Corrective Action Plans

Finding 2022-002 - U.S. Department of Education (USDE), Title IV Student Financial Aid Programs (material weakness): b) Two (2) out of 20 students tested had missing official transcripts with a questioned cost of $8,511. c) The College was unable to provide the enrollment history for withdrawals whether part-time or full-time to determine whether funds have to be returned. Recommendation - The College should implement corrective actions to ensure that the abovefindings are resolved and will not recur in future periods." Corrective Action - Management will implement procedures to ensure Federal Wark-Study students' files are reviewed and ensure that student files are properly completed and maintained, including inclusion of identification cards, official transcripts, and enrollment histories.

Condition: The University did not accurately calculate the return of title IV funds (R2T4) and return funds for 1 of 25 students (4%) who withdrew from the University. The University entered the incorrect dates for the term the student enrolled and attended, resulting in an incorrect calculation of unearned aid. We consider this finding to be an instance of noncompliance in relation to Special Tests and Provisions. Questioned costs: $178. Repeat Finding: No. Corrective Action Plan: Responsible Person for Corrective Action: Susan Swisher, Executive Director Office of Financial Aid. Implementation Date for Corrective Action Plan: Action has already been completed. A manual calculation was performed to determine the number of days in the payment period and the number of days the student attended. Closed days were not removed from the calculation which created the error. The refund calculation was purged and recalculated with the correct dates. Based on the recalculation, the student completed at least 60% of the term and a return of funds was not required. The return amount was disbursed directly to the student in July when the error was identified. Management currently reviews all refund calculations to ensure accurate calculations and will continue that practice to ensure compliance.

As a corrective measure, along with additional staff training, Vanderbilt will be implementing a quality control step to ensure that the notifications are properly made. This step will essentially do a sweep of students whose financial aid awards have been finalized (but prior to the actual disbursement of funds) but have not yet received the required financial aid notification letter. This process will be executed on a weekly basis. Vanderbilt University expects to have this process in place by November 2022. For follow-up questions and information, please contact Brent Tener, Executive Director of Student Financial Aid and Scholarships at Vanderbilt University.

Reference No. 2022-001 Explanation: The College had not reported changes of withdrawn students to the NSLDS as required under the Uniform Grant Guidance for the year ended May 31, 2022. The College had a system upgrade in the Fall of 2021 and did not realize there was a bug in the system that did not properly report withdrawn students on one of the standard reports produced by the system. The College did not have another monitoring mechanism in place that would have alerted them to this deficiency in the automated system reporting. Corrective Action Plan: The Registrar's Office will change their enrollment status and dates in National Student Clearinghouse to reflect accurate information and contact NSLDS to report the issue. To ensure this doesn't happen in the future, these steps will be taken: ? IT will report the bug to Jenzabar. ? Registrar will manually create a new row in the Registration Transaction table anytime a student fully withdraws from a term. ? IT will create a report that flags any inconsistencies in hours in Student Registration vs. NSC status.

Department of Education 2022-001 Student Financial Assistance Cluster ? Federal Assistance Numbers 84.063, 84.268 Recommendation: We recommend the University evaluate its procedures and review policies in overseeing submissions to the NSLDS completed by the third-party servicer. Additionally, we recommend the University review its policies and procedures on reporting enrollment and program information to the NSLDS to ensure that all relevant information is being captured 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: Item 1: Student Status did not match (1 student) Internal reports in Argos for review will be created to review student status in comparison with NSC and NSLDS reports and records. Particular attention will be paid to withdrawn students, as in the case of the student with this finding. Reports will be reviewed and documented on a monthly basis. Item 2: Effective Enrollment Dates do not match (3 students) For this finding, of the three students, two were withdrawn and one graduated. In addition to the reports mentioned for Item 1, guidance from Ellucian on Banner system indicates that completely withdrawn students must be assigned for the term an enrollment status code with the 'Withdraw Indicator' check box checked. Staff will be instructed to ensure this is done. For graduating students, the graduation date on the extract to Clearinghouse will be a date that matches the final date of the term. This will also be checked on a monthly basis with internal reports and NSLDS. Item 3: Status change reported outside 60-day requirement (3 students) This was due to a timing error where the data sent to NSC was after their transmission date to NSLDS, causing the update to not be sent for several weeks from NSC to NSLDS. This, in conjunction with the five-week winter break, caused the data to be received at NSLDS beyond the 60-day requirement. Having reviewed the NSLDS website, there is a capability to update an individual student there without waiting for NSC transmission dates if there is a concern with timeliness. Our Registrar has coordinated with NSC to verify all transmission dates and ensure ample time to allow updates to reach NSLDS in a timely manner. Item 4: Enrollment Effective Dates and Program Enrollment Dates did not match at NSLDS (2 students) Of the two students with this finding, one was a graduating student. The actions described for graduating students in Item 2 should also prevent this finding. The other student was updated to less than half time following a course drop. In the case where a student changes time status but remains enrolled, the actual date of the drop should be the enrollment and program enrollment date, not the start of the term. Changes in status that are either close to the beginning of term (before the first transmission to Clearinghouse) or are backdated should be verified at NSLDS once the file from NSC has been accepted. Internal reports to find all students with this situation and additional analysis of the NSC reporting process are planned and will be run on a monthly basis. Item 5: Institution's Enrollment Effective Date, NSLDS Enrollment Effective Date, and Program Enrollment Effective Date did not match (1 student) The one student in this finding Withdrew. In a case with the Ellucian action line, the student did not receive an enrollment status code with the 'Withdraw Indicator' checked. The actions described for Item 2 should also prevent this type of finding. Name(s) of the contact person(s) responsible for corrective action: Avery Turner, Thomas Mazzolla Planned completion date for corrective action plan: June 30, 2023

March 17, 2023 Cognizant or Oversight Agency for Audit Coffeyville Community College respectfully submits the following corrective action plan for the year ended June 30, 2022. Name and address of independent public accounting firm: Jarred, Gilmore & Phillips, PA, P.O. Box 779, 1815 S Santa Fe, Chanute, Kansas 66720. Audit period: Year ended June 30, 2022. The findings from the March 17, 2023 schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. Finding: 2022-001 ? Special Tests and Provisions ? Enrollment Reporting Condition: During our testing of the enrollment reporting, it was noted that Coffeyville Community College did not have internal controls of reporting changes in student status? to NSLDS. Recommendation: Policies and procedures should be written to provide additional training and oversight of staff responsible for enrollment reporting. We recommend the College establish an oversight process that includes additional controls necessary until staff are fully trained in the area of enrollment reporting. Views of responsible officials and planned corrective action: The VP for Academic Services will review and establish written policies/procedures to provide transparency regarding graduation deadline dates for awarding academic degrees, as well as student current enrollment status at the institution. The VP for Academic Services will hold meetings with the Registrar, Advising, Financial Aid, and Institutional Research departments to identify and address data inconsistencies prior to enrollment reporting dates. If the Oversight Agency for Audit has questions regarding this plan, please call Jeff Morris, Vice President for Operations and Finance. (620)251-7700. Sincerely, Coffeyville Community College

Federal Direct Loan and Pell disbursement dates per the University's billing system did not agree with the reportd dates per the Common Origination Disbursement (COD) records. Cost of attendance transaction numbers, and the Pell award amount did not agree between the students' file and COD records. Personnel Responsible for Corrective Action: Tonya Mourning, Chief Financial Officer, and Mike Pepple, Student Financial Services Director Anticipated Completion Date: Corrective action plan will be implemented by June 30, 2023. Corrective Action Plan - Management has overhauled the underlying processes to include formal monthly reconciliations and additional levels of review. Further, the new process requires that Pell and Direct Loan origination and disbursement records are submitted to the COD by the end of next business day. The newly implemented reconciliation process validates disbursement dates, amounts and COA in the COD.

Enrollment information was not submitted accurately or within the required timeframe by the University. Personnel Responsible for Corrective Action: Tonya Mourning, Chief Financial Officer, and Alicia Murillo, Director of Institutional Research Anticipated Completion Date: Corrective action plan will be implemented by June 30, 2023. Corrective Action Plan: Management has hired a new Student Financial Services Director and is aware of the federal regulations surrounding enrollment information that must be reported to the NSLDS. Given the complexity of the reporting, management has established additional policies and procedures to address the errors related to enrollment reporting to the NSLDS in a timely and accurate manner.

Finding 2022-005 Special Tests and Provisions ? Enrollment Reporting Federal Agency Name: Department of Education Program Name: Student Financial Aid Cluster CFDA # 84.268 ? Federal Direct Student Loans CFDA # 84.063 ? Federal Pell Grant Program Finding Summary: During testing of enrollment reporting, the following deficiencies were noted: ? 1 of 81 students was reported to NSDLS with incorrect effective dates. ? 3 of 81 students were reported to NSLDS with incorrect status changes. ? 9 of 81 students were reported to NSLDS with incorrect program begin dates. Responsible Individuals: Jessica Papa, Director of Financial Aid Corrective Action Plan: Management has noted the high error rate and taken steps to improve review of reporting student enrollment information to NSDLS. The external review planned for the Spring term will also address this high error rate. Anticipated Completion Date: Ongoing.

Finding 2022-004 Special Tests and Provisions ? Borrower Data Transmission and Reconciliation (Direct Loan) Significant Deficiency in Internal Controls over Compliance Federal Agency Name: Department of Education Program Name: Student Financial Aid Cluster CFDA # 84.268 ? Federal Direct Student Loans Finding Summary: When testing special tests and provisions related to COD, the following was noted: ? 9 of the 12 monthly SAS reconciliations were not completed by Presentation College. ? 1 of 60 students was incorrectly reported to COD as having received Title IV funds. Responsible Individuals: James (Rocky) Query, Interim CFO and Jessica Papa, Director of Financial Aid Corrective Action Plan: Management has identified an outside consultant with the appropriate expertise to review current monthly SAS reconciliation processes. Anticipated Completion Date: We anticipate this external review to be completed over the next several weeks with implementation of recommended changes made prior to the end of the Spring term.

Assistance Awarded Federal Agency Name: Department of Education Program Name: Student Financial Aid Cluster CFDA # 84.268 ? Federal Direct Student Loans CFDA # 84.063 ? Federal Pell Grant Program Finding Summary: During testing over the eligibility requirements, the following deficiencies were noted: ? 2 of 60 students were not awarded the correct amount of Pell. Both students were under awarded for the Summer 2022 semester. ? 6 of 60 students were not awarded the correct amount of subsidized loans. 4 students were under awarded subsidized loans based on being packaged as the wrong year in school; 1 student was not given full amount of loan agreed to on packaging; and 1 student was over awarded subsidized loans as the student did not have financial need. ? 4 of 60 students were not awarded the correct amount of unsubsidized loans. 3 of the students were under awarded unsubsidized loans based on being packaged as the wrong year in school. 1 student was awarded an unsubsidized loan which was not credited to student account but was reported in the COD system. ? 1 of 60 students received subsidized/unsubsidized loans exceeding the aggregate limit. Student was over awarded subsidized loans in the 2021 fiscal year, and this was not properly corrected before 2022 aid was reported. Responsible Individuals: James (Rocky) Query, Interim CFO and Jessica Papa, Director of Financial Aid Corrective Action Plan: As described in management?s response to the prior finding, transition in the Financial Aid Office, combined with insufficient training for new staff and adequate support from external resources, contributed to a high error rate in calculation of the proper amount of aid for Pell, unsubsidized loans and subsidized loans. In response, management has redoubled efforts to improve the review of award calculations and intends to engage external resources to review award calculations for FY23. Anticipated Completion Date: The Financial Aid Office has made necessary corrections in all student accounts. Further, the Office has emphasized correct calculations of awards for both the Fall and Spring 2023 semester. Training has improved during the current fiscal year. External resources will be engaged within the next several weeks to further review the award process; proper calculation of drawdown and return of Title IV funds, and proper conduct of internal control processes including adequate monthly reconciliations of student accounts and Title IV drawdowns.

Finding 2022-007 Special Tests and Provisions ? Disbursements to or on Behalf of Students ? Lack of Documentation for Disbursement Notices. Federal Agency Name: Department of Education Program Name: Student Financial Aid Cluster CFDA # 84.033 ? Federal Work Study Program CFDA # 84.268 ? Federal Direct Student Loans CFDA # 84.007 ? Federal Supplemental Educational Opportunity Grants (FSEOG) CFDA # 84.063 ? Federal Pell Grant Program Finding Summary: During 2022, out of the total of 60 students tested, 9 students did not receive proper notification of the loan disbursement required under the CFR. Responsible Individuals: James (Rocky) Query, Interim CFO and Jessica Papa, Director of Financial Aid Corrective Action Plan: Management has initiated a review of its student notification process for loan disbursement. Corrective actions are planned for the Spring term. Anticipated Completion Date: Ongoing.

Finding 2022-006 Special Tests and Provisions ? Lack of Transfer Monitoring Federal Agency Name: Department of Education Program Name: Student Financial Aid Cluster CFDA # 84.033 ? Federal Work Study Program CFDA # 84.268 ? Federal Direct Student Loans CFDA # 84.007 ? Federal Supplemental Educational Opportunity Grants (FSEOG) CFDA # 84.063 ? Federal Pell Grant Program Finding Summary: During 2022, out of the total of 60 students tested, 3 students were not properly reported as being required to be monitored by NSLDS. Responsible Individuals: Jessica Papa, Director of Financial Aid Corrective Action Plan: Management has noted the error rate and taken steps to improve review of reporting student enrollment information to NSDLS. The external review planned for the Spring term will also address this error rate. Anticipated Completion Date: Ongoing.

Finding 2022-003 Special Tests and Provisions ? Return of Title IV Funds ? Calculation of the Amount of Title IV Assistance to be Returned, Timely Return of Funds Federal Agency Name: Department of Education Program Name: Student Financial Aid Cluster CFDA # 84.268 ? Federal Direct Student Loans CFDA # 84.007 ? Federal Supplemental Educational Opportunity Grants (FSEOG) CFDA # 84.063 ? Federal Pell Grant Program Finding Summary: During testing over return of Title IV funds, the following deficiencies were noted: ? 5 of 8 students? percentage completion rate were calculated incorrectly which resulted in 3 of the 8 students not having the correct amount of Title IV funds to be returned. ? 1 of 8 students did not return Title IV funds in the required time frame. Responsible Individuals: James (Rocky) Query, Interim CFO and Jessica Papa, Director of Financial Aid Corrective Action Plan: The Business Office and Financial Aid Office have examined the internal control processes to address shortcomings that have contributed to deficiencies in the calculation and return of Title IV funds. External review of internal controls during the Spring term may contribute to further corrective actions. All required corrections in student accounts noted in the findings have been made. Anticipated Completion Date: Review and corrective action ongoing.

Finding 2022-002 U.S. Department of Education Student Financial Assistance Cluster: Federal Direct Student Loans, Assistance Listing 84.268 Federal Pell Grant, Assistance Listing 84.063 Federal Work Study Program, Assistance Listing 84.033 Federal Supplemental Education Opportunity Grants, Assistance Listing 84.007 Teacher Education Assistance For College and Higher Education Grants, Assistance Listing 84.379 P268K220568, P063P210568, P033A212492, P007A212492, P379T220568 Special Test and Provisions ? Return of Title IV Funds Material Weakness in Internal Control over Compliance Finding Summary: In the current year, there was no evidence of an independent review over the return of Title IV calculations. Responsible Individuals: Maia Rowland, Student Financial Aid Director Corrective Action Plan: This issue will cease to exist in the future due to the acquisition of SNU by UNR. The acquisition of SNU by UNR was effective July 1, 2022. Anticipated Completion Date: This issue will cease to exist in the future due to the acquisition of SNU by UNR. The acquisition of SNU by UNR was effective July 1, 2022.

Management accepts the recommendation to request from students receiving federal financial assistance voluntary consent to participate in electronic transactions. The Corrective Action Plan is as follows: Effective December 1, 2022, the University added language to its NetID and other communication portals outlining the policy and obtaining a student?s consent for electronic transactions. 1. The Voluntary Consent for Electronic Transactions was added to our consumer information page. https://financialaid.rice.edu/forms-resources/consumer-information 2. The Voluntary Consent for Electronic Transactions was added to the https://mynetid.rice.edu/ page. Effective Date: December 1, 2022 Person responsible for implementation: Paul Negrete, Executive Director for University Financial Aid Services, 713-348-5905

Finding Number: 2022-002 Condition: Shawnee State University did not report student status changes timely and accurately for certain students who graduated or withdrew during the year. Planned Corrective Action: Prior to an enrollment report being uploaded to the National Student Clearinghouse, the Recalculate Academic Record process in our student information system, currently J1, will be ran to identify any student registration records that may be stuck in a current status due to a mixed Repeat status. Those records will be corrected as needed. The office underwent major staffing changes, which caused a delay in submitting reports in a timelier manner. The staffing issues have been resolved and reports are uploaded on the scheduled submission date. Contact person responsible for corrective action: Tamara Sheets Anticipated Completion Date: 10/6/2022

Finding Number: 2022-001 Condition: The University did not return title IV funds to the Department of Education within the required time frame for certain students who required a return of funds and did not identify all students initially that required a return of title IV. Planned Corrective Action: Upon notification of Finding No. 2021-003, a new R2T4 process was created for the Spring 2022 academic term. This process consists of a new report created to identify students who withdrew from all courses during each academic term. Once the R2T4 calculation is completed, the aid adjustment is made in the financial aid system and posted to the student's account the same day. The aid amounts are manually adjusted in COD. All errors related to finding No. 2022-001 are from Summer 2021 academic term and the Fall 2021 academic term. There were no errors in the audit sample for Spring 2022. The new process continues to be in place. Contact person responsible for corrective action: Nicole Neal Anticipated Completion Date: 10/6/2022

Corrective Action: New student information system has processes in place that will prevent over awarding/over payments, assisting reduce human error. Contact Person: Duane Valencia, Assistant Financial Vice President Completion Date: Began School year 22-23, ongoing

Corrective Action: We have hired additional full-time staff who is being trained and will be overseeing the document requirements for student files. Contact Person: Duane Valencia, Assistant Financial Vice President Completion Date: In progress, staff hired Spring ?23. Currently in training, ongoing.

Enrollment Reporting to NSLDS Planned Corrective Action: The registrar?s office (RO) will begin using the Status Discrepancy report that is available in Anthology to identify conflicting information on a student-by-student basis. This report will help in resolving status discrepancies prior to submitting the report to NSC. Once the Enrollment Report is submitted, the RO will promptly resolve any Error Resolution Reports received from NSC and submit corrections. The RO will continue to follow up with NSC on the status of data transmissions. Person Responsible for Corrective Action Plan: Sabrina Hopson Anticipated Date of Completion: July 2023

Federal Agency: U.S. Department of Education Federal Program: Student Financial Assistance Cluster AL Number: 84.063 Finding Number: 2022-001 Department?s Response: Management recognizes the finding in Pell disbursement reporting to the Common Origination and Disbursement (COD) System (OMB No. 1845-0039). The COVID-19 Pandemic has presented the financial aid office with unprecedented administrative challenges, and we continue our efforts to return to pre-pandemic norms. Management would like to acknowledge the deficiency did not result in ineligible payments to students nor required the college to return any Title IV funds. Planned Corrective Action: As recommended the financial aid office has implemented additional monitoring controls. Management will develop a process to perform secondary reviews of all Pell disbursements reporting prior to the COD reporting deadline, and the Associate Vice President for Financial Aid is now actively involved in ensuring timely reporting disbursements by reviewing monthly internal reports. Anticipated Completion Date: May 31, 2023 Name and title of responsible contact: If you have any questions, please contact De Rodrick Jonkins AVP for Financial Aid, Maryland Institute College of Art djonkins@mica.edu.

U.S. Department of Education 2022-002: Student Financial Assistance Cluster ? Student Eligibility and Awarding ? Assistance Listing Number: 84.268 Recommendation: We recommend the College to evaluate its procedures related to the manual input of information from the student loan request. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: This issue was discovered during the audit process, and we performed the following activities in response: ? We consulted with the auditing team?s national resource about the proper way to correct this award. Implemented by August 2022. ? Following their guidance, we corrected the student?s awards so that the appropriate amount of sub and unsub were in place and then re-ran her R2T4 calculation to make sure everything was correct in our system and on COD. Implemented by September 2022 ? We conducted a review of our other Direct Loan awards, and found that this incident was an isolated manual mistake, not a systemic one. Implemented by August 2022 ? Although the person responsible for this error is no longer employed in the financial aid department, we have done training with the current Direct Loan coordinator to reduce the likelihood of this mistake in the future. Implemented by August 2022 ? We modified the Direct Loan procedure log to include a reminder about this regulation. Implemented by August 2022 Name(s) of the contact person(s) responsible for corrective action: Alysa Borelli, Dean of Enrollment and Student Services. Planned completion date for corrective action plan: The corrective action plan was implemented by September 2022.

2022-002 Student Financial Assistance Cluster ? ALN 84.007/84.033/84.038/84.063/84.268/84.379 Recommendation: We recommend the University reviews outstanding checks regularly to ensure funds are returned to the Department of Education before 240 days of the original disbursement attempt. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: In the fall of 2021, the University changed banking relationships. Outstanding checks from the former bank were cancelled and a check was issued from the new bank. The reissuance of checks showed a flaw in our 240-day reconciliation tool which focused on the check date rather than the original disbursement date. This was an isolated issue and we have adjusted our 240-day review tool to calculate based on the original disbursement date. Name(s) of the contact person(s) responsible for corrective action: John Greentree, Controller Planned completion date for corrective action plan: Completed as of September 2022

Return of Title IV (R2T4) Calculations Planned Corrective Action: I met with our Registrar, our Brightspace Administrator, our Assistant Provost and a faculty member of our Data Science department to collaborate on how to properly identify and document online student?s attendance, participation, and activity. We have already crafted a report that captures this information and we will continue to add to this report and utilize it for the current year to determine any adjustments that need to be made to Federal Student Aid. We are meeting again this week to discuss and finalize this report and test it out repeatedly to ensure it captures the right information every time. Person Responsible for Corrective Action Plan: Andrea L Ruth, Director of Financial Aid Anticipated Date of Completion: 4/1/2023