Corrective Action Plans

This Corrective Action Plan is in response to Lancaster Bible College’s single audit report for the fiscal year ended June 30, 2024, prepared by Tait, Weller & Baker. Finding 2024-001 Recommendation: The College should review its procedures related to the request and disbursement of federal funds, including controls over compliance, to ensure they are following the advance payment method and establish controls to ensure it complies with the federal requirement. Corrective Action: In July 2024, a new tracking system was implemented for daily reconciliation of award batch detail along with specific individual training to ensure staff follows compliance responsibilities and understand the requirements of the program. The Controller and Financial Aid Director meet monthly to discuss any potential gaps in compliance. Person Responsible for Corrective Action: Matthew Mason, Vice President of Finance Anticipated Completion Date: The Corrective Action Plan was corrected during July 2024.

Finding 2024-002 – Student Financial Aid Cluster, Assistance Listing # 84.063 and 84.268 Limestone University utilizes Jenzabar software to extract and report enrollment data to the National Student Clearinghouse (NSC). However, in some instances, the data reported was incorrect. Since the occurrence of this issue, the University hired a new Registrar in August 2024. After reviewing the findings, the Registrar implemented the use of the NSC Edit Student Data Records window, in addition to the NSC Edit Registration Transactions window. This change allows a special status on the NSC Edit Student Data Records window to override the status on the Registration Transactions window, providing more precise monitoring of withdrawal dates and ensuring the accuracy and timeliness of the data reported to NSC. To ensure ongoing accuracy, the Registrar now reports enrollment status changes to NSC on a monthly basis. Additionally, the University reviewed the students identified in the findings, along with other students who had the same status (withdrawn) and made adjustments as necessary to ensure that all student data was accurately reported.

2024-027 Oregon Department of Human Services Strengthen controls around background checks Management Response: Child Welfare has robust business processes that support the accurate and timely completion of fingerprint-based background checks. These include an OR-Kids provider record that ensures all required elements are completed prior to issuing a full certificate of approval, including management approval. Additionally, Title IV-E eligibility business processes require the verification of finger-print based background checks through review of the original documentation (1011f). The Foster Care Program completes regular quality assurance reviews in all districts as an ongoing effort to identify issues and ensure compliance. Any issues identified during reviews are discussed with local managers and staff to coordinate corrections and identify solutions and/or training needs. Program analysis of this error has determined the issue to be an isolated event of human error. Foster Care Program and Federal Policy and Resources will collaborate to ensure the error case is corrected and provide documentation to demonstrate those corrections. Anticipated Completion Date: April 30, 2025. Contact Persons: Megan Brazo-Erickson, Federal Policy and Resources, Donna Haney, Foster Care Program

CORRECTIVE ACTION PLAN YEAR END JUNE 30, 2024 Gettysburg Area School District respectfully submits the following corrective action plan in response to the findings listed in Section II of the Schedule of Findings and Questioned Costs for the year end June 30, 2024. Finding 2024-001: Reporting Requirements Condition: The District did not file the Title I, Title II, Title III, Title IV, ARP ESSER, ARP ESSER 7%, ARP ESSER Homeless Children and Youth, and ARP ESSER 2.5% Reconciliation of Cash on Hand Quarterly Reports for September 2023 and March 2024 in an timely manner within the 10-day requirement. The District did not file the Title I, Title II, Title III, Title IV, ARP ESSER, ARP ESSER 7%, ARP ESSER Homeless Children and Youth, and ARP ESSER 2.5% Reconciliation of Cash on Hand Quarterly Reports for December 2023 and June 2024. Additionally, the Final Expenditure Report for the ESSER II was not filed by the required due date. The reports noted here were not related to a single audit requirement and thus were reported as a financial statement internal control finding. Corrective Actions Taken or Planned: Corrective Action has been addressed for the Federal filing requirements for the 2024-2025 fiscal year and thereafter.

2024-027 Oregon Department of Human Services Strengthen controls around background checks Management Response: Child Welfare has robust business processes that support the accurate and timely completion of fingerprint-based background checks. These include an OR-Kids provider record that ensures all required elements are completed prior to issuing a full certificate of approval, including management approval. Additionally, Title IV-E eligibility business processes require the verification of finger-print based background checks through review of the original documentation (1011f). The Foster Care Program completes regular quality assurance reviews in all districts as an ongoing effort to identify issues and ensure compliance. Any issues identified during reviews are discussed with local managers and staff to coordinate corrections and identify solutions and/or training needs. Program analysis of this error has determined the issue to be an isolated event of human error. Foster Care Program and Federal Policy and Resources will collaborate to ensure the error case is corrected and provide documentation to demonstrate those corrections. Anticipated Completion Date: April 30, 2025. Contact Persons: Megan Brazo-Erickson, Federal Policy and Resources, Donna Haney, Foster Care Program

Condition: Northeastern Illinois University (University) did not have adequate procedures and controls in place to ensure student that unofficially withdrew during the semester were accurately reported to the National Student Loan Data System (NSLDS) for the effective date of the enrollment change Planned Corrective Action: Registrar’s office will utilize the financial aid’s last date of attendance report to back date the effective enrollment reported date for unofficially withdrawn students. Contact person responsible for corrective action: Rahshida Walker, Registrar Anticipated Completion Date: 6/30/2025

The different conditions mentioned pertain to two students. There were errors in calculation which have been corrected by the financial aid office and the cause noted to prevent future occurrences. Since the college does not require repayment from students for amounts returned in an R2T4 calculation, it is positive to note that the students were not financially affected by the errors. 54

Student exceptions were caused by a coding error within the Banner reporting system. Upon discovery, the errors were promptly reviewed and corrected subsequent to year end. The necessary adjustments were made to the enrollment data, and the corrected information was submitted to the appropriate federal and state agencies in compliance with reporting requirements. The Financial Aid Director and Registrar will work closely together to continue to monitor the withdrawal process put in place after the finding was identified in the 2023 fiscal year.

2024-001: Return of Title IV - Student Financial Aid Cluster - Assistance Listing Number 84.007, 84.033, 84.063, 84.268, Grant Period - Year Ended August 31, 2024 Condition: During our return of Title IV Fund testing we noted that University did not properly calculate or return Title IV for one student out of the five students in our sample. The University returned $687 more in Title IV funds than they were required to return. We consider this to be an instance of non-compliance relating to the Special Tests and Provisions Compliance Requirement. Corrective Action Plan Financial Aid Office will make sure to accurate calculate the return of Title IV. EWU will return the over awarded Direct Loan Subsidized to reflect the correct amount for the student. This was an isolated data entry error while entering the amounts on COD R2T4 calculator. Responsible Person for Corrective Action Plan Director of Financial Aid Cesar Campos Implementation Date of Corrective Action Plan 02/10/2025

Description of Finding During the 2024 audit, it was identified that 3 out of 19 sampled students were not disbursed the correct Pell award. Corrective Action Plan The College is dedicated to awarding and disbursing all federal awards timely and accurately. A system error resulted in the locking of Pell grant awards which prevented the automated updates of award amounts when students’ registered credits changed. The College has implemented training to all Financial Aid team who award students to not lock any federal aid awards with the system. When reviewing and disbursing there will also be a specific check for locked awards to prevent this going forward. Timeline for Implementation of Corrective Action Plan The College has implemented the corrective action plan on October 31, 2024. Contact Person James Ryan, Ph.D. Vice President of Enrollment Management

Identifying Number: 2024-002 Finding: Special Tests: Enrollment Reporting – Improper Reporting of Withdrawal Date Applicable Regulation: Per the National Student Loan Data System (NSLDS) enrollment reporting guide (Section 4.4.3) when a student withdraws during a term, the effective date for the withdrawn status is the withdrawal date used by the Institution in accordance with 34 CFR 668.22. Finding: 3 out of a total of 24 students tested for enrollment reporting in NSLDS had an incorrect date listed as the effective date of the student’s enrollment status. Summary: During our enrollment testing, we noted that the effective date of withdrawal in NSLDS for 3 students tested was incorrectly listed as the date of determination by UWS instead of the withdrawal date determined in accordance with 34 CFR 668.22. Internal controls in place did not identify the errors. Three students with incorrect enrollment reporting dates were due to the student’s out of school status treated by the relevant University department as an unofficial withdrawal instead of an official withdrawal for enrollment reporting purposes. The Dates of Determination were therefore used incorrectly. Corrective Action Planned or Taken: The University of Western States has updated its policy for all out of school and reporting for all out of school students. Additionally, an internal Decision Tree resource document has also been created for use when processing student withdrawals and reporting student statuses. All out of school students will have the appropriate out of school date selected and submitted for enrollment roster reporting based on the updated policy and the supplemental Decision Tree. UWS staff has also reviewed all students and confirms reporting statuses align with the updated policy. Contact Person: Michelle Miller, Senior Vice President of Enrollment Management mmiller10@tcsedsystem.edu Anticipated Completion Date: September 17, 2024

Response to audit report Audit Period: June 30,2024 Audit Finding: Finding No. 2024-01 Special Tests and Provisions - Return of Title IV Funds Corrective Action: Since August 2023, the institution has implemented a new unofficial withdrawals (UW) policy. This policy defines an unofficial withdrawal as a student who stops attending one or more courses without officially withdrawing. An unofficial withdrawal will be assigned to any student who has consecutively ceased attending a course for three weeks and for whom no evidence of attendance is available at the time of reporting within the specified period. If a student stops attending all their courses, the Registrar's Office will inactivate the student and issue a report to the Financial Aid office for an R2T4 calculation. This process will occur on the last instructional day before the final exams, as outlined in the academic calendar. According to the policy, Faculty members submit a report of students who have stopped attending (using an official form) and indicate the last date of academic activity for each student reported as UW. These students are not assigned a grade but rather a "UW." Students who complete the course by continuing to attend but fail to meet the academic requirements receive a grade of "F." In addition, effective March 2025, the Academic Deanship has established an institutional policy for submitting grade records (roll books) at the end of each academic term. Since 2024, some faculty members have participated in a pilot project to adopt the Electronic Gradebook (Roll book). After adjusting the system, the institution will offer training sessions to all faculty members. By the end of the February-May 2025 term, faculty will submit the required documentation to maintain records of the grades assigned to each student. Name of the Contact Person: Norma Ortiz, EdD Academic Dean 787-720-1022 ext. 1138 nortiz@atlanticu.edu Projected Completion Date: Beginning in May 2025, the institution will require all faculty members to submit roll books. The Academic Dean's Office will ensure compliance with this new policy. Ramón Barquín Torres Chairman of the Board rbarquin3@atlanticu.edu

AUDIT FINDING Finding 2024-001 NSLDS Status Reporting Error MANAGEMENT'S COMMENTS ON FINDINGS AND RECOMMENDATIONS We concur with the auditor's finding and identification of a deficiency in our internal controls. ACTIONS TAKEN OR PLANNED We will increase internal controls to ensure all NSLDS status reporting is done correctly. EMPLOYEE/ DIVISION RESPONSIBLE Financial Aid Director TIMELINE AND ESTIMATED COMPLETION DATE Immediately

FINDING 2024-002: Program Income Response: Montana Office of Public Instruction has informed us of this error in management of the 21st Century Grant. In order to be compliant, we are not charging fees for programs within this grant.

Corrective Action Plan The College is required to notify students who have borrowed Title IV student loans to complete loan exit counseling if they withdraw, take a leave of absence, are enrolled less than half-time or have completed their academic program. The Director, or designee, will evaluate students in the above conditions twice a month and email students about the requirement to complete loan exit counseling. In addition, at the end of the fall, spring and summer terms, the Director will request a list of students who completed programs from the Registrar, identify those with loans and send the notice. Timeline for Implementation of Corrective Action Plan: The corrective action plan was implemented in January 2025.

The 3999-AD Grant (After School Grant) was not approved by ISBE until January 19th, 2024. No expenditure report could have been done by December 30, 2023. Title 2, Title 4, IDEA Flow Through and IDEA PS were all submitted on October 27, 2023. Moving forward reports will be submitted within the required time frame.

The University has established policies and procedures to report a change in a student’s enrollment status in its next updated Enrollment Reporting roster. The University will take the necessary steps to ensure compliance with established policies and procedures with regard to reporting a change in a student’s enrollment status.

Lane College acknowledges the audit finding regarding delayed reporting of withdrawal and graduation dates to the National Student Loan Data System (NSLDS). The College recognizes the importance of timely and accurate reporting as a critical compliance requirement under 2 CFR Part 200 and the compliance supplement. In response to this audit finding, Lane College commits to implementing immediate and sustained corrective actions as follows: 1. Enhanced Tracking System: Lane College will implement a robust tracking system specifically designed to monitor student enrollment status changes, including withdrawals and graduations, to ensure these changes are promptly identified and reported. The tracking system will be integrated within the existing enrollment management software, enabling automatic notifications to designated staff when an enrollment status change occurs. 2. Internal Control Improvements: The College will strengthen internal controls by clearly delineating responsibilities for enrollment reporting among relevant departments. The Registrar's Office will have primary accountability for overseeing timely reporting, supported by coordinated 3. checks and balances from the Financial Aid Office to cross-verify reporting accuracy and timeliness. 4. Staff Training: Regular training sessions will be conducted for all staff involved in reporting enrollment status changes. These trainings will focus on compliance requirements, reporting timelines, and use of the updated tracking and reporting system. Attendance will be mandatory, and training effectiveness will be evaluated through periodic assessments. 5. Periodic Audits: To sustain compliance, the College will institute internal audits conducted quarterly by the Office of Enrollment Management. These audits will sample enrollment status changes and assess the timeliness of reports submitted to NSLDS. Audit results will be documented, reviewed by senior management, and any deviations will be promptly addressed. 6. Reporting Accountability: Staff responsible for reporting enrollment status changes will be required to submit monthly summaries of reporting activities to their supervisors. Supervisors will review these summaries to ensure adherence to the 60-day reporting deadline and address any delays proactively. Lane College is committed to rectifying this compliance issue swiftly and effectively. The College understands that maintaining accurate and timely reporting to NSLDS is essential to prevent inaccuracies in student loan records, avoid potential financial consequences, and uphold regulatory compliance. These measures demonstrate our dedication to robust compliance practices and continuous institutional improvement.

Federal Program: Student Financial Assistance (SFA) Cluster - Various ALN Compliance Requirement - Enrollment Reporting Management’s Response The UPR concurs with this finding. On February 26, 2025, we met with all deans for Academic Affairs and explained to them the importance of complying with federal requirements. Twenty-two exceptions were found in the FY2023 single audit report, and an exception was found in FY2024 single audit report. We recognize that we have improved, however, we are not satisfied with the results. We understand that we have not achieved 100% compliance, and our correction action plan remains in force. We will take additional actions such as: • Continue to guide professors on the importance of taking and reporting attendance timely. • One of the special assistants of the Vice Presidency for Academic Affairs will send a reminder to the registrars every month indicating how much time they have left to inform the NSLDS of the change in status on or before 60 days after the change occurred. • The next meeting of the University Board will be used to inform members (chancellors, faculty, and student representatives) so that they can take the message to their institutional units. The goal is to have 100% compliance. Responsible Person or Office: Executive Vice President for Academic Affairs and Research. Timeline: 2025-2026

Federal Program: Student Financial Assistance (SFA) Cluster - Various ALN Compliance Requirement - Return of Title IV Funds Management’s Response The UPR concurs with this finding. Since April 2024, Río Piedras implemented the following procedure for students who request a total withdrawal. 1. The information system office produces a list of students who request total withdrawal. 2. This list is received by the financial aid office. 3. The financial aid office identifies the students with financial aid. 4. The financial aid office sends to the fiscal financial aid office the students who requested total withdrawal and received financial aid. 5. The fiscal financial aid office analyzes the cases and prepares the R2T4 form. 6. The finance office returns the determined amount to ED using the G5 platform. This procedure worked well for students who requested a total withdrawal but did not prevent another case in Río Piedras noted by the auditor in which the student never attended his courses (Note: The three additional cases of Río Piedras in which the student requested total withdrawal occurred before the implementation of this process (April 2024)). Neither will work for another case identified by the auditors for which the student stopped attending on the Mayagüez campus. For the three cases of the Cayey campus in which the student requested a total withdrawal and the funds were returned after 45 days, the employee in charge was a new employee in the fiscal office without direct supervision because her supervisor, the finance director, was on maternity leave. Currently, the Cayey campus has a finance coordinator, a position between the fiscal office director and the finance director. The finance coordinator will directly supervise the fiscal office. In his or her absence, the director will oversee the fiscal office. In May 2025, the finance office at central administration will have a meeting with the finance directors and fiscal financial aid directors to discuss this finding and establish a uniform procedure to address: • Students who requested total withdrawal. • Students who stopped attending. • Students who never attended. Responsible Person or Office: Finance office at the central administration and finance offices at each of the eleven (11) institutional units. Timeline: 2025-2026

"Finding 2024-002 – U.S. Department of Education (USDE), Title IV Student Financial Aid Programs Planning (significant deficiency) Information on the federal program – Federal Direct Student Loans, FAL No. 84.268, June 30, 2024; Federal Pell Grants Program, FAL No. 84.063, June 30, 2024; Federal Supplemental Educational Opportunity Grant, FAL No. 84.007, June 30, 2024; Federal Work-Study Program, FAL No. 84.033, June 30, 2024 Criteria – Federal regulations governing Title IV programs. Condition – Non-compliances were noted, as more fully described in the context below. Questioned Costs – N/A Context – 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) Three (3) out of 25 students had a credit balance on their account created by Title IV program funds longer than 14 days. 34 CFR 668.164(h)(1). Cause – Oversight by responsible employees. Effect – The College’s participation in the Title IV programs could be subject to USDE sanctions as applicable. Repeat Finding – No Auditor’s Recommendation – We strongly recommend the College refine the processes and procedures for the timely recording of disbursements in the general ledger allowing for more accuracy in financial reporting. View of Responsible Officials – The College has refined processes and procedures to ensure student refunds are processed within 14 days after the credit appears on the student account.

Name of Responsible Individual: Benjamin Carmichael, Associate Director for Compliance, Enrollment Management; Christina Veith, Associate Director of Loans, Financial Aid; Malik Artis, Interim Director of System, Office of Enrollment Systems; Sarah Mariner, Assistant Director for Compliance, Financial Aid Corrective Action: Howard University uses automated processes to identify and send loan disbursement notifications to parents and students. The nightly UC4 process prompted Banner to send out a Direct Loan notification to the student and/or parent. This UC4 process showed all students who had a Direct Loan disbursement after the last nightly UC4 process was run. During a compliance review of disbursement notifications during the Fall 2023 semester and the Loans Team worked with Banner consultants to determine the reason for this. While this issue was being reviewed and a solution created, the Loans Team used the RLRDLDD report in Banner, which is a report that showed all loans disbursed. This report could be matched against the UC4 listing of loans disbursed. This check between UC4 and the RLRDLDD report was used to send out loan notifications that was missed during the UC4 process during the Fall 2023 semester. During a Spring 2024 compliance review of disbursement notifications, it was discovered the RLRDLDD report was missing disbursements as well. As a corrective action, the Loans Team then began using a loan audit report out of the Argos reporting system to identify students who may have a disbursement not included in the UC4 and/or RLRDLDD report. The support time required for maintenance of Banner was also reduced due to the ongoing integration and implementation efforts to prepare Workday for the Fall 2024 semester. This increased the length of time it took to correct the UC4 process and RLRDLDD reports. Howard no longer uses Banner to send out Graduate PLUS, Subsidized and Unsubsidized loan notifications. Workday now is now responsible for sending out the disbursement notification after a loan has disbursed and there is a record in the student’s Activity History to document the loan notification has been sent. Parent PLUS Loan notifications must be sent out manually due to Workday not having the capability to send a disbursement notification to the parent’s email on file. The “FA CR Parent PLUS Disbursement Notification Report” is run weekly out of Workday to identify all Parent Plus Loan disbursements and a notification is sent to the parent’s email address on file. Bi-semester reviews are completed by the Associate Director for Compliance to ensure the loan disbursement notifications are being sent to students and parent in the required 30-day timeline. These reviews also ensure inclusion in the loan notification of all federally required information. Anticipated Completion Date: This corrective action plan was completed during Fall 2024 implementation of Workday. Monitoring and reviewing of loan disbursements has been ongoing to ensure the Workday system is correctly identifying and transmitting Direct Loan disbursements. Given that Workday is a new ERP, Howard recognizes maintenance and review of the disbursement notification process will be ongoing.

Name of Responsible Individual: Oliver Street, Interim University Registrar; Saleem Sullivan, Associate Registrar for Compliance; La Estes, Records Specialist; Ben Carmichael, Associate Director for Compliance, Enrollment Reporting; Sarah Mariner, Assistant Director for Compliance, Financial Aid Corrective Action: The Enrollment Reporting process is supervised by the University Registrar and is responsible for transmitting enrollment reports to Howard University’s third-party servicer, National Student Clearinghouse (NSC), who then submits the enrollment status report to NSLDS. The University Registrar resigned in July 2024 and the Associate Registrar position was also vacant at that time. These “peak time” staffing issues helped create confusion as to which enrollment files had been scheduled and sent to NSC. The University hired an experienced Associate Director Registrar for Compliance in December 2024 and is currently searching for a University Registrar with experience working in the Workday Enterprise Resource Planning system (ERP). Howard moved to using Workday Student as the University’s ERP beginning Fall 2024 and it has been confirmed the accurate program lengths for each program were entered in Workday. The transition to Workday Student allowed the University to review each program to ensure accuracy when integrating the data from Banner to Workday and certifying the correct program lengths are reported to NSLDS. Screenshots of the programs reported to NSLDS incorrectly have been provided to BDO as a way to document the program length will be accurately reported in the future. Graduation files are scheduled to be transmitted on the first of every month to NSC. This will allow students cleared for graduation to be transmitted monthly and ensure the 60-day timeline will be met. In Workday, the date the student has been cleared for graduation (i.e. the effective day) is available on the “Academics” tab. This should make it easier to show an audit trail for the student’s graduation clearance date. Anticipated Completion Date: The correction to the length of each program in Workday was implemented during setup prior to the start of the Fall 2024 semester. There will be a Spring 2025 review performed by the Associate Director for Compliance to ensure the program length is accurately reported and testing shows this issue to be resolved. Each semester, enrollment reporting samples will be selected (approximately) 2 to 3 weeks after the first enrollment file for the semester is sent to NSC. Howard has set up a transmittal calendar with NSC which determines when enrollment files, including the graduate files, are transmitted. Due to work completed regarding the integration of Workday with NSC, Howard worked closely with NSC during Fall 2024 to troubleshoot issues that could delay enrollment files transmission. The schedule for submission of files was setup during this time. Howard currently has a vacancy at the University Registrar position and experienced individuals with Workday user knowledge will be pursued for hire. The hiring date for the University Registrar has not been approximated due to the positional requirement of Workday experience and the newness of the ERP system into the higher education space. The current Interim Registrar has prior University Registrar experience with knowledge of the requirements to be effective in the position.

Name of Responsible Individual: Keith Anderson, Associate Provost, Office of Undergraduate Studies; Paapa Berko, Federal Work-Study Coordinator; Tina Knight, Director, Center for Career & Professional Success; Ben Carmichael, Associate Director for Compliance, Enrollment Management; Dani Hollis, Associate Director of Operations & Customer Service; John Hooth, Senior Director of Payroll; Sasha Quinga, Senior Director, Human Resources Information Systems Corrective Action: Federal Work Study (FWS) supervisors are required to have training on the appropriate policies and procedures when hiring a FWS student. They sign off on the Federal Work Study supervisor agreement stating they understand they must follow these procedures and losing the privilege of hiring FWS students can be the result of not following these policies and procedures. One of these policies is that students cannot have time approved prior to working those hours, as this is a not a best practice. The Center for Career & Professional Success began using this updated FWS supervisor agreement beginning with the Spring 2025 semester. All FWS supervisors who had students for Fall 2024 were required to review and sign the updated agreement as well. The Federal Work Study Coordinator (located in the Center for Career & Professional Services) is responsible for reviewing the hours a student works. The Federal Work Study Coordinator also ensures supervisors have approved the correct number of hours and the hours were approved after the student worked those hours. The full-time Federal Work Study Coordinator position was filled prior to the end of the Fall 2024 semester, and this ensures a full-time employee is now in place to help provide a more active review of the Federal Work Study program. One student was not paid FWS earnings within 30 days. At the time, Howard University did not print out paper checks, only providing FWS payments as a direct deposit. The student was to be paid for those two pay periods (10/8/23-10/21/23 and 10/22/23-11/4/23) on 11/3/23 and 11/17/23. The student did not have any payment selections set up in the system for the earnings to be deposited into and this delayed the receipt of the Federal Work Study payment. Working with the AVP for Enrollment Management, we have discussed with Payroll the need to process a paper check if a student chooses this delivery method. The University is also working on an awareness campaign that will encourage students to set up their direct deposit information in Workday. Students understanding the need to set up direct deposit and the willingness to process paper checks, if necessary, should prevent this finding from recurring. The Associate Director for Compliance or designee will review when the supervisor approved the students’ hours as a part of the bi-semester Federal Work Study sample. These reviews are completed to ensure students are paid on-time and accurately, as well as ensure the student is not working during class hours. These reviews of FWS hours matching the students’ earnings will provide another layer of oversight. Anticipated Completion Date: The Center for Career and Professional Services hired a full-time Federal Work Study Coordinator towards the end of the Fall 2024 semester. All FWS supervisor training occurs prior to the hire of any FWS students, and the supervisor agreement has been updated as of December 2024 to reflect supervisors signing they understand students are not to have time approved prior to working those hours. The awareness campaign encouraging students to choose the direct deposit option in Workday will begin in late Spring as the Fall 2025 class prepares to enter Howard.

Name of Responsible Individual: Ben Carmichael, Associate Director for Compliance, Enrollment Management; Robert Muhammad; Executive Director of Financial Aid; Brenda Willis, Senior Executive Director of Financial Grants & Contracts; Teshome Metaferiya, Director of Reporting Corrective Action: A statement of procedure and workflow will be implemented to formally reconcile FWS - Title IV expenses to the general ledger on a monthly basis to ensure timely draws and adjustments. Adjustments and updates to the FISAP including prior year adjustments will be included in the Title IV reconciliation process and communicated immediately. The reconciliations will require two-tier approvals. Anticipated Completion Date: May 30, 2025