Corrective Action Plans

During the Fall 2021 semester, the late disbursement of funds was the result of staff being displaced as a result of Hurricane Ida in which the University started on time but had to stop due to the hurricane and its impact. Several staff members were also impacted, and the departments were working short staffed, which filtered into the Spring 2022 semester whereby there was an increase in the reduction of staff within the Office of Business and Finance.

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.

Corrective Action: The two students whose information was not reported within 60 days was due to an internal failure to report the status change by the Financial Aid and Registrar's Office. The one student whose effective date varied between program and campus level stems from system limitations, as the process to report this status change on the program level but not the enrollment level, as required by NSLDS, is a manual process. The University continues to refine the manual process required for reporting this type of status change. For the four students who never had their graduation status reported to the NSLDS, Management noted one actual failure to report and three instances where the status change was reported to the Clearinghouse, but not reflected on NSLDS. The University is working with the Clearinghouse to understand what went wrong and how to prevent it in the future. The University is in the middle of implementation of a new student information system which is expected to improve this and other processes. Implementation is anticipated to be complete by July 2023.

Finding 2022-006 Federal Agency Name: Department of Education Program Name: Education Stabilization Fund ALN 84.425 Finding Summary: The College provided emergency grants to students with the student portion of the HEERF funding, but the College could not provide evidence that the student met the definition of ?eligible student?. The emergency grants were used to relieve the delinquent student accounts. There were 5 students identified in our testing that were not ?enrolled in an institution of higher education on or after the date of the declaration of the national emergency (March 13, 2020).? It appears the 5 students were not enrolled at the College on or after March 13, 2020, and the College did not obtain evidence that the students were enrolled on or after this date at another institution of higher education. Responsible Individuals: Courtney Judah, Director of Institutional Effectiveness Corrective Action Plan: Ongoing training was conducted with Enterprise Management Software support to develop reporting and process steps to prevent reporting errors and improve accuracy for student?s assistance. Prevention to include creation of reports for awards pending and detailed disbursement and reconciliations schedules. Develop ongoing student intervention processes to identify student with emergency financial need. Student Funding Committee formed that processes request includes verification of enrollment, number of credits, and financial aid standing. Committee includes representatives from Financial Aid, Advising, Foundation, and the Business Office. The College has entered into an agreement with a third-party financial aid provider to service and administer financial aid awards, reporting and reconciliation. Contracted services include award packaging, document collection and compliance review, disbursement logs, direct flow of federal funds, account reconciliation and exit process. The added third-party support reduced workload on Financial Aid and allowed for a more proactive engagement with student emergency funding needs. Contacted Department of Education grant administrator for guidance on program requirements and compliance. Completed and will continue to participate in ongoing Department of Education training. Anticipated Completion Date: June 30, 2023

Finding 2022-004 Federal Agency Name: Department of Education Program Name: Student Financial Assistance Cluster ALN 84.007, 84.033, 84.063, 84.268 Finding Summary: During our testing, we noted 42 instances out of 182 disbursement transactions tested where the disbursement date per the College?s records and the processing date at COD was outside the mandatory 15-day reporting window. In addition, we noted 52 instances out of 182 disbursement transactions tested where the disbursement date per the student?s record and the disbursement date per COD did not agree. Responsible Individuals: Axel Hernandez, Director of Financial Aid Corrective Action Plan: Continue to identify and resolve Enterprise Management Software (ERP) issues that result in disbursement delays. The College has entered into an agreement with a third-party financial aid provider to service and administer financial aid awards, COD reporting and reconciliation. Contracted services include award packaging, document collection and compliance review, disbursement logs, direct flow of federal funds, account reconciliation and exit process. Ongoing training was conducted with ERP support and third-party disbursement software support to develop reporting and process steps to prevent reporting errors and improve accuracy in reporting in identifying student?s assistance needs. Prevention to include creation of reports for awards pending and detailed disbursement and reconciliations schedules. Anticipated Completion Date: Ongoing

Finding 2022-003 Federal Agency Name: Department of Education Program Name: Student Financial Assistance Cluster ALN 84.007, 84.033, 84.063, 84.268 Finding Summary: During our testing over the NSLDS reporting requirements, we noted that 27 enrollment status certifications out of 151 enrollment certifications tested were not reported to NSLDS in the required timeframe. In addition, it was noted that 57 enrollment statuses out of 151 enrollment statuses tested did not agree to the enrollment status that was submitted to NSLDS. Responsible Individuals: Mary Martin, Registrar Corrective Action Plan: Enrollment reporting is the responsibility of the Columbia Gorge Community College (CGCC) Registrar. Reporting of enrollment information in a timely manner for the year ended June 30, 2022, was impacted by the implementation of a new Student Information System (SIS) in May 2021. The SIS included significant changes to student record procedures and a new enrollment reporting process. In response to the Enrollment Reporting Finding for the year ended June 30, 2022, the Registrar continues working to mitigate any issues negatively impacting enrollment reporting by: ? working with the Vice President of Student Services and Director of Financial Aid to establish internal checks and balances to ensure reporting is being done in a timely manner; ? working with SIS system support staff and internal IT staff to promptly address technical issues and/or other issues impacting enrollment reporting; ? working with National Student Clearinghouse representative to ensure reporting schedule meets required timeframes; ? consistent review of enrollment files prior to submission to ensure correct student enrollment statuses and program information are being reported; ? prompt resolution of reporting errors; ? identifying and training of additional staff on enrollment reporting. Anticipated Completion Date: Ongoing

Finding ? Eligibility ? Federal Direct Student Loan Program Assistance Listing Number 84.268 and Federal Pell Grant Program Assistance Listing Number 84.063; June 30, 2022 Award Year; U.S. Department of Education Criteria or Specific Requirement The annual maximum loan amount an undergraduate student may receive must be prorated when the borrower is enrolled in a program that is shorter than a full academic year; or enrolled in a program that is one academic year or more in length but is in a remaining period of study that is shorter than a full academic year. (2021 - 2022 Student Financial Aid Bank Book, Volume 3, Chapter 5, Page 3-160, 34 CFR 685.203(a),(b),(c)) The amount of a student's Pell Grant for an academic year is based upon the payment and disbursement schedules published by the Secretary for each award year. (2021 - 2022 Student Financial Aid Handbook, Volume 3, Chapter 3, Page 3-68, 34 CFR 690.62) Condition Of the 40 students selected for eligibility testing, two students within the sample were incorrectly awarded aid based upon their specific circumstances. This was not a statistically valid sample. Views of Responsible Officials and Planned Corrective Actions The University concurs with the finding. The University will implement periodic quality control checks to ensure student aid is being appropriately calculated and awarded based upon relevant student enrollment and financial information. Names of Contact Persons Responsible for Corrective Action: Joan Romano, Registrar and Anne-Marie Caruso, Assistant Vice President/Director of Financial Aid Anticipated Completion Date: October 24, 2022

Finding ? Special Tests and Provisions: Enrollment Reporting ? Federal Direct Student Loan Program, Assistance Listing Number 84.268; June 30, 2022 Award Year; U.S. Department of Education Criteria or Specific Requirement Enrollment information, including the effective date of separation from the institution, must be accurately reported within 30 days whenever attendance changes for a student, unless a roster will be submitted within 60 days. The changes include reductions or increases in attendance levels, withdrawals, graduations, and approved leaves-of absence. It is the institution?s responsibility, as a participant in the Title IV aid programs, to monitor and report these changes to the National Student Loan Data System (?NSLDS?). (NSLDS Enrollment Reporting Guide September 2021, and 34 CFR 685.309(b)) Condition Of the 40 students selected for enrollment reporting testing, three students within the sample were reported to NSLDS outside the maximum 60-day window. This was not a statistically valid sample. Views of Responsible Officials and Planned Corrective Actions The University concurs with the finding. The University will continue to remain vigilant in its oversight over timely communication of enrollment reporting detail to NSC and from NSC to NSLDS. Names of Contact Persons Responsible for Corrective Action: Joan Romano, Registrar and Anne-Marie Caruso, Assistant Vice President/Director of Financial Aid Anticipated Completion Date: October 24, 2022

2022-003 Student Financial Assistance Cluster ? Federal Assistance Listing Nos. 84.063 and 84.268 Recommendation: We recommend the University review its policies and procedures on reporting enrollment information to the NSLDS to ensure that all relevant information is being captured accurately and reported timely in accordance with applicable regulations. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The University will work towards adjusting policies and systems to ensure more timely and accurate reporting to NSLDS. This will include working with representatives at NSLDS and the Clearing House to ensure transmission of data is happening more frequently and accurately. Changes have also been made on how long after the close of semester we will allow a retroactive medical withdrawal. The timing of this will help ensure more timely reporting. Name(s) of the contact person(s) responsible for corrective action: Natalie Durant, Registrar Planned completion date for corrective action plan: May 2023

2022-001 Student Financial Assistance Cluster ? Federal Assistance Listing No. 84.038 Recommendation: We recommend the University evaluate is procedures and policies around recordkeeping and retention. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Management have reviewed their policies and procedures in regards to recordkeeping and retention of Perkins loan documents. Assigned and Retired Perkins loans are maintained in a locked, fireproof container in the Bursar office. The repayment schedules are electronically kept in our borrower files in Heartland ECSI. In addition, the Perkins loan program expired September 30, 2017. Name(s) of the contact person(s) responsible for corrective action: Diane Purcell, Bursar Senior Accountant, (860) 768-4361 Planned completion date for corrective action plan: March 2023

Finding 2022-001: Direct Loan Reconciliation Finding Type: Internal control over compliance ? Significant deficiency and noncompliance Federal Program title and Assistance Listing Number: Federal Direct Student Loan (84.268). Criteria: In accordance with 34CFR ?685.300 (b)(5), a school must, on a monthly basis reconcile institutional records with Direct Loan funds received from the Department of Education and Direct Loan disbursement records submitted to the and accepted by the Department of Education. Condition: During the audit, AFI was unable to provide evidence that the reconciliations were performed on a monthly basis. Context: AFI disbursed $8,050,495 in Federal Direct Student Loans during the year. Questioned Costs: None Cause: AFI did not maintain the documentation to support compliance with 34CFR ?685.300 (b)(5). Effect: AFI was not able to demonstrate compliance with 34CFR ?685.300 (b)(5). View of responsible officials and corrective actions taken or planned: The Institute has performed monthly reconciliations. However, the reconciliations were not kept on file for every month, particularly those with little to no activity. Accordingly, the Institute agrees on the finding. AFI has updated its procedures to retain documentation on all reconciliations that are performed on a monthly basis, and going forward, the Institute is implementing a formal second review process, with a new hire to support this long-term. Individuals responsible for corrective action: Robin Bailey-Chen, Director, Financial Aid 323.856.7764 Anticipated completion date: October 1, 2022

2022-002 Student Enrollment Reporting June 30, 2023 The University agrees with the finding. The University?s procedures between multiple departments lacked a collaboration on the timing of reports to NSLDS via NSC for degree confirmations. This procedural change has been identified and will be implemented moving forward. In addition, adequate procedure changes have also been identified as it relates to program-level reporting and will be implemented to ensure compliance. The contact person for this corrective action plan is Shannon Sutton, Interim Vice President for Finance and Administration. She can be reached by calling (309) 298-2073 or at the following address: Vice President for Finance and Administration Office Western Illinois University Sherman Hall 200 1 University Circle Macomb, IL 61455

Finding 2022-003 ? Special Tests and Provisions ? Enrollment Reporting Previously, some withdrawals were delayed as the result of electronic forms stalling within the workflow process. The Office of Records and Registration has met with the consultants and revised the process so that Records and Registration and Financial Aid is alerted immediately when a Term Withdrawal is submitted. Withdrawals are processed within 24 hours of receipt. Faculty will be trained to ensure the timeliness of them reporting students who have not been attendance so the student?s status will be updated expeditiously so they will be reported correctly. The Office of Records and Registration is working with Academic Affairs to hire staff who will be responsible for Enrollment Reporting and NSLDS. We will also report monthly to the National Student Clearinghouse in an effort to capture any changes in students? enrollment status. Anticipated Date of Completion: Corrective action completed as of the date of this report. Contact: Marie McNear Director Records and Registration mmcnear@alasu.edu 334.229-4312 The Office of Financial Aid works closely with the Office of the Registrar to ensure that all withdrawn students from the University are reported to the Clearinghouse on a monthly basis. Once the students are withdrawn and the report is generated to the Clearinghouse, the Registrar?s Office will submit a copy of those monthly reports to the Office of Financial Aid. Anticipated Date of Completion: September 30, 2023 Contact: K. Michael Francois Associate Vice President for Student Affairs/Financial Aid kfrancois@alasu.edu 334.229.4826

Finding 2022-001 ? Special Tests and Provisions ? Individual Program Compliance ? Federal Work Study Programs The Office of Student Financial Aid has hired a Federal Work Study Coordinator. The responsibilities of the coordinator are as follows: ? Determine eligibility ? Award the student for the year ? Ensure that the student has a federal work-study contract prior to starting work ? Student and supervisor must sign a work-study responsibility contract ? Student is assigned a work-study job placement ? Student enters their time into TimeClock Plus (TCP) ? Ensures the student time is correct by doing a monthly audit o Audit to ensure that the student doesn?t work more than 20 hours nor that the student works during the class schedule ? Submit information to payroll for processing Anticipated Date of Completion: Corrective action completed as of the date of this report. Contact: K. Michael Francois Associate Vice President for Student Affairs/Financial Aid kfrancois@alasu.edu 334.229.4826

Corrective Action Plan Monday, February 20, 2023 Harrisburg Area Community College respectfully submits the following corrective action plan for the year ended June 30, 2022. The findings from the June 30, 2022 audit report dated February 20, 2023 schedule of findings and questioned cost are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. Agency: U.S. Department of Education Audit Period: July 1, 2021 ? June 30, 2022 Name and Address of independent public accounting firm: Smith Elliott Kearns & Company, LLC, Certified Public Accountants & Consultants 804 Wayne Avenue Chambersburg, Pennsylvania Finding Type: Student Financial Aid Cluster: Significant Deficiency in Internal Control over Compliance and NonCompliance Internal Control Type: (please choose the type per the finding) o Material Weakness(es) ? Significant Deficiencies Audit Finding No.: 2022-003 Federal Program: (per Finding) Student Financial Aid Cluster Compliance Requirement: (per Finding) Activities Allowed or Unallowed and Eligibility Audit Finding Title/Statement of Condition: (copy from audit findings documentation) Significant Deficiency in Internal Controls over Compliance and Noncompliance 34 CFR 668.32-a student is eligible to receive Title IV, HEA (Higher Education Act) program assistance if the student is a regular student enrolled, or accepted for enrollment, in an eligible program at an eligible institution. Auditor Recommendation: (copy from audit findings documentation) We recommend that the College contact the U.S. Department of Education to review the programs in question and determine what additional programmatic changes may be necessary, if any, to ensure the student financial aid program is in compliance with federal regulations. Specific steps to be taken to correct the situation [including a timetable for performance of the CAP] or reason why corrective action is not necessary (including disagreement with the finding). This finding was resolved in April 2022. Below are some of the specific steps the College took (and will continue) to correct the situation. o Identified an approved program and/or degree that aligns with each former pre-program student?s academic goal. Currently enrolled students moved to approved programs and degrees listed on the College?s ECAR. ? It is also important to note that the program(s) do not have a selective separate admissions process. o Removed the pre- or p-coded programs from Banner to ensure this error does not occur in the future relative to auto packaging. o Updated the admissions welcome/acceptance letter to inform new student about the selective/competitive (i.e., Nursing, Dental Assisting, etc.) entry programs and their next steps. o Conducted semesterly tests to ensure no currently enrolled students are coded under ?pre? or ?p-coded? programs. The next test is scheduled for October 2022. o Updated the financial aid policies and procedures manual and checklists. o Provided and will continue to provide professional development opportunities to financial aid employees. Anticipated Completion Date: Done Name(s) and Title(s) of contact person(s) responsible for correction action: Dawn K Mull Director, Financial Accounting & Reporting Harrisburg Area Community College dkmull@hacc.edu

Corrective Action Plan Monday, February 20, 2023 Harrisburg Area Community College respectfully submits the following corrective action plan for the year ended June 30, 2022. The findings from the June 30, 2022 audit report dated February 20, 2023 schedule of findings and questioned cost are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. Agency: (Federal Agency per Finding) U.S. Department of Education Audit Period: July 1, 2021 ? June 30, 2022 Name and Address of independent public accounting firm: Smith Elliott Kearns & Company, LLC, Certified Public Accountants & Consultants 804 Wayne Avenue Chambersburg, Pennsylvania Finding Type: (per Finding) Student Financial Aid Cluster: Significant Deficiency in Internal Control over Compliance and NonCompliance Internal Control Type: (please choose the type per the finding) o Material Weakness(es) ? Significant Deficiencies Audit Finding No.: 2022-004 Federal Program: (per Finding) Student Financial Aid Cluster Compliance Requirement: (per Finding) Reporting Audit Finding Title/Statement of Condition: (copy from audit findings documentation) Significant Deficiency in Internal Control over Compliance and NonCompliance Institutions are required to report enrollment information under the Pell grant and direct loan programs via the National Student Loan Data System (NSLDS). Auditor Recommendation: (copy from audit findings documentation) We recommend that the College contact the student to obtain a copy of their social security card to confirm the name and number to correct this situation. The College should also review its internal procedures to ensure controls are in place to timely identify reporting discrepancies and make corrections as necessary Specific steps to be taken to correct the situation [including a timetable for performance of the CAP] or reason why corrective action is not necessary (including disagreement with the finding). ? The College contacted the student (via email) on Jan. 16, 2023, to verify their information. The student did not respond. ? The College sent a follow up communication on Feb. 13, 2023. ? If the student does not respond by close of business this week (Friday, Feb. 24, 2023), then a member of the Registration and Records unit will contact the student via phone. ? If the student does not respond, a hold will be placed on the student account. The student will not be able to perform any transition until the requirement is met. *The case in question is a unique situation in which the College does not know if the student provided the wrong SSN to HACC or the previous institution, and there is no way that the College would have known that information prior to the reject from the National Student Clearinghouse. At this point the College does not know if the student provided the wrong information to HACC or their prior institution because the student has not responded to the College?s outreach. Moving forward, the College plans to contact students immediately AND place a hold on their accounts (immediately). In most cases, the holds prompt students into action that they would not otherwise take. Anticipated Completion Date: In process Name(s) and Title(s) of contact person(s) responsible for correction action: Dawn K Mull Director, Financial Accounting & Reporting Harrisburg Area Community College dkmull@hacc.edu

Student Financial Assistance - Cluster - Federal Pell Grant Program; Award ID No. P063P210331, 2021 - 2022 Federal Award Year Identifying Number: 2022-005 Audit Finding: The University was required, as a result of the Focused Program Review (OPE ID: 00301200) (FPR) regarding the University?s participation in the ?Pell for Students Who Are Incarcerated? experiment (Second Chance Pell), to complete a full file review (enrollment status, effective dates and reporting dates) of all National Student Loan Data System (NSLDS) enrollment reporting for the 2019-20 and 2020-21 award years and update and correct errors identified. Corrective Actions Taken or Planned: Management concurs with the finding. The Registrar?s Office has performed a review of its policies and procedures and has revised them accordingly to ensure timely, accurate and complete submissions to the NSLDS. The determination of the review was that the enrollment effective status data field required correction in the NSLDS Enrollment History system. Since the restoration of the NSLDS system in November 2022, the Registrar?s Office has been correcting the data.

Student Financial Assistance - Cluster - Federal Pell Grant Program; Award ID No. P063P210331, 2021 - 2022 Federal Award Year Identifying Number: 2022-004 Audit Finding: The University did not have an established policy and procedure to ensure that the University consistently applied the regulations regarding payments of Pell if a student?s program crossed over an award year. Corrective Actions Taken or Planned: Management concurs with the finding. In April 2022 a formal policy and procedures addressing the awarding of the Pell Grant has been established to ensure compliance including staff training.

Student Financial Assistance - Cluster - Federal Pell Grant Program; Award ID No. P063P210331, 2021 - 2022 Federal Award Year Identifying Number: 2022-003 Audit Finding: As part of Schneider Downs testing of the origination records, we noted within a sample of 25 transactions, there were three records that had differences between the Common Origination and Disbursement (COD) data and the University?s data for their verification status codes. Corrective Actions Taken or Planned: Management concurs with the finding. Once management was made aware of the unresolved variances of verification codes, the variances were corrected immediately. Upon discovery in August 2022, the Student Financial Aid Office immediately implemented additional controls and training of staff to ensure that these issues do not reoccur.

Student Financial Assistance - Cluster - Federal Pell Grant Program; Award ID No. P063P210331, 2021 - 2022 Federal Award Year Identifying Number: 2022-002 Audit Finding: As part of the audit for the 2021- 2022 Federal award year, Schneider Downs determined that the University used the same determination for the payment period for those students who had been awarded Pell grants that it had been using in the periods for which the U.S. Department of Education (ED) conducted the Focused Program Review (FPR). In addition to the population of students who are participating the Second Chance Pell program, the University also identified additional students, that when using ED?s interpretation of the Code of Federal Regulations (CFR), the University used a payment period that did not reflect enrollment in a nonstandard instructional term program. Corrective Actions Taken or Planned: Management does not concur with the criteria of this finding due to a disagreement with the interpretation of the regulations included in ED?s Final Program Review Determination (FPRD) and has appealed the finding as stated in the following paragraphs. Management followed the direction received from the ED Reviewers during the FPR exit interview on September 24, 2021, stating the University should not change its practice for the Second Chance Pell students enrolled in their respective instructional program nor the calculation using Formula 1 for the payment period until the Program Review Report (PRR) is received. The PRR was received on January 3, 2022, which was after the summer and fall 2021 semesters and just weeks prior to the start of the spring 2022 semester. Moreover, pursuant to the Higher Education Act ?498A(b), the University was entitled to an opportunity to review the PRR and within 60 days of receipt, submit a response for ED?s review prior to their preparing a final determination. The University submitted its response to the PRR on March 11, 2022. The University disagrees with the determinations in the FPRD and is vigorously defending itself against the ED interpretation of the regulations, the findings and the proposed financial assessments. The University filed an appeal of the findings and the associated financial assessments contained in the FPRD on October 24, 2022, and submitted a brief in support of the appeal on January 22, 2023, to the ED Office of Hearings and Appeals within the guidelines as prescribed by the Higher Education Act ? 487(b)(2) and U.S.C. ? 1094(b)(2). Effective with the fall 2022 semester term and each fall and spring terms thereafter, the Second Chance Pell students enrolled in their respective instructional programs have a fifteen (15) week standard instructional term and the payment period qualifies for calculations utilizing Pell Formula 1.

Responsible Individual(s): Ron Anderson, Associate VP of Student Financial Services Finding 2022-002 Federal Agency Name: Department of Education Program Name: Student Financial Aid Cluster CFDA No.: Various Finding Summary: When a recipient of Title IV grant or loan assistance withdraws from an institution during a payment period or period of enrollment in which the recipient began attendance, the institution must determine the amount of Title IV grant or loan assistance that the student earned as of the student's withdrawal date and must return the amount of Title IV funds for which it is responsible as soon as possible but no later than 45 days after the date of the institution's determination that the student withdrew. During 2022, three students that withdrew during the period of enrollment required a refund of funds. These returns of Title IV funds were not made within the 45 day period required. Corrective Action Plan (CAP): The University will partner with the Registrar?s Office to determine students who have withdrawn from Lipscomb and need to have Federal Title IV funds returned. These returns will be tracked in a spreadsheet, calculated within the Student Information System, and returned through Common Origination and Disbursement within the regulated 45 days. Anticipated Completion Date: The procedures will be implemented for the 2022-2023 Financial Aid Year. Responsible Parties: The Return to Title IV process will be done by staff in the Financial Aid Office as assigned by the Director and monitored by the Associate VP of Student Financial Services.

Responsible Individual(s): Ron Anderson, Associate VP of Student Financial Services Finding 2022-001 Federal Agency Name: Department of Education Program Name: Student Financial Aid Cluster CFDA No.: Various Finding Summary: In accordance with 34 CFR Sections 685.102(b), 685.301, and 303, each month, the Common Origination and Disbursement system provides institutions with a School Account Statement (SAS) data file which consists of a Cash Summary, Cash Detail, and (optional at the request of the institution) Loan Detail records. The institution is required to reconcile these files to the institution's financial records. Since up to three Direct Loan program years may be open at any given time, institutions may receive three SAS data files each month. During fiscal year 2022, only three of the twelve monthly reconciliations were completed due to a system conversion and turnover in the financial aid department. Corrective Action Plan (CAP): The University will implement procedures to reconcile the Common Origination and Disbursement system to the University?s financial records for Direct Loans monthly. This task will be completed in the Financial Aid Office as assigned by the Director of Financial Aid and monitored by the Associate VP for Student Financial Services. Reconciliations will be completed for each month with disbursements, staring with the 2022-2023 Financial Aid Year. Anticipated Completion Date: The procedures will be implemented for the 2022-2023 Financial Aid Year. Responsible Parties: The monthly reconciliation will be done by staff in the Financial Aid Office as assigned by the Director and monitored by the Associate VP of Student Financial Services.

Aggregate Loan Limits Planned Corrective Action: I) We will ensure our automated process for verifying Direct Loan eligibility is functioning properly in Powerfaids (financial aid software). We will ensure that we are capturing all aggregate loan limits and are verified when a student is clo e to or at their aggregate limits. In addition, we will review our automated processing when FAFSAs come into the financial aid department to identify the correct people who need to be reviewed. 2) Counselor will go in and reviews NSLDS information and verifies loan eligibility and corrects if needed. 3) Counselor determines proper loan amount and adjusts the loan limit if student is eligible for funding Person Responsible for Corrective Action Plan: Dr. Anthony Turner, Vice President of Enrollment and Marketing Anticipated Date of Completion: 12/17/2022

Finding Number: 2022-007 Condition: The Seminary did not maintain appropriate documentation to substantiate the allowable charges on the students ledger account to identity whether credit balances were created and required additional documentation from the student to hold the credit balance. Planned Corrective Action: The Seminary will no longer be holding any credit balances for students. Any Title IV aid that is disbursed for 23-24 and creates a credit balance will be refunded to the student within 14 days of disbursement. Contact person responsible for corrective action: Vu Huynh Anticipated Completion Date: 07/31/2023

Finding Number: 2022-003 Condition: Of the 16 students who received disbursements selected for testing, the Seminary did not notify 11 students or parents, as applicable, that received direct federal loans within the required 30 days. Planned Corrective Action: Financial Aid Director has already set up a disbursement notification email to be sent out of the new financial aid management system (JFA). Shortly after Title IV disbursements are made, the Director will send out the disbursement notification to any group of students who have had aid disbursed. Each time a disbursement is made, these notifications will be sent to the necessary students. These notifications will be documented in each students? records. Contact person responsible for corrective action: Ashley Schreiner Anticipated Completion Date: 07/31/2024 (to be completed throughout 23-24 academic year)