Corrective Action Plans

Views of Responsible Officials and Planned Corrective Actions: The College agrees with the finding. The College had internally identified the failure to send the required notifications in January 2023 and took corrective action to create new processes and made system adjustments effective for the fall 2023 semester. All required notifications were made for fall 2023 disbursements. The College is evaluating alternate notification processes to improve efficiencies and ensure completeness. Names of Contact Persons Responsible for Corrective Action: Barbara Schmitt, Director of Financial Aid Anticipated Completion Date: Changes were effective for the fall 2023 semester

Views of Responsible Officials and Planned Corrective Actions: The College agrees with the finding. The Associate Director of Financial Aid is responsible for calculating Return of Title IV (R2T4) refunds for all students who withdraw from the College within the first 60% of the payment period using the Colleague software R2T4 module for calculating refunds. The Director of Financial Aid will provide a secondary review of all calculated R2T4 refunds before funds are returned to the Common Origination and Disbursement system. Names of Contact Persons Responsible for Corrective Action: Barbara Schmitt, Director of Financial Aid Anticipated Completion Date: Changes were effective for the fall 2023 semester

Management Views and Corrective Action Plans 2023-001 – Inaccurate Submission of Student Enrollment Change Submissions to the National Student Loan Data System (NSLDS) Point of Contact – Jennifer Spiegel Goldberg, University Registrar, (646-592-6275) Management agrees with the current year finding and the recommendations. The Office of the Registrar has recently been reorganized to create a dedicated, Records unit to assure that limited personnel will be responsible for leaves and withdrawals and who will use internal reports available to quality control data input before external reporting. All staff have been retrained to watch for the condition that led to this error when handling requests, including reminder of University policies and procedures. This retraining took place on September 6, 2023. The NSC Roster and NSLDS will be updated by December 29, 2023. We believe this finding will be remediated in fiscal 2024.

Inaccurate and Untimely Returns of Title IV Funds (R2T4) Planned Corrective Action: In conjunction with the Registrar’s Office, we have implemented the following corrective actions to improve our processes/timeframe for withdrawals: 1) This summer, the Financial Aid Office was added to the workflow in Etrieve (document management system used by CIU) so that 2 of our counselors (one for UG trad and one for online) now receive notifications directly of every withdrawal received by the Registrar’s Office. This allows our office to begin the process of returning funds without the reliance of emails forwarded from the Registrar’s Office. 2) Director and Associate Directors of Financial Aid met with the Registrar and Assistant Registrar on 10/31/23 to discuss how communication and processes could improve between offices. The following are several action items the Registrar will complete on their end that can assist in accomplishing this goal. • Registrar will ask Deans to explain to their faculty that when a student completes an assignment after their module is complete, the date to be entered must be the last date of that module so that our reports will capture the date needed for the return to process correctly. • Registrar will review their current procedures for processing official withdrawals and tighten their turn around time so that the Financial Aid Office can return aid within the required 45 days. 3) CIU made the decision to convert all 5-week UG online classes to 8-week classes starting the 23-24 academic year. These modules now fall within our standard academic calendar which should greatly improve our ability to monitor and process withdrawals for this student population. Person Responsible for Corrective Action Plan: Patty Hix, Director of Financial Aid; Lynsay Shumpert, Associate Director for Online Studies; Elizabeth Haselden, Registrar Anticipated Date of Completion: A follow-up meeting has been set before the end of fall semester to discuss the progress of our action plans with the Registrar.

Inaccurate Pell Calculations Planned Corrective Action: The University recognized that this was an isolated concern based on the late notification from the Department of Education on Pell Grant Awards for the 2022-23 award year. System updates and 20 hours of system training have been scheduled and/or implemented to prevent this from reoccurring. Person Responsible for Corrective Action Plan: Shondra Dickson, Director of Financial Aid Anticipated Date of Completion: April 2024

Need Analysis Planned Corrective Action: The University recognizes the federal regulations regarding over‐awarding and has implemented the use of a delivered report through the Student Information System to address this concern. Person Responsible for Corrective Action Plan: Shondra Dickson, Director of Financial Aid Anticipated Date of Completion: Implemented

Finding 2023-005: Reporting of disbursement dates to the Common Origination and Disbursement system Contact person responsible for correction action – Mitzi Suhler, Vice President of Enrollment Services Anticipated completion date – June 30, 2023 Corrective action Sterling College agrees with the finding regarding the disbursement dates of two students who were reported incorrectly to the COD system. We will provide continued training to those who are responsible for compliance of reporting accurate disbursement dates. We will review processes and internal controls and make any necessary changes to prevent and/or detect issues so that they can be corrected in a timely manner.

Finding 2023-004: Quarterly Reporting of Emergency Financial Aid Grants to Students and Annual Reporting for COVID-19 Education Stabilization Fund Contact person responsible for correction action – Mitzi Suhler, Vice President of Enrollment Services Anticipated completion date – June 30, 2023 Corrective action Sterling College agrees with the finding of not meeting the posting deadline for the quarterly reports for March 31, 2023, and June 30, 2023. The reports were posted within the required month but did not meet the ten-day limit for posting. Sterling College recognizes the importance of meeting reporting requirements for all federal programs and if any additional programs were to arise that are similar in nature, we will review the compliance requirements, and prior findings, to ensure proper processes are in place to ensure compliance in reporting are met.

Contact person responsible for correction action – Mitzi Suhler, Financial Aid Director Anticipated completion date – June 30, 2023 Corrective action Sterling College agrees with the finding of the under award and over award of federal aid for two students. During the 2022-2023 year we hired new financial aid staff that required significant training in the regulations of financial aid. Although checks and balances were in place these two instances were overlooked. Continued training, along with improved checks and balances through our updated software system, will enable the financial aid office to avoid issues with under and over-awarding federal student aid. The office will perform periodic reviews of awarding through reports from the system that will flag students who have potentially been under or over awarded federal aid.

Finding 2023-001: Enrollment Reporting Contact person responsible for correction action – Mitzi Suhler, Financial Aid Director Anticipated completion date – June 30, 2023 Corrective action Sterling College agrees with the finding. A review of enrollment reporting is being done at the end of each semester with particular attention being paid to students who have withdrawn during the semester or graduated at the end of the term. Along with reviewing those students, a random list of students that are not a part of the withdrawal or graduation list are being chosen for review, and if no student enrollment is found to be reported inaccurate, no further review is required per our policy. We feel that there are some changes soon that will help us with our enrollment reporting. One of them is that Sterling College is implementing a new version of our software system, Jenzabar, in 2024. This system will have better checks and balances for enrollment reporting, cleaner data, and will enable the College to have more accurate reporting. There will still be a need to do a review of each semester’s enrollment reporting. The financial aid office will review all student enrollment records that are enrolled for the semester to ensure the reporting dates are correct from this point forward. Once we have confidence that the system is doing what is expected, we will adjust the review to a random list of students.

CORRECTIVE ACTION PLAN Finding No. 2023-01: Credit Card was not reconciled and receipts were not obtained. Expenses were not properly recorded in the general ledger. Recommendation: Management should reconcile credit card accounts monthly and secure receipts for purchases and expenses should be posted to the proper general ledger account. Action Taken or Planned: Credit card accounts will be reconciled and receipts will be requested for purchases. Accounting will review the nature of purchases and properly post to the general ledger. Responsible Person: Mary Amador, Property Manager Completion Date: October 31, 2023

The College will examine the document destruction date on student related files related to federal compliance requirements to ensure accuracy of the document destruction date and accuracy of student files.

Uniform Guidance Corrective Action Plan Year ended June 30, 2023 Federal Finding #2023-001 Returns of Title IV funds are required to be deposited or transferred into the student financial assistance account or electronic fund transfers initiated to the Department of Education as soon as possible, but no later than 45 days after the date the institution determines the student withdrew. Quinnipiac University agrees with the finding. For one student who withdrew during the 2022 – 2023 academic year, the Pell funds awarded to that student were not returned to the student financial assistance account within 45 days after the University determined the student withdrew. As a result of this finding, Management has implemented additional steps within the reconciliation process of Title IV awards in order to prioritize the return of any unearned Title IV awards so that they are remitted to the student financial assistance account in a timely manner. If the Office of Management and Budget have questions regarding this plan, please reach out to Stephen Allegretto, the Associate Vice President for Finance and Controller, who is responsible for ensuring this corrective action plan is implemented, at 203-582-7962.

2023 Corrective Action Plan Finding Reference Number 2023-001 Contact person - Stephanie Wilhelm, Registrar Cause - Management oversite during a status update report submission Current Status - All student enrollment statuses from spring 2023 semester has been reviewed and corrected as needed. All students that graduate at mid semester will be reviewed individually to ensure that they are not re-reported as enrolled after degree completion. We have also updated our conferring process to add a status flag to ensure the graduated status is sent to NSC-NSLDS for updates. For those students that begin our graduate program immediately after completing the undergraduate program, they will be managed individually for reporting mid-stream until the new term begins. Views of Responsible Officials and Planned Corrective Action - the software cause of the re-reportig of graduated students as enrolled has not been determined. All mid-term graduate prior to March 2023 worked correctly and those that graduated July 2023 all worked correctly. Reports have been created for mid-term graduates and students begining another program immediately after degree completion. Anticipated Completion Date - Already completed and ongoing.

Department of Education Immaculata University respectfully submits the following corrective action plan for the year ended June 30, 2023. Audit period: July 01, 2022 - June 30, 2023 The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. FINDINGS—FINANCIAL STATEMENT AUDIT No findings over financial statement audit. FINDINGS—FEDERAL AWARD PROGRAMS AUDITS Department of Education 2023-001 Student Financial Assistance Cluster – Federal Assistance Numbers 84.007, 84.063, 84.268 Recommendation: We recommend the University develop a process to ensure that all Title IV outstanding checks are returned back to the ED within the required timeframe and verify on a regular basis the process has been followed. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The University had an established monthly process for returning Title IV outstanding checks to the Department of Education. During the months of January, 2023 and May, 2023, the University did not follow this established monthly process. Beginning in August, 2023, the University began scheduling monthly meetings to ensure all Title IV outstanding checks are returned to the Department of Education within the required timeframe. Name(s) of the contact person(s) responsible for corrective action: Joanne Cristinzio Planned completion date for corrective action plan: August 15, 2023 If the Department of Education has questions regarding this plan, please call Joanne Cristinzio at 484- 323-3067.

Finding 2023-001 - Special Tests and Provisions – Gramm-Leach-Bliley Act Responsible Individuals – Director of Computer Services and Vice President for Finance & Risk Management. Finding Summary: During testing of Gramm-Leach-Bliley Act and inquiry with management, it was determined that the University does not have a written comprehensive information security program in place. Corrective Action Planned: Dordt will be working with an external organization familiar with the policy requirements of the Gramm-Leach-Bliley Act to take existing procedures and incorporate them into a formal written information security policy that addresses the key areas of the Gramm-Leach-Bliley Act. Anticipated Completion Date: June 30, 2024.

Action taken: Saint Martin’s University will review the requirements of 16 CFR 314.4, update our written policy to ensure that it addresses all the required elements 16 CFR 314.3(b), and perform an annual review of our updated policy to ensure that it continues to comply with all relevant regulations. The University is currently in the process of formally adopting a cybersecurity framework as well as securing a vendor to perform an IT security assessment. This ongoing work in the interest of the security, confidentiality, and integrity of student information will position us well to make the recommended updates to our policy Name of Responsible Party: Mary Donahoo, Chief Information Officer Anticipated completion date: 3/31/2024

Action taken: As of June 2023, the Financial Aid department has a full-time Director, who is responsible for the Return to Title IV (R2T4) determinations. Following the regulations set forth by the Department of Education on R2T4 calculations for schools not required to take attendance, we have reviewed procedures and controls to ensure they are properly designed and implemented to ensure calculations are occurring accurately and timely. Going forward, we will ensure maintenance of proper documentation on students requiring a calculation, including indication of withdrawal date. Potential R2T4 calculations audits are now run multiple times a week, and will continue to be, in order to address timely calculations. The Director plans to continue education in the area of R2T4 calculations to maintain the most accurate and updated information on the topic. Name of Responsible Party: Erin Schaffer, Director of Financial Aid Anticipated completion date: 12/31/2023

CORRECTIVE ACTION PLAN YEAR ENDED JUNE 30, 2023 Finding: Special Tests and Provisions - Gramm-Leach-Bliley Act (GLBA) -Student Information Security - Yosemite Community College District (the "District") did not have a designated individual responsible for implementing and monitoring the institution's information and security program and did not have a written security program in place that addresses the minimum required elements as required under GLBA. Corrective actions taken or planned: The District has started the process of developing a job description for the creation of a position expected to be called the Chief Information Security Officer. The individual hired for this position will be directly responsible for coordinating the information security program, preparing a risk assessment that meets the requirements of 16 CFR 314.4{b), and document a safeguard for each risk identified. Anticipated completion date: June 30, 2024 Contact person responsible: Vice Chancellor of District Administrative Services Columbia

A. The specific findings and plans of action are as follows: Huntington Junior College is committed to addressing the findings of our administration of Title IV programs. We concur with the findings and recommendations of the audit team. B. Actions Taken or Planned. Finding 2023-002 Failure to Meet the Standards for Safeguarding Customer Information. The security of all customer information is very important to Huntington Junior College. We have engaged a new IT firm to establish and maintain proper GLBA requirements. All faculty and staff will be retrained on information security policies and procedures.

A. The specific findings and plans of action are as follows: Huntington Junior College is committed to addressing the findings of our administration of Title IV programs. We concur with the findings and recommendations of the audit team. B. Actions Taken or Planned - Finding 2023-001 Untimely Enrollment Status Reporting. During Spring 2023 the transition to non-profit status created some delays in processing information. Financial Aid officers have been counseled to emphasize the importance of timely enrollment reporting.

Finding 2023-001 – U.S. Department of Education (USDE), Title IV Student Financial Aid Programs We observed the following conditions in connection with our testing of the various U.S. Department of Education, Title IV, Student Financial Assistance Programs: 1. Two (2) out of 16 students tested did not have timely or accurate enrollment reporting to the National Student Loan Data System (NSLDS). 2. One (1) out of 16 students tested did not have a post withdrawal disbursement within the allotted days of the school’s withdrawal date determination. 3. One (1) out of 16 students tested did not have Title IV funds returned within the allotted days of the school’s withdrawal date determination. 4. One (1) out of 16 students received Title IV funding and was not charged for courses taken. The questioned cost is $124. The funds were subsequently returned to the USDE. 5. One (1) out of 16 students received a Pell grant greater than the amount for which the student was eligible. The questioned cost is $862. The funds were subsequently returned to the USDE. 6. Five (5) out of 16 students were selected for refund canceled check testing. There was no documentation provided to test signatures for two (2) of the students selected. All requested documents were subsequently provided. 7. One (1) out of 16 students tested was eligible for a Federal Direct Subsidized loan and was not awarded. 8. One (1) out of 16 students tested had an award letter that stated subsequent Title IV disbursements were available to the student and the subsequent disbursements were not awarded." The University should implement corrective actions to ensure that the above findings are resolved and do not recur in future periods. Corrective Actions – 1. NSLDS reporting is actively reconciled monthly with our third-party financial aid servicer and, as of November 16, 2023, the University confirmed 97.34% reported. The University will continue to actively monitor this reporting to ensure accuracy and timeliness. 2. Student Information System integration with third-party financial aid servicer’s system will allow the University to improve timing of drop notifications to ensure the third-party financial aid servicer is notified timely. The University will continue to monitor and review the process of withdrawal disbursement more thoroughly with the third-party financial aid processor to ensure that they are processed timely. 3. The University will monitor and review the process of returning Title IV funds to ensure that returns are processed timely. 4. The University has implemented a process that cross-checks enrollment with financial aid funding to identify and address situations in which students are inappropriately awarded Title IV funding. 5. The University is working with its third-party financial aid servicer to ensure Pell grants are awarded appropriately and within the amounts eligible. The University will ensure timely enrollment changes are sent to third-party financial aid servicer for any adjustments to aid eligibility. 6. The University has robust controls related to student refunds, and will continue to enforce these controls and retain the necessary documentation. 7. The University is working with its third-party financial aid servicer to ensure Federal Direct Subsidized Loans are awarded in all cases where appropriate. This is a unique situation where the FA software failed to recognize NSLDS information. The third-party financial aid servicer will monitor students closer until the system issue is resolved. 8. The Universiy is working with its third-party financial aid servicer to ensure Title IV disbursements, as outlined in award letters, are ultimately awarded.

Finding 2023-002 Using a Servicer of Financial Institution to Deliver Title IV Credit Balances Views of Responsible Officials The District agrees with the auditor’s findings and recommendations. Corrective Action Plan Under the Title IV cash management regulations, institutions are required to publicly disclose any contract that governs a Tier One or Tier Two Arrangement as well as information about the costs incurred by students who elect to use a financial account offered under one of those arrangements. The District submitted the required disclosure of its Tier One contract with BankMobile Technologies, Inc. to the Department of Education on November 29, 2023. Additional information about student refunds including the District’s contract with BankMobile Technologies, Inc. is currently available to the public at the following link. https://www.tccd.edu/services/paying-for-college/refunds/ Implementation Date Immediate Individual(s) Responsible The Director of Business Services is responsible for disclosures related to student refunds.

The College has returned the ineligible FSEOG to ED. In addition, the College has implemented a system rule in our Financial Aid Management system to prevent additional funds from disbursing after a Return to Title IV is calculated. The College continues to develop its staff and is comfortable with their abilities to prevent such findings in future years.

Review and correct, if necessary, all May and August 2023 graduation records that were returned with the G Not Applied indicator in NSC to ensure that each student’s G status is accurate at the campus and program level in NSC and NSLDS. Anticipated Completion Date November 2023 Run queries to identify Fall 2023 withdrawn students (to date); review the students’ NSC time status to ensure it has been submitted accurately. Anticipated Completion Date November 2023 Add a “Grads Only” file submission to the NSC reporting cycle for all campuses. Anticipated Completion Date on or about January 2024 (or when query is built) Increase the frequency of the Daytona Beach campus and Prescott campus NSC/NSLDS enrollment file submissions to improve the timeliness of reporting. Anticipated Completion Date on or about January 2024 (or when query is built)