Corrective Action Plans

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 This will get students who have withdrawn, less than 1/2-time attendance, not enrolled, graduated or schedule to graduate.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

California: Recommendation: We recommend the University review the R2T4 requirements and implement procedures to ensure the R2T4 calculations are using the correct amount of term days and are accurately completed.Explanation of disagreement with audit finding: There is no disagreement with the audit finding.Action taken in response to finding: The missing component in this finding was an isolated occurrence of a configuration that is directly related to the integration and is unlikely to occur again. The Office of the Registrar maintains a semester calendar of tasks to be completed with associated dates. The process in place is that the break days for any term are configured by the staff in the Office of the Registrar, management reviews that configuration and then financial aid staff review to confirm.Name(s) of the contact person(s) responsible for corrective action: Management reviews configuration of staff data entry of the break days.Planned completion date for corrective action plan: Plan is currently being employed.

Finding: 2022-084 - The enrollment effective date reported to the National Student Loan Database System for five of the ten sampled students from the UAS campus was incorrect and did not match the correct last dates of attendance on file in the institution?s records.Questioned Costs: NoneAssistance Listing Number: 84.007, 84.038, 84.063, 84.268, 84.379Assistance Listing Title: Student Financial Assistance ClusterViews of Responsible Officials (state whether your agency agrees or disagrees with the finding; if you disagree, briefly explain why): There is no disagreement with the audit finding.Corrective Action (corrective action planned): The UAS Financial Aid Office will work the Registrar?s Office to ensure that our last dates of attendance are being reported accurately. We are working on adjusting our procedures to have a process in place to ensure the last date of attendance can be manually updated to be sent to Clearinghouse and NSLDSCompletion Date (list anticipated completion date): June 30, 2023Agency Contact (name of person responsible for corrective action):Janelle Cook, Director of Financial Aid, 907-796-6257Jennifer Sweitzer, Associate Director of Financial Aid, 907-796-6296Trisha Lee, Registrar, 907-796-6294

Finding: 2022-083 - During the testing of the outstanding Title IV student check listing we observed nine instances of stale checks at the University of Alaska Southeast (UAS) and three stale checks at UAF that were aged greater than 240 days and not returned to the Department of Education.Questioned Costs: NoneAssistance Listing Number: 84.007, 84.038, 84.063, 84.268, 84.379Assistance Listing Title: Student Financial Assistance ClusterViews of Responsible Officials (state whether your agency agrees or disagrees with the finding; if you disagree, briefly explain why): There is no disagreement with the audit finding.Corrective Action (corrective action planned): UAF and UAS Financial Aid Offices will work with the Statewide Office of Finance and Accounting to pull a regular report of uncashed checks and review for Title IV aid. The Financial Aid Offices or Bursars? Offices will contact students with uncashed checks to attempt to provide the refund. Checks still uncashed after attempts will be canceled and returned to Title IV aid programs within 240 days of payment.Completion Date (list anticipated completion date): June 30, 2023Agency Contact (name of person responsible for corrective action):Janelle Cook, UAS Financial Aid Director, 907-796-6257Jon Lasinski, UAS Business Office Director, 907-796-6497Ashley Munro, UAF Financial Aid Director, 907-474-1934Jennie Witter, UAF Bursar, 907-474-6196

Recommendation: We recommend the College evaluate its procedures and policies around reporting Direct Loan disbursements to COD to ensure that student information is reported accurately and timely.Explanation of disagreement with audit finding: There is no disagreement with the audit finding.Action in Response to Finding: New selection sets were implemented in database to ensure students do not disburse until all documents are received and that they disburse to COD and to the Business Office at the same time.Name of the contact person responsible for corrective action: Shannon Amundson, Director of Financial Aid (719) 389-6651.Planned completion date for corrective action plan: Completed September 1, 2023

Recommendation: We recommend the College evaluate its procedures and policies around reporting to NSLDS, including those that are unique in nature, to ensure that student information is reported accurately and timely.Explanation of disagreement with audit finding: There is no disagreement with the audit finding.Action in Response to Finding: College personnel met with the National Student Loan Clearinghouse to determine what steps were needed to fix the issues we have. Adjusting the dates of submission was determined to be the best course of action to ensure that all rejects could be corrected at Clearinghouse prior to the NSLDS submission monthly.Name of the contact person responsible for corrective action: Shannon Amundson, Director of Financial Aid (719) 389-6651.Planned completion date for corrective action plan: Implemented September 1, 2022.

Recommendation: The auditors recommend the University follow and enhance existing policies to ensure all student changes in status are identified timely and submitted accurately within the required time frame. They also recommend the University establish a formal internal monitoring control whereby a designated individual with NSLDS access, on a sample basis, spot checks the status updates on NSLDS so to internally audit the National Student Clearinghouse submissions.Planned Corrective Action: Heritage University will adhere to and improve the current standards to guarantee that all student status changes are promptly identified and submitted accurately within the appropriate time period. In order to internally audit the National Student Clearinghouse submissions, the University will set up a formal internal monitoring system whereby a designated person with access to NSLDS periodically monitors the status updates on NSLDS.Name of Responsible Party:1. Dianne Fernandez, Director of Financial Aid2. Mary Neal, Registrar3. Thomas Richter, VP of Administration/CFOAnticipated Completion Date: June 30, 2023

Recommendation: The auditors recommend the University further educate and train those involved in the Financial Aid department regarding the Eligibility rules surrounding Federal awards, specifically regarding types of and scenarios using estimated financial assistance. They also recommend the University revise the inputs within the PowerFAIDS system so that the control established to prevent (and subsequently detect) overawards is appropriately considering all scholarships and institutional grants as estimated financial assistance, regardless of need-based or not. Lastly, as a monitoring control, the auditors recommend an overaward report showing both Federal and non-Federal overawards be developed and be run and reviewed at a set frequency by the Director.Planned Corrective Action: Heritage University is to give individuals working in the financial aid office more information and training about the eligibility requirements for federal awards, particularly with regard to the several forms and potential uses of anticipated financial aid. Additionally, the University is to update the PowerFAIDS system's inputs so that all institutional grants and scholarships, regardless of whether they are need-based or not, are adequately taken into account by the control mechanism created to avoid (and consequently detect) overawards. As a monitoring measure, the Director of Financial Aid will create an overaward report that lists both Federal and non-Federal overawards and runs it on a regular basis.Name of Responsible Party:1. Dianne Fernandez, Director of Financial Aid2. Thomas Richter, VP of Administration/CFOAnticipated Completion Date: June 30, 2023

2022 ? 001: Student Financial Aid Cluster - Student Eligibility and Awarding: Exit Counseling ?Program Number 84.268Recommendation: We recommend the college review its policies and procedures around disbursingexit counseling information to students to ensure students are receiving proper counseling and ensureentrance 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: The Financial Aid Office recognized that the exit loan counselingrule was not being met prior to the commencement of the 2021-2022 audit. The following action planwas already taking shape during the annual audit of 2021-2022 to ensure compliance rule would bemet for the 2022-2023 aid year.Process: Use SIS Colleague system to run query to identify current loan borrowers at beginning andend of term to identify those who have ceased half-time enrollment. Send communication via email andphysical letter notification to ensure student receive important information about loan repaymentresponsibilities, including Department of Education links and contact information.Procedure: Created documentation with step by step procedures for assigned staff to run query toidentify students, request exit loan counseling communication, and run batch posting of communication.Communication: Loan borrowers will receive an email on Day 1 run, a second email on Day 14 run, anda paper letter on Day 30 run.Staff Training: Staff assigned to the Loan program have been trained to run process by ourSystems/Programmer. Financial Aid Staff have been provided information about policy and proceduresto assist students who may contact our office for assistance after receiving exit loan counselingcommunication.Quality Assurance: Two additional staff members have been assigned to help with the Loan program.Name(s) of the contact person(s) responsible for corrective action: Chau Dao - Director ofFinancial AidPlanned completion date for corrective action plan: November 2022.

2022 ? 003: Student Financial Aid Cluster: Enrollment Reporting ? VariousRecommendation: Evaluate the current processes and possible backup controls to ensure errors arecaught in a timely manner.Explanation of disagreement with audit finding: There is no disagreement with the audit finding.Action taken in response to finding: El Camino College will review the Enrollment VerificationProcess to ensure it is capturing all student enrollments and reporting them properly to NationalStudent Clearinghouse. The Departments involved Information Technology, Admissions & Recordsand Financial Aid will review how the data is collected from the college?s student information system(Ellucian Colleague) and the submissions to the National Student Clearinghouse and The NationalStudent Loan Data System to ensure the records are correct and submitted in a timely fashion.Name(s) of the contact person(s) responsible for corrective action: Lillian Justice, RegistrarPlanned completion date for corrective action plan: Immediate review of the data collection processwith the Information Technology Department and Financial Aid to ensure it is capturing all currentlyenrolled students. This will be an ongoing review beginning February 2023 to ensure we are capturingthe correct data.

2022 ? 002: Student Financial Aid Cluster - Return to Title V Exit Counseling ? Program NumberVariousRecommendation: We recommend that the Colleges improve the existing procedures and controls toensure compliance with the aforementioned criteria. We also recommend an additional level of reviewis added in the process to ensure completed Return to Title IV calculations are properly completed.Action taken in response to finding: The Financial Aid office is implementing the following steps toensure all R2T4 rules are met.Process: Create new report to monitor return of unearned aid to ED within 45 days of determination.Training: Staff involved with R2T4 processing will be provided time to undergo annual training by ED orNASFAA to ensure understanding of rules and regulations. Trainings by ED and NASFAA includepractice case studies to ensure correct application of R2T4 regulations.Quality Assurance: Two additional staff members have been assigned to help with R2T4 processing.One member to assist with the review of R2T4 calculations with the second staff member to help withthe return of aid on the accounting side. Also added to our R2T4 procedures, is management review ofR2T4 calculations per term.Name(s) of the contact person(s) responsible for corrective action: Chau Dao - Director ofFinancial AidPlanned completion date for corrective action plan: December 2023.

Finding 2022-07 Return to Titel IV - Post withdrawal disbursement - Pell Grant - see corrective action plan submitted with the audit report.

Finding 2022-08 Return to Titel IV - Post withdrawal disbursement- Direct Loans - see corrective action plan submitted with the audit report.

Finding 2022-05 Return to Titel IV - refunds made late - see corrective action plan submitted with the audit report.

Finding 2022-04 Late Notification to NSLDS - see corrective action plan submitted with the audit report.

Finding 2022-02 Direct Loan exit counseling - see corrective action plan submitted with the audit report.

Finding 2022-01 Late Notification to NSLDS - see corrective action plan submitted with the audit report.

February 24, 2023Audit Response to Federal Grants Audit (A-133) - Enrollment reporting to National Student ClearinghouseAnalysis:Robert Morris University (University) attributes the delay in reporting changes of student enrollment status (withdrawal, graduated, less than half time, etc.) to the National Student Clearinghouse (NSC) to the implementation of a new student information system conversation (Banner) that occurred in June 2021. Banner replaced a legacy system that the University had used for decades that had reliable processes and reporting controls that accurately reported information to the NSC.The identified exceptions can be categorized into the following two general categories:Off-Cycle GraduationOne group of exceptions related to students who had degrees conferred but the University had not updated their status to "graduated" in the NSC. Upon further review, the University determined extenuating circumstances (i.e. completion of all paperwork, and assignments, incomplete grade(s), etc.) existed for these students' and their graduation date fell outside of the normal graduation date of their peers for that semester cohort. Because of the off-cycle graduation timing, these students were not captured in the new graduate reporting process in Banner at the end of each semester. This resulted in the students not being reported to the NSC.Fall 2021 Status ChangesThe final group of exceptions occurred due to the University's new student information system conversion (Banner) in June 2021. Due to the specific requirements and customized nature of the clearinghouse file, the University's first electronic submission for Fall 2021 was delayed as errors/issues were being resolved in conjunction with the NSC. During that time frame, there were students who had fully withdrawn and/or status changes from the University, but due to the delay and file parameters, they were inadvertently excluded in the first submission and/or their status change wasn't reported in a timely manner.

February 24, 2023Audit Response to Federal Grants Audit (A-133) - Return of Title IV Aid (R2T4)Analysis:Robert Morris University ("University") attributes the isolated delay in refunding Title IV funds in excess of the required 45-day window following the student's complete withdrawal to a student information system conversation (Banner) that occurred in June 2021. Banner replaced a legacy system that the University had used for decades. Specifically, customized reporting in Banner was needed in order to provide additional visibility so that the University could timely fulfill R2T4 obligations. As a result of the above, the University enacted several measures and safeguards to strengthen controls around the R2T4 process.Response:The University implemented the following control measures:-In September 2022, the University Registrar performed a retraining for all individuals who process complete withdrawals from the University. This training included a detailed walk through of all the steps required to timely and accurately process a complete withdrawal in Banner.-The University's IT department developed custom reports showing complete withdrawals from the University, which are generated and distributed to the Financial Aid office who reviews this report on a weekly basis to make sure withdrawals are completed timely and the appropriate financial aid adjustments are reflected on the students account.-On a monthly basis, the Senior Director of Student Financial Services now performs a double check review of a withdrawal report and alerts Financial Aid of any additional withdrawals that may meet the criteria for a return.Conclusion:The University deems that the control measures in place listed above are adequate and will prevent any future instances of untimely R2T4 funds. Overall, although the refunds were issued in excess of 45 days, the Department of Education did receive all required refunds in full and no amounts were outstanding at the time of the audit procedures.Keith A. RoeperChief Accounting Office and Controller and Assistant Treasurer

2022-009 Special Tests and Provisions – The Gramm-Leach-Bliley Act (GLBA) Student Financial Aid Cluster – Assistance Listing No. 84.007, 84.033, 84.063, 84.268 Recommendation: We recommend the University engage a third party or perform the risk assessment for the two areas required by the Gramm-Leach-Bliley Act that have not been completed and documented and ensure that there are documented safeguards for identified risks. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The University began engagement with AIS, an IT Managed Service Provider in May 2022 and hired a Director of IT in November 2023. The University is working with AIS and Cowbell to develop and implement a Cybersecurity policy, as well as to provide training for all employees, the Board of Governors, and students. The University has also deployed Cloud Storage backup solutions for all data. Name(s) of the contact person(s) responsible for corrective action: Scharvin Wilson, Director of IT, AIS, IT Managed Services Provider, E. ZeNai Savage, CPA, CFO and Executive VP of Finance and Administration Planned completion date for corrective action plan: June 30, 2024

2022-007 Reporting – Common Origination and Disbursement (COD) Student Financial Aid Cluster – Assistance Listing No. 84.007, 84.033, 84.063, 84.268 Recommendation: We recommend that the entity strengthen its internal controls to ensure that all disbursement dates are reported to COD accurately and timely. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The University has begun to restructure all accounting and reconciliation functions. The University is implementing financial internal controls to improve the internal financial reporting process. Names of the contact persons responsible for corrective action: E. ZeNai Savage, CPA, CFO and Executive VP of Finance and Administration, and Qiana Hall, Associate VP of Enrollment Services Planned completion date for corrective action plan: June 30, 2024

2022-006 Special Tests and Provisions – Return of Title IV Funding Student Financial Aid Cluster – Assistance Listing No. 84.007, 84.033, 84.063, 84.268 Recommendation: We recommend the institution maintain proper documentation in accordance with federal grantor requirements and ensure that the documents are readily available for review upon request, including monitoring of students with triggering events that require a return to Title IV calculation to be completed, reviewed, and approved. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The University has implemented policy and procedures that require a review of all official and unofficial withdrawals to have R2T4 calculations on a real time basis to ensure compliance with the Department of Education guidelines on a consistent and regular basis. Internal audits of the process will also be implemented for continuous improvement. Names of the contact persons responsible for corrective action: E. ZeNai Savage, CPA, CFO and Executive VP of Finance and Administration, and Qiana Hall, Associate VP of Enrollment Services Planned completion date for corrective action plan: June 30, 2024