Corrective Action Plans

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 21 students tested, student's Campus Level NSLDS records not found within NSLDS website. Corrective Action Plan: The Registrar?s Office revised its monthly processes and procedures guide to include better monitoring of any potential errors with NSLDS reporting. The Registrar submits an enrollment report on the 15th day of every month to the Clearinghouse. Once an email is received from the Clearinghouse allowing the Registrar to view any errors on the website, the Registrar will check the NSLDS portion of the website to see if any corrections are necessary. These procedures were followed in regard to the finding reported. The College is not aware of why the student?s record was not found within the NSDLS website however, it will be more diligent in its monitoring of this activity going forward. 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 27 of 40 students tested, per review of the COD screenshot provided by the client, the College did not report required Pell disbursements via the COD within 15 calendar days. Corrective Action Plan: It is a compliance requirement to report Pell files to the Department of Education through the COD system. 27 student files were identified as a compliance finding out of the 40 students sampled. This is a repeat finding from the prior year (June 30, 2021), but had not been an issue in previous audits. The Office of Financial Aid has experienced significant turnover in its staffing during fiscal years June 30, 2021 and 2022. This included employing two different Directors, the second of which vacated the position in June 2022. The staffing of the Financial Aid Office has since stabilized and the new Director has implemented practices whereby the office is now receiving and sending files to the COD system daily. This allows for resolving issues/rejects much sooner and within the 15-day timeframe. The Director has also conducted training with financial aid staff to emphasize the importance of sending files and resolving issues in a timely fashion. Anticipated Completion Date: August 31, 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) Certain key line items within submitted FISAP report did not agree to source documentation. Corrective Action Plan: The College recognizes the importance of completing the FISAP in a timely and accurate manner. The Office of Financial Aid has experienced significant turnover in its staffing during fiscal years June 30, 2021 and 2022. This included employing two different Directors, the second of which vacated the position in June 2022. The staffing of the Financial Aid Office has since stabilized and the new Director assumed the role in August 2022 and has updated the procedures related to preparation of the FISAP report to ensure timely and accurate reporting. 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 40 students tested, refund was processed outside of the 14-day required time frame from initial date credit balance was created to date credit refund was paid back to the student. Corrective Action Plan: This finding relates to aid that was disbursed in January 2022. A miscommunication occurred between the Financial Aid Office and the Business Office, and the Student Accounts Manager was not made aware the aid had been disbursed and a refund was due to the student. As a result of a similar finding during the June 30, 2021 audit, the College changed its policy as of February 15, 2022. The Student Accounts Manager is now completing timely reviews of credit balances on student accounts and coordinating with the Financial Aid Office to expedite its review of the student?s financial aid to insure all FSA credit balances are refunded to students within the required timeframe. Anticipated Completion Date: February 15, 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 2 students tested, the student was in V5 tracking group, his Identity/Statement of Educational Purpose form was signed and received as of 11/17/21 which is after first title IV disbursement. Per IFAP verification guide. "No disbursements of Title IV aid may be made until the V5 verification is satisfactorily completed." Corrective Action Plan: The College acknowledges institutions are required to verify applications selected by the Central Processing System for students who will receive or have received need based/subsidized student financial assistance. As permitted in federal regulations (34 CFR 668.54(b)), verification is not required for students who are only eligible for unsubsidized student financial assistance. Students in this situation are noted as ?Selected, not verified? to COD. At Presbyterian College, graduate and professional students only receive unsubsidized federal financial assistance, so only those selected in the ?V4? and ?V5? verification groups are required to complete the verification requirements of these groups. The Office of Financial Aid has experienced significant turnover in its staffing during fiscal years June 30, 2021 and 2022. This included employing two different Directors, the second of which vacated the position in June 2022. The staffing of the Financial Aid Office has since stabilized and the new Director has implemented procedures for the 2023-2024 academic year through Banner (software) setup that prevents disbursement of federal aid with any outstanding fund or non-fund requirements. Any student with V1, V4, or V5 set on the ISIR will automatically populate outstanding requirements. Aid will not disburse until those are fully satisfied. Anticipated Completion Date: March 1, 2023

Management concurs with the finding and recommendations. Isabella Graham Hart School of Nursing (the School) has revised its Enrollment Status Reporting procedures and provided training to ensure changes are submitted and reported on time. The above procedures have been implemented.

Management concurs with the finding and recommendations. Isabella Graham Hart School of Nursing (the School) recognizes that our Student Information System (SIS) used to monitor and manage the credit balances for students is limited in its capabilities. We are in process of implementing a new SIS that has ability to perform the necessary requirements to ensure we are processing any credit balance within the required time permitted. The School has implemented a weekly process of monitoring credit balances through the utilization of a Credit report, along with issuing payments if needed on a weekly basis to students. Implementation of the new SIS in expected to be completed in 2024 and in the interim have begun a weekly manual monitoring process.

2022-005 - Enrollment Reporting Federal Pell Grant Program; Federal Direct Student Loans - Assistance Listing No. 84.063, 84.268 Recommendation: We recommend the University evaluate its procedures and review policies in overseeing submissions to the NSLDS completed by the third-party servicer. Additionally, we recommend the University review its policies and procedures on reporting enrollment and program information to the NSLDS to ensure that all relevant information is being captured and reported timely in accordance with applicable regulations. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Felician University has evaluated and updated our procedures in overseeing submission to NSLDS and notified the appropriate staff. Management will monitor this issue regularly during the year to ensure compliance. Name(s) of the contact person(s) responsible for corrective action: Cynthia Montalvo, Assistant Vice President of Enrollment Planned completion date for corrective action plan: March 1, 2023

From: Daniel Ayala, District Director Center of Student Information Subject: Corrective Action Plan for Audit Finding 2022-001 Finding 2022-001: Enrollment Reporting Submissions for Graduates Views of Responsible Officials and Planned Corrective Actions Due to a changes in record processing and the addition of a new audit report at the National Student Clearinghouse (NSC), additional steps were needed at the institutional level to guarantee the accurate reporting of student graduation status. To ensure correct and comprehensive reporting of students as ?graduated?, the Alamo Colleges District Center for Student Information (CSI) has implemented a three step process: 1) submitting a sixth submission audit per semester (recommended by NSC) which will provide graduated student information to NSC; 2) review of the DegreeVerify exceptions report each semester to identify any needed corrections and/or updates to report to NSC; and 3) completion and review of these processes will be done by a CSI Enrollment Service Professional and CSI Director and documented (signed off) on the monthly compliance certificate form. With these processes in place, CSI will be in line with NSC recommendations and allow the National Student Loan Data System (NSLDS) to align with correct graduation dates. At this time, all needed corrections to student ?graduated? status have been completed. Implementation Date: November 2022 Responsible Persons: Dr. Adelina S. Silva, Vice Chancellor of Student Success;

Federal Program Title: Student Financial Aid Cluster (SFA) ALN Number: 84.007, 84.038, 84.063, 84.268, and 84.379 Recommendation: We recommend that the SFA department work with the campus registrar?s office to develop an alternative process that will enable the student financial aid office to review and correct the last dates of attendance and enrollment status prior to being reported to the Clearinghouse. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned/taken in response to finding: The student financial aid director will coordinate with the registrar to implement a process by which the student financial aid director can review and edit student enrollment effective dates prior to the data being sent to NSLDS. Name(s) of the contact person(s) responsible for corrective action: David Fisher, dlfisher@neo.edu Planned completion date for corrective action plan: June 30, 2023

Federal Program Title: Student Financial Aid Cluster (SFA) ALN Number: 84.007, 84.038, 84.063, 84.268, and 84.379 Recommendation: CLA recommends the institution review student activity logs in Canvas when determining an online student?s last date of attendance. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned/taken in response to finding: Students in the sample have had their records updated to reflect the correct enrollment effective date in NSLDS. Going forward, professors and the student financial aid department will review online course attendance when determining the last date of attendance for online courses. Name(s) of the contact person(s) responsible for corrective action: David Fisher, dlfisher@neo.edu Planned completion date for corrective action plan: June 30, 2023

FINDING 2022-003 ? Subsidized Loan Allocation Condition Found: The amount of Subsidized and Unsubsidized Federal Direct Loans awarded was incorrect for one of the fifty-four students in our sample that received Federal Direct Loans. Corrective Action Plan: The Financial Aid Director updated reallocated $1,407 of unsubsidized loan funds as subsidized loan funds on August 3, 2022. Procedures will be improved to ensure that subsidized loan eligibility is reviewed before awarding unsubsidized loans. Anticipated Completion Date: The corrective action was completed on August 3, 2022. Contact Person Tirzah Knight, Director of Financial Aid 918-335-6252

FINDING 2022-002 ? Federal Direct Loan Exit Interview Condition Found: A Federal Direct Loan exit interview was not completed by nor were instructions sent to the student on how to complete an exit interview when the student graduated from the University. This omission occurred for one of the sixty students in our sample. Corrective Action Plan: Federal Direct Loan exit interview information was sent to the student in question on August 3, 2022. Procedures will be improved to ensure Federal Direct Loan exit interviews are completed or information is sent to students when they cease enrollment at the University. Anticipated Completion Date: The corrective action was completed on August 3, 2022. Contact Person Tirzah Knight, Director of Financial Aid 918-335-6252

FINDING 2022-001 ? NSLDS Reporting Condition Found: The incorrect last date of attendance was reported to the National Student Loan Database System (?NSLDS?) incorrectly for two of the sixty students selected for testing. Corrective Action Plan: The Financial Aid Director updated the withdrawal dates in NSLDS for the student in question on August 3, 2022. Procedures will be improved to ensure that the correct withdrawal date is reported in NSLDS. Anticipated Completion Date: The corrective action was completed on August 3, 2022. Contact Person Tirzah Knight, Director of Financial Aid 918-335-6252

Finding 2022-001 - U.S. Department of Education (USDE). Title IV Student Financial Aid Programs (material weakness}: We observed the following conditions in connection with our testing of the various U.S. Department of Education, Title IV, Student Financial Assistance Programs. a. Three (3) out of 60 students tested had missing official transcripts with total questioned costs of $36,516. b. Twelve (12) out of 26 students tested did not have refunds given to students within the required 14 days. c. Two (2) out of six (6) students tested for R2T4 did not have Title IV funds returned to the Federal government within the required 45 days. The University should implement corrective actions to ensure that the above findings are resolved and will nor recur in future periods. Corrective Action - The College concurs with the finding. The College continues to be challenged with finding qualified staff in the Financial Aid Office and Business Office. The College will be working closely with staffing companies to identify qualified personnel. The College is working diligently to ensure all positions are filled to ensure compliance with all federal and state regulations. We understand the seriousness of these findings and implementing appropriate strategies to minimize and/or eliminatefurther auditfindings. TheCollege plans to start implementing these strategies beginning July 1, 2023.

Finding 2022-001 - U.S. Department of Education (USDE}, Title IV Student Financial Aid Programs (Significant Deficiency): We observed the following conditions in connection with our testing of the various U. S. Department of Education, Title IV, Student Financial Assistance Programs: ? Title IV awards for six (6) of twelve (12) students sampled for Return of Title IV (R2T4) did not have funding returned within the required 45-day time frame with total questioned costs of $18,768. ? The College had differences in the following programs which were not reconciled to the general ledger: Program Description Federal Work-Study Federal Direct Student Loans ? FISAP Work-Study totals did not match general ledger totals. Recommendation - We recommend the College implement corrective actions to ensure the above findings are resolved and do not recur in future periods. Moreover, internal controls over compliance with Federal program regulations should be revisited to ensure adequate supervisory controls, quality assurance reviews of compliance steps, technical training of staff, and adequate procedures are being followed for compliance purposes. Corrective Action - The Office of Financial Aid understands the seriousness of these findings and are implementing appropriate strategies to minimize and/or eliminate further audit findings, including: ? Conduct monthly reconciliations between the Business and Financial Aid Offices reviewed and approved by the Vice President of Finance and Administration. ? Provide specialized Title IV training for the Financial Aid staff through resources and services provided by our auditors, The Wesley Peachtree Group, CPAs to improve and ensure processes align with federal reporting guidelines.

Finding 2021-002 ? U.S. Department of Education (USDE), Title IV Student Financial Assistance Programs (Significant Deficiencies): We observed the following condition in connection with our testing of the various U. S. Department of Education, Title IV, Student Financial Assistance Programs: a) Two (2) out of 60 students selected for R2T4 testing did not have his/her funds returned to the U.S. Department of Education within the required 45 days. b) The College had differences in the following programs which were not reconciled to the general ledger: Federal Work Study, Federal Pell Grant, Federal Direct Student Loans and Federal Supplemental Educational Opportunity Grant (SEOG). Recommendation: The College should implement corrective actions to ensure that the above findings are resolved and does not recur in future periods. Moreover, internal controls over compliance with federal program regulations should be revisited to ensure adequate supervisory controls, quality assurance reviews of compliance steps, technical training of staff, and adequate procedures are being followed for compliance purposes. Corrective Action ? a) The two (2) students cited were oversights and the R2T4 funds have been returned. Official Withdrawal Notifications are scheduled bi-weekly, and the Unofficial Notifications are scheduled for the end of the semester. b) As previously mentioned, the College experienced significant turnover in the Business Office, responsible for the reconciliations, during 2022. We are in the process of replacing staff and recently hired a new CFO. The required reconciliations will be completed on a timely basis going forward.

(Significant Deficiency) We observed the following conditions in connection with our testing of the various U. S. Department of Education, Title IV, Student Financial Assistance Programs: 1. Enrollment status reporting to NSLDS for four (4) students tested was not provided as required by Federal regulations. 2. The Center did not provide the Common Origination and Disbursement (COD) funding report for the entire 2021-2022 award year for Federal Direct Loans. As of the report date, the Center had requested it from the U.S. Department of Education. Recommendation ? The Center should implement corrective actions to ensure that the above findings are resolved and do not recur in future periods. Moreover, internal controls over compliance with federal program regulations should be revisited to ensure adequate supervisory controls, quality assurance reviews of compliance steps, technical training of staff, and adequate procedures are being followed for compliance purposes. Corrective Action ? The enrollment information was provided to the FA auditor and several inquiries were made for verification and no timely response was received from the FA auditor. Three versions of the COD reports were provided along with several inquiries for confirmation that the report is what was needed. No timely response was made to our request. Management further explained that it takes 24 hrs. to receive the revised report if what was submitted was not what was needed, again no timely response from the FA auditor.

Finding 2022-006: Material Weakness - Federal Direct Student Loan Enrollment Reporting Repeat of Prior Year Finding 2021-004 Condition: For 12 students tested, the incorrect enrollment status was reported to the National Student Loan Data System (NSLDS). For 21 students tested, the effective date of the change of enrollment status that was reported to NSLDS did not match the University's records. For 11 students tested, the change of enrollment status was not reported within the 60 day requirement. For 6 students tested, in the program-level record, the student's program begin date that was reported to NSLDS did not match the University's records. For 9 students tested, in the program-level record, the program length reported to NSLDS did not match the University's records. For 1 student tested, in the program-level record, the program the student was enrolled in, and the related Classification of Instructional Programs (CIP) code, reported to NSLDS did not match the University's records. Corrective Action: Briar Cliff will work with Ellucian on a review of the setup and processes that the Registrar's Office currently follows and we will work with Ellucian for recommendations on implementing a process/procedure that ensures the Registrar's Office has been trained and is in compliance. Person Responsible for Corrective Action: Matt Thomsen VP of Enrollment; Todd Knealing VP of Academic Affairs Anticipated Completion Date: 8/1/2023

Finding 2022-005: Perkins Loan Recordkeeping and Record Retention Condition: For 1 borrower selected for testing, the University was unable to locate the original signed MPN. Corrective Action: Briar Cliff University has maintained all records related to Perkins loan, even though these loans have been discontinued since September 2017. The University has no intentions to delete or remove any documents until the time is appropriate. The current staff unfortunately was not employed when these records were originally collected or reviewed. Person Responsible for Corrective Action: Ann M. Oatman - Interim VP of Finance Anticipated Completion Date: 4/1/2023

Finding 2022-004: Significant Deficiency - Return of Title IV Funds Calculations Condition: For 3 students selected for testing, the amount of the title IV refund was calculated incorrectly. Corrective Action: The errors were made because the incorrect terms dates were entered into Colleague by the Registrar's Office. Moving forward, the Financial Aid office will work with the Registrar's Office to ensure the term dates are entered correctly in Colleague. After the Registrar's Office enters the term dates in Colleague, the Associate Vice President of Student Financial Systems will review the entries for accuracy. Person Responsible for Corrective Action: Matt Thomsen - VP of Enrollment; Todd Knealing VP of Academic Affairs Anticipated Completion Date: 8/1/2023

Finding 2022-002 - U.S. Department of Education (USDE). Title IV Student Financial Aid Programs: We observed the folfowing conditions in connection with our testing of the various U.S. Department of Education, Title IV, Student Financial Assistance Programs. ? We noted in our testing that one (1) out of twenty-five (25) students selected for R2T4 testing did not have his/herfunds returned to the U.S. Department of Education within the required 45 days. Corrective Action - Management concurs with observation. The College has implemented corrective actions to ensure that the above finding is resolved and will not recur in future periods.

Finding 2022-002 - U.S. Department of Education (USDEJ. Title IV Student Financial Aid Programs (deficiency}: We observed the following conditions in connection with our testing of the various U.S. Department of Education, Title IV, Student Financial Assistance Programs: 1. One (1) out of 10 students tested did not have timely or accurate enrollment reporting to the National Student Loan Data System (NSLDS). 2. One (1) out of 60 students tested was overpaid Pell funds. The over awarded funds were subsequently returned. 3. One (1) out of 60 students tested was not eligible for but was awarded Federal Supplemental Educational Opportunity Grant (FSEOG). The University subsequently returned the ineligible grant amount. 4. One (1) out of 60 students tested showed a discrepancy during verification testing where we observed tax documents submitted with an incorrect social security number. The questioned cost is $5,195. 5. Two (2) out of Five (S) students tested did not show the returned amount on the student's statement of account during R2T4 testing. Both statements of account were subsequently updated with the returned amounts. Corrective Actions - 1. NSLDS reporting is actively reconciled monthly with our financial aid servicer and, as of August 18, 2022, the University confirmed 97.18% reported. The University will continue to actively monitor this reporting to ensure accuracy and timeliness. 2. The University will monitor and review the process of enrollment more thoroughly with the third-party financial aid processor to ensure all non-enrolled students are not included in payment batches. The University has moved to a new third-party financial aid processor in a further effort to ensure compliance with Title IV regulations. 3. The University will monitor and review the process of enrollment more thoroughly with the third-party financial aid processor to ensure all non-enrolled students are not included in payment batches. The University has moved to a new third-party financial aid processor in a further effort to ensure compliance with Title IV regulations. 4. The University will monitor and review the process of verification more thoroughly with the third-party financial aid processor to ensure all applicable steps are taken and that all information is accurate. The University has moved to a new third-party financial aid processor in a further effort to ensure compliance with Title IV regulations. 5. The University has implemented a new student information system, as well as processes to ensure that Title IV transactions are applied timely to student ledgers. The University also notes that, in the case of this finding, the Title IV funds were returned timely and accurately.

Finding 2022-001 U S DOE Title IV Student Financial Aid Programs (significant deficiency): The auditors observed the following conditions in connection with our testing of the various U.S. Department of Education, Title IV, Student Financial Assistance Programs. a) One (1) out of six (6) student files tested did not have their Title IV funds returned within the required 45 days. b) Two (2) out of sixty (60) student files tested did not have their refund issued within the required 14 days. The college should implement corrective actions to ensure that the above findings are resolved and will not reoccur in future periods. The College?s Corrective Plan: (a) The College accepts the auditor?s recommendation. The College?s Registrars Office and Financial Aid Office will coordinate and communicate relating to student enrollment to ensure that information is reported timely. (b) The College accepts the auditor?s recommendation. The Business Office has reviewed its information retrieval process to ensure that the correct parameters are being used for information retrieval purposes

A. Comments on Findings and Recommendations: We agree with the finding and recommendation. B. Actions Taken or Planned: By November, the Vice President of Financial Aid will update the Withdrawal Checklist to include a final enrollment field to notate the number of hours enrolled. The Withdrawal Checklist will also include a checkbox to notate that all financial aid has been updated to the proper enrollment status prior to completing the R2T4 calculation.