Corrective Action Plans

U.S. Department of Education Alcorn State University (ASU), Delta State University (DSU), and Mississippi University for Women (MUW) respectfully submit the following corrective action plans for the year ended June 30, 2022. Audit period: July 1, 2021 ? June 30, 2022 The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. FINDINGS?FEDERAL AWARD PROGRAMS AUDITS 2022-010: NSLDS Enrollment Reporting (ASU) Student Financial Assistance cluster - Assistance Listing No. 84.007, 84.033, 84.063, 84.268 Recommendation: We recommend the applicable institutions review its reporting procedures to ensure that students' statuses are accurately and timely reported to NSLDS as required by regulations. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Effective Fall 2022, we began reporting enrollment twice a month to the National Student Clearinghouse. This eliminates any inaccuracies and oversights for timely enrollment reporting. Any additional enrollment reporting errors will be corrected directly in NSLDS. Name of contact person responsible for corrective action: Kisha Bond, Registrar and Director of Student Records Planned completion date for corrective action plan is June 30, 2023 If the Department of Education has any questions regarding this plan, please contact Juanita Edwards at 601-877-6672. 2022-010: NSLDS Enrollment Reporting (DSU) Student Financial Assistance cluster - Assistance Listing No. 84.007, 84.033, 84.063, 84.268 Recommendation: We recommend the applicable institutions review its reporting procedures to ensure that students' statuses are accurately and timely reported to NSLDS as required by regulations. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Office of Financial Aid will work with the Registrar's Office to verify each student's last date of attendance is entered in Banner to ensure accurate and timely reporting. Name of contact person responsible for corrective action: Megan Smith Planned completion date for corrective action plan is June 30, 2023. If the Department of Education has any questions regarding this plan, please contact Megan Smith at 662-846-4670. 2022-010: NSLDS Enrollment Reporting (MUW) Student Financial Assistance cluster - Assistance Listing No. 84.007, 84.033, 84.063, 84.268 Recommendation: We recommend the applicable institutions review its reporting procedures to ensure that students' statuses are accurately and timely reported to NSLDS as required by regulations. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Office of the Registrar will coordinate with the Information Technology Services department to ensure files are submitted by the due date. Name of contact person responsible for corrective action: Shannon Lucius, Registrar Planned completion date for corrective action plan is June 1, 2023. If the Department of Education has any questions regarding this plan, please contact Nicole Patrick at 662-329-7114.

U.S. Department of Education Alcorn State University (ASU), Jackson State University (JSU), Mississippi Valley State University (MVSU) and Mississippi University for Women (MUW) respectfully submit the following corrective action plans for the year ended June 30, 2022. Audit period: July 1, 2021 ? June 30, 2022 The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. FINDINGS?FEDERAL AWARD PROGRAMS AUDITS 2022-009: NSLDS Error Reporting (ASU) Student Financial Assistance cluster - Assistance Listing No. 84.007, 84.033, 84.063, 84.268 Recommendation: We recommend the applicable institutions review their reporting procedures to ensure that students' statuses are accurately and timely reported to NSLDS and the requisite response to error records occurs within the 10-day time period. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Effective Fall 2022, we began reporting enrollment twice a month to the National Student Clearinghouse. This eliminates any inaccuracies and oversights for timely enrollment reporting. Any additional enrollment reporting errors will be corercted directly in NSLDS. Name of contact person responsible for corrective action: Kisha Bond, Registrar and Director of Student Records Planned completion date for corrective action plan is June 30, 2023. If the Department of Education has any questions regarding this plan, please contact Juanita Edwards at 601-877-6672. 2022-009: NSLDS Error Reporting (JSU) Student Financial Assistance cluster - Assistance Listing No. 84.007, 84.033, 84.063, 84.268, 84.379 Recommendation: We recommend the applicable institutions review their reporting procedures to ensure that students' statuses are accurately and timely reported to NSLDS and the requisite response to error records occurs within the 10-day time period. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Jackson State has an established and published academic calendar which guides the day-to-day academic operations and functions of the University. In some instances, the census and financial purge deadlines are extended to ensure students complete their registration requirements. When extensions are provided, the enrollment file is unable to be submitted timely and also causes delays in processing the error report. To alleviate the untimely submission of the enrollment report, different practices have been established to aid students in completing their registration before the published deadline and subsequently ensuring the enrollment file is submitted by the deadline. Name of contact person responsible for corrective action: Ozie Ratcliff Planned completion date for corrective action plan is June 30, 2023. If the Department of Education has questions regarding this plan, please call Ozie at 601-979-3347. 2022-009: NSLDS Error Reporting (MVSU) Student Financial Assistance cluster - Assistance Listing No. 84.007, 84.033, 84.063, 84.268 Recommendation: We recommend the applicable institutions review their reporting procedures to ensure that students' statuses are accurately and timely reported to NSLDS and the requisite response to error records occurs within the 10-day time period. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Office of Student Records/University Registrar will closely monitor all errors received from the National Student Clearinghouse and correct them within the 10-day timeframe. For errors related to system updates and etc., the Office of Student Records/University Registrar will collaborate with the Department of Information Technology in an effort to correct the issues in a timely manner. This will allow submission of the error reports to be timelier. Additionally, the Office of Student Records/University Registrar will strengthen communication with the NSCH relative to technical issues online which may hinder the timeliness of submitting error reports. Lastly, our office will coordinate the collaboration between our Information Technology Team and the Technical Team of NSCH to resolve any technical issues forthcoming. Name of contact person responsible for corrective action: Jeffery Loggins, University Registrar Planned completion date for corrective action plan is April 13, 2023 If the Department of Education has questions regarding this plan, please call Deborah Banks at 662-254-3335 2022-009: NSLDS Error Reporting (MUW) Student Financial Assistance cluster - Assistance Listing No. 84.007, 84.033, 84.038, 84.063, 84.268 Recommendation: We recommend the applicable institutions review their reporting procedures to ensure that students' statuses are accurately and timely reported to NSLDS and the requisite response to error records occurs within the 10-day time period. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: A staff member has been designated to correct errors within the 10-day time period. Name of contact person responsible for corrective action: Shannon Lucius, Registrar Planned completion date for corrective action plan is June 1, 2023. If the Department of Education has questions regarding this plan, please call Shannon at 662-329-7135.

U.S. Department of Education Mississippi Valley State University (MVSU) respectfully submits the following corrective action plan for the year ended June 30, 2022. Audit period: July 1, 2021 ? June 30, 2022 The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. FINDINGS?FEDERAL AWARD PROGRAMS AUDITS 2022-008: Gramm-Leach-Bliley Act (MVSU) Student Financial Assistance cluster - Assistance Listing No. 84.007, 84.033, 84.038, 84.063, 84.268 Recommendation: For those institutions noncompliant with requirements, CLA recommends that the institution needs to complete all areas. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Office of Financial Aid stores all student files in a locked file room. There are only two keys to gain access which is held by the director and the associate director. The file room remains locked at all times unless a request is made by a counselor or if the director or associate director needs to obtain a file. All financial aid personnel have been trained to initiate the following processes - lock computer screens when leaving their area for a short period of time, if gone for an extended time frame the computer is locked and the financial aid representative's office door is locked. Financial aid documents are electronic and exist in the institution's software module. Name of contact person responsible for corrective action: Deborah Banks, Interim Director of Financial Aid Planned completion date for corrective action plan is April 13, 2023. If the Department of Education has questions regarding this plan, please call Deborah Banks at 662-254-3335.

The district will implement stricter procedures to ensure all expenditure reports are filed within the 20 day period after the quarter ends. To ensure this happens, the district will create calendar reminders and a system of checks and balances. See full Corrective Action Plan on the district letterhead.

Finding 2022-003 Federal Agency Name: U.S. Department of Education Program Name: Student Financial Assistance Cluster CFDA #: 84.063, 84.007, 84.268, 84.033 Finding Summary: Due to the changeover in software in the current year, the College did not have an internal control process in place to provide for an independent review over the return of Title IV calculations. Responsible Individuals: Frankie Everett, Director of Financial Aid Corrective Action Plan: The department will assign an individual to randomly sample 30% of the R2T4?s each term, documenting the results and ensuring the system is calculating and reporting these accurately throughout the year. Anticipated Completion Date: January 15, 2022

Condition: One of the 40 student files examined, we noted the students (2.5%) were not properly awarded Subsidized Direct loans. Corrective Action Plan: The financial aid office will implement a process of review of reallocation of federal financial aid funds at the time of notification from a student of the ineligibility of outside awards. Responsible Person for Corrective Action Plan: Becky Whithaus, Director of Financial Aid. Implementation Date for Corrective Action Plan: 1/2/2023.

202 Flex Subsidy Assistance Loan ? Assistance Listing No. 14.157 Replacement Reserve Deposits: Per the regulatory agreement a monthly deposit is to be made into the replacement reserve. Per HUD-9250, starting January 1, 2022 that monthly amount is $4,343.50 which equates to an annual deposit of $52,122. The replacement reserve was underfunded $1,122 at December 31, 2022. Recommendation: Recommend that a catch-up payment is made as soon as possible to make the replacement reserve whole. There is no disagreement with the audit finding. Action taken in response to finding: Management made the additional $1,122 deposit on February 24, 2023. Name of the contact person responsible for corrective action: Lisa Gindt Planned completion date for corrective action plan: February 24, 2023.

2022-001: Missing Exit Counseling Documentation - Student Financial Aid Cluster - Assistance Listing #s 84.033, 84.007, 84.063, 84.268, 84.038 - Grant Period - Year Ended August 31, 2022 Condition: During our student file testing, we noted one student out of 40 did not have documentation in their file that exit counseling was sent thirty days after the student withdrew. We consider the missing exit counseling to be an instance of non-compliance with the Eligibility Compliance Requirement. Corrective Action Plan: Our office has updated the document letter template to automatically input the date of creation. The office will also ensure that the letters are generated promptly when informed of student withdrawal. The office will also periodically review withdrawn students to verify exit notification was sent. Responsible Person for Corrective Action Plan: Director- Marc Yambao Assistant Director- Josie Extrom Implementation Date of Corrective Action Plan: 10/27/2022

Federal Student Aid - Corrective Action Plan Date written: 01/05/2023 Finding: Notification of Right to Cancel Direct Loans The Fiscal 2022 audit identified insufficient communication regarding borrowers' rights to cancel Direct Loans. Schools are required to notify borrowers in writing within 30 days of loan disbursement regarding their right to cancel the loan. NBSS agrees that these communications were insufficient to meet the requirement. Existing student account procedures already ensure that every borrower receives an account statement within 30 days of any Direct Loan disbursement. As such, NBSS has added the following statement which will appear on every account statement procedures from its billing software. "Federal Direct Loan recipients can cancel all or a portion of a loan within 30 days of disbursement date." This statement was added to the account statement template within the billing software on 12/01/2022. All statements produced after 12/01/2022 are in compliance with this requirement. The Direct of Finance is responsible for all student account procedures. Any questions regarding this matter should be directed to: Director of Finance Levi Barrett lbarrett@nbss.edu 617-227-0155 X 150

Finding 2022-001 ? Special Tests and Provisions ? Enrollment Reporting (Student Financial Assistance Cluster) Contact Persons: Diana Dimas, Registrar?s Office Cristen Alecia, Office of Financial Assistance Current Status: Correction of this finding is in-progress. Anticipated Completion Date: December 31, 2023 Condition: The University of the Incarnate Word did not accurately or timely report student status changes to the NSLDS for 6 out of 60 students selected for testing. Identification of Repeat Finding: 2021-001, 2020-001, 2019-002 While the condition reported above is considered a repeat finding, it is important to note that the errors are different this year and that these findings are not a reflection of the university ignoring previous findings or failing to make changes, but rather a reflection of the complexity of enrollment reporting. There were no inaccurate or untimely attendance level changes, and the official withdrawals were reported accurately and timely. In this year?s errors, we had a student who graduated outside of a normal conferral date, causing them not to be reported during our normal degree conferral report to NSC. The Registrar?s Office is putting changes in place to either eliminate out-of-cycle conferrals, or increase the number of conferral and reporting dates to effectively capture all graduates. We know that only 6 students were caught up in this out-of-cycle graduation, as it was a specific exception for the School of Osteopathic Medicine, and is not a wide-spread issue. We had two unofficial withdrawals reported later than 60 days ? at 69 and 70 days. While the withdrawal and the changes were processed timely, the timing of the roster from NSLDS compared to the submission to NSC caused the report not to be acknowledged until after the 60 days had passed. The Office of Financial Assistance is researching the option of manually reporting unofficial withdrawals outside of the monthly reporting cycle in order to eliminate this problem. The Registrar?s Office will review the roster and NSC submission schedules to see if changes need to be made in order to better align reporting dates. We had three students inaccurately reported as withdrawn for the summer semester. These students were at least half-time in the preceding Spring and the following Fall, and therefore were not required to be reported as withdrawn. The Office of Financial Assistance and the Registrar?s Office will work together to research options in Banner and with NSC. It may be necessary to create a separate withdrawal code to identify summer withdrawals that should not be reported as withdrawn, and create a report to monitor the fall enrollment for these students in case they later withdraw from Fall and transition to a withdrawal which must be reported. The Banner system alone does not allow for the complicated logic mandated for summer reporting in the NSLDS Enrollment Reporting Guide. Our offices will continue to work in partnership to resolve these enrollment reporting issues. Cristen Alicea Director Office of Financial Assistance 210.805.1238 gimenez@uiwtx.ed www.uiw.edu/finaid Diana Dimas Associate Registrar Registration and Technology Office of the Registrar 210.832.5484 dimasd@uiwtx.edu www.uiw.edu

Instructors will do a better job communicating to the Registrar of student course drops and reporting LDAs. The Registrar has implemented a review of all data to ensure it is correct moving forward. Our third-party financial aid processer, FAME, has agreed to review all r2T4 forms going forward for accuracy.

Finding No. 2022-002 Enrollment reporting Cluster: Student Financial Assistance Cluster Grantor: Department of Education Award Name: Federal Direct Student Loans Award Year: July 1, 2021 ? June 30, 2022 Award Number: Not applicable Assistance Listing Number: 84.268 The College agrees with the finding noting that this exception is an unusual occurrence as a result of improper recording of the leave status in Colleague, the student information system. The record in Colleague should have had hiatus data entered on April 11, 2022, the date in which the College was aware of the student?s enrollment change, which would allow the change in enrollment information to be queried and transmitted to the National Student Clearinghouse (?NSC?) in in the May 17, 2022 submission. As this hiatus data was not updated, the student?s enrollment record was reported as enrolled at that time, which is attributed to an error in data entry of the multiple fields required in Colleague to reflect a leave from the College. The student?s transcript was correctly marked as ?W? as of April 8, 2022. However, the effective date was not correctly reported to the NSLDS. Management is in the process of correcting the effective date reporting to the NSLDS. The College has since implemented Workday Student, the College?s new student information system, in August of 2022. New business processes for entering student leaves have been documented and staff have been trained. The Office of Student Affairs initiates the leave process and a system process prompts records, financial aid, and billing to review the student record. The leave is updated within the student information system once all of the relevant offices have completed their processing. Training was done as a part of the implementation and testing process. The NSC enrollment reporting in Workday is automated. Jesse Barba, Director of Institutional Research and Registrar Services, is responsible for the implemented corrective action plan.

Finding No. 2022-001: Review of Return of Title IV Funds calculation Cluster: Student Financial Assistance Cluster Grantor: Department of Education Award Names: Federal Pell Grant Program, Federal Supplemental Educational Opportunity Grants, Federal Direct Student Loans Award Year: July 1, 2021 ? June 30, 2022 Award Number: Not applicable Assistance Listing Numbers: 84.063, 84.007, 84.268 The College agrees with the finding noting that a business control process was in place for a review of all Return of Title IV aid calculations, however, the College did not retain documentation evidencing this review. The College confirmed none of the Return of Title IV aid calculations selected had errors and the control was working as it was designed. The control is taken seriously and both training and oversight of personnel performing return of title IV calculations is exercised. As of March 31, 2023, the review will be noted on the change sheet at the time of award revision with the signature stamp in Perceptive Content (imaging and workflow software). Gail Holt, Dean of Financial Aid is responsible for implementing this corrective action plan.

Individuals Responsible for Corrective Action Plan: Eileen F. Doyle, Associate Vice President of Student Financial Services, (914) 633-2483 Corrective Action Plan: In this instance, there was a manual intervention which caused a loan to credit to the student account. A decision was made to leave the credit but not refund as a motivation for the student to complete the required Entrance Counseling. The student subsequently completed the Entrance Counseling when the loan credit was reversed. As soon as the Entrance Counseling was completed the loan was recredited and the refund was processed within the appropriate timeframe. The individual who made the decision to not refund is no longer with the University. Staff have been trained that, unless the borrower has completed all requirements, loans cannot be credited to an account and the ?do not refund? option is not an appropriate tool in such an instance. Anticipated Completion Date: Completed.

Individuals Responsible for Corrective Action Plan: Eileen F. Doyle, Associate Vice President of Student Financial Services, (914) 633-2483 DJ Arndt, Registrar, (914) 633-2520 Corrective Action Plan: Iona University?s Registrar?s office updated the Holiday Calendar schedules in PeopleSoft, the Student Information System, to ensure that institutionally scheduled breaks of 5 or more consecutive days are properly reflecting weekend days. These updates will be used to accurately calculate the percent of a term attended and federal aid earned for federal aid recipients who withdraw from the University during a term as part of the Return to Title IV aid mandatory calculations. The calendar entries will be made by the Associate Registrar and reviewed and approved by the Registrar during the academic year set up process each academic year. Anticipated Completion Date: Completed.

Emmanuel College Audit Response Finding number 2022-001 from the 2022 audit has been copied below with the management response and corrective action plan provided. EMMANUEL COLLEGE SCHEDULE OF FINDINGS AND QUESTIONED COSTS JUNE 30, 2022 Condition: Out of a sample of 108 students there were 20 who withdrew. We decided to test all 20 of those students as it related to return of Title IV funds. Return of funds were sent in by the required date except for two instances. One was late due to the Thanksgiving Holiday. The school was closed on that Thursday and Friday, so the funds were not submitted until the following Monday. This was not a big deal; however, the other instance was simply late by 4 days and no Holidays were involved. Cause: Simply an oversight in which the date simply slipped by them. Effect: The Department of Education received the transferred return of funds 4 days later than they were required to be deposited into the SFA account. Recommendation: College management should design and implement procedures to ensure that there are checks and balances to make sure that when a student withdraws and the return of funds are calculated that the required return date is flagged and sent to whomever is responsible for submitting those funds to the SFA account. Management Response and Corrective Action Plan: Financial Aid personnel will utilize a built in Return to Title IV funds feature of the financial aid software, PowerFaids, to function as a quality assurance measure for Accounting Office staff. The PowerFaids function archives the date of withdrawal and calculates the deadline for return of funds. This feature will allow for quality assurance reports to be pulled no less than a week before the deadline so that Financial Aid staff can serve as an accountability partner for accounting staff in ensuring funds are returned in a timely fashion and in compliance with all federal guidelines. Contact Responsible for Corrective Action: Donna Quick, Vice President for Enrollment, 706-245-2872

Name of Responsible Officials: Margherite Powell, Director of Financial Aid. The Policy and Procedures manual has been updated to reflect the following updated process: The Financial Aid Office has implemented measures to ensure students/parents that have Title IV loans disbursed are sent loan disbursement notifications via Colleague once a loan disbursement has been made. The process is done via Colleague each day and captures all Title IV loan disbursements made for the previous day. The notifications are processed via the ST-PCB process in Colleague, which sends a system generated loan disbursement notification to the student/parent. Processes are being worked on with the Information Technology department to generate a copy of the notification and to put in place a paper notification if no parent email is provided.

Name of Responsible Officials: Carlos Chaves, Business Office Manager. The Business Office processes student refunds within 14 days after a Title IV credit balance appears on a student?s account. At least once per week, the Refunds Coordinator generates a refund report (ARTM) which lists students with credit balances. The University?s policy is that all refunds are processed via ACH (direct deposit), and all students are required to provide their bank account information. Communication is sent to students throughout the semester reminding them to sign up for direct deposit. To ensure that all students receive their refunds by the required 14 days, a paper check is issued to students missing banking information. Checks are sent to the mailing address on file. Communication will continue to be sent to all students encouraging them to sign up for ACH refunds. However, refunds are processed timely even if the banking information is not available. The Policy and Procedures manual has been updated to reflect this process.

Name of Responsible Officials: Carlos Chaves, Business Office Manager. The Business Office has implemented measures to ensure that Perkins Promissory Notes are identified, stored, and accessible during their repayment and collection period. In addition to the current filing system, the Business Office will utilize management software for ease of access and recording. To ensure that all remaining promissory notes are kept in accordance with Department of Education regulations, the Business Office will: ? Record all incoming promissory notes internally and externally. ? Promissory notes created prior to 2013 will be made digitally accessible through Perceptive Content, a secure content management system. Access to these promissory notes will only be accessible by parties with authorized access. ? Promissory notes created after 2013 will continue to be made available through Heartland ECSI?s third party filing system. ECSI records paid, completed, cancelled, and retired promissory notes that were created after 2013. ? In accordance with the Perkins Assignment and Liquidation Guide from the Department of Education (EA ID: General-21-53), all accounts with promissory notes unable to be located will be written off and/or purchased from the Department of Education prior to the end of FY 2023. The Policy and Procedures manual has been updated to reflect this process.

To Whom It May Concern: Midland University Single Audit Report: Corrective Action Plan - Year ended May 31, 2022 Finding 2022-002 ? NSLDS Enrollment Reporting Condition/Context: For 6 of 25 students tested, the status effective date or program was reported incorrectly or the student was not reported to NSLDS. ? Two students' withdrawn dates reported to NSLDS did not agree to the support provided from the University's system. Additionally, one of these student's enrollment status was reported incorrectly as full time not 3/4 time. The University subsequently corrected these students? records in NSLDS and the auditor viewed the screen prints with the corrections. ? One student's graduated date reported to NSLDS did not agree to the support provided from the University's system, however the University believes the date reported to NSLDS was correct and the system's date was incorrect. ? One student's full time status effective date was reported incorrectly as January 10, 2022 not August 30, 2021. The University subsequently corrected the student?s record in NSLDS and the auditor viewed the screen print with the corrections. ? One student was incorrectly not reported to NSLDS when they attended and had Title IV loans during 2021-22. The University subsequently corrected the student?s record in NSLDS and the auditor viewed the screen prints with the corrections. ? One student's status dates reported to NSLDS for campus level January 10, 2022 did not agree to the support provided by the University's system of April 4, 2022. The University subsequently corrected the student?s record in NSLDS and the auditor viewed the screen print with the corrections. The sample was not a statistically valid sample. Corrective Action Plan The University has made all corrections to the identified records. The University is reviewing its current processes and evaluating if additional review controls need to be put in place to ensure timely and accurate NSLDS data.

To Whom It May Concern: Midland University Single Audit Report: Corrective Action Plan - Year ended May 31, 2022 Finding 2022-001 ? Title IV Credit Balances Condition/Context: For 4 of 25 students tested, the credit balance was not resolved in compliance with the regulations, the student?s Title IV credit balances on their accounts were held and applied to future charges without student or parent authorization. The first student?s Title IV credit balance was $759 of Direct Loan funds, the second student?s was $3,702 of Direct Loan funds, the third student?s was $390 of Direct Loan funds and the fourth student?s was $2,850 of Direct Loan funds and $943 of Teach Grant funds. The sample was not a statistically valid sample. Corrective Action Plan The University agrees with the finding. The occurrence of Title IV credit balances occurs primarily with graduate program students. A review is being conducted of current internal control processes and evaluating what additional reporting is capable within the student information system to assist in identifying these Title IV credit balances in a more timely manner. Title IV credit balances are being monitored during the Spring 2023 terms and new procedures will be put in place for the Fall 2024 term.

FY 2022 SFA Audit Corrective Action Plan Audit Firm: RSM US LLP 30 S Wacker Drive, Suite 3300 Chicago, IL 60606 Audit Period: 1/1/2022 ? 12/31/2022 Comments on Findings and Recommendations: Finding 2022-001 ? Error in Reporting for NSLDS Finding: Herzing University did not properly report the student enrollment change for a student who received federal student aid to the National Student Loan Data System (NSLDS). Condition: The University did not report a student?s Program-Level or Campus-Level enrollment status change to NSLDS. Out of the 60 students tested, we noted 1 student (1.7%) whose status change at the Program-Level and Campus-Level was not reported to NSLDS. Action Taken: In this instance, the student identified was withdrawn from the University and was correctly reported to NSLDS as such through our standard enrollment reporting processes. The student then subsequently re-enrolled at the University in the subsequent academic period becoming an Active student, and then withdrew again prior to our next standard enrollment reporting process occurring (one month after the previously reported withdrawn status). At the point of the second standard enrollment reporting timeframe, the student status was once again withdrawn, therefore an update did not occur to their enrollment status. Our process did not have a mechanism to identify the student changing statuses in between those reporting periods so that the active enrollment status was reported and then changed back to withdrawn versus simply staying at a withdrawn status. In August 2022, Herzing University updated our enrollment reporting policy to send in enrollment reporting biweekly instead of monthly. This was done to ensure that each student?s enrollment status was accurately reported as soon as possible and to prevent issues that occur from delays in proper enrollment statuses being reported to NSLDS. This update inherently decreased the likelihood that status timing issues would occur given the condensed timeframe for reporting. In addition, as of May 1st, 2023 Herzing University has developed and implemented an exception reporting process that will identify any student that has status updates that occur but reverts back to the original status within the timeframe of the two enrollment reporting periods. Using the student identified in this finding as an example, if the student is at a withdrawn status at the first enrollment reporting period, then moves to an active status immediately after that but then withdraws again within that 2 week window and therefore goes back to a withdrawn status in the subsequent enrollment reporting period, while our standard reporting would still show the student withdrawn for both standard enrollment reporting timeframes, the exception report will flag that student for review since a status change occurred in between the two withdrawn statuses being reported out. Upon review of the exception report, all relevant status progressions will be correctly reported to NSLDS. The required corrective action for Finding 2022-001 listed in the SFA audit for the period 1/1/2022 ? 12/31/2022 was completed on 5/1/2023. The person responsible for completion of the corrective action was Kevin McShane, Vice President of Financial Aid & Compliance.

AUDIT FINDING Finding 2022-001 Late Return to Title IV (R2T4) MANAGEMENT'S COMMENTS ON FINDINGS AND RECOMMENDATIONS We concur with the auditor?s finding and identification of a deficiency in our internal controls. MANAGEMENT'S CORRECTIVE ACTION PLAN We will enact stronger controls to ensure that all R2T4s are returned in a timely manner. EMPLOYEE/ DIVISION RESPONSIBLE Financial Aid Director TIMELINE AND ESTIMATED COMPLETION DATE Immediately

AUDIT FINDING Finding 2022-002 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. MANAGEMENT'S CORRECTIVE ACTION PLAN We will enact stronger controls to ensure that all future enrollment reporting is submitted timely. EMPLOYEE/ DIVISION RESPONSIBLE Financial Aid Director TIMELINE AND ESTIMATED COMPLETION DATE Immediately

It was brought to our attention that we are unable to update our third transmittal to NSC due an uploading error with Jenzabar. Once we were notified of this error, we began communicating with NSC to find an alternative route to submit the third transmittal. The third transmittal was submitted but we later learned that the file was rejected. Unfortunately during that time, the notification of the error message was inadvertently overlooked due to the challenges we were faced with during the recovery period of Hurricane Ida. To mitigate this from occurring in the future, we have discussed changing how and when our enrollment transmittal data will be reported. Furthermore, we had participated in training and scheduled additional training opportunities with Jenzabar to create an errorless transmittal process.