Corrective Action Plans

REFERENCE # 2022-003 ELIGIBILITY FOR INDIVIDUALS ? NONCOMPLIANCE Program ADOPTION ASSISTANCE TITLE IV-E (Assistance Listing # 93.659) Identification Number(s) 18000 Finding New York State has enacted legislation which allows payments to be made for the care and maintenance of children when they are adopted. Suffolk County Department of Social Services (the ?Department?) provides a monthly adoption subsidy payment mandated by law for the care, maintenance, and/or medical needs of a child who fits the definition of handicapped or hard-to-place as defined by New York State law and regulations. Subsidy payments are available to all eligible children until the age of 21 regardless of the adoptive parent?s income. These payments are discontinued only when it is determined by a social service official that the adoptive parent(s) is no longer legally responsible for the support of the child or that the child is no longer receiving any support from the parent(s). Of the sixty (60) files selected for testing: ? Five (5) case file did not include the Home Studies narrative; and one (1) case file did not include the Criminal check form. Therefore, we were not able to determine if the eligible participants met all the eligibility criteria. Questioned Costs Cannot be determined. Recommendation We recommend the Department strengthen its monitoring controls over the adoption assistance case files to ensure the timely and accurate determination of eligibility. Corrective Action Plan With regards to the Criminal check form: Corrective Action Plan: It was found that one (1) case file did not include the criminal check form. The criminal check forms for this case was conducted when the children were in Foster Care and the results were included in the Foster Home record. Foster Home records are purged after eight (8) years of the home closing and no longer available. Currently: The criminal record check is included in the Adoption Subsidy file upon adoption as well as maintained in our Adoption vendor files. With regards to the Home Study narrative: Corrective Action Plan: It was found that five (5) cases did not include the Home Study narrative. The Home Study narratives for these case files were conducted when the homes were first certified as Foster Homes and were included in the Foster Home case record. Foster Home records are purged after eight (8) years of the home closing and no longer available. Currently: The Home Study narrative is included in the Adoption Subsidy file upon adoption as well as maintained in our Adoption vendor files. Action Date Record Check ? 2018 Home Study ? 2021 Final Implementation Date Record Check ? 2039 Home Study ? 2042 Name And Phone # Of Person Responsible For Implementation Carleen Newlands, Division Administrator 631-854-9626

A. Comments on Findings and Recommendations: Finding 2022-001 Exit Counseling Condition: The Institution did not timely perform the required FDL exit counseling for 10 of 20 students in the sample requiring exit counseling. PMC agrees with the condition outlined in Finding 2022-001 Exit Counseling. B. Prior Audit Findings There were no findings in the prior audit. C. Corrective Action Taken on Findings Finding 2022-001 Exit Counseling Current processes for exit counseling are to ensure graduating students receive exit counseling during the final quarter of enrollment as well as receive an e-mail with directions on how to complete exit counseling at www.studentloans.gov from the financial aid department. Students that are enrolled in less-than-halftime credits are also provided exit counseling when the quarter starts or known when the student drops down to that enrollment status through reduction of courses. When students withdraw they will be notified that they are to confirm whether or not a student has received direct loans or not; if yes, they are to perform their exit counseling duties. There has been a lack of quality assurance that has led to exit counseling being completed after 30 days for a variety of reasons. To correct this issue, PMC Registrar will run an enrollment status change report on a bi-weekly basis to catch any student that has changed to an out-of-school status and/or a less-than-half-time status to ensure the financial aid department completes their exit counseling phone call or in-person meeting, as well as their exit counseling e-mail with information regarding completing exit counseling via www.studentloans.gov. Within seven (7) days of the report being run, each student file will be checked to ensure exit counseling was completed and notes are placed within the file to verify exit counseling was completed within the 30 day period of the enrollment status change as required.

Corrective Action Plan The University of Tulsa Student Financial Services External Audit: Academic Year 21/22 During the spring 2022 semester, The University of Tulsa closed for a 5-day period due to inclement weather. The Return of Title IV (R2T4) calculations that were conducted adjusted total number of days in the semester; but did not adjust total days attended on the R2T4 calculations. The University of Tulsa reviewed all R2T4 calculations for spring 2022 with a withdraw date of February 2 or after. 11 recalculations were required, funds are being returned to the Department of Education. For future semesters, the formula for breaks will be hard coded into the COD R2T4 formula for all new breaks in the event of school closure during a semester to avoid missing either a reduction in the numerator or denominator. Name of the contact person responsible for corrective action: Vicki Hendrickson, Director, Student Financial Services

Finding 2022-001: Federal Program: Community Facilities Loans and Grants Cluster: Community Facilities Loans and Grants Assistance Listing Number: 10.766 Criteria: Section 4.4 of the Community Facilities Direct Loan agreement stipulates that the borrower must maintain funds in accounts in accordance with Section 4 of the Loan Resolution. The Loan Resolution stipulates that the borrower must establish a General Account and Reserve Account. The Reserve account must be funded to an amount equaling or exceeding $1,167,219. Condition and Context: The Association did not have a specific Reserve Account established in accordance with the Loan Resolution. Corrective Action Plan: Corry Memorial Hospital Association d/b/a LECOM Health Corry Memorial Hospital and Subsidiaries agrees with the finding and will implement controls sufficient to identify and monitor ongoing compliance with requirements. Additionally, Corry Memorial Hospital Association d/b/a LECOM Health Corry Memorial Hospital and Subsidiaries will establish and fund the required reserve account. Contact Person: Tim McGahen, Chief Financial Officer 965 Shamrock Lane, Corry, PA 16407 Expected Date of Resolution: The policies are expected to be updated effective March 30, 2023. The Reserve account is expected to be established and funded by March 1, 2023.

2022-001: Errors Relating to Return of Title IV Financial Aid - Student Financial Aid Cluster - Assistance Listing Number #s 84.007, 84.033, 84.063, 84.268 - Grant Period - Year Ended June 30, 2022 Condition Found During our return of Title IV Fund testing we noted that the College did not calculate or return Title IV for students who ceased attendance correctly for three students out of twenty-two. The College used the incorrect number of days the student attended when calculating the return of Title IV. We consider this to be an significant deficiency relating to the Special Tests and Provisions Compliance Requirement. Corrective Action Plan The Financial Aid Office has reviewed all late start students and recalculated their file to include the 6 day break for Spring 2022 semester. We have since updated our training materials to include reviewing the break periods within our schedule to ensure our manual calculations are correct. In addition, we are adding in a quality control review process to ensure dates are calculated correctly. Responsible Person for Corrective Action Plan Gregory Putra, Director of Financial Aid & Veterans Affairs Implementation Date of Corrective Action Plan 7/01/2022

Audit Finding Number 2022-003 Program Student Financial Assistance Cluster ? Federal Direct Loan Program Federal Assistance Listing Number 84.268 Federal Grantor U.S. Department of Education Views of Responsible Officials We recognize that the effective withdrawal date for 2 students were not updated in the NSLDS in the prescribed timeline. While we believe that our systemic enrollment changes are updated appropriately in NSLDS, we acknowledge that certain events taking place outside of the normal timeline may be currently delayed. Planned Corrective Action The Registrar?s Office will amend their policy to apply an appropriate status update in NCH for any student whose enrollment status has changed after the reporting term has ended, but is prior to the start of the next reporting term. In turn, the timely update of the NCH will lead to the NSLDS being updated for these unique situations in a timely manner. Anticipated Completion Date December 31, 2022 Responsible Contact Person Michael Bedel, Assistant Vice President of Finance and Accounting Contact Information 317-955-6009

Recommendation: The auditors recommended that the Institute review and revise its current procedures and have controls in place to ensure required notifications regarding Federal Direct Loan Program proceeds are provided to participating students. Action Plan: We agree with both the finding and the recommendation. A system has been implemented to send out the required notifications regarding Federal Direct Student Loan Program proceeds that have been applied to a participating student?s ac-count.

Recommendation: The auditors recommended that the Institute review and revise, if necessary, its current procedures and have controls in place to ensure that participating student's enrollment status on the Enrollment Reporting roster file via the Na-tional Student Loan Data System is reported in a timely manner as prescribed by U.S. Department of Education regulations. Action Taken: We agree with both the finding and the recommendation. A system has been imple-mented to ensure that the National Student Loan Data system is updated on a timely basis as pre-scribed by U.S. Department of Education regula-tions.

Recommendation: The auditors recommended that the Institute continue its efforts to ensure all required exit counseling procedures are conducted and documented in compliance with U.S. Department of Education regulations. Action Taken: We agree with both the finding and the recommendation. The instances of missed exit conferences with borrowers under the Federal Direct Loan Program were primarily related to students who had been dropped due to non-payment of tuition and who did not respond to our attempts to contact them for an exit conference. We understand that we failed to properly document our efforts to contact these students to schedule and perform an exit conference. We have amended our procedures to document our efforts to contact any students for which an exit conference is required and we have not been able to schedule one.

Finding Number: 2022-001 Untimely Returns of Title IV Funds and Inaccurate Returns of Title IV Funds (R2T4) Planned Corrective Action: Three of the four students with inaccurate return of Title IV fund calculations were corrected during the audit. FA Office is in the process of reaching out to the student with an over-return of $418 in FDL for authorization to disburse this amount. FA Office has met with Assistant Registrar for Online Studies and Academic Advising to review the federal regulations for R2T4 in modular programs. The Online Advising and Registrar team were provided with a list of module withdrawal questions that should help to determine if a student is a withdrawal. A copy of questions that were provided to those teams is attached. The following procedures were established between both offices to eliminate untimely and inaccurate return of Title IV funds going forward: If a student is dropped for inactivity/nonparticipation, the remainder of their courses for that payment period are dropped as well. This allows the return of unearned Title IV funds to be completed no later than 45 days after the school determines the LDA. If a student would like to take a break and return to a module that begins later in the payment period, they must provide a statement of intent to return (written confirmation) and the module must begin no later than 45 calendar days after the end of the module the student ceased attending. Financial Aid also met with Associate Registrar and CIU Database Developer to create a report that better captures students who are determined as withdrawals in modular programs. This will assist in monitoring the online student population and achieve more accuracy in reporting. Online Financial Aid team has redistributed workload so that the Associate Director has more time designated to monitor and oversee the R2T4 process. Person Responsible for Corrective Action Plan: Patty Hix, Director of Financial Aid and Lynsay Shumpert, Associate Director for Online Studies Anticipated Date of Completion: Report has been created and we are in the testing phase.

FINDING 2022-001-Late Notification to NSLDS

Federal Direct Loans Reconciliations Planned Corrective Action: The University will ensure that incomplete reconciliation is completed for 2021-2022. We will ensure that monthly reconciliation is completed as required as follows: 1. Monthly reconciliations will be signed by the Director of Financial Aid and Vice President for Enrollment Management Person Responsible for Corrective Action Plan: Sheri Jefferson, Interim Director of Financial Aid Anticipated Date of Completion: June 30, 2023

Individuals Responsible for Corrective Action Plan Jeff Scaccia, CPA (Vice President for Finance and Administration) Libby Shull, CPA (Controller) April Baur, (Director of Student Financial Aid) For 1 of 25 students tested, the College was unable to locate Perkins promissory note related to this student. Corrective Action Plan: The College maintains all Perkins promissory notes in alphabetical order, in a dedicated filing cabinet, in a fireproof vault. This finding relates to a promissory note that was signed in 1987 and the College is not aware of what may have caused this Promissory note to be misplaced. No further action is planned by Management as the Perkins Loan Program expired on September 30, 2017 and no additional Perkins Loan disbursements were made by the College since the Program?s expiration. Anticipated Completion Date: March 1, 2023

Individuals Responsible for Corrective Action Plan Jeff Scaccia, CPA (Vice President for Finance and Administration) Libby Shull, CPA (Controller) April Baur, (Director of Student Financial Aid) For 1 of 2 students selected for testing, the College did not return the correct amount to COD. Corrective Action Plan: As of September 2022, the Office of Financial Aid began utilizing the R2T4 Worksheet found on COD. This more clearly and specifically states the net total that should be returned. Anticipated Completion Date: September 1, 2022

Individuals Responsible for Corrective Action Plan Jeff Scaccia, CPA (Vice President for Finance and Administration) Libby Shull, CPA (Controller) April Baur, (Director of Student Financial Aid) For 1 of 40 students tested, the College was unable to provide a copy of the award disbursement notification letter sent to student and or parent for parent plus borrowers, which includes the amount of funds the student and his or her parent can expect to receive from each FSA program and how and when those funds will be disbursed. Corrective Action Plan: The College recognizes that when Direct Loan funds are being credited to a student?s ledger account (except in the case of loan funds made as part of a post-withdrawal disbursement), the school must notify the borrower in writing (paper or electronically) of the: ? anticipated date and amount of the disbursement; ? student?s or parent?s right to cancel all or a portion of a loan or loan disbursement and have the loan proceeds returned to the Department; and ? procedures and deadlines by which the student or parent must notify the school that he or she wishes to cancel the loan or loan disbursement. The timing of a loan notification varies depending on whether a school obtains affirmative confirmation from a student that he or she wants a loan. Affirmative confirmation is a process under which a school obtains written confirmation of the types and amounts of Title IV loans a student wants for the period of enrollment before the institution credits the student?s account with those loan funds (34 CFR 668.165(a)(6)). Presbyterian College requires students to accept Direct Loan awards in BannerWeb so notifications are sent according to requirements when a student actively confirms the loan. Disbursement notifications were sent to students after each disbursement during the 2021-2022 academic year; however, the parent was not directly notified of a PLUS loan disbursement. For the 2023-2024 academic year, a PLUS Loan Form has been created and will be sent to the parent borrower to confirm the amount requesting. As of March 6, 2023, notifications are being created to notify parents with PLUS loans of disbursement and their rights. Anticipated Completion Date: March 6, 2023

Individuals Responsible for Corrective Action Plan Jeff Scaccia, CPA (Vice President for Finance and Administration) Libby Shull, CPA (Controller) April Baur, (Director of Student Financial Aid) For 2 of 2 mid-year transfer students tested, the school did not actively add these students to the NSLDS transfer monitoring list. Corrective Action Plan: The College acknowledges the requirement that schools obtain financial aid history information for their transfer students. Due to the small number of transfer students accepted by the College, it is the College?s belief that it followed US Department of Education guidance allowing a school to use NSLDS information for a mid-year transfer student if it obtained that information no earlier than 30 days prior to the first day of the student?s payment period (Dear Partner Letter GEN 00-12). The new Director of Financial Aid works closely with the Office of Admission and will update NSLDS manually to ?inform? it of the transfer students applying to PC mid-year. This is a relatively small group of students. For those students included on a school?s ?Inform? list, NSLDS ?Monitors? changes to the student?s financial aid history that have occurred since the latest ISIR for the student was generated and sent to the school. NSLDS will continue to monitor changes to the student?s financial aid history, and alert the school of any subsequent relevant changes. A staff member in the Office of Financial Aid will be assigned to review the Transfer Monitoring files. Anticipated Completion Date: March 1, 2023

Findings and Questioned Costs Related to Federal Awards Finding Number: 2022-001 Contact Person: Dr. Shelley Isai, Assistant Superintendent for Education Services Anticipated Completion Date: November 21, 2022 Planned Corrective Action: The District reviewed the procedures used to determine Title I, Part A eligibility in the Grants Management System as well as a process that includes maintaining records. The process was redefined for the fiscal year 2023 grant application but will change slightly in future years due to a change in the options in criteria available used to determine eligibility for fiscal year 2023 grant applications. To complete this process with accuracy, the Director of Federal Projects will communicate the required eligibility criteria to the Director of Nutrition Services. The Nutrition Services department will provide Federal Projects with the necessary information to complete the process. Supporting documentation for the basis of fiscal year 2023 and the future years will be stored in a shared file and readily accessible for reference or audits. This process has been documented to ensure consistency through any department transitions.

Texas Wesleyan University Corrective Action Plan 2021 Academic Year (Summer 21, Fall 21, Spring 22) Fiscal Year Ending May 31, 2022 Reference Number: 2022-001 Recommendation: The University should update its controls to ensure that the days attended for students who withdraw from a program offered in modules is correct. Corrective Action Plan: The Financial Aid Administrator acknowledges the error with the Title IV Calculation for the student who was enrolled in two modules in one semester. Initially, the calculation was based on the student being enrolled in one module. When the file was chosen for the 2021-2022 audit, the error was caught that the student was enrolled in module two, as well. The Director of Financial Aid has reached out to ?Ask a Fed? for guidance on the calculation of the numerator in a Title IV calculation about modules. The guidance was received on September 1, 2022, and confirmed that the numerator should only include the actual days the student attended. This guidance has been implemented. The 2021-2022 return of funds for students enrolled in the modules will be recalculated by October 31, 2022.

Student Financial Aid Cluster Status Change Not Reported Enrollment Reporting The Student Financial Aid Office and the Office of Student Records will work closely to ensure students? date of withdrawal from all courses are entered into Colleague correctly and that both offices? dates match. The Office of Student Records will provide the National Clearinghouse enrollment reporting dates for Central Wyoming College to the Financial Aid Office. This will ensure the Financial Aid Office provides the Office of Student Records with the Return to Title IV student report in a timely manner for reporting to the National Clearinghouse. The Registrar will make sure any student on the Return to Title IV list has a record on the National Clearinghouse for program-level and campus-level reporting. The Registrar will verify all students on the Return to Title IV list are showing correctly on the National Clearinghouse upon submittal. The Director of Financial Aid will review NSLDS monthly to ensure status dates for all Return to Title IV students are accurately reflected. The Director of Financial Aid will also communicate any issues found with any student?s status on the NSLDS site to the Registrar. The Director of Financial Aid, in collaboration with the Office of Student Records, will work to obtain and review the SOC 1 report from the third-party servicer (National Clearinghouse) to ensure proper controls are implemented. Anticipated Completion Date: December 1, 2022 Contact Person(s): DeeAnna Archuleta, SFA Director Connie Nyberg, Registrar

October 14, 2022 U.S. Department of Education 400 Maryland Avenue, SW Washington, D.C. 20202 Re: Corrective Action Plan Finding 2022-001 Program: Federal Direct Loan Programs CFDA Number: 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 was reported incorrectly. Two students were enrolled in Law Masters degree programs and were reported as less than full-time although should have been full time. Additionally, one GSEC Masters student was reported correctly on the program level enrollment reporting as withdrawn on March 15, 2022, however, the campus level reporting included an incorrect status of less than half time and status date of March 16, 2022 before later being corrected to withdrawn status date of March 15, 2022. 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. The College has reconfirmed the full and part time definitions for Law Masters students, and corrected the underlying technical issue that had interfered with the reporting of correct enrollment statuses for Law Master's students. The correction of the enrollment status for the two Law Masters students in NSLDS is in process. The College has also updated the procedures and documentation for enrollment reporting of GSEC Masters students to ensure the scenario identified is handled correctly and consistently in the future. The College has corrected this student's program level withdrawal date in NSLDS. Lewis & Clark College Andrea Dooley Chief Financial Officer and Vice President of Operations

CORRECTIVE ACTION PLAN Program Name: Foster Care Title IVE Finding: 2022-001 Name of Contact: Keri Jerrell, Child Welfare Program Manager Corrective Action Plan: As children enter foster care, a DSS-5120 is required to be completed in order to determine foster care funding eligibility. Once determined, the eligibility is used in a variety of ways, including, administrative coding and payment for room and board services. As both of these areas involve fiscal operations and county, state, and federal funds, proper determination is imperative. Once satisfied that the proper determination has been made, proper communication and transfer of that determination is of equal importance. In order to assure that a prompt and efficient foster care funding determination is made for each child entering custody of the Alexander County Department of Social Services, the Department is adopting the following plan: 1. Internal guidance for completing the initial DSS-5120 and all subsequent DSS-5120 reviews will be developed and implemented. Guidance will include specialized training for identified staff and a multi-party review process. Projected completion date: 12-31-22 2. 100% of Alexander County DSS cases will be reviewed to ensure that the original funding determination cited on the DSS-5120 is reflected on the respective DSS-5094. Projected completion date: 11-30-22 3. Existing internal guidance document involving the use of the PQA-020 report will be reviewed with involved staff, stressing the importance of consistent documentation of funding source. Projected completion date: 11-30-22

Incorrect and Untimely Return of Title IV (R2T4) Funds Planned Corrective Action: The Financial Aid Office reviewed the new modular regulations and guidance again as it was identified that exemption(s) were missed in the initial review. The team updated the 2021 NASFAA R2T4 decision tree with notes breaking down the complexity of the new modular regulations and how they apply to our modules/programs. The unofficial withdrawal list for the academic year was re-requested from the registrar?s office and reviewed. Students that met exemption were awarded funds back, recalculated if needed, and processed. Although the Financial Aid Office did implement changes on identifying unofficial withdraws (students were identified) from the prior year finding, the complexity of the modular regulations impacted the finding for 2022. A review of each student?s module will be performed (Executive Director of Financial Aid / Lead Director) and then reviewed and processed by staff member (Financial Aid Director). The final determination list will be compared to the R2T4?s processed. Person Responsible for Corrective Action Plan: Sandy Wilkinson, Executive Director of Financial Aid Anticipated Date of Completion: Implemented

Finding 2022-004: Information on the Federal Program Federal Agency: United States Department of Education (ED) Program Name: Student Financial Assistance Cluster AL: 84.268 - Federal Direct Student Loans Federal Award Identification Number: N/A Federal Award Year: Year Ended May 31 , 2022 The College will implement a control procedure to ensure disbursement notification letters are sent to every student who received direct loan disbursement, within 7 days, to be in compliance with the requirement described above. The College supplies to the student a notification of each disbursement via a Statement of Account. The College has added a clause in the Terms and Conditions which addresses the cancelation of loans. Estimated Completion Date: December 31 , 2022 Contact Person: Pamela A. Bernstein Director of Business and Registrar Affairs thomasmorecollege@hotmail.com 603-324-1420

WorkNet Pinellas, Inc. management and MIS Team reviewed the monitoring issue with the WIOA team and provided training on the subject. WorkNet Pinellas, Inc. has improved the enrollment process, hired an eligibility specialist and implemented Quality Control (QC) processes to include a review by the eligibility specialist, Career Counselor, and WIOA Lead or MIS QC prior to enrollment to ensure eligibility and accuracy and to ensure "training services be limited to individuals who are unable to obtain other grant assistance for such services including Federal Pell Grants."

Federal Direct Loans and Pell Grants Reconciliations Planned Corrective Action: Implement a procedure where Pell Grants and Direct Loans are reconciled by student using reports from CAMS as well as COD. Person Responsible for Corrective Action Plan: Anna Peters Anticipated Date of Completion: May 31, 2023