Corrective Action Plans

Identifying Number: 2022-005 - USDOE Student Financial Assistance Cluster - Special Tests and Provisions: Students' Satisfactory Academic Progress Ineligibility Finding: The College disbursed funds within 30 days of the first day of class for 12 first year students out of 40 students tested. Name of Contact Person: Karen Overton, Director of Financial AidCorrective Action Plan: The College will create, follow, maintain, and monitor an appropriate satisfactory academic progress (SAP) policy that meets USDOE requirements. The USDOE requires all institutions to sustain an SAP policy that requires students to maintain a 2.0 GPA and successfully complete 67% of their educational program in order to be eligible for financial aid. Anticipated Completion Date: Beginning August 2022

Identifying Number: 2022-004 - USDOE Student Financial Assistance Cluster - Special Tests and Provisions: Early Disbursements to Students Finding: The College disbursed funds within 30 days of the first day of class for 12 first year students out of 40 students tested. Name of Contact Person: Karen Overton, Director of Financial Aid Corrective Action Plan: The College will not disburse any Title IV federal aid until after the first 30 days of classes each semester for all students. Faculty are required to take attendance. On the 30th class day, staff will submit attendance reports for all students. After a review of the reports, staff will only disburse aid for students who have been attending the College for the first 30 days per USDOE regulations. Anticipated Completion Date: Beginning August 2022

Identifying Number: 2022-003- USDOE Student Financial Assistance Cluster-Special Tests and Provisions: Exit Counseling Support Finding: The College could not produce support showing completed exit counseling or proof of an attempt to send exit counseling for 19 students that graduated/withdrew out of 40 students tested. Name of Contact Person: Karen Overton, Director of Financial Aid Corrective Action Plan: The College will provide and document exit counseling information ( or proof of an attempt to send exit counseling) to all graduated and withdrawn students. The College will maintain the evidence through email communication, certified mail receipts, and USDOE Common Origination and Disbursement (COD) reports.

Identifying Number: 2022-002 - USDOE Student Financial Assistance Cluster - Special Tests and Provisions: Enrollment Status Reporting Finding: The College did not report status changes for various students, primarily withdrawn students, within a timely manner as required. Name of Contact Person: Karen Overton, Director of Financial Aid Corrective Action Plan: The College will report status changes for all students, including withdrawn students, every 30 to 45 days which is required by National Student Clearinghouse and National Student Loan Data System (NSLDS). All faculty are required to take attendance. Faculty report excessive absence concerns to lcabscences@louisburg.edu. During the first seven days of classes all students who are identified as 'No Shows' will be reported to the Registrar's Office. After Census Day (the end of Drop/Add), students will be identified who have missed the equivalent of 14 class days per USDOE regulations. These students will be withdrawn according to USDOE regulations. This process will be initially completed in National Student Clearinghouse, per regulations, and then reconciled in NSLDS. Anticipated Completion Date: Monthly, beginning August 2022

Identifying Number: 2022-001 - USDOE Student Financial Assistance Cluster - Special Tests and Provisions: Borrower Data Transmission and Reconciliation Finding: The College was unable to produce the reconciliations for review. Name of Contact Person: Karen Overton, Director of Financial Aid Corrective Action Plan: Using the data files, provided by USDOE Common Origination and Disbursement (COD), the College will upload the files every month into CAMS to perform COD reconciliation monthly. A specific staff has been assigned to perform this task each month. Anticipated Completion Date: Monthly, beginning August 2022

Finding Number: 2022-002 Condition: The University initiated certain returns of Title IV funds after the required timing and, for other students, did not initiate certain returns. The University performed certain return calculations using inappropriate inputs. There were three errors that attributed to this finding: 1.Of the 60 students tested, there were 29 students with discrepancies between the date utilized in return to Title IV calculations and the date required to be utilized based on Federal regulations resulting in $5,990 in questioned costs. 2.Of the 60 students tested there were 18 students identified where the University had returned the funds untimely (45 days if student attended, 30 days if never attended). 3.Of the 60 students tested, there were 4 identified where no return to Title IV calculation was performed and therefore no return of funds until students were selected for testing for the audit resulting in $1,715 in questioned costs. Views of Responsible Officials and Corrective Action Plan - The University agrees with the finding. Planned Corrective Action: The procedures used to monitor, calculate, report, and return Title IV funds are being updated in the following ways to address the errors found and the cause of the errors: ?All procedures will be tied to FSA Handbook and regulatory guidance with references linked as appropriate. This will clarify the procedures being used for the return to Title IV process. ?Procedures will include updated regulations related to module courses. This will address the errors that were caused in misinterpreting these new regulations. ?Methodology for dates being used for end of semester and date of determination will be clearly documented for each semester along with the actual dates used. For non- modular courses, the end of semester date will be the Friday of final exam week. (This will be verified via guidance received from the ask regs function of NASFAA.) This will clarify the required deadlines for each semester. ?A new report generated from our Data Warehouse system will be used to reconcile all required returns for a given semester have occurred. This will address students who were also missed in the prior year process. Contact person responsible for corrective action: Brian Bell, Director Student Account Services Anticipated Completion Date: 10/31/2022

Finding Number: 2022-001 Condition: The University did not report certain students' status to NSLDS in an accurate and timely manner during the fiscal year. There were three errors identified that attributed to this finding. 1. Of the 40 students tested, there was 15 students who withdrew/graduated whose status change was not reported accurately to the NSLDS. Student withdrew or graduated and was reported but with an incorrect effective date. 2.Of the 40 students tested, there were 7 students who withdrew/graduated whose status changes were not reported to the NSLDS within 60 days. 3.Of the 40 students tested, there were 6 students who withdrew/graduated whose status change were not reported to the NSLDS. Views of Responsible Officials and Corrective Action Plan - The University agrees with the finding. Planned Corrective Action: Following guidance provided via Plante Moran and the Dept, of Education (2020-2021 desk file review and NSLDS direct support), we will be implementing the following changes effective Fall 2022 to address correct enrollment status change reporting by: ? Adopt the use of the published academic semester end date for enrollment reporting vs using the long-standing use of the SAP/SLCM 100 Date or end of a semester payment period. It was learned that published end of an academic semester, per the Academic Calendar, is expected to be reported for use in applicable enrollment compliance timing calculations. ? Registrars will update NSLDS with the actual status effective date when learned for all unofficial withdrawal or graduated statuses. This date will be the earliest date at which Registrars retroactively learns was the actual last date of attendance that created an enrollment status change. Our past practices did not update such students but used the end of the previous semester date (SAP/SLCM 100 Date) if a student was shown to be enrolled in the next upcoming semester. This corrective action will occur for all cases even if the student is not required to have a R2T4 initiated, due to having attended at least 60% of the semester. Students who officially withdraw, in part or total, during a given semester are found in our monthly enrollment reporting as last date of attendances are supplied at the time of formal withdrawal. ?Registrars will enhance or develop (if not already in place), in conjunction with SASUB, necessary control reports to ensure accuracy of identifying students who are unofficial withdrawals at the end of an academic semester and adjust staffing resources as necessary to account for critical time periods such as the period between CMU?s Fall and Spring semesters when the university is closed. This will be necessary due to using the published last date of the semester instead of the end of the payment period date that was used in prior years. ?Planned timeline to complete corrective actions is February 2023 to account for end of Fall 2022 grading processes and manual updating of NSLDS as necessary for identified unofficial withdrawals. ?Contact person responsible for corrective action: Keith Malkowski, Registrar ?Anticipated Completion Date: February 2023 following end of semester grading and subsequent student record updating per our Date of Determination process.

Identifying Number: 2022-001 Finding: During the course of testing, the University incorrectly calculated Pell grant on one student from a sample of 40, incorrectly calculated a Title IV refund on one student from a sample of 2, and did not complete a Title IV refund within 14 days on one student from a sample of 25. Corrective Action Taken or Planned: Wittenberg University's Office of Financial Aid has seen changes in staffing over the last two years with new employees having limited experience regarding student financial aid federal, state and institutional regulations. These changes have caused delays and misunderstandings related to Pell grant calculations and Title IV refund calculations. As of November 2021, one part-time financial aid employee was hired and in December 2021, the other open position (full-time status) was filled. With new employees being continuously trained and developed on federal, state and institutional guidelines, the Director of Financial Aid, or their designee, will review all calculations performed by employees moving forward. The institution will also implement reporting tools to ensure Pell, Title IV refunds, and other calculations are correct based on federal, state and institutional guidelines. Wittenberg University's Office of Student Accounts has also seen changes in staffing over the last two years with new employees having limited experience regarding accounts receivables and Title IV regulations. These changes have caused misunderstandings around Title IV refunds. The Office will implement new reporting tools where all credit balances on students' accounts will be reviewed and, if applicable, refunded at least once per week. The weekly reports and refunds will be monitored and reviewed by the Controller, or their designee, per week in consultation with the Office of Student Accounts. Completed Date: Fiscal year 2023

A control has been added to require a member of the accounting department to review the FISAP prior to submission

The Title IV withdrawal calculation was complete on COD, but the amount the student was eligible for was transposed when entered on the internal withdrawal calculation form. A secondary review will be done prior to adjusting federal funds in the College?s internal system. This process was implemented February 15, 2023, and the responsible college official is Tina Wiseman, Director of Financial Aid.

The Registrar?s Office will use the date the student confirms their intent to withdraw. If that isn?t available, then the last available date of attendance will be used. The College is not an attendance taking college according to its policy and procedures and that has been revised in the academic catalog. This process was implemented February 15, 2023, and the responsible college official is Tina Wiseman, Director of Financial Aid.

The Financial Aid Office has updated its internal procedures to ensure disbursements for first-time borrowers will not occur until after the 30 day delayed requirement. To ensure this procedure, the disbursement date has been calculated for 30 days after the first day of class for first-time borrowers on the Period of Enrollments (POE). This process was implemented October 1, 2022, and the responsible college official is Tina Wiseman, Director of Financial Aid.

The College has implemented a weekly review and refund of student account credit balances to maintain compliance with this requirement. This process was implemented August 22, 2022, and the responsible college official was Diane Bozarth, Chief Financial Officer, who retired January 6, 2023. The new responsible college official will be Julie Straus, Chief Financial Officer.

The district has entered into a contract with Huron Consulting Group to address the internal controls pertaining to returning funds and reissuing funds back to students. District Finance has been working closely with each College to return funds to the Department of Education. Queries have been created to identify returned checks which will be monitored on a regular basis to reverse financial aid disbursements and re-report changes to COD. Planned completion date for corrective action plan: March 31, 2023.

The District Administration & Records will perform a study of the current business processes to identify data discrepancies. The District will engage the Clearinghouse and review the applicable reporting procedures with the financial aid offices to ensure sound internal controls over reporting and updating of NSLDS enrollment data. Planned completion date for corrective action plan: June 30, 2023.

The district has entered into a contract with Huron Consulting Group to address internal controls pertaining to reconciliation of Title IV funds, R2T4 processing, award packaging and verification. Huron has created more robust packaging and disbursement rules to ensure only eligible students are awarded and paid. Additionally, the district has created business processes and procedures to improve internal controls over federal awards. While the cutoff date for the audit was missed for the 2021-2022 school year, corrective actions have been taken to ensure the reconciliation of Title IV funds and secondary reviews have been completed and are currently underway for 2022-2023. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Planned completion date for corrective action plan: June 30, 2023.

View of Responsible Officials and Corrective Action Plan The District will implement processes to ensure that student withdrawal dates match what is reported to NSLDS, that enrollment status matches and is reported accurately.

View of Responsible Officials and Corrective Action Plan The District will implement procedures to ensure that the student withdrawal calculations are performed accurately and occur within 45 days from the end of the academic period.

FINDING 2022-005? Pell Award Calculation AL# and Program Expenditures: 84.063 ($279,693) Award Number: P063P227533 Federal Award Year: July 1, 2021 to June 30, 2022 Questioned Costs: $-0- Condition Found: The amount of Pell grant awarded was calculated incorrectly for one of the fourteen students who received Pell in our sample. The student was awarded Pell grant funds as if the student was enrolled ? time when the student was enrolled full-time. Corrective Action Plan: An additional $318 of Federal Pell Grant funds was awarded to the student in question in August 2022. Communication between the offices will be improved to ensure that the financial aid office is made aware of enrollment status changes timely. Anticipated Completion Date: The corrective action was completed in August 2022. Contact Person: Stephanie Dickerson, Registrar/Financial Aid 910-323-5614

FINDING 2022-008 ? Biennial Review of the Drug and Alcohol Abuse Prevention Program and Policies Program Name: Federal Pell Grant Program Federal Direct Loan Program AL# and Program Expenditure: 84.268 ($451,732) 84.063 ($279,693) Award Number: P268K227533 P063P217533 Federal Award Year: July 1, 2021 to June 30, 2022 Questioned Costs: $-0- Condition Found: The College administration did not complete the biennial review of their Drug Free Workplace Policy and drug free prevention process. Corrective Action Plan: Management will complete the biennial review after the drug free workplace and drug and alcohol abuse prevention polices have been updated and the required data has been tracked. Anticipated Completion Date: The corrective action will be completed by June 30, 2023 Contact Person: Richard Hovater, Vice President of Finance 910-323-5614

FINDING 2022-007 ? Drug Free Workplace Policy and Drug and Alcohol Abuse Prevention Program Name: Federal Pell Grant Program Federal Direct Loan Program AL# and Program Expenditure: 84.268 ($509,387) 84.063 ($331,937) Award Number: P268K217533 P063P207533 Federal Award Year: July 1, 2020 to June 30, 2022 Questioned Costs: $-0- Condition Found: The Drug Free Workplace Policy and other drug and alcohol abuse prevention material does not include all of the required documentation. Corrective Action Plan: Management will update the drug free workplace policy and drug and alcohol abuse prevention in the 2023 fiscal year. The information will be distributed to the staff and students. Anticipated Completion Date: The corrective action will be completed by June 30, 2023 Contact Person: Richard Hovater, Vice President of Finance 910-323-5614

FINDING 2022-006 ? NSLDS Reporting Program Name: Federal Direct Student Loan Program AL# and Program Expenditures: 84.268 ($451,732) Award Number: P268K227533 Federal Award Year: July 1, 2021 to June 30, 2022 Questioned Costs: $-0- Condition Found: The incorrect enrollment status was reported to the National Student Loan Database System (?NSLDS?) for two of the sixteen students selected for testing. Corrective Action Plan: The Student Financial Aid Director corrected the enrollment status for the students in question in August 2022. Procedures are being improved to ensure that the student enrollment statuses are reported to NSDLS accurately and timely. Anticipated Completion Date: The corrective action was completed in August 2022. Contact Person: Stephanie Dickerson, Registrar/Financial Aid 910-323-5614

FINDING 2022-004 ? R2T4 Calculation Program Name: Federal Direct Student Loan Program Federal Pell Grant Program AL# and Program Expenditures: 84.268 ($451,732) 84.063 ($279,693) Award Number: P268K227533 P063P227533 Federal Award Year: July 1, 2021 to June 30, 2022 Questioned Costs: $4,227 Condition Found: The R2T4 was not calculated correctly for two of the sixteen students in the compliance testing sample. A separate sample was selected to test additional R2T4 calculations. The R2T4 was not calculated correctly for two of the three students in the R2T4 testing sample. Between the two samples, all of the R2T4s completed during the year were reviewed. Corrective Action Plan: All of the R2T4s completed during the year were recalculated in October 2022. On October 6, 2022, $3,381 of Federal Pell Grant Funds and $846 of Federal Direct Loan Funds were returned to the Department of Education. Procedures will be improved to ensure that R2T4s are calculated correctly. Anticipated Completion Date: The corrective action was completed by October 6, 2022. Contact Person: Stephanie Dickerson, Registrar/Financial Aid 910-323-5614

FINDING 2022-003 ? Exit Interview Program Name: Federal Direct Student Loan Program AL# and Program Expenditures: 84.268 ($451,732) Award Number: P268K227533 Federal Award Year: July 1, 2021 to June 30, 2022 Questioned Costs: $-0- Condition Found: Two of the sixteen federal student financial aid recipients in our sample did not complete an exit interview or were not sent exit interview instructions. Corrective Action Plan: An exit interview was sent to both of students in question on August 9, 2022. Procedures will be improved to ensure that an exit interview is completed when a student withdraws from the College Anticipated Completion Date: The corrective action was completed on August 9, 2022. Contact Person: Stephanie Dickerson, Registrar/Financial Aid 910-323-5614

FINDING 2022-002 ? COD Disbursement Dates Program Name: Federal Direct Student Loan Program Federal Pell Grant Program AL# and Program Expenditure: 84.268 ($451,732) 84.063 ($279,693) Award Number: P268K227533 P063P217533 Federal Award Year: July 1, 2021 to June 30, 2022 Questioned Costs: $-0- Condition Found: The Common Origination and Disbursement System (?COD?) disbursement date did not agree with the disbursement date on accounts for five of the eight students receiving Federal Direct Loans and ten of the fourteen students receiving Federal Pell Grant funds in our sample. A total of twelve students were affected by this finding. Corrective Action Plan: The Vice President of Finance corrected the disbursement dates for the students in question in October 2022. Going forward, the Student Financial Aid Office and Business Office will coordinate the drawdown of funds, reporting to COD, and posting to student accounts. Anticipated Completion Date: The corrective action was completed in October 2022. Contact Person: Stephanie Dickerson, Registrar/Financial Aid 910-323-5614