Corrective Action Plans

Condition: The institution submitted a FISAP to the U.S. Department of Education that reported inaccurate information in several data fields within the report. In addition, there was no evidence that an individual other than the preparer reviewed the report. Planned Corrective Action: The Iliff School of Theology has contracted with a professional, third-party processing company to administer its student aid programs. Preparation and submission of the FISAP will be completed with coordination between the VP of Business and the third-party processor. This includes a quality review process for accuracy. Contact person responsible for corrective action: Jason Warr, VP for Business, Controller Anticipated Completion Date: May 2024

Condition: Due to the limited number of personnel within the Financial Aid Department, the director of financial aid is solely responsible for packaging, awarding, and disbursing to student accounts Federal Student Financial Aid (Title IV) as well as calculating return of Title IV funds for students who withdraw from the School to student accounts. The packaging of Title IV aid and the return of Title IV funds are complex calculations that are not formally reviewed by another employee. Planned Corrective Action: The Iliff School of Theology has contracted with a professional, third-party processing company to administer its student aid programs. This third-party processing company is structured to properly segregate financial processing and includes a quality review function. Contact person responsible for corrective action: Jason Warr, VP for Business, Controller Anticipated Completion Date: May 2024

Since August 2022, the Financial Aid Office has been responsible for enrolment reporting. The contract with the third-party vendor was terminated, and the process was reassigned to the Financial Aid Office. As of August 2022, the Financial Aid Office staff is required to update the roster monthly through the NSLDS website, no later than 15 days after receiving it. The Registrar’s Office generates a graduate student report at the end of each academic period, and the Financial Aid Office updates the student statuses on the NSLDS website.We commit to implementing the corrective plan for this finding by March 31,2025.

Management will be more vigilant and will review future filings before they are published.

The financial aid department has developed a Direct Loan workflow process in accordance with federal guidelines. Utilizing Colleague's software, the financial aid office can now accurately assess students' aid eligibility to ensure they are appropriately awarded. Colleague has Award Eligibility Critiera (AEC) rules invoked at transmittal to determine if the student is eligible to receive loan funds.

The Univesity implemented a comprehensive ERP software tool, Ellucian Colleague in FY2021 and FY2022 and hired more staff. The built-in internal control structure, which includes access to enrollment reports and data coupled with a complete reconciliation process with the Office of Financial Aid, Office of the Registrar and Student Account wills prevent this from recurring.

Return of Title IV (R2T4) Calculations Planned Corrective Action: Southwestern Christian University will provide more training and resources regarding the R2T4 process of modular withdrawals. Southwestern Christian University will have all R2T4's reviewed by a second financial aid staff member. Person Responsible for Corrective Action Plan: Rita Palmer, Director of Financial Aid/Fully Disbursed, Third­ Party Servicing Agreement Anticipated Date of Completion: Immediately

Credit Balances and Heightened Cash Monitoring 2 (HCM2) Compliance Planned Corrective Action: Southwestern Christian University will provide ongoing training to current staff as well as new staff on HCM1 and/or HCM2 compliance regulations with the Department of Education. SCU will have additional staff review student accounts for credit balances that would result from disbursements of Title IV Aid. Person Responsible for Corrective Action Plan: Rita Palmer, Director of Financial Aid Anticipated Date of Completion: Immediately

Audit Period: June 20, 2022 The finding from the June 30, 2022 Schedule of Findings and Questions Costs is discussed below. The Corrective Action Plan does not include the corrective actions for our discreetly presented component unit, Luna Community College Foundation (LCC Foundation). LCC Foundation does not have federal funds in excess of $750,000. The finding is numbered consistently with the numbers assigned in the schedule. FEDERAL PROGRAM INFORMATION: 2022-005 – Return of Title IV Funds (Other Non-Compliance) Funding Agency: U.S. Department of Education Title: Student Financial Assistance Cluster Assistance Listing Number: 84.007, 84.033, 84.063, 84.268 Award Year July 1, 2021 to June 30, 2022 Compliance Requirement: Special Tests and Provisions CONDITION: In our test work over the Return of Title IV funds, we noted the following noncompliance: In 3 out of 9 students examined totaling $1,733, the College did not return the funds to the Department of Education in the required 45 days after the withdrawal date of the student.CRITERIA: According to 34 CFR 668.173(b), return of Title IV funds are required to be deposited or transferred into the Student Financial Assistance account or electronic fund transfers initiated to the Education of Department as soon as possible, but no longer than 45 days after the date the institution determines that the student withdrew.QUESTIONED COSTS: None EFFECT: The College returned Title IV funds to the Department of Education later than the timeframe required by the program requirements. CAUSE: The College was late in sending the returned funds to the Department of Education for a few of our samples examined because the City of Las Vegas was under a fire emergency due to Calf Canyon/Hermit Peak Fire. Upon return to the College offices, it was noted some of the funds to be returned to the Department of Education had not been processed. RECOMMENDATIONS: We recommend that the College policies and procedures to ensure that it regularly checks any student withdrawals and ensure that they send the Return to Title IV funds within the 45 day requirement. MANAGEMENT’S RESPONSE: The College acknowledges the auditors' comments and has taken steps to address the findings. The college’s Financial Aid department has experienced key staff turnover. In FY23, the college contracted with Attain Partners, a third-party service provider, to enhance our policies and procedures, ensuring alignment with best practices and compliance requirements. Attain, with college staff, are conducting a thorough review of the processes used by the Registrar, Bursar, and Financial Aid Office to improve coordination and the timely reporting of R2T4s. RESPONSIBLE PARTY/TIMELINE TO CORRECT: The Return to Title IV (R2T4) policy and procedures will be updated as necessary to remain current, and all staff will be informed of any revisions. The Interim Vice President of Student Services and the Interim Chief Financial Officer, working with Attain contractors, will review and update R2T4 policies by September 30, 2024. Due Date of Completion: September 30, 2024 Responsible Party: Dr. Loretta Montoya If the U.S. Department of Education has questions regarding this plan, please call me at 505-235-1755. Respectfully, Loretta Montoya Dr. Loretta Montoya Interim CFO

A. Comments on Findings and Recommendations: We agree with the finding and recommendation. B. Actions Taken or Planned: The Institution has reviewed the details of the finding and determined the error to be an isolated instance due to human error. The Institution returned $268 to the Federal Pell Grant Program on behalf of student #AR8. Student AR8 failed a class/module for the payment period in a non-standard program. On the Return of Title IV (R2T4) calculation, the payment period ending date should have been extended by an additional class/module. File Review will be added to the final review of all R2T4 calculations prepared for non-standard term programs. If the academic transcript includes repeat classes/modules, payment periods used in the calculation will be reviewed for accuracy.

Timely Submission of Enrollment DataEVMS has implemented a new student information system to assist with managing student data and enrollment reporting. The EVMS Information Technology developed a new report that will be automatically generated every Monday to show any status changes that occurred in the previous week. This report will be emailed every Monday to several areas, including the Registrar?s Office and Financial Services. The Registrar?s Office will reconcile the enrollment report that is sent to the National Student Clearinghouse every week to ensure the changes are being properly updated in the report. Enrollment reports will continue to be processed on a monthly basis to the National Student Clearinghouse which will be then sent to the National Student Loan Data System (NSLDS).Financial Services will serve as a secondary review after the fact for all students who have had a status change to go on a leave of absence, withdraw from EVMS, return from a leave of absence, or graduate off cycle. Financial Services will check NSLDS around 30 days after the change has occurred to ensure that the last enrollment report information is accurate and up to date. If there are any discrepancies with the status or last date of attendance, Financial Services will reach out to the Registrar and the Director of Financial Aid. The Director of Financial Aid will update the student?s record directly in NSLDS and the Registrar will ensure that the update is on the next version of the enrollment report so that it does not override the manual update.EVMS Financial Aid and Financial Services drafted a new policy to address the requirements and timing related to notifications of a status change for students. Once approved, the policy will be distributed to all departments impacted and training will be scheduled with responsible parties.The contact person for this finding is David Golay, Registrar.

Finding 2022-001Federal Program InformationFederal Agency: United States Department of EducationAssistance Listing Nos.: 84.063 and 84.268, Student Financial Assistance ClusterAward Periods: July 1, 2021 through June 30, 2022, and July 1, 2022 through June 30, 2023Corrective Action PlannedMayo Clinic Information Technology will work with the Student Financial Aid office to review the risk rating of the Banner application. A complete user access review based on job roles will be completed for 2023. To improve the speed and accuracy of the completion of these requests, we will be working with the Identity Management Platform team to add the Banner application into SailPoint for access management and review.Persons Responsible for Corrective ActionAlec Haws, ETC Education Application Analyst Raj Sanwal, Lead IT Analyst/ProgrammerTarget Completion DateOctober 31, 2023

Foster Care Eligibility Controls Not Completed in a Timely MannerState Agency: Department of Health and Human ServicesFederal Program: Foster Care Title IV-EThe Department concurs with this recommendation. The agency is in the process of building an integrated eligibility team and will increase its capacity by having three team leads and one support coordinator III to support the eligibility review process.Anticipated Correction Date: June 30, 2023Contact Person: Tracy Wiggill, Eligibility Program Manager, twiggill@utah.gov

CORRECTIVE ACTION PLANAudit Period: September 1, 2021, to August 31, 2022Finding 2022-001: Student Financial Assistance Cluster- Calculating Return of Title IV FundsThe Institution relied on their previous 3rd party servicer who processed their R2T4 forms. The Institution was not satisfied with their services and terminated that company and subsequently hired a new 3rd party service provider. It was discovered during the transition of service providers, that 2 of the R2T4 forms in our sample were not correctly calculated by their previous third-party servicer.Recommendation:We recommend the institution to update the incorrect R2T4 worksheets and follow up accordingly as required and to work with their new 3rd party service provider to determine effective dates at which 60% completion is achieved during each enrollment session.Management Response:Management agrees with the finding and will implement the recommendations immediately.Action Taken or Planned:Management has met with their current 3rd party service provider and have corrected the incorrect R2T4 worksheets and will follow up as required. Management has also met with their 3rd party service provider to determine effective dates at which 60% completion is achieved during each enrollment session.

STUDENT FINANCIAL ASSISTANCE CLUSTER FINDINGSFINDING 2022-003 - Internal Control over Compliance (Repeat Finding 2021-003, 2020-001, 2019-002, 2018-003, 2017-002, 2015-002, 2014-008)ResponsesNSHE Overall response/context ?NSHE increased its dialogue amongst the three instances of the student information system throughout fiscalyear 2022. The results of this robust dialogue led to additional controls to reduce related IT risks, enhancedmonitoring of activities, and targeted periodic reviews, highlighted in each instance?s response below. Theseenhanced techniques operating throughout the entire fiscal year ahead, should provide a stronger overall controlenvironment and lower associated risks.UNR ?? Detailed corrective action taken, including what will be done to avoid the identified issues inthe future, and when these measures will be in place;UNR has implemented controls to address the risk associated with the PeopleSoft Administrators(PSA?s) access to the production and development environments. The controls include:1. The University will remove the PSA role for the three individuals that are identified as not havingthe appropriate segregation of duties. The PSA role is still required of the University and will onlybe granted on a temporary basis when necessary and this access will be, documented, monitored,and deactivated upon completion of the required tasks.a) Approvals ? A PSA role is granted for task specific business needs and when the individualssecurity level does not permit the action to be performed. When justified, the PSA role isgranted by a security administrator.b) Documented ? When the PSA role is granted a notification is triggered to the Associate VicePresident, Planning, Budget and Analysis, the Registrar and the Director of AccountingOperations as to the role assignment and the person assigned.c) Monitored ? The activities performed are documented and monitored in a TeamDynamixticket.d) Deactivated ? The PSA system access is deactivated upon completion of the required activity.The deactivation is documented in the TeamDynamix ticketing system.2. The University will implement a quarterly User Access Review that identifies the incidences ofwhen the PSA role is granted and when the PSA login occurs and compares this to Team Dynamixto establish the activity. The activity can be compared to the system for validity. This will beperformed by the Registrar. 3. The University will continue to explore and research Change Control Systems as options tomonitor activities of the PSA?s.? How compliance and performance will be measured and documented for future audit,management and performance review.The PSA role will not be established for continuous periods of time. When the PSA role is temporarilygranted it is documented and tracked in Team Dynamix. This provides an audit trail of role access,timeframes of logins, and activities.? Who will be responsible and may be held accountable in the future if repeat or similarobservations are noted.The Associate Vice President, Planning, Budget and Analysis will monitor the compliance with thecorrective action plans and will implement new processes as needed to meet the needs of mitigatingthis risk and the system updates and changes.UNLV ?UNLV agrees with this finding.? Detailed corrective action taken, including what will be done to avoid the identified issues inthe future, and when these measures will be in place;UNLV understands the importance of adequate segregation of duties within the PeopleSoftenvironments and applications. The PeopleSoft Administrator (PSA) position that is the subject ofthe finding is responsible for the installation, configuration, upgrades, and troubleshooting of all theapplication environments. The PeopleSoft Administrators are not programmers/developers, andtheir access to the production environments is periodically required to perform the needed activitiesrequired to provide timely support of the application within the scope of their job duties.UNLV has implemented the following controls to mitigate the risks associated with the elevatedaccess required for the administrators to perform their required support activities.a. UNLV will remove the PeopleSoft Administrator role from all PSAs in productionenvironments.b. The PeopleSoft Administrator role will be assigned temporarily when elevated actions arerequired. The assignment will have the following requirements:i. Be limited in duration.ii. Document a justification detailing the need and actions to be performed.iii. Generate notification to the Director of Enterprise Applications.iv. Automatically be removed.v. It is reviewed as part of normal audit activities. c. UNLV will increase their reviews of access, activities, and assigned privileges to monthly forthe PeopleSoft Administrators.d. UNLV will continue researching and implementing other control methods to address thesegregation of duties while providing appropriate service and support.? How compliance and performance will be measured and documented for future audit,management and performance review.The PeopleSoft Administrator role will no longer be a persistent assignment to the PSA position.UNLV will perform monthly reviews of the access and activities to determine if the PeopleSoftAdministrators' current levels require further refinement. Additionally, UNLV will continue toresearch other control methods that will address the segregation of duties while providingappropriate service and support.? Who will be responsible and may be held accountable in the future if repeat or similarobservations are noted.The Director of Enterprise Applications will be responsible for reviewing the access needs of thePeopleSoft Administrators. The Director will complete the reviews and is also accountable if repeat orsimilar observations are noted. The Chief Information Security Officer will verify the reviews are permonthly audit practices.SCS ?? Detailed corrective action taken, including what will be done to avoid the identified issues inthe future, and when these measures will be in place;PeopleSoft Administrator (PSA) access to the Production and Development environments arereviewed on an ongoing basis. Due to the need to develop and perform program changes for all fiveshared-instance Institutions on a frequent basis it was determined that PSA access cannot be reducedany further. However, to address the segregation of duties risk the following compensating controlsare in place:(a) STAT for PeopleSoft ? Code control and internal modification tracking provides visibility over PSAactivities that are processed via this tool. These object changes are reviewed and approved by theDirector of Information and Application Services.(b) JIRA - Change control management and project tracking software. Change requests and projectsrelated to the PeopleSoft shared instance are tracked and approved. This would include user accessmodifications and system updates for example.(c) Security e-mail alerts ? The SCS security team are alerted via automated e-mails when user access(to include PSA roles) is changed.(d) User Access Reviews ? On an annual basis a user access review is performed incorporatingSCS/SA privileged users and all shared instance security coordinators SCS will implement the following additional control from FY22/23 going forward:(e) Splunk reporting and monitoring ? Reporting and trigger events developed incorporating PSAactivity ?anomalies?. For example, PSA after-hour logins reviewed and matched to plannedupdates/activities.(f) Periodic management reviews ? A formal review incorporating, and documenting PSA andassociated exception activities will take place. Where appropriate this will include approvals anddocumented rationale.SCS will continue to explore additional solutions to minimize the segregation of duties risk, especiallyas it relates to the monitoring of PSA activities.? How compliance and performance will be measured and documented for future audit,management and performance review.The periodic management review where appropriate will include documentation and approvals tosupport PSA activities that do not meet established criteria. This review will also document anyfollow-ups required as it relates to similar controls. For example, security e-mail alerts.? Who will be responsible and may be held accountable in the future if repeat or similarobservations are noted.SCS Director of Information and Application Services, SCS Security Group.

FINDING 2022-004 - Special Tests and Provisions: Return of Title IV funds for withdrawn students(Repeat finding 2021-004, 2020-002, 2019-003, 2018-005, 2017-004, 2016-003, 2015-004, 2014-011)ResponsesCSN?? Detailed corrective action taken, including what will be done to avoid the identified issues inthe future, and when these measures will be in place.All student accounts needing an R2T4 that require a date adjustment due to a gap between the lastdate of attendance for one course and the start of a new modular course will be reviewed by a secondindividual on the R2T4 processing team. This will ensure that the institution counts the correctnumber of complete days for the calculation when there is a gap in enrollment and a schedule breakof five days or more. These measures will be in place beginning October 15, 2022. Due to the error,the student will be made whole using institutional funds.? How compliance and performance will be measured and documented for future audit,management, and performance review.CSN will notate student accounts that must be reviewed as processors come across them. Who will be responsible and may be held accountable in the future if repeat or similarobservations are noted.The Assistant Director of Financial Aid will be responsible and may be held accountable if repeat orsimilar observations are noted.UNLV?UNLV agrees with this finding.? Detailed corrective action taken, including what will be done to avoid the identified issues inthe future, and when these measures will be in place:For context 1 (summer 2021), the student withdrawal occurred in FY 2021, with funds returned inAugust. This coincides with our 2020-2021 audit review, at which time many of the controlsdescribed in our response to findings for that year were in their early stages. Since summer 2021none of the identified issues that led to late fund returns have recurred.For context 2 (spring 2022), funds were returned one day late due to a failed transmission to theCommon Origination and Disbursement (COD) system. Normally when transmissions occur, anyrejected records are reviewed by the following day, in part to ensure that returns of funds are timely.In this particular instance, the file failed entirely and was never transmitted to COD at all, andtherefore no record was received of a file reject. Fortunately our own internal reconciliation controlsidentified the issue before even more time had passed.We regularly review records of when fund returns are processed in PeopleSoft to ensure reporting toCOD occurs within 45 days. In addition to our record of the PeopleSoft return date, we will nowtrack a second date to mark when the return record is accepted and reflected in COD. Thiscorrective action has been implemented as of October 10, 2022, and a review of fall 2022 R2T4returns to date indicates that all returns have been made within the 45-day timeframe.? How compliance and performance will be measured and documented for future audit,management and performance review:Steps taken in prior years, including expanded training around R2T4, the addition of a staff memberto support the R2T4 process, and increasing internal controls, have been successful in remediatingthe issues that were previously identified. To control for the file transmission issue, the correctiveplan will be monitored by both the Assistant Director for Financial Aid Processing and the ExecutiveDirector of Financial Aid & Scholarships on a weekly basis. Notes from these reviews will berecorded for future audits. Who will be responsible and may be held accountable in the future if repeat or similarobservations are noted:The Assistant Vice President for Admissions & Financial Aid and the Executive Director forFinancial Aid & Scholarships will be responsible for ensuring ongoing compliance.

REFERENCE: 2022-017 ? Special Tests and Provisions ? Disbursements to or on Behalf of StudentsSFA Cluster (84.268)Federal Grantor: U.S. Department of EducationFacility: Good Samaritan College of Nursing and Health ScienceFinding: Good Samaritan College of Nursing & Health Science did not send loan notifications to 2 of 28 students selected for disbursement testing for direct loans.Corrective Action Plan: Compliance will be verified through internal audit of student disbursements. A sample of disbursements will be checked for proper notifications on periodic basis throughout the semester.Person Responsible: James Younger, Dean of Financial Services and DevelopmentExpected Completion: April 2023

REFERENCE: 2022-001 ? Special Tests and Provisions ? Disbursements to or on Behalf of StudentsStudent Financial Assistance Cluster (Assistance listing No. 84.268)Federal Grantor: U.S. Department of EducationFacility: Good Samaritan College of Nursing and Health ScienceFinding: Good Samaritan College of Nursing & Health Science did not have evidence of whether the quality assurance system was operating effectively during the fiscal year ended June 30, 2022.Corrective Action Plan: This finding was corrected by June 30, 2022. In January 2021 the institution updated the Financial Aid Department Policy and Procedure Manual to include a section that address quality assurance oversight. The Quality Assurance Plan developed includes the following: reports loan records, disbursements, and adjustments to disbursements correctly to the Common Origination Disbursement system; disburses and returns loan funds in accordance with regulatory requirements; disburses the correct loan amount to the correct student; completes monthly reconciliation and Program Year Closeout. Program will be reviewed annually and updated accordingly by FAS and GSC Management. Compliance with the quality assurance policy is monitored through the reconciliation process which was implemented in June 2022.Person Responsible: Judy Kronenberger ? President Good Samaritan College of Nursing and Health ScienceCompletion: June 2022

REFERENCE: 2022-002 ? Special Tests and Provisions ? Borrower Data and Reconciliation (Direct Loan)Student Financial Assistance Cluster (Assistance Listing No. 84.268)Federal Grantor: U.S. Department of EducationFacility: Good Samaritan College of Nursing and Health ScienceFinding: Good Samaritan College of Nursing & Health Science did not perform the direct loan monthlyreconciliations for FY22.Corrective Action Plan: Good Samaritan implemented a formal monthly reconciliation process, includingcomparison of all systems for the period, a final review of G5 funds prior to draw down, a cover sheet noting anyexplaining any differences, proper sign off for preparation and review and the date by Good Samaritan management.A year end reconciliation will also be performed following the same process.Person Responsible: Judy Kronenberger ? President Good Samaritan College of Nursing and Health Scienceand Financial Aid Services (FAS)Completion: June 2022

REFERENCE: 2022-003 ? Reporting ? Common Origination and Disbursement (COD) SystemStudent Financial Assistance Cluster (Assistance listing No. 84.063)Federal Grantor: U.S. Department of EducationFacility: Good Samaritan College of Nursing and Health ScienceFinding: Good Samaritan College of Nursing & Health Science did not perform its internal control over therequirement to submit Pell payment data to the Department of Education through the COD system, which consists ofmonthly Pell COD reconciliations.Corrective Action Plan: Good Samaritan will implement a formal monthly reconciliation process, includingcomparison of all systems for the period, a final review of G5 funds prior to draw down, a cover sheet noting anyexplaining any differences, proper sign off for preparation and review and the date by Good Samaritan management.A year end reconciliation will also be performed following the same process.Person Responsible: Judy Kronenberger ? President Good Samaritan College of Nursing and Health Scienceand Financial Aid Services (FAS)Completion: June 2022

Lockhaven: Recommendation: The University should ensure all necessary employees receive proper training, support, and time to follow the university policies and federal requirements related to monthly reconciliations and maintenance of documentation.Explanation of disagreement with audit finding: There is no disagreement with the audit finding.Action taken in response to finding: All employees will receive proper training, support, and time to follow the university policies and federal requirements related to monthly reconciliations and maintenance of documentation. The reconciliation will be reviewed and signed off of monthly ensuring proper documentation is on file to validate the review process.Name(s) of the contact person(s) responsible for corrective action: Michael Hall, Director of Financial Aid.Planned completion date for corrective action plan: June 30, 2023

California: Recommendation: We recommend the Institute review its policies and procedures around sending entrance and exit counseling information to students to ensure students are receiving proper counseling and ensure entrance counseling is documented before loans disbursements are made.Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: A process in banner is run to catch any new students that need RRAAREQ updates with exit counseling. This will get students who have withdrawn, less than 1/2-time attendance, not enrolled, graduated or schedule to graduate. Once the requirement is on the account, then another process is run to get all of the students with the EXIT code still outstanding and send an e-mail to campus and personal e-mail. Students will receive emails every 30 days to complete the requirement until it is satisfied.Name(s) of the contact person(s) responsible for corrective action: Financial Aid Office, California, Clarion and Edinboro- Kelly Vitelli, Sue Bloom or Traci NecciaiPlanned completion date for corrective action plan: Plan is currently being employed.

Kutztown: Recommendation: The University should review its reporting procedures to ensure that students? statuses are timely reported to NSLDS as required by Federal regulations.Explanation of disagreement with audit finding: There is no disagreement with the audit finding.Action taken in response to finding: We are re-evaluating our reporting procedures and will work with the Registrar?s Office to further redefine our process(es). Currently, the Registrar?s Office submits monthly transmissions to NSC (National Student Clearinghouse), who in turn updates our information to NSLDS. Moving forward, a financial aid resource will work in conjunction with the Registrar?s Office to ensure errors are addressed timely to certify the accuracy of our reporting.Name(s) of the contact person(s) responsible for corrective action: Bernard McCree, Director of Financial Aid Services, at 610-683-4032 or mccree@kutztown.edu.Planned completion date for corrective action plan: June 30, 2023 Cheyney: Recommendation: The University should review its reporting procedures to ensure that students? statuses are timely reported to NSLDS as required by Federal regulations.Explanation of disagreement with audit finding: Per federal regulations 34 CFR 685.309(b), 682.610(c), and 674.33(j), Management concurs with the finding. There is no disagreement with the audit finding.Action taken in response to finding: Cheyney University of Pennsylvania utilizes the National Student Clearinghouse as a third-party service provider for enrollment reporting and provides all enrollment data to NSC, believing that enrollment would be reported to NSLDS in compliance with federal regulations; unfortunately, NSC only includes enrollment data for students on the enrollment roster they receive from the National Student Loan Data System (NSLDS). Cheyney University is a Heightened Cash Monitoring 2 (HCM2) institution, and students' Title IV aid/ disbursements are reported differently than advance pay institutions. Students did not appear on the rosters, so NSC did not provide the enrollment data to NSLDS. While investigating the issues with enrollment reporting for our HCM2 students, Cheyney University learned that NSLDS did not receive students' enrollment from NSC. As of spring 2023, Cheyney University has implemented procedures to report enrollment for all Title IV recipients to NSLDS.Name(s) of the contact person(s) responsible for corrective action: Rhonda Thompson, RegistrarPlanned completion date for corrective action plan: January 15, 2023

Kutztown: Recommendation: The University should review its policies and procedures around COD reporting to ensure students? information is reported timely and accurately.Explanation of disagreement with audit finding: There is no disagreement with the audit finding.Action taken in response to finding: We are reviewing our policies and procedures for COD reporting. A financial aid resource will refine their calendar to ensure that we are in compliance with the 15-day rule for PELL reporting is met consistently.Name(s) of the contact person(s) responsible for corrective action: Bernard McCree, Director of Financial Aid Services, at 610-683-4032 or mccree@kutztown.edu.Planned completion date for corrective action plan: June 30, 2023

Kutztown: Recommendation:a. The University should evaluate their procedures and review policies surrounding reporting status changes to NSLDS to ensure the enrollment effective date reported to NSLDS is aligning with the University?s last date of attendance.d. The Universities should evaluate their procedures and review policies surrounding reporting program enrollment statuses to NSLDS.Explanation of disagreement with audit finding: There is no disagreement with the audit finding.Action taken in response to finding: We are re-evaluating policies and procedures to ensure compliance in reporting. We will be working with the Registrar?s Office to rectify any errors in a timely fashion, as well as to detail and update our processes moving forward.Name(s) of the contact person(s) responsible for corrective action: Bernard McCree, Director of Financial Aid Services, at 610-683-4032 or mccree@kutztown.edu.Planned completion date for corrective action plan: June 30, 2023Cheyney: Recommendation: The University should evaluate their procedures and review policies surrounding reporting status changes to NSLDS to ensure the enrollment effective date reported to NSLDS is aligning with the University?s last date of attendance.Explanation of disagreement with audit finding: Per federal regulations 34 CFR685.309(b), 682.610(c), and 674.33(j), Management concurs with the finding. There is no disagreement with the audit finding.Action taken in response to finding: Cheyney University of Pennsylvania utilizes the National Student Clearinghouse as a third-party service provider for enrollment reporting and provides all enrollment data to the National Student Clearinghouse. The National Student Clearinghouse only includes enrollment data for students on the enrollment roster they receive from the National Student Loan Data System (NSLDS). Students did not appear on the rosters, so The National Student Clearinghouse did not provide the enrollment data to NSLDS. Cheyney University learned that NSLDS did not receive students' enrollment status changes from NSC. As of spring 2023, Cheyney University has implemented procedures to report enrollment status changes and last date of attendance for all Title IV recipients to NSLDS.Name(s) of the contact person(s) responsible for corrective action: Rhonda Thompson, RegistrarPlanned completion date for corrective action plan: April 30, 2023 California: Recommendation: The University should evaluate their procedures and review policies surrounding reporting enrollment statuses to NSLDS.Explanation of disagreement with audit finding: There is no disagreement with the audit finding.Action taken in response to finding: This finding was a direct result of the complexity of the integration. The finding is resolved when the timely submission of the graduation file to NSC and subsequent updating to NSLDS. The Office of the Registrar has a semester calendar that outlines important tasks and associated dates and what team is responsible to complete them. Once the team submits the degree file to NSC, the acceptance notice will be retained.Name(s) of the contact person(s) responsible for corrective action: Office of the Registrar Planned completion date for corrective action plan: Plan is currently being employed. Slippery Rock: Recommendation: The University should review its reporting procedures to ensure that students? statuses are timely reported to NSLDS as required by Federal regulations. Explanation of disagreement with audit finding: There is no disagreement with the audit finding.Action taken in response to finding: Before the office of Academic Records closes out a medical withdrawal, NSLDS/NSC files will be checked/notified of the proper LDA.Name(s) of the contact person(s) responsible for corrective action: Rebecca Farren, supervisor; Bobbi Jo Eakman, Clerical Assistant IIPlanned completion date for corrective action plan: immediate