Corrective Action Plans

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. ? Two (2) out of five (5) students tested for R2T4 calculations and refunds did not have funds returned back to the U.S. Department of Education within the required 45 days. Auditor?s Recommendation ? The University should implement corrective actions to ensure that the above finding is resolved and will not recur in future periods. Corrective Action ? With regard to the return of funds back to the U.S. Department of Education, employee turnover at the University caused this delay. The University returned all funds as required and is currently filling positions with competent employees to handle these processes.

Name of Responsible Individual: Melanie Mason, Director of Student Financial Aid Corrective Action: In the event any future award requires separate reporting on the FISAP, these awards will receive unique award codes in our Colleague system. During the process of developing the FISAP report, the Director of Financial Aid will generate Colleague reports to identify these awards and include in the report. Award totals per code will be validated by the Office of Finance for the University. Anticipated Completion Date: September 30, 2023

Name of Responsible Individual: Melanie Mason, Director of Student Financial Aid Corrective Action: The University will transition from a manual review process to an automated electronic process utilizing a combination of both Informer and Colleague reports. The process will compare components of the Cost of Attendance to the student?s current billing as of the census date. Each Financial Aid counselor will run the automated report for their students and freeze each student?s award budget. This freeze process will prevent any further changes to the award budget for the student. Confirmation of this review will be provided to the Director of Financial Aid by each counselor. The Director will verify the process has been completed. Anticipated Completion Date: March 31, 2023

Description of Finding: There was a sample of forty (40) students for which enrollment changes were reported to NSLDS. There was one (1) instance where the student information was rejected, and for which a correction was not made within the required 10 days. Corrective Action Plan: Uploads to the National Student Clearinghouse are now reviewed through a report which performs a pre-check for common errors in an effort to reduce the number of enrollment errors overall. The reject reports are monitored with every upload and are managed using the outlined best practices from the National Student Clearinghouse directly. The reject reports are managed within 10 days of receipt with any changes captured within the same timeframe. The responsible parties are Adam Evans at aevans@laverne.edu. This will be corrected by July 1, 2023.

2022-003 Student Financial Assistance Cluster ? Assistance Listing No. 84.038 Recommendation: We recommend the University evaluate its procedures around the retention of Perkins loans records to ensure that all records for open loans are being properly maintained. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The University will continue to identify open loan records with missing master promissory notes. As such loan records are identified, the University will take necessary measures to request permission to assign these loans to the Department of Education. As this work is ongoing, all current loan records will continue to be stored securely in the Bursar?s area. Name(s) of the contact person(s) responsible for corrective action: Rita Lambert, Bursar Planned completion date for corrective action plan: August 31, 2023

2022-004 Student Financial Assistance Cluster ? Assistance Listing No. 84.268 Recommendation: We recommend the University review all R2T4 calculations to ensure the correct net disbursed amounts are entered for all Title IV aid. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Office of Financial Aid will recalculate the R2T4 with the correct net disbursement amount and request the additional funding directly through COD. Going forward, the Office of Financial Aid will perform a secondary review of all R2T4 calculations prior to processing for accuracy. Name(s) of the contact person(s) responsible for corrective action: Robert Forest, Director of Financial Aid Planned completion date for corrective action plan: March 30, 2023

2022-002 Student Financial Assistance Cluster ? Assistance Listing No. 84.063, 84.268 Recommendation: We recommend the University review its policies and procedures to ensure accurate effective dates are reported in both the campus and program level records submitted to the NSLDS. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Registrar?s Office will review National Student Clearinghouse (NSC) information following transmission, particularly for effective dates of completely withdrawn students. The NSC reports enrollments to NSLDS for the University. Name(s) of the contact person(s) responsible for corrective action: Gerard J. Donahue, Registrar Planned completion date for corrective action plan: June 30, 2023

Finding number: 2022-001 Federal agency: U.S. Department of Education Programs: Student Financial Assistance Cluster CFDA #: 84.007, 84.033, 84.038, 84.063, 84.268 Award year:2022 Corrective Action Plan: An external consultant (Higher Education Assistance Group) was contracted to bring current NVU?s required reporting for enrollment and student program status changes through the Spring 2022 term. This work was complete September 9. Letters/Notifications were issued to United Educators (August 10) and impacted students (week of September 5). Ongoing, NVU has received support from the registrar at our sister institution Community College of Vermont (CCV). CCV?s registrar has coordinated with the National Student Clearinghouse and submitted the first of term enrollment file for Fall 2022 on 10/3/22. NVU plans to hire a registrar soon and ongoing enrollment reporting will fall within the responsibilities of this new hire. Additionally, the Vermont State Colleges System registrar team will perform monthly checks to confirm that enrollment reporting for NVU has been completed. Timeline for Implementation of Corrective Action Plan: September 2022 Contact Person Sharron Scott, CFO

Audit Firm: J&J CPA LLC Certified Public Accountants & Consultants Audit Period: October 1 2021 to September 30 2022 Finding No: 2022-002: CFDA No: 84.063 Program Name: Pell Grant Compliance Requirement: Disbursements ? Over award / Inaccurate recordkeeping Criteria According to Federal Register (86 FR 33245) an institution must submit Pell Grant, Iraq and Afghanistan Service Grant, Direct Loan, and TEACH Grant disbursement records to COD, no later than 15 days after making the disbursement or becoming aware of the need to adjust a previously reported disbursement. Cause Disbursements were originally authorized, processed and registered correctly on the student?s ledger; however, apparently the student had used portion of the same award year in another university resulting in an automatic system adjustment. Even though disbursements were requested and approved yet again the Finance Office was involuntary not notified of what had happened and of the new disbursement date. Recommendation The Institution must reinforce disbursement control procedures to ensure that COD and Institution?s disbursement records match. Such a procedure could be to perform weekly examination of disbursement and trace dates between COD and student?s ledger. Management Response and Corrective Action Plan The finding has been detected and the institution has already established all the necessary measurements to assure that the Title IV Office is following all the policies and regulations that rule the Pell Grant Program. Recommendation from the auditor will be taken and the institution will perform weekly examinations of the disbursements tracing dates between the COD system and the student?s ledger ensuring that all disbursements are correctly posted and that it accurately shows all the activity performed on the COD system.

Audit Firm: J&J CPA LLC Certified Public Accountants & Consultants Audit Period: October 1 2021 to September 30 2022 Finding No: 2022-001: CFDA No: 84.063 Program Name: Pell Grant Compliance Requirement: Disbursements ? Reporting disbursements within 15 days and inaccurate recordkeeping Criteria According to 34 CFR 668.164 an institution must disburse during the current payment period the amount of title IV, HEA program funds that a student enrolled at the institution, or the student?s parent, is eligible to receive for that payment period. Cause Both disbursements were made on the same date; however, inadvertently the correct steps were not performed in ED Express in order for the return to be processed. Recommendation The Institution must reinforce disbursement control procedures to ensure that all disbursements are correctly posted and the amounts between COD and student?s ledger are a match. Management Response and Corrective Action Plan The finding has been detected and the institution has already established all the necessary measurements to assure that the Title IV Office is following all the policies and regulations that rule the Pell Grant Program. The monthly evaluation, verification and reconciliation will include an internal audit performed by another office responsible for comparing the COD system with the student ledger to reinforce the actual disbursement control procedures ensuring that all disbursements are correctly posted and that the student?s ledger correctly shows all the activity performed on the COD system. The institution already refunded the questioned cost of $3,247.50

2022-Single Audit 01 Department of Social Services Title IV-E Adoption Assistance A sample of 40 children that received Title IV-E adoption subsidies during FY2022 was tested for compliance with the above criteria and the observations were noted below. ? 40 out of 40 children - Met the eligibility requirements, had special needs that prevented them from being placed without a subsidy, and could not return home. ? 40 out of 40 children - RDSS made reasonable efforts to place the children without the subsidy or waived the requirement as it was not in the best interest of the child. ? 40 out of 40 children ? The adoption assistance agreements were signed prior to the final adoption decree, the authorized amounts were in line with the State?s rates, and payments were issued in accordance with the agreements. ? 9 out of 40 children ? Sufficient evidence of the completion of the required criminal background and child abuse and neglect registry checks for the adoptive parents and adult household members was not in the adoption case files. The home studies and report of investigations narrative indicated the required checks were completed for the adoptive parents and household members but did not identify when they occurred. Also, in some cases, it was not noted if the adoptive parents met the eligibility requirements for the criminal record checks. As such, the auditors were unable to confirm when the checks occurred, and supporting documentation was not provided prior to the completion of fieldwork. In addition, during the initial file review, documents such as court orders, negotiation documents, and annual affidavits were missing from some of the files. The Adoption Unit was ultimately able to retrieve and provide the missing items. However, an opportunity exists to improve the adoption case file documentation. Recommendations: ? We recommend that the Children, Families, and Adults (CFA) Deputy Director develop and implement a quality control process to ensure that the required documentation is maintained in the adoption case files. ? We recommend that the CFA Deputy Director develop and implement standard documentation requirements for documenting the completion of the background checks in the adoption case files. Explanation of disagreement with audit finding: n/a ? no disagreement Action planned/taken in response to finding: Audit Recommendation: We recommend that the Children, Families, and Adults (CFA) Deputy Director develop and implement a quality control process to ensure that the required documentation is maintained in the adoption case files. RDSS Corrective Action Plan: The Reunification and Permanency Program Manager or designee will conduct quarterly adoption case reviews using the VDSS Guidance Section 3.9.3 - Adoption Records. The quarterly case sample represents 10% of the case and all cases will be reviewed at least once annually. Any findings will be documented to include corrective actions, person responsible and timeframe for correction. The Reunification and Permanency Program Manager or designee will review cases to confirm corrections. Audit Recommendation: We recommend that the CFA Deputy Director develop and implement standard documentation requirements for documenting the completion of the background checks in the adoption case files. RDSS Corrective Action Plan: All RDSS Adoptions files must include the VDSS Adoption File Checklist and the child?s adoptive family documentation. The required adoptive parent documentation includes: o Criminal Background Check Results - Licensed Child Placing Agencies ( Non-Conviction and/or Conviction Letter); Local Department of Social Services (Office of Background Investigations Determination Letter) o Sworn Statement of Affirmation o Child Abuse and Neglect Central Registry Check results for adoptive parent and adult household members. The Adoption and Resource Families Supervisors are responsible for monitoring compliance with documentation requirements for completion of the background checks, including insuring that documentation is requested from child ?placing agencies and third parties. Standard documentation requirements regarding background checks will be included in the quarterly review by the Reunification and Permanency Program Manager or designee. Name(s) of the contact person(s) responsible for corrective action: Brinette Jones, Deputy Director, Division Children, Families and Adults Lavinia Hopkins, Reunification and Permanency Program Manger Planned completion date for corrective action plan: Ongoing, beginning 2nd quarter 2023 If there are any questions regarding this plan, please contact Brinette Jones at (804) 646-4543.

In regard to the two students who were never reported as graduated, the College did in fact submit the required documentation to the National Student Clearinghouse (?NSC?) for further processing to the NSLDS, but the updates were reported as rejected due to errors by the NSLDS. The College has updated the students' records on the NSC and will monitor the NSLDS portal weekly to ensure that all student updates are processed and correct on both the campus and program levels. In regard to the publication of the length of the Master?s level program, the College is revising its documentation and publication of the length of the Master?s program to reflect adjustments to the program that reduced the amount of time needed to complete the program. In addition, the College?s student information system was reviewed/updated to accurately reflect the published length for each program. To assure that the information is being transmitted correctly, the College will monitor the next six months of enrollment updates to ensure that each student, in the different programs, has the correct publication program length.

The College reviewed and updated the effectiveness of its procedures governing the reporting of Federal Direct Loan and Pell Grant disbursements to COD no later than 15 days after disbursements to students. The College is reporting the disbursements to COD within the 15-day timeframe to allow for more timely drawdowns of federal funds. Those measures were and continue to be to extract and submit reporting to COD on a minimum weekly basis (with a goal of daily) to remain within the 15-day reporting requirement. Between the 2021-2022 aid years, the College?s Financial Aid department has experienced the leadership transition of three directors, and our current Director is identifying and implementing process refinements to previous steps taken to further improve internal controls. Further, the College has taken steps to both continue and enhance ongoing staff professional development sessions and training. In addition, the College contracted a Financial Aid consultant in the Fall of 2022 for an assessment of our system configurations and processes. The consultant has been retained to undertake a quarterly review of our setups and processes and assist in training the team. In accordance with best practices, Financial Aid?s goal is to continue to eliminate such errors. The findings continue to be addressed.

Finding 2022-002: Information on the Federal Program: CFDA 84.268 - Federal Direct Student Loan. United States of Department of Education. Compliance Requirements: Disbursement to or on Behalf of Students Type of Finding: Significant deficiency. Criteria: Program requirements state that the institution may not disburse or deliver the first installment of Direct Loans to first-year undergraduates who are first time borrowers until 30 days after the student's first day of classes (34 CFR 668.164(1)(2)). Condition: For each student in the sample selection receiving direct loans, we reviewed the school's documentation to determine if the student was a first-year undergraduates who are first time borrowers to determine is the institution disburse the first installment of direct loans until 30 days after the first day of class. Questioned Costs: $0 Context: We identified one student who was not coded as first-year undergraduate who was a first-time borrower in the Colleague System when he should have. Thisbefore the 30 days required time frame. Effect or Potential Effect: Early distribution to first-year undergraduates who are first time borrowers' students who are subject to the 30-day delayed disbursement requirement. Cause: Internal control process failure. Repeat Finding: No. Recommendation: TVCC should develop and institute a sustainable internal control system for appropriate identification of first-year undergraduates who are first time borrowers. Explanation of Disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The student identified in this finding did not attend in the fall and when switching over to a spring summer loan, the student was coded incorrectly. The TVCC Financial Aid Office has updated our process in packaging students that start in the spring term and did not attend in the fall to include reviewing those students manually. The financial aid job aide has been updated to include a manual review of students that are being imported into Colleague and plan to begin in the Spring semester. At the time of the review, the financial aid counselor is responsible for assigning the correct attendance pattern to the student's financial aid file to, so the student is packaged with the correct loan disbursement code.

Finding 2022-001: Information on the Federal Program: CFDA 84.268 - Federal Direct Student Loan. United States Department of Education Compliance Requirements: Disbursement to or on Behalf of Students Type of Finding: Significant deficiency. Criteria: Program requirements state that the institution must notify the student, or parent, in writing of (1) the date and amount of the disbursement; (2) the student's right, or parent's right, to cancel all or a portion of that loan or loan disbursement and have the loan proceeds returned to the holder of that loan or the TEACH Grant payments returned to ED; and(3) the procedure and time by which the student or parent must notify the institution that he or she wishes to cancel the loan, TEACH Grant, or TEACH Grant disbursement. The notification requirement for loan funds applies only if the funds are disbursed by EFT payment or master check (34 CFR 668.165). Institutions that implement an affirmative confirmation process (as described in 34 CFR 668.165 (a)(6)(I)) must make this notification to the student or parent no earlier than 30 days before, and no later than 30 days after, crediting the student's account at the institution with Direct Loan or TEACH Grants. Institutions that do not implement an affirmative confirmation process must notify a student no earlier than 30 days before, but no later than seven days after, crediting the student's account and must give the student 30 days (instead of 14) to cancel all or part of the loan. Condition: For each student in the sample selection of Title IV students who received Direct Loans we reviewed the school's documentation to ensure a disbursement notification was sent within the required time frame. Questioned Costs: $-0- Context: Twenty-six students in the sample selection were identified as not receiving a loan disbursement notification due to a personnel change in the Financial Aid Department.Effect or Potential Effect: Students were not provided information concerning the date and amount of the disbursement. the right to cancel all or a portion of the loan, and the process by which the student or parent must notify the institution that he or she wishes to cancel the loan. Cause: Internal control process failure. Repeat Finding: No Recommendation: The Financial Aid Office should implement an internal control process/procedure to ensure that all students receiving direct loan awards are receiving a disbursement notification within the required timeframe. Explanation of Disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Financial Aid Office experienced a change in personnel that caused the email notification not to be sent out to these students. The Financial Aid Office has updated their process for emailing notifications to students. The process consists of setting up a notification to be sent out through the communication management system in Colleague. This task has been assigned to two financial aid counselors, on various campuses, to monitor and review.

Identifying number: 2022-002 ? Return of Title IV Funds Identification of the federal program: U.S. Department of Education Student Financial Aid Cluster Finding: Criteria or specific requirement: Uniform Guidance for Student Financial Aid (SFA) Programs {III. Compliance Requirements, N. Special Tests and Provisions, 3. Return of Title IV Funds ? Compliance requirements (34 CFR 668.22 (a)(1) through (a)(5)))} stipulates that when a recipient of Title IV grant or loan assistance withdraws from an institution during a payment period or period of enrollment in which the recipient began attendance, the institution must determine the amount of Title IV aid earned by the student as of the student?s withdrawal date. If the total amount of Title IV assistance earned by the student is less than the amount that was disbursed to the student on his or her behalf as of the date of the institution?s determination that the student withdrew, the difference must be returned to the Title IV programs. Anticipated Completion Date: Action Already Taken Person Responsible: Joanne Brown, AVP, Director of Student Financial Aid Corrective Actions Taken or Planned: The Office of Student Financial Aid, in accordance with federal regulations, reviews all student withdrawals if the student was a recipient of Title IV funds to determine the correct amount of earned financial aid. The calculation is prepared based on the date of notification of withdrawal. Of the sample tested, all calculations were performed accurately; however, on two records, the funds designated as return to program were not returned within the timeframe allowed resulting in a finding. Scheduled disbursements and un-disbursements performed as planned; however, the population selection was produced manually and failed to pick up the withdrawn status of the students which would have returned the funds to the programs. All Return to Title IV Calculations will be performed with an immediate, on-the-spot un-disbursement of funds to be returned. Log files will be reviewed and checked to ensure the updates are transmitted to the federal programs in a timely manner. In addition to the above steps, the Office of Student Financial Aid has begun an internal review of a sample of 2021-2022 R2T4 calculations to ensure calculations were performed accurately and return of Title IV funds were completed in a timely manner and in compliance with federal regulations.

Identifying number: 2022-001 Identification of the federal program: U.S. Department of Education Student Financial Aid Cluster Finding: Uniform Guidance for Student Financial Aid (SFA) Programs {III. Compliance Requirements, N. Special Tests and Provisions, 4. Enrollment Reporting ? Compliance requirements (34 CFR 685.309 (b)(2)(i))} stipulates that unless it expects to submit its next updated enrollment report to the secretary within the next 60 days, the school must notify the Secretary within 30 days after the date the school discovers that a loan under title IV of the Act was made to or on behalf of a student who was enrolled or accepted for enrollment at the school, and the student has ceased to be enrolled on at least a half-time basis or failed to enroll on at least a half-time basis for the period for which the loan was intended. The University did not properly provide to the National Student Loan Data System (NSLDS) notification for one student who withdrew or graduated during FY 2022. Anticipated Completion Date: Action Already Taken Person Responsible: Colin Hilton-MacFarlane, Executive Director of Institutional Research and Effectiveness Corrective Actions Taken or Planned: The Office of Institutional Research and Effectiveness reports graduated students to the National Student Clearinghouse upon degree conferral. The concern about solely relying on a third-party to submit to the National Student Loan Data System was identified in the FY2021 audit with a management response involving reconciling extracts directly from NSLDS to validate that all graduated students were successfully reported (and updating directly within NSLDS for any that failed to be submitted by NSC). The finding in this FY2022 audit occurred prior to the management response and associated business process implementation from the FY2021 audit. The institution remains confident this direct reconciliation within NSLDS will resolve future instances of a lack of timely reporting. This finding also involved a rare case of a student completing a master?s level degree program and immediately enrolling in a subsequent master?s level degree program. The institution believes this uncommon circumstance may have contributed to this specific failure in NSC reporting the graduated status to NSLDS, so although the new business process of reconciliation should prevent the general case of this issue, specific review within NSLDS of students immediately moving from one degree program to another upon graduation will be conducted to ensure no additional mitigations are necessary beyond what has already been implemented to address the general case.

Management response to finding 2022-003: Notifications of Disbursements to Students Sent Prior to 30 Days before Crediting a Student?s Account Federal Awarding Agency: Department of Education (ED) Award Name: Federal Direct Student Loans Award Number: Various Award Years: 7/1/2021-6/30/2022 Assistance Listing Title: Federal Direct Student Loans Assistance Listing Number: 84.268 Pass-through entities: Not applicable As described in finding 2022-003, the Financial Aid Office (?FAO?) provided loan disbursement notifications earlier than 30 days from actual disbursement for some borrowers. Our Student Information System (SIS) was programmed to send the notification at the time the loan was originated, which may have been earlier than 30 days before the date of disbursement. FAO has updated the trigger in SIS so that the notifications will now be sent as soon as we receive the booking notice from COD, which is shortly after each disbursement. This update will ensure the notice is provided no later than 30 days after the date of disbursement (34 C.F.R. ? 668.165(a)(3)(i)). Contact Person: Megan Chan, Associate Dean, Compliance and Training, Enrollment Services Financial Aid Office, chanmega@usc.edu

Finding 2022-001 Condition The change in status for two of three students tested were not reported to the National Student Loan Data System (NSLDS) within thirty days or included in a response to a roster file within sixty days. However, the students were ultimately reported to the NSLDS. Corrective Action Plan During AY 2021-22, Fall 2021 and Spring 2022 graduates were mis-reported to Clearinghouse and NSLDS as `Withdrawn? instead of `Graduated?. Their final enrollment dates were reported correctly. A software update in our SIS now clearly flags graduates correctly. This update was in place in time for Fall 2022 graduates to be reported within the permitted time frame. This information was submitted to Clearinghouse on 12/6/22 and to NSLDS on 1/18/23. Going forward, after graduate data to Clearinghouse is submitted through our SIS the Registrar will double-check the NSLDS database to confirm it reflects the same information. In addition (and in broader terms) the Registrar will review available online enrollment reporting training modules provided by both FSA and Clearinghouse. Name(s) of Contact Person(s) Responsible for Corrective Action: John G M Seal Anticipated Completion Date: Software update was installed on 11/21/2022. Other corrective actions will be ongoing. John G M Seal, Consortial Registrar

FINDINGS-FEDERAL AWARD PROGRAMS AUDITS U.S. Department of Education 2022-002 Student Financial Assistance Program - Assistance Listing No. 84.063 and 84.268 Recommendation: We recommend that the College enhance its policies and procedures regarding enrollment reporting, including additional monitoring over the third-party service provider to ensure that reporting is completed accurately and timely. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: [Describe action planned or taken]. ? Additional reports will be reviewed before submitting the first-of-term information to the National Student Clearinghouse. ? Future semesters begin and end dates are created three years in advance to avoid date changes. ? The Registrar will complete a monthly review of students in the NSLDS system to ensure enrollment begin and end dates are accurate according to College Academic Calendar and clearinghouse submission. Name(s) of the contact person(s) responsible for corrective action: ? Connie Young, Director of Enrollment/Registrar Planned completion date for a corrective action plan: ? August 1, 2023. If the U.S. Department of Education has questions regarding this schedule, please call Sheila Mingee at 217-709-0923.

Student Financial Assistance Cluster ? Assistance Listing No. 84.268 Recommendation: We recommend the College evaluate the limitations of their software around COD reporting and establish procedures and policies that address any limitations around reporting disbursements to COD to ensure that student information is reported timely. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Financial Aid Director and Assistant Director are now aware of the system deficiencies around newly expired MPN?s and will report disbursements manually in COD. Name(s) of the contact person(s) responsible for corrective action: Sarah Geleynse Planned completion date for corrective action plan: Completed

Student Financial Assistance Cluster ? Assistance Listing No. 84.063, 84.268, 84.007, 84.033 Recommendation: We recommend the College update its procedures for processing and monitoring outstanding checks to students, to ensure compliance with the Title IV requirements. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Staff is being trained to monitor all outstanding checks and to follow the federal and state guidelines. Name(s) of the contact person(s) responsible for corrective action: Margaret Antilla Planned completion date for corrective action plan: June 30, 2023

Student Financial Assistance Cluster ? Assistance Listing No. 84.063, 84.268, 84.007, 84.033 Recommendation: We recommend the process be put in place to ensure the calculation of the R2T4 is done correctly and that all calculations are reviewed and such review is documented. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: All R2T4 calculations are now being performed in COD. All calculations are being reviewed by a second staff member. Name(s) of the contact person(s) responsible for corrective action: Sarah Geleynse Planned completion date for corrective action plan: Completed.

Student Financial Assistance Cluster ? Assistance Listing No. 84.063, 84.268, 84.007, 84.033 Recommendation: We recommend that the College put a process in place to ensure all error reports are updated within the required 10 days. They should also establish a process to ensure all students who have a status change are accurately and timely reported to NSLDS. This process should include understanding of NSC?s processes and ensuring they are correctly reporting to NSLDS. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: A request for additional staffing due to the systems limitation has been submitted. Financial Aid will provide the registrar with the list of students who have aid so they can review those students in NSLDS and not rely on the clearinghouse. Name(s) of the contact person(s) responsible for corrective action: Siv Serene Barnum Planned completion date for corrective action plan: June 30, 2023

Student Financial Assistance Cluster ? Assistance Listing No. 84.063 Recommendation: We recommend that a process be put in place to test the software system prior to doing award packages to ensure that the Pell award for all students is calculated correctly. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Financial Aid Director and Assistant Director will test the first 40 Pell awards of each academic year to ensure the Pell tables are accurate. Name(s) of the contact person(s) responsible for corrective action: Sarah Geleynse Planned completion date for corrective action plan: June 1, 2023