registrar’s census report.

Management has reviewed the draft Schedule of Findings and Questioned Costs for FY 2023. We agree with the finding and are actively working to improve processes to ensure student files are uploaded timely and accurately. The Vice Presidents of Administrative and Student Services have discussed the issue with the Director of Enrollment Management and the Assistant Registrar. We have reached out to the Clearinghouse for resolution help and have already received data from them. Vernon College will follow the recommended procedures of the Clearinghouse moving forward to ensure the accuracy of data reported to the NSLDS.