Corrective Action Plans

Finding No. 2022 009: Eligibility, Activities Allowed or Unallowed, Allowable Cost (Material Weakness) Federal Agency: U.S. Department of Health and Human Services AL Number and Title: 93.090 and COVID 19 ? 93.090 ? Guardianship Assistance Award Number and Award Year: 2101HIGARD, 2201HIGARD Condition We selected a non statistical sample of 60 case files which approximated $55,000 in monthly benefit payments, out of a population of approximately 380 case files which approximated $3.9 million in total annual benefit payments, for testing and noted exceptions in 17 case files as follows: ? Seven case files where the initial or modified guardianship/permanency assistance agreement was missing and therefore did not have any support for the amount of monthly assistance paid. ? Four case files where the ?difficulty of care? determination was missing and therefore did not have any support for the assistance amount paid. ? One case file where we were unable to determine if a child who attained the age of 14 was consulted regarding the kinship guardianship agreement. ? Three case files where the State, Federal Bureau of Investigation, and/or child abuse and neglect clearances were missing in the case files. ? Two case files where documentation regarding continuation of monthly subsidy payments after the child?s 18th birthday was missing. ? One case file where the supporting documentation regarding whether the State determined that the guardian/permanent custodian has a strong commitment to caring permanently for the child was missing. Views of Responding Officials: The Department agrees with the finding and will implement corrective action. Corrective Action Taken or Planned: 1. Child Welfare Service (CWS) will make a note in each specific case record identified in this audit explaining the audit findings, and secure missing/incomplete eligibility documents for cases identified in the audit. 2. The identified errors and the related corrective action step above will be reviewed by CWS Administrators, staff supervisors, and the Management Information Compliance Unit (MICU) within ninety days to ensure missing documentation has been secured and properly noted in record. ? Additionally, the MICU will complete a random Guardianship Agreement audit review approximately six months later. i. MICU will share random audit findings with CWS Administration. ii. CWS Administrators will take corrective action based on MICU audit findings. 3. CWS supervisors will ensure that line staff are familiar with these policies and procedures and monitor through individual supervision meetings and work product review. ? Staff with errors identified in this audit, during individual supervision meetings or through work product review will: i. Be given coaching/supervisory support to correctly complete documentation. ii. Be required to participate in refresher training on Title IV-E Foster Custody, which is offered three times a year with participation documented by Staff Development Office. ? All staff who manage payment-only cases will review a quarter of their cases each month with their supervisor, during monthly supervision. i. Each month a different quarter of their cases will be reviewed, so that all cases are reviewed three times a year. ii. During this review between the supervisor and the staff, documentation in the case file, as well as Child Protective Services System (CPSS) coding and payments, will be examined for completeness and accuracy. iii. Needed corrections will be made to the documents and/or CPSS, as identified in the monthly reviews. iv. If a supervisor notices consistent errors by a staff member in Guardianship Agreement documentation, they shall refer the staff to the Staff Development Office for refresher training. v. The supervisor shall document which cases were reviewed each month. 4. At the next Management Leadership Team meeting, CWS Branch Administrators will share with staff the results of this audit, explaining the direct correlation between documentation (or lack thereof) and financial penalties to the State. ? Reminder conversation about this audit and the importance of following current policies and procedures will be held during CWS weekly huddles. 5. As CWS implements this corrective action plan and monitors the results, the action steps proposed in one through four may be modified based on input from CWS Administrators and/or focus/exploration groups with line staff who complete this documentation. Expected Completion Date: May 31, 2023 Responding Officials: Kisha C. Raby, Social Services Division Program Development Administrator, Elladine Olevao, Social Services Division Child Welfare Social Services Manager, and Carolina Anagaran, Social Services Division Administrative Officer

Finding No. 2022 008: Eligibility, Activities Allowed or Unallowed, Allowable Cost (Material Weakness) Federal Agency: U.S. Department of Health and Human Services AL Number and Title: 93.659 and COVID 19 ? 93.659 ? Adoption Assistance Award Number and Award Year: 2101HIADPT, 2201HIADPT Condition We selected a non statistical sample of 60 case files which approximated $33,000 in monthly benefit payments, out of a population of approximately 2,500 case files which approximated $15.4 million in total annual benefit payments, for testing and noted exceptions in 38 case files as follows: ? 19 case files where the initial or modified adoption agreement was missing and therefore did not have any support for the amount of monthly assistance paid. ? 21 case files where the State, Federal Bureau of Investigation, and/or child abuse and neglect clearances were missing. ? Eight case files where the ?difficulty of care? determination was missing and therefore did not have any support for the assistance amount paid. ? Eight case files where documentation of a child?s special needs was missing. ? Eight case files where the supporting documentation regarding whether the State determined that the child cannot or should not be returned to the home of his or her parents was missing. ? One case file where documentation of monthly non-recurring expenses was missing. ? One case file where documentation regarding continuation of monthly subsidy payments after the child?s 18th birthday was missing. ? One case file where the final approval was granted to a household with an individual who was convicted of spousal abuse. ? Five case files where the adoption decree was missing from the case records. Views of Responding Officials: The Department agrees with the finding and will implement corrective action. Corrective Action Taken or Planned: Views of Responding Officials: The Department agrees with the finding and will implement corrective action. Corrective Action Taken or Planned: 1. Child Welfare Service (CWS) will make a note in each specific case record identified in this audit explaining the audit findings, and ? secure current modified adoption agreements for the nineteen missing documents, ? locate missing clearances for the twenty-one cases or re-run them if not located, Note: Not all clearances are secured prior to placement; Federal Bureau of Investigations (FBI) clearances come later and are NOT required prior to placement in a ?provisionally licensed? home. ? document the need precipitating Difficulty of Care (DOC) determination for the 8 records, showing how DOC was calculated. i. ensure that the written Adoption Assistance Agreement (AAA) matches the calculations and amount in the payment system or update/modify the AAA as appropriate, ? secure documentation of child?s special needs for the eight cases, noting categorical eligibility qualification as special needs for children adopted from foster care. Note: Hawaii is in the process of developing its new Comprehensive Child Welfare Information System (CCWIS) and plans to use this system to automatically code children in foster care as meeting the eligibility criteria for special needs. ? secure a copy of the court order which specified that the child should not be returned home, i.e., the order containing the ?contrary to the child?s welfare? language for the eight cases, ? document monthly non-recurring expenses in the missing case, ? document the reason for continuation of monthly subsidy payments after the child?s eighteenth birthday in one case, ? research/review and document why final approval was granted to a household with an individual who was convicted of spousal abuse. i. If review determines that AAA was inappropriately authorized, provide family with an adverse action notice discontinuing the AA and explaining the appeals process, ? Although adoption assistance is an incentive program with payment beginning prior to the finalization of an adoption, secure a copy of the five missing adoption decrees. Note: The adoption decree is NOT required for payment as the AAA must be entered prior to the finalization of an adoption. 2. The identified errors and the related corrective action steps proposed above will be reviewed by CWS Administrators, staff supervisors, and the Management Information Compliance Unit (MICU) within ninety days to ensure missing documentation has been secured and/or properly noted in record. ? Additionally, the MICU will complete a random AA audit review approximately six months later. i. MICU will share random audit findings with CWS Administrators. ii. CWS Administrators will take corrective action based on MICU audit findings. 3. CWS supervisors and Social Services Division (SSD) Staff Development Specialists will ensure that line staff are familiar with these policies and procedures through individual supervision meetings and work product review. ? Staff with errors identified in this audit, consistent errors identified during individual supervision meetings or through work product review will: i. be given coaching/supervisory support to correctly complete documentation, ii. be required to participate in refresher training on Title IV-E Foster Custody, which is offered three times a year with participation documented by Staff Development Office. iii. During this review between the supervisor and the staff, documentation in the case file, as well as Child Protective Services System (CPSS) coding and payments, will be examined for completeness and consistency. iv. Needed corrections will be made to the documents and/or CPSS, as identified in the monthly reviews. 4. In consultation with the Department of Accounting and General Services (DAGS), CWS will develop and implement a new AAA form which identifies payment amounts by age, informing families of the progression. This will eliminate the need for a new agreement when a child moves from one payment category to another, as they age. ? Should the standard AA amounts change, an addendum to this universal agreement will be sent to families noting the change(s). ? Once a new AAA form has been created, the Staff Development Office will update the AA training module to include this new form and offer the updated training in the regular training rotation. 5. At the next Management Leadership Team meeting, CWS Branch Administrators will share with staff the results of this audit, explaining the direct correlation between documentation (or lack thereof) and financial penalties to the State. 6. As CWS implements this corrective action plan and monitors the results, the action steps proposed in one through five may be modified, based on input from CWS Administrators and/or focus/exploration groups with line staff who complete this documentation. Expected Completion Date: May 31, 2023 Responding Officials: Kisha C. Raby, Social Services Division Program Development Administrator, Elladine Olevao, Social Services Division Child Welfare Social Services Manager, and Carolina Anagaran, Social Services Division Administrative Officer

Finding Number: 2022-004 Condition: Certain credit balances were not refunded to students within 14 days. Planned Corrective Action: Identify one or more additional staff members who can perform this function in the event of illness or absence, cross-train these individuals, and ensure permissions are granted, ensuring appropriate segregation of duties. Contact person responsible for corrective action: Matt Beattie, Mark Schroeder Anticipated Completion Date: February 28, 2023

Finding Number: 2022-002 (repeat finding) Condition: The student status changes for certain students with status changes were not reported accurately and/or within 60 days. Additionally, certain students were reported within correct effective dates. Planned Corrective Action: Enrollment Services is working with IT on an error report and ongoing review process to identify reporting errors for timely correction. Contact person responsible for corrective action: Dina DuBuis, Assistant Vice President, Enrollment Services and Registrar Anticipated Completion Date: February 1st, 2023

Finding Number: 2022-003 Condition: The University could not provide records to substantiate that the relevant criteria was complied with by the University in all cases. Planned Corrective Action: Train faculty to preserve and provide documentation related to reported last dates of attendance. This will be stored in the university?s enterprise document management system. Contact person responsible for corrective action: Dina DuBuis, Ann Elinski Anticipated Completion Date: February 15, 2023

Finding Number: 2022-004 Condition: Of the 40 students tested for NSLDS Enrollment Reporting, the University: -For 3 students, reported the status change with incorrect effective dates -For 2 students, reported the status change to NSLDS in an untimely manner Planned corrective Action: The new person hired as the Assistant Registrar for Special Programs and Compliance was officially hired on January 11, 2022. She has gone through training for both NSC and NSLDS. She is and will continue to work closely with Financial Aid related to status change dates and reporting data to the NSLDS. She is responsible for dealing with NSLDS error reports. Contact person responsible for corrective action: Noreen Ferguson, University Registrar Anticipated Completion Date: June 30, 2022. The responsibilities of this position are completed. There will be ongoing training as training sessions become available either through NSC or NSLDS.

Finding Number: 2022-003 Condition: Of the 21 students selected for Return to Title IV testing, the University: -For 4 of the students, utilized inappropriate withdrawal dates -For 2 of the students, inaccurately calculated returns -For 5 of the students, returned funds in an untimely manner -For 1 of the students, student authorization wasn?t obtained prior to crediting account for post-withdrawal disbursement Planned corrective Action: One Stop Center staff were retrained on September 7th on the process of backdating a drop/withdraw to the appropriate date. This training will continue to be ongoing to be sure they are aware and understand the importance of the backdating being accurate. An error report has been created that can identify if the last date of attendance is equal to the date the transaction took place. If students appear on this report further investigations will be done to determine if it is the accurate date to use. R2T4 calculations are always processed on students who withdraw without regard to percentage of time attended. The staff will continue to process R2T4 in Banner for withdrawn students who receive federal aid, with a secondary calculation using the COD online R2T4 calculator to confirm outcomes. The student found regarding post-withdrawal was an oversight. Notification letters will be mailed to students who are eligible for the Post Withdrawal disbursements requesting the student acceptance of offered aid. This area will also become a review item in our process to review R2T4 calculations weekly. Contact person responsible for corrective action: Noreen Ferguson, University Registrar Anticipated Completion Date: September 7, 2022. The error report is already developed and in use. The additional training will be ongoing.

Corrective Action Plan The University will update written procedures to include an additional manual process, which identifies and updates withdrawals within the National Student Clearinghouse with a higher frequency. These procedures are targeted for the summer term, in which the current year lapse was identified. This will ensure that no one is reported outside of the 60 day window.

Incorrect Enrollment Reporting to National Student Loan Data System (NSLDS) Planned Corrective Action: In late June 2022, known settings and data required by the baseline report were in place, and a small sample of test records passed a basic test. In July 2022, full-term data generated by the PowerCAMPUS baseline tool was submitted to NSCH as a more extensive test for Summer 2022. Due to the discovery of a significant number of SIS data errors for at least two major categories and a quickly approaching deadline, the previous tool was used for that end-of-term enrollment data. In addition, the previous tool was used for earlier registration reporting within the Fall 2022 term. The PowerCAMPUS baseline tool is being updated and tested again during the Fall 2022 term with anticipation that the baseline tool will be used for reporting the final end-of-term enrollment data reported in January 2023. Person Responsible for Corrective Action Plan: Cagan Cummings, CIO and Christy Miller, Executive Director of Financial Aid Anticipated Date of Completion: January 2023

Finding Number: 2022-001 Planned Corrective Action: The School District has already implemented policies and procedures to ensure timely updating and has documented the remedies taken for the items noted as noncompliant in the audit. Anticipated Completion Date: January 31, 2023 Responsible Contact Person: Donna Solano, Financial Aid Coordinator

2022-007 Gramm-Leach-Bliley Act Award Period: July 1, 2021 to June 30, 2022 Type of Finding: Significant Deficiency in Internal Control over Compliance; Other Matters Recommendation: We recommend that the College engage a third party or perform the risk assessment for the three areas required by the Gramm-Leach-Bliley Act and ensure that there are documented safeguards for identified risks. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Tabor College is currently meeting with companies who provide services to assist with meeting the requirements of the Gramm-Leach-Bliley Act. Name(s) of the contact person(s) responsible for corrective action: Cathy Castle, Vice President for Business and Finance Planned completion date for corrective action plan: April 2023 and ongoing. If the Department of Education has questions regarding this plan, please call Cathy Castle at 620-947-3121 x 1056.

2022-004 National Student Loan Data System (NSLDS) Award Period: July 1, 2021 to June 30, 2022 Type of Finding: Significant Deficiency in Internal Control over Compliance; Other Matters Recommendation: We recommend the College review its reporting procedures to ensure the students' statuses are accurately reported to NSLDS as required by regulations. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Tabor College utilizes a clearing house for submitting student statuses. Tabor will ensure that all students statuses are filed accurately and timely. Name(s) of the contact person(s) responsible for corrective action: Scott Franz, Interim Financial Aid Director Planned completion date for corrective action plan: April 2023

2022-003 Return of Title IV (R2T4) Award Period: July 1, 2021 to June 30, 2022 Type of Finding: Significant Deficiency in Internal Control over Compliance; Other Matters Recommendation: We recommend the College review the return of Title IV funds requirements and implement procedures to ensure the return of Title IV funds calculations are using the correct number of break days and are accurately completed. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Tabor College will ensure the correct number days are used in all R2T4 calculations, including times when there are break days during the school term. Name(s) of the contact person(s) responsible for corrective action: Scott Franz, Interim Financial Aid Director Planned completion date for corrective action plan: This has begun with the 2022-23 school term

The College will put additional processes in place to ensure that student information is reviewed and reconciled between the NSC and NSLDS systems.

Finding 2022-001: Enrollment Reporting Federal Program - Federal Direct Student Loans Federal Agency - U.S. Department of Education Pass-Through Entity - Not Applicable CFDA Number - 84.268 Federal Award Year - June 30, 2022 Condition/Context: The change in student status for 1 out of 25 students tested was not reported to the National Student Loan Data System (NSLDS) within 30 days or included in a response to a roster file within 60 days. The student withdrew in September 2021 but was not reported until December 2021. Views of Responsible Officials and Planned Corrective Actions: The College agrees with the finding. The Office of Academic Success now notifies all pertinent offices of any student withdrawals in a timely manner. In addition, if a student withdraws with more than a week between their withdrawal and the last day of attendance, their change in status notification is processed immediately in NSLDS by the Registrar?s office. The Registrar also performs a monthly review of all status changes to verify all enrollment status changes are updated accurately and reported to NSLDS within the required timeframe. Names of Contact Persons Responsible for Corrective Action: Barbara Schmitt, Director of Financial Aid and Dan Cebrick, Registrar Anticipated Completion Date: Changes were effective for Fall 2022 semester.

2022-003: Loan disbursement notifications {14 day right-to-cancel letters). Management Views and Opinion The University of Miami acknowledges that some students did not receive their notifications informing them of the 14 day right-to-cancel for their Federal Direct Loans within the proscribed timeframe of 7 days from the date of disbursement. The root cause was a defect in the server set-up for our financial aid automated processing; the administrative software appeared to generate letters and provided no error message, however, notifications were not sent. Once identified by UM on October 21, 2021, UM sent notifications to any students not originally notified, however, this notification occurred outside the required window of time (7 days). Corrective Action The University has worked with the software provider to diagnose the issue as a missing instance of Microsoft Word on the server which processed the 14-day letters. We have addressed this issue and repaired the automated functionality as of September 21, 2022. During the down time, the university prepared these letters using a daily manual process to ensure that they were sent in a timely fashion. Timeline for Action Plan The issue was initially identified, and a temporary corrective action was put in place in October 2021 with a final correction in October 2022. Responsibre Individuals Daniel T. Barkowitz Roosevelt Deleveaux Beth Hernandez

2022-002: FOL and Pell Reporting Management Views and Opinion The University of Miami acknowledges that the disbursements as reflected on the individual student account were different by one day from the date reported to COD (Common Origination and Disbursement system). This error occurred due to the timing of scheduled jobs to run financial aid disbursement. The file process to disburse jobs ran late at night prior to midnight, but the job to post the disbursed aid ran after midnight and therefore showed a day later than reflected on the financial aid system. Corrective Action Plan In mid-August 2022, the University changed the evening job schedule to ensure that Federal financial aid will be both disbursed from the-financial aid system and posted to the Student Account on the same calendar day. This evening schedule job change will resolve this situation moving forward. Timeline for Action Plan The underlying issue was already corrected in August 2022. Responsible Individuals Daniel T. Barkowitz Roosevelt Deleveaux Norma De La 0

2022-001 Enrollment Reporting Management Views and Opinion Graduation Status Change UM management agrees that I out of 40 students had graduated but whose graduation status change was not reported at the campus or program level. While this student's graduation status change was not reported at the campus or program level, the student's record was reported as withdrawn within the allotted 60 days and therefore NSLDS was aware student was no longer enrolled. Enrollment Status Change UM management agrees that 14 out of 40 students' program level withdrawal date did not match their campus level withdrawal date. While all the students' withdrawal statuses were reported within the NSDLS guidelines and the final day of the Fall 2021 semester was used for their campus level withdrawal date, the first day of the Spring 2022 semester was incorrectly used for the program level withdrawal date. Corrective Action Plan Graduation Status Change Management will expand on the current controls in place by adding a review process for those student accounts that require manual status changes. Enrollment Status Change Management will expand on the current controls in place by adding a review process for those student accounts that require manual status updates based on the National Student Clearinghouse (NSC) Error Resolution Report. Timeline for Action Plan Graduation Status Change The review process for graduation status changes was implemented effective December 9, 2022. Enrollment Status Change The review process for enrollment status changes was implemented effective December 9, 2022. Responsible Individuals Allen Augustin, Associate Registrar

The finding was due to a human error. The Registrar?s Office failed to notify the Finance Division and Financial Aid Division of the student enrollment cancellation. These kinds of human errors will be prevented with the following procedure established by the university: Beginning with academic year 2022-2023 (August-2022), the university is taking the following measures: 1. A MSSharePoint was created in collaboration among the Registrar?s, Financial Aid and Finance Offices staff to serve as an easy access documentation repository and to enhance communication. Information of changes in the enrollment status of any student is documented internally for discussion among the offices (Monthly Withdrawal Conciliation Report). 2. Monthly meetings with the Registrar?s, Financial Aid and Finance Offices staff takes place. Personnel from the Institutional Effectiveness Office, and the Offices of the Dean and the Assistant Dean of Academic Affairs also attend to facilitate the discussion. During these meetings the three offices reconcile data on student enrollment status (as documented in the MSSharePoint). This best practice assures that: a. Student enrollment status is recorded accurately and on time. b. Withdrawal cases in which transactions are required with the USDoE are documented early so that funds are returned within the allowable prescribed period. c. As an extra bonus, communication is improved among the Registrar?s, Financial Aid and Finance Offices staff. 3. The dean of student affairs and the dean of academic affairs have provided faculty development seminars on the expectations of a faculty member to comply with federal regulations. Among the topics discussed is the importance of attendance recording and documentation. As well, faculty were required to refer to the Registrar?s and to the Dean of Admissions and Student Affairs Offices any student absent to two consecutive significant academic events. The purpose is: a. Early detection of a student that might be at risk of academic difficulties. b. Early awareness of a student that might be changing enrollment status. 4. To date four (4) attendance surveys have taken place taken place (3/semester). The attendance surveys provide the opportunity to capture any students at risk of changes in enrollment status. As a consequence, student enrollment status may be recorded accurately and on time and as well funds are returned to the USDoE within the allowable period. 5. Periodic letters to the faculty from the Office of the Dean of Academic Affairs to highlight the importance pf promptly referring any changes in student attendance to activate retention efforts or in order to identify and record accurately and on time any changes in student enrollment status.

This error was due to the fact that the professor did not notify that the student was missing. Instead, the student was graded as if she had completed the course.In order to prevent the recurrence of this error, the university has established the following procedure: 1. The dean of student affairs and the dean of academic affairs have provided faculty development seminars on the expectations of a faculty member to comply with federal regulations. Among the topics discussed is the importance of attendance recording and documentation. As well, faculty were required to refer to the Registrar?s and to the Dean of Admissions and Student Affairs Offices any student absent to two consecutive significant academic events. The purpose is: a. Early detection of a student that might be at risk of academic difficulties. b. Early awareness of a student that might be changing enrollment status. 2. To date four (4) attendance surveys have taken place (3/semester). The attendance surveys provide the opportunity to capture any students at risk of changes in enrollment status. As a consequence, student enrollment status may be recorded accurately and on time and as well funds are returned to the USDoE within the allowable period. 3. Periodic letters to the faculty from the Office of the Dean of Academic Affairs to highlight the importance of promptly referring any changes in student attendance to activate retention efforts or in order to identify and record accurately and on time any changes in student enrollment status.

An additional procedure was established since March 2023, incorporating a second checkpoint in the filling of the R2T4. After the filing, all dates required in the calculation of the withdrawal process (R2T4) will be reassured/validated by a different official at the Financial Aid Office other than the preparer. The reviewer will also initialize the R2T4 as evidence of the review and compliance with this new procedure. This system will help prevent human errors like this to occur again.

The identified instances were recorded before the university put in place the controls described below. In order to assure compliance with NSLDS reporting requirements, determinations of funds earned, and timing, beginning with academic year 2022-2023 (August-2022) the university is taking the following measures: 1. A MSSharePoint was created in collaboration among the Registrar?s, Financial Aid and Finance Offices staff to serve as an easy access documentation repository and to enhance communication. Information of changes in the enrollment status of any student is documented internally for discussion among the offices (Monthly Withdrawal Conciliation Report). 2. Monthly meetings with the Registrar?s, Financial Aid and Finance Offices staff takes place. Personnel from the Institutional Effectiveness Office, and the Offices of the Dean and the Assistant Dean of Academic Affairs will also attend to facilitate thediscussion. During these meetings the three offices reconcile data on student enrollment status (as documented in the MSSharePoint). This best practice assures that: a. Student enrollment status is recorded accurately and on time. b. Withdrawal cases in which transactions are required with the USDoE are documented early so that funds are returned within the allowable prescribed period. c. As an extra bonus, communication is improved among the Registrar?s, Financial Aid and Finance Offices staff. 3. The dean of student affairs and the dean of academic affairs have provided faculty development seminars on the expectations of a faculty member to comply with federal regulations. Among the topics discussed is the importance of attendance recording and documentation. As well, faculty were required to refer to the Registrar?s and to the Dean of Admissions and Student Affairs Offices any student absent totwo consecutive significant academic events. The purpose is: a. Early detection of a student that might be at risk of academic difficulties. b. Early awareness of a student that might be changing enrollment status. 4. To date four (4) attendance surveys have taken place (3/semester). The attendance surveys provide the opportunity to capture any students at risk of changes in enrollment status. As a consequence, student enrollment status may be recorded accurately and on time and as well funds are returned to the USDoE within the allowable period. 5. Periodic letter to the faculty from the Office of the Dean of Academic Affairs to highlight the importance to promptly refer any changes in student attendance to activate retention efforts or in order to identify and record accurately and on time any changes in student enrollment status. n addition to the above-mentioned procedures the following measures will be taken: 1. Late reporting of graduation dates in NSLDS and effective dates: a. Prior to graduation all academic program directors review the degrees to be conferred and certify candidates eligible for graduation b. The Registrar?s Office changes the status to graduate in the NSLDS Report after graduation date. c. To assure that all degrees are reported on time and accurately to the NSLDS system from now on, the Registrar?s Office, within ten days after graduation date, will process the changes in the NSLDS system. After the Registrar?s Office processes the changes in the NSLDS system, it will send to all program directors the list of all the students processed as graduated in the NSLDS system and they will be asked to double verify and attest accuracy of the lists of conferred degrees and asked to provide a certification within two days that the changes processed were accurate and that they agree with their record of students officially graduated during the last graduation date. This double certification of conferred degrees within the proposed time-frame will provide a second opportunity to add or delete any missing information within the NSLDS system increasing accuracy and timelines. d. A copy of the certification will be submitted to the Office of the Dean of Academic Affairs as evidence of the compliance with the new process established.

Student Financial Aid Cluster: Federal Pell Program ? Assistance Listing No. 84.063 Recommendation: We recommend the College review its current procedures for awarding Title IV funds and implement changes necessary to ensure federal funds are awarded and disbursed in accordance with federal regulations. We also recommend the College disburse the proper Pell award to these students. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: This was a Pell error due to COA calculation and assignment error. Procedures will be implemented to review COA components to confirm accuracy of COA which will result in correct Pell awards. Name(s) of the contact person(s) responsible for corrective action: Laura Hughes, Travis Osburn and John Bender. Planned completion date for corrective action plan: Immediate

Student Financial Aid Cluster: Federal Supplemental Educational Opportunity Grant ? Assistance Listing No. 84.007 Federal Work Study Program ? Assistance Listing No. 84.033 Federal Perkins Loan Program? Assistance Listing No. 84.038 Federal Pell Grant Program ? Assistance Listing No. 84.063 Federal Direct Student Loans ? Assistance Listing No. 84.268 Teacher Education Assistance. for College and Higher Education Grants? Assistance Listing No. 84.379 Nursing Student Loans ? Assistance Listing No. 93.364 Recommendation: We recommend the College review its current procedures for tracking SAP requirements and implement procedures to ensure SAP status is accurate. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Procedures will be implemented to select a random sample of students each term to confirm accuracy of SAP calculation. Name(s) of the contact person(s) responsible for corrective action: Laura Hughes, Travis Osburn and John Bender Planned completion date for corrective action plan: 06/01/2023

Student Financial Aid Cluster: Federal Supplemental Educational Opportunity Grant ? Assistance Listing No. 84.007 Federal Work Study Program ? Assistance Listing No. 84.033 Federal Perkins Loan Program? Assistance Listing No. 84.038 Federal Pell Grant Program ? Assistance Listing No. 84.063 Federal Direct Student Loans ? Assistance Listing No. 84.268 Teacher Education Assistance. for College and Higher Education Grants? Assistance Listing No. 84.379 Nursing Student Loans ? Assistance Listing No. 93.364 Recommendation: We recommend that the College work with their third party servicer and implement procedures to ensure that enrollment data, changes in status and effective dates within NSLDS are reported timely. And we recommend that the College implement formal review procedures to document the review process. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Procedures will be implemented to enhance the current process to ensure compliance and documentation of review process. The Registrar will formally document the review process for the initial reporting and all corrections submitted by the Assistant Registrar. The Financial Aid Team will expand the random review of select enrollment statuses and maintain documentation of such reviews. Name(s) of the contact person(s) responsible for corrective action: Soo Lee Bruce-Smith, Cheyenne Gaspar, Laura Hughes, Travis Osburn and John Bender Planned completion date for corrective action plan: April 15, 2023