Corrective Action Plans

Student Financial Assistance Cluster ? Assistance Listing No. 84.063, 84.268, 84.007, 84.033 Recommendation: We recommend a process be put in place to ensure documentation is maintained and available, particularly when making software changes. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: SAP policy has been updated to include only classes taken under current major to better work within system limitations. Staff will run SAP manually on students with prior attendance in legacy system. Name(s) of the contact person(s) responsible for corrective action: Sarah Geleynse Planned completion date for corrective action plan: Completed

Reporting views of responsible officials and planned corrective actions Management will put in place controls and procedures to ensure principle, accrued interest, and interest expense on debt is properly accounted for and reported.

Finding 2022-006 Errors in Reporting for NSLDS Plan: The unofficial withdrawal enrollment reporting process is a manual process for the University of Illinois Urbana-Champaign. The Office of the Registrar and the Office of Student Financial Aid are continuing to review the process and find ways to reduce the potential for human error. An additional staff member was hired in the Office of the Registrar and beginning January 2023 is reviewing all manually entered information. The Office of Student Financial Aid has implemented an additional check to ensure information provided to the Office of the Registrar is accurate. Expected Implementation Date: March 2023

Finding 2022-005 Excess Cash - SFA Plan: The University will continue to use the enhanced excess cash identification process which was implemented in May 2022 Expected Implementation Date: May 2022

FINDINGS ? FEDERAL AWARD PROGRAMS AUDITS U.S. Department of Education 2022-001 ? Student Financial Assistance Cluster ? CFDA No. 84.268, 84.063 Special Tests and Provisions ? Enrollment Reporting ? Significant Deficiency in Internal Control over Compliance Recommendation: The auditors recommend the College follow and enhance existing policies to ensure all student changes in status are identified timely and submitted accurately within the required time frame. The auditors also recommend a review of roles and responsibilities surrounding this process be evaluated and, if deemed necessary, revised. Lastly, the auditors recommend the College establish a formal internal monitoring control whereby a designated individual with NSLDS access, on a sample basis, spot checks the status updates on NSLDS so to internally audit the NSC submissions. Action taken: The College concurs with this finding. The College has made progress in the restructuring of positions and duties in the financial aid and registrar offices within the Student Services area. This will assist in improving coordination between those parties involved in degree and enrollment reporting as well as contributing to the streamlining of the reporting and correction process to eliminate errors and findings. Each of these departments will coordinate training and standard operating procedures for timely and accurate reporting to the appropriate entities. The College has intentions of fulfilling the following actions to make continued progress toward compliance under this finding: ? Hire Enterprise Network Position in Student Services to assist with reporting and student information services. ? Provide ongoing and intensive trainings for new Financial Adi Staff, new Registrar and the Enterprise Network position, once filled. ? Collaborate with appropriate colleagues in Oregon using similar Student Information Systems that are currently addressing or have previously addressed enrollment reporting concerns. ? Utilize an external review service of Financial Aid software for recommendations on improvements. ? Identify college policy to address and draft to support accurate enrollment reporting. Name of Responsible Party: Diahann Derrick, Director of Financial Aid Anticipated completion date: June 30, 2023

Enrollment Reporting to National Student Loan Data System (NSLDS) Planned Corrective Action: To date all past due enrollment and graduate reports have been filed with the National Student Clearinghouse (NSC). The Registrar?s Office is currently clearing any and all error resolution reports that are generated for each submission. This week the May 2022 graduates error report was cleared. This leaves the summer and fall terms of 2022 to be corrected. Those should be resolved no later than 5/15/2023. The Registrar?s Office reported the spring 2023 reports and are back on a transmission schedule. Person Responsible for Corrective Action Plan: Ann Marie Vickery ? Interim Registrar Anticipated Date of Completion: 5/15/2023

The underlying cause of the University's internal control system deficiency regarding Enrollment Reporting primarily related to staffing changes as well as an employee performance matter. The Financial Aid Office has addressed the employee performance matter and provided additional training across all team members. In addition, the Financial Aid Office has implemented new oversight, review processes and procedures across internal departments intended to enhance the timely submission of enrollment changes to the NSLDS in accordance with the requirements. These enhanced processes and procedures were implemented during the fiscal year ending June 30, 2023.

FINDING 2022-002 ? Special Tests and Provisions ? Enrollment Reporting: Material Weakness in Internal Control Condition/Context: A sample of 75 federal aid recipient students were selected from system generated reports of students who graduated, reported a physical address change, withdrew, or dropped during the 2021-2022 academic year. Of the 75 students who had a change in address, graduated, or withdrew, 19 were not reported to the NSLDS within the required timeframe. Of the 75 students, 3 had an incorrect effective date reported to the NSLDS. Cause: The attendance queries periodically used for change of status purposes were incomplete and failed to identify several students who had stopped attending class prior to completion of a payment period. Corrective action plan: In January of 2023, NU updated its NSLDS reporting policies and procedures overseen by Jorge Salas from our registrar team. The Quality Assurance, under Brandy Baker, team began reviewing enrollment reporting on a regular basis in February of 2023 to confirm the reporting process is consistent with the Title IV regulation. In the event that the Quality Assurance review yields inaccurate reporting, the Quality Assurance team will lead the investigation to determine the cause of the inaccurate reporting and will work with the appropriate departments and teams to ensure that any required corrections to process, reporting, reporting code or systems is rectified. NU reviewed and confirmed that the revised reporting logic would accurately report enrollment statuses, effective dates, and locations.

FINDING 2022-001 ? Special Tests and Provisions ? Return of Title IV: Material Weakness in Internal Control Condition/Context: A sample of 60 students who were recipients of Title IV funding and had withdrawn during the year were selected and the student records were compared to the calculation of the return of Title IV funds, if any, and the federal government?s Common Origination and Disbursement system. National University (NU) did not identify 19 of the 60 sampled students as withdrawn. Of these 19 students, 5 students ultimately required funds to be returned. After the error was identified, NU appropriately returned the funds. For 8 of the 60 sampled students, the amount to be returned was not remitted within the required 45 days after NU?s determination of withdrawal. Cause: The attendance queries periodically used for withdrawal determination purposes were incomplete and failed to identify several students who had stopped attending class prior to completion of a payment period. In addition, there is not an established internal control in place to ensure Title IV funds are returned subsequent to the calculation. Corrective action plan: NU has revamped its R2T4 process completely. We have built new reporting, added additional staff, retrained the team in January of 2023, and created a new workflow management tool within our SIS to ensure timely and accurate completion. We have also expanded our quality reviews through our Quality Assurance (QA) team. The QA team, under the leadership of Brandy Baker, on January 1st of 2023 began reviewing files on a regular basis and providing feedback from the reviews with the leaders of the R2T4 team who then use that information to coach or retrain team members and correct errors. We are confident that all of these changes will allow us to effectively correct the findings from this and the previous audit.

Auditors? Recommendation - We recommend the College strengthen controls over return of unearned aid the institution is responsible for to ensure timely return within 45 days and monitoring data entry process. Views of Responsible Officials and Planned Corrective Action - The College will review its current procedures and address any deficiency within Banner. The College will address in current procedure for the review and return of Title IV funds, to ensure compliance with the requirement. The College will address specific steps and timeframes for this process to include the proper documentation. Responsible Official ? Ivan Lopez, Provost and Kathy Levine, Director of Financial Aid Timeline and Estimated Completion Date - June 30, 2023

Auditors? Recommendation - We recommend the Registrar and/or Admission?s Office strengthen controls over enrollment reporting as well as the requirements under 34 CFR 690.83(b)(2) and 685.309 to ensure accurate reporting to the US Department of Education. Views of Responsible Officials and Planned Corrective Action - The College agrees with the finding. The College notes that specific steps were taken during the fiscal year to correct the deficiency; however, the process developed did not work. The College will review and modify its existing procedure to remedy the reporting deficiencies. Responsible Official - Ivan Lopez, Provost, Janice Baca, Registrar, Carmella Sanchez ,Director of Institutional Research, Scott Stokes, Chief Information Officer, and Emma Hashman, Admissions Timeline and Estimated Completion Date - June 30, 2024

FINDING 2022-001 - Specials Tests and Provisions - Enrollment Reporting - Significant Deficiency in Internal Control over Compliance. Response: Cal Lutheran concurs with the exception of one student for whom a permanent address change was not reported within the required timeframe. After investigation, it was determined that the selection criteria for data extraction required adjustment to ensure all students were included in the data extraction and reporting process. Corrective Action Plan: Maria Kohnke, Associate Vice President of Academic Services & Registrar, modified the selection criteria for the data extraction process in the Colleague system to ensure all permanent address changes are extracted and submitted for all students as required. The Associate Registrar is responsible for reviewing and modifying the selection criteria for the data extraction process at the beginning of each year and at each change in criteria. The criterion will be reviewed and approved by the Associate Vice President of Academic Services & Registrar when changes are made. Responsible person: Maria Kohnke. Date of expected correction: September 1, 2022.

Finding 2022-002: National Student Loan Data System (NSLDS) Enrollment Reporting Corrective Action Plan: We concur with the auditor?s finding. We have reviewed our processes related to the enrollment reporting of withdrawing students. The student affairs department will receive training on the requirements related to status change effective dates in accordance with the Department of Education regulations. In addition, the financial aid department and the registrar?s office are working together to confirm student rosters to verify that enrollment reporting is timely and accurate. Contact Person Responsible for Corrective Action: Shana Meyer, VP for Student Affairs; Andy Olsen, Director of Financial Aid; Rhianna Reed, Assistant Registrar Anticipated Completion Date: Corrective action is in progress as of August and will be completed by December.

Finding 2022-001: Federal Pell Grant Over-awards Corrective Action Plan: We concur with the auditor?s finding. We have reviewed our processes related to verifications and have established a review procedure to catch errors. A second person will be reviewing all verification adjustments to ensure accuracy. We are also adding a step to our Pell reconciliation process to verify that the Pell awarded to the student is the same as the amount approved by the Department of Education. Contact Person Responsible for Corrective Action: Andy Olsen, Director of Financial Aid Anticipated Completion Date: Corrective action was completed in September.

Finding 2022-003: Perkin?s Loan Recordkeeping and Record Retention Corrective Action Plan: We concur with the auditor?s finding. We have reviewed our filing processes to ensure that loan files are maintained in an organized manner so all files can be located as needed. The missing file is paid in full. Contact Person Responsible for Corrective Action: Carol Summervill, VP for Finance Anticipated Completion Date: Corrective action was completed in October.

A. Incorrect Calculation of Return of Title IV Funds The student in question has an unusual circumstance because the college canceled the last enrolled class. The student was correctly identified as a withdrawal through an external student information system (SIS) query designed to identify students with unusual circumstances not currently identified by the R2T4 program. Unfortunately, the R2T4 worksheet was not manually added to the SIS due to an inadvertent oversight. We believe this is an isolated incident, but in order to automate the manual process, CFAU requested the Office of Information Technology to incorporate the external query logic into the R2T4 program. The worksheet has been manually added. Note that the internal controls have been substantially strengthened which has reduced the number of students impacted year-over-year. B. Untimely Notification of Grant Overpayment to Students and Secretary The college inadvertently failed to report the student overpayment to NSDLS timely. Due to SIS communication limitations with this last batch for the summer 2022 term, the District was unable to send the notification through SIS and had to send the R2T4 OP notification outside of SIS manually resulting in the late notification. C. Distance Education Courses ? Lack of Formal Process to Determine Accuracy of Student Withdrawal Date With regards to student withdrawal dates as it relates to DE courses, the District will provide communications to all faculty throughout the semester instructing them to assess individual student participation in the class and to exclude students from the class if prior to exclusion deadlines, or drop students if exclusion deadlines have passed. The communications will refer to the Academic Senate guidelines on regular and substantive interaction and use of authentic assessments to ensure that active participation is being effectively evaluated. Communications will be times around core deadlines for enrollment and financial aid processes. The DE Coordinators will be informed of the new standard to supplement the existing required and optional trainings currently provided to teaching faculty. This process will be implemented in Fall 2022. Personnel responsible for implementation: Steve Giorgi Position of responsible personnel: CFAU Financial Aid Manager Expected Date of Implementation: Fall 2022

The District has already developed an automated summer Pell solution. The solution has been tested by the field and Central Financial Aid Unit (CFAU) and will be implemented Summer 2023. Personnel responsible for implementation: Steve Giorgi Position of responsible personnel: CFAU Financial Aid Manager Expected date of Implementation: Summer 2023

Return of Title IV (R2T4) Calculations Planned Corrective Action: The College is now taking additional steps to check R2T4 calculations. While our 3rd party servicer processes R2T4's, our Student Finance Clerk has been trained in this process as well. The Student Finance Clerk will complete the R2T4 internally, and then compare to confirm that dates and calculations match before refunds are completed. There is also an internal countdown between the Registrar and the Student Finance Clerk that tracks withdrawals and the days remaining until R2T4 needs to be completed. Person Responsible for Corrective Action Plan: Lyndsi Romero, Director of Financial Aid Anticipated Date of Completion: June 30, 2023

Finding 2022-003: Internal Control Deficiency Reporting Federal Grantor: United States Department of Health and Human Services Assistance Listing No.: 93.048, Special Programs for the Aging, Title IV, and Title II, Discretionary Projects Summary of Finding: There are no internal controls in place to ensure that reports that are submitted are complete and accurate. The same individual that prepares the SF-425 report, is the same person that reviews and submits the reports. Corrective Action Plan: Internal controls will be implemented to ensure that once the SF-425 report is completed, someone from the accounting department will verify funds being reported are correct and appropriate. Documentation will be maintained to support the review process. Responsible Party: Sonja Landry, Executive Director Anticipated Completion Date: December 31, 2023

Finding 2022-001: Internal Control Deficiency over Activities Allowed/Allowable Costs and Period of Performance Federal Grantor: United States Department of Health and Human Services Assistance Listing No.: 93.048, Special Programs for the Aging, Title IV, and Title II, Discretionary Projects Summary of Finding: Management did not have adequately designed internal controls in place over expenses charged to the federal program. Corrective Action Plan: Internal controls will be implemented to ensure expenditures are appropriately reviewed and approved prior to entering into the expenditure or requesting reimbursement from the federal program. Documentation will be maintained to support that expenditures were reviewed for appropriate period of performance. Management will ensure all duties are appropriately segregated. Responsible Party: Sonja Landry, Executive Director Anticipated Completion Date: December 31, 2023

Finding Number: 2022-003 Common Origination and Disbursement (COD) Dates Not Reflecting Actual Disbursement Dates Planned Corrective Action: date FA office will verify that disbursement date in COD matches the disbursement date on the student account. Person Responsible for Corrective Action Plan: Jean Claude St. Juste, Financial Aid Administrator Anticipated Date of Completion: Immediate

Finding Number: 2022-002 Incorrect Enrollment Reporting to National Student Loan Data System (NSLDS) Planned Corrective Action: Change the academic software set up to more accurately reflect the last date of attendance for DCC Online classes by adding the last date possible for the student to attend at the end of the last week (rather than the beginning of the week only). And, once the term has ended, exit anyone who has not registered (or pre-registered) for the next semester within two weeks of the end of the term. Person Responsible for Corrective Action Plan: Crystal Laidacker, Registrar Anticipated Date of Completion: Immediate

Finding Number: 2022-001 Return of Title IV (R2T4) Calculations Planned Corrective Action: FA Office will review the timing of the withdrawal to verify if the student earned 100% of the disbursed aid. Person Responsible for Corrective Action Plan: Jean Claude St. Juste, Financial Aid Administrator Anticipated Date of Completion: Immediate

Federal Program: ALN 14.218 ? U.S. Department of Housing and Urban Development (HUD) ? Community Development Block Grant (CDBG) ? Entitlement Grants Cluster, CFDA 14.239 - U.S. Department of Housing and Urban Development (HUD) ? HOME Investment Partnership (HOME), CFDA 93.563 ? Title IV-D, U.S. Department of Health, and Human Service - Child Support Enforcement (CSE) Condition per Auditor: Controls in place were not adequate to ensure compliance with 2 CFR 200 Appendix V submission requirements for its self-insurance cost allocation process and annual chargeback plan. Planned Corrective Action: Management agrees and will submit subsequent plans to federal cognizant agency as required by 2 CFR 200. Anticipated Completion Date: 4/30/2023 Responsible Contact Person: Jake Bower and Shauntika Bullard

2022-004 ? Enrollment Reporting Cluster: Student Financial Assistance Sponsoring Agency: Department of Education Award Names: Federal Pell Grant Program and Federal Direct Student Loans Award Numbers: Not applicable Assistance Listing Titles: Federal Pell Grant Program and Federal Direct Student Loans Assistance Listing Numbers: 84.063 and 84.268 Award Year: 2021-2022 Pass-through entity: Not applicable Campus 1 The mismatch between the enrollment effective dates on the campus-level and program-level reports identified by PwC auditors occurred due to a bug in the Campus Solutions system during the calculation of enrollment status change dates. The campus-level status date was sometimes incorrectly set as blank, which was then set to the term start date by NSLDS import process. As of September 14, 2022, the Office of the Registrar has modified the program that creates the NSLDS data file to correct the blank status dates, removing the mismatches that were found by PwC auditors. This ensures that the campus-level and program-level effective dates match. Campus 2 Historically, reporting to the National Student Clearinghouse (the ?Clearinghouse?) of students? enrollment status, e.g., full-time status, has been accomplished via enrollment files. These files are submitted at least every 30 days to ensure changes in enrollment status, especially withdrawals, are captured in a timely manner. To update enrollment status to graduated, two other processes have been relied upon: ? The first process uses Graduates Only files. Relying on the Clearinghouse?s advice, Graduates Only files are submitted for spring quarter only. ? The second process is the degree file submissions to support third-party verification of students? degrees through the Clearinghouse. When a degree file is submitted, the enrollment status should be updated to graduated. The issue exists with the second process where, for a variety of reasons, the Clearinghouse process does not successfully update every enrollment record with a graduated status when the degree file is submitted. These problems typically occur when students have been in more than one Clearinghouse branch, such as medical students in more than one degree program, students receiving their degree in a quarter in which they were not registered, and students who do not have a SSN. The campus began to recognize these problems in the summer of 2022 and had already decided to utilize a feature available in the quarterly Clearinghouse enrollment reporting to send a graduated status, rather than full-time status, whenever a student has graduated. This change, which is scheduled to be implemented in March 2023, will resolve most of the issues in which students may not have been reported to NSLDS as graduated. Effective immediately, error reports will be methodically checked and resolved after degree files are submitted to the Clearinghouse to ensure that enrollment records are updated for every student. By adjusting and coordinating the timing and sequencing of file submissions, the number of ?false? errors will be greatly reduced, and the error resolution process will be manageable. The resequencing of files submission will begin with the Spring 2023 semester. These two steps, in addition to the continuation of enrollment and degree reporting, should eliminate cases of students not being reported to NSLDS as graduated. For inquiries regarding this finding, please contact Cruz Grimaldo (510) 316-2932 and Jerry Lopez at (415) 476-4181 who are responsible for the corrective action.