Corrective Action Plans

Finding 2022-003 Condition For six students out of nine tested, the change in student status was not reported to the NSLDS within 30 days or included in a response to a roster file within 60 days. However, the students were ultimately reported to the NSLDS. This sample was not statistically valid. Corrective Action Plan Corrective Action Planned: We agree with this finding and are rectifying the issue. United Lutheran Seminary has retained a new Financial Aid Specialist who possesses the required knowledge and suitable skills for the position. Name(s) of Contact Person(s) Responsible for Corrective Action: Susie Kowalski, Director of Financial Aid. Anticipated Completion Date: Ms. Kowalski started with United Lutheran Seminary July 1, 2022.

Finding 2022-002 Condition One roster file out of three tested was not completed and returned within the 15-day requirement to the NSLDS. This sample was not statistically valid. Corrective Action Plan Corrective Action Planned: We agree with this finding and are rectifying the issue. United Lutheran Seminary has retained a new Financial Aid Specialist who possesses the required knowledge and suitable skills for the position. Name(s) of Contact Person(s) Responsible for Corrective Action: Susie Kowalski, Director of Financial Aid. Anticipated Completion Date: Ms. Kowalski started with United Lutheran Seminary July 1, 2022.

Finding 2022-001 Condition There was not an adequate system of controls in place that would have prevented or detected potential material noncompliance matters within the Activities Allowed or Unallowed, Eligibility and Special Tests and Provisions (related to Return of Title IV Funds, Enrollment Reporting and Federal Direct Loan Disbursements) compliance requirement areas. Corrective Action Plan Corrective Action Planned: We agree with this finding and are rectifying the issue. United Lutheran Seminary has retained a new Financial Aid Specialist who possesses the required knowledge and suitable skills for the position. Name(s) of Contact Person(s) Responsible for Corrective Action: Susie Kowalski, Director of Financial Aid. Anticipated Completion Date: Ms. Kowalski started with United Lutheran Seminary July 1, 2022.

Findings 2022-004 and 2021-001 Direct Loan Reconciliations Condition: For the fiscal year ending May 31, 2022, monthly Direct Loan Reconciliations were not performed for the months of June 2021 through September 2021. Views of Responsible Officials: The Academy does not disagree with this audit finding. Corrective Action Plan: Direct Loan reconciliations a performed on a monthly basis by the Director of Financial Aid and a report is provided to the VP of Administration of Finance showing the tie out between G5 and COD. Responsible Party: Frances Hutchinson, Director of Financial Aid Anticipated Completion Date: This process was implemented in October 2021.

Finding 2022-003 Disbursements to or on Behalf of Students Condition: During testing of disbursements to or on behalf of students, 16 out of the 25 students selected for testing did not receive a written notification from the institution for the Fall of 2021 semester. Views of Responsible Officials: The Academy does not disagree with this audit finding. Corrective Action Plan: The Academy's student information system, Campus Cafe, provides online award letter notification to all students for review to approve and/or decline. Responsible Party: Frances Hutchinson, Director of Financial Aid Anticipated Completion Date: This process was implemented in Fall 2022.

Finding 2022-002 Internal Controls Condition: During testing of compliance requirements such as eligibility and verification testing, there was not documentation of a level of review to ensure the requirements were met and accurate. Views of Responsible Officials: The Academy does not disagree with this audit finding. Corrective Action Plan: The Academy's Financial Aid Counselor will complete a checklist for eligibility and verification and the Director of Financial Aid will provide documented signoff once the checklist is reviewed for completeness and accuracy. Responsible Party: Frances Hutchinson, Director of Financial Aid Anticipated Completion Date: This process was implemented in November 2021 once Clifton Larson Allen started assisting the Academy.

Finding 2022-001 Fiscal Operations Report and Application to Participate (FISAP) Condition: Under Part II. Application to Participate for Award Year July 1, 2022 through June 30, 2023 Section E. Assessments and Expenditures, the undergraduate total tuition and fees for the award year July 1, 2020 to June 30, 2021 was overreported by $380,731. Graduate total tuition and fees for the award year July 1, 2020 to June 30, 2021 was underreported by $28,122. Views of Responsible Officials: The Academy does not disagree with this audit finding. Corrective Action Plan: The Academy's Director of Financial Aid will prepare the FISAP and the VP of Administration and Finance will review and provide official signoff on the FISAP before it's submitted. Responsible Party: Frances Hutchinson, Director of Financial Aid Anticipated Completion Date: This process will be implemented with the submission of the FISAP for July 1, 2023 through June 30, 2024.

Marymount University administration acknowledges the findings from the 2021-2022 audit. Marymount administration takes the findings, which arose as part of the fiscal year 2021-2022 audit, very seriously and, following a root cause analysis, has put in place the following comprehensive corrective action plan: - Marymount University has experienced a turnover in the financial aid office from the Director down to the counselor position. Transitional issues have arisen from the turnover, including lack of continuity in office processes and lack of knowledgeable staff. - In late 2022, Marymount University contracted with Attain Partners, LLC, to provide interim management services in Financial Aid. After the turnover of personnel, this was necessary to fill the void created by the departure of the Director of Financial Aid and other staff. The Attain Partners consultants have provided the interim management services to assure compliance with Title IV regulations, including Return to Title IV Funds process. - Due to the turnover in the office, the calculations were not completed. Attain Partners has completed the reconstruction and COD updates. - Current R2T4 processes are in line with Title IV regulations. Attain Partners will assure timely processing going forward. - Attain Partners will be reviewing existing processes related to student financial aid. As an outcome of this review the processes and schedule will be fully documented and implemented as documented.

Marymount University followed the University grading policy when determining whether or not a student received an earned F grade in all of his/her courses. (See below for policy information). Marymount University?s grading policy states that an F grade is assigned for students who fail to meet course objectives; such an F grade is by definition an earned F and not an unearned F as the student has completed the course but failed to meet standards. Marymount University instructors assign FA (Failure to Attend) grades for students who disappear, walk away, or otherwise fail to complete a course. For FA grades, last dates of attendance are assigned by instructors in the majority of cases. In the case of the students cited in the finding, Marymount followed its own grading policy when determining whether or not the failing grade received by the student was an earned F (completing the course but failing to meet course objectives) or an FA grade (failure to attend and did not complete the course). F grades would not result in Return to Title IV Funds calculations since they were considered earned. FA grades would result in Return to Title IV Funds calculations because they were considered unearned failing grades. Marymount University is not an attendance-taking institution according to Title IV standards, and individual instructors have control over their own attendance policies. Last dates of attendance as reported by these instructors are used in Return to Title IV Funds calculations; if a last date of attendance cannot be determined, the 50% point is used. Marymount University has the policy in place. However, Marymount University will review the language of the policy and revise the language to remove any ambiguities in the future. Marymount University Attendance Policy https://marymount.smartcatalogiq.com/en/2021-2022/catalog/marymount-university-catalog-2021-22/academic-information-and-policies/undergraduate-academic-information-and-policies/attendance/ Undergraduate Grading Policy https://marymount.smartcatalogiq.com/2021-2022/catalog/marymount-university-catalog-2021-22/academic-information-and-policies/undergraduate-academic-information-and-policies/evaluation-of-students/undergraduate-grading-policies/ Graduate Grading Policy https://marymount.smartcatalogiq.com/2021-2022/catalog/marymount-university-catalog-2021-22/academic-information-and-policies/graduate-academic-information-and-policies/evaluation-of-students/graduate-grading-policies/

Marymount University administration acknowledges the findings from the 2021-2022 UG Audit. Marymount administration takes the findings very seriously and, following a root cause analysis, has put in place the following comprehensive corrective action plan: ? Marymount University has experienced a turnover in the Office of Financial Aid from the Director down to the counselor position. Transitional issues have arisen from the turnover, including lack of continuity in office processes and lack of knowledgeable staff. ? In late 2022, Marymount University contracted with Attain Partners, LLC, to provide interim management services in Financial Aid. After the turnover of personnel, this was necessary to fill the void created by the departure of the Director of Financial Aid and other staff. The Attain Partners consultants have provided the interim management services to assure compliance with Title IV regulations, including Direct Loan reconciliation. ? Attain Partners has fully reconciled the 2021-2022 Federal Direct Loan funds and has put processes in place in conjunction with the Marymount University Financial Affairs Division to assure monthly and final reconciliation going forward. ? Attain Partners will be reviewing existing processes related to student financial aid. As an outcome of this review the processes and schedule will be fully documented and implemented as documented.

Finding 2022-001: Timely Enrollment Report The Institute failed to notify the National Student Loan Data System for three selected students' withdrawals within the required 60 days. However, it was properly determined for the students to have earned 100% of the Title IV funds. Corrective Action Plan Management has immediately implemented the ad hoc reporting option, which includes the Associate Director of Registration and Student Records notifying the NSLDS of student withdrawals at time of withdrawal. This policy will ensure timely reporting of withdrawals and will be included in the standard procedure process for the withdrawal of a student. Contact Person Leanne Beaudoin Ryan Director of Research, Records and Registration lbeaudoinryan@erikson.edu Anticipated Completion Date February 2023

Student Financial Assistance Cluster ? Assistance Listing Number 84.268 Recommendation: We recommend the University review its policies and procedures around exit counseling to ensure students are receiving proper counseling and documentation is maintained of this process in the University?s student files. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: This error also occurred during the transition period of the previous Financial Aid Director and winter graduates were forgotten to be notified. The Financial Aid Office has updated its procedures and have been in discussions with the IT Department to automate the process. Name(s) of the contact person(s) responsible for corrective action: Hannah Brown, Director of Financial Aid Planned completion date for corrective action plan: Complete.

2022-003 Student Financial Assistance Cluster ? Assistance Listing Number 84.268 Recommendation: The University should ensure all necessary employees receive proper training, support, and time to follow the University's policies and federal requirements related to monthly reconciliations. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Monthly reconciliations have occurred in the Financial aid office, however, the sample selection occurred during the month when a transition in director occurred. The reconciliation was completed a month late. Reconciliations have now been improved by including other offices in the process and have been placed on a regular schedule. Name(s) of the contact person(s) responsible for corrective action: Hannah Brown, Director of Financial Aid Planned completion date for corrective action plan: Complete

2022-001 Student Financial Assistance Cluster ? Assistance Listing Numbers 84.063, 84.268 Recommendation: We recommend the University review its policies and procedures to ensure accurate effective dates are reported in both the campus level and program level records submitted to the NSLDS. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: This was addressed in February 2023, the Registrar's office met with the Office of Financial Aid to determine what date on a student's withdraw application is the correct to Clearinghouse reporting. Name(s) of the contact person(s) responsible for corrective action: Bill Manley, Registrar Planned completion date for corrective action plan: Complete

2022-002 Student Financial Assistance Cluster ? Assistance Listing Numbers 84.007, 84.033, 84.063, 84.268 Recommendation: We recommend the University review the R2T4 requirements and implement procedures to ensure scheduled breaks are properly factored into calculations. Part of this process should include review of calculations by another member of the Financial Aid office. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: This was corrected once identified in the FY21 single audit, however, due to timing of that audit, it was a repeat finding for 2022. Name(s) of the contact person(s) responsible for corrective action: Hannah Brown, Director of Financial Aid Planned completion date for corrective action plan: Completed May 2022

FINDING: 2022-001 Return of Title IV Funds Federal Agency / Federal Program: U.S. Department of Education / Student Financial Assistance Cluster Subject: Special Tests and Provisions (N) CFDA Number: Federal Pell Program ? 84.063 The School agrees with the finding. Planned Corrective Action Plan: The School performed the RT24?s in a timely manner and then requested from its third party servicer to return the necessary funds. The third party servicer failed to return them. Upon discovery, the School terminated its relationship with the servicer. The School will update its policies and procedures to ensure timely returns. Responsible for corrective action: Galina Shumskaya Anticipated completion date: September 30, 2023

FINDING 2022-002 ? Verification Condition Found: The information on the verification worksheet and tax transcript for Parents? AGI, Parents? Taxes Paid, Parent 1 and 2 Earned Income, and Parents? Military/Clergy Housing Allowance did not agree to the amounts reported on the ISIR for one of the twenty-five students sampled. Corrective Action Plan: The Financial Aid Office updated the income items and recalculated the EFC for the students in question. The amount of Pell the student was eligible to receive was calculated based on the new EFC. $300 was returned to the Department of Education in August 2022. Anticipated Completion Date: The corrective action was completed in August 2022. Contact Person: Samuel Tschetter, Director Student Affairs/Title IX Coordinator 816-322-0110 Ext. 1384

FINDING 2022-002 ? Verification Condition Found: The information on the verification worksheet and tax transcript for Parents? AGI, Parents? Taxes Paid, Parent 1 and 2 Earned Income, and Parents? Military/Clergy Housing Allowance did not agree to the amounts reported on the ISIR for one of the twenty-five students sampled. Corrective Action Plan: The Financial Aid Office updated the income items and recalculated the EFC for the students in question. The amount of Pell the student was eligible to receive was calculated based on the new EFC. $300 was returned to the Department of Education in August 2022. Anticipated Completion Date: The corrective action was completed in August 2022. Contact Person: Samuel Tschetter, Director Student Affairs/Title IX Coordinator 816-322-0110 Ext. 1384

Enrollment Reporting to National Student Loan Data System (NSLDS) Explanation: It was found that some students enrollment data were being reported incorrectly. It is not known if the error is coming from PowerCampus or NCS as majority of student records are correctly submitted. Planned Corrective Action: The Office of Financial Aid will be working more closely with Registrar?s Office on the enrollment reporting submitted to the National Student Clearinghouse (NCS) each reporting cycle. Errors will be reviewed to determine why the error happened and how to correct the issue to prevent future errors. Comparisons will be done between our report and NSC and then with NSLDS. Person Responsible for Corrective Action Plan: Karen LaQuey and Dr. Wendy McNeeley Anticipated Date of Completion: Ongoing. Will do review for success December 2022 and then again in May 2023

Incorrect Modular Return of Title IV Funding Explanation: Students that were enrolled in summer modules and required a Return to Title IV (R2T4) calculation were being processed under the standard summer session calculation and not under modules. If a student was enrolled in more than one module, we did not review the enrollment between the two modules to determine percentage of attendance and if R2T4 was required. Planned Corrective Action: Additional review steps are in place to review summer module enrollment and percentages. The Return to Title IV calendar will be set up differently inside Common Origination and Disbursement (COD) to allow for the module funding calculations. Person Responsible for Corrective Action Plan: Karen LaQuey Anticipated Date of Completion: September 30, 2022

Inaccurate Return of Title IV Funds (R2T4) Planned Corrective Action: A master schedule has been created that includes the starting date, ending date, and break dates for each term. The break dates provided and used previously were not accurate and the master schedule provides the document all departments will use going forward. This will fix the issue involving the incorrect number of days used in the R2T4 calculations. Per the auditor?s recommendations, the institution has hired an experienced professional with over fifteen years of experience in Title IV processing to complete the R2T4 calculations. Person Responsible for Corrective Action Plan: Wes Brothers, Financial Aid Director Anticipated Date of Completion: Completed 3/9/2023

Finding: 2022-001 Student Financial Assistance Cluster Special Tests and Provisions Department?s Response: We concur Corrective Action: This finding was due to human error. The spreadsheet was copied from the last year, and dates were updated to be the current year. The past year may have had a holiday which caused the G5 funds to be received an additional day before the disbursement date. When updating the dates to the current year, the 4 days was not caught. The form was only reviewed by the Director of Financial Aid. To prevent this error from occurring in the future, 3 members of the Finance Team will review and approve the Disbursement schedule so that there are 3 sets of eyes reviewing the dates. These 3 members will include the Director of Financial Aid, and any 2 of the following: Accounting Manager, Staff Accountant, Registrar, or Business Office and Bookstore Manager.

Finding 2022-001 - Enrollment Reporting Federal Program - Student Financial Assistance Cluster Federal Agency - U.S. Department of Education Pass-Through Entity - Not Applicable ALN - 84.007, 84.033, 84.038, 84.063, 84.268 Federal Award Year - June 30, 2022 Criteria: Title IV regulations (34 CFR 685.309(b)) require that upon receipt of an enrollment report from the Secretary, institutions must update all information included in the report and return the report to the Secretary: (i) in the manner and format prescribed by the Secretary; and (ii) within the timeframe prescribed by the Secretary. Unless it expects to submit its next updated enrollment report to the Secretary within the next 60 days, an institution must notify the Secretary within 30 days after the date the institution discovers that: (i) a loan under Title IV of the Act was made to or on behalf of a student who was enrolled or accepted for enrollment at the institution, and the student has ceased to be enrolled on at least a half-time basis or failed to enroll on at least a half-time basis for the period for which the loan was intended; or (ii) a student who is enrolled at the institution and who received a loan under Title IV of the Act has changed his or her permanent address. Condition/Context: The change in student status for 6 of 25 students tested was not reported to the National Student Loan Data System (NSLDS) within 30 days or included in a response to a roster file within 60 days. A statistical sample was not used. Cause: The College failed to follow its procedures for reporting student status changes. Effect: The accuracy of Title IV student loan records depends heavily on the accuracy of the enrollment information reported by institutions. If an institution does not review, update, and verify student enrollment statuses, effective dates of the enrollment status, and the anticipated completion dates, then the Title IV student loan records will be inaccurate in NSLDS. Questioned Costs: None. Recommendation: The College should review its policy on enrollment reporting to NSLDS. Views of Responsible Officials and Planned Corrective Actions: Graduated Student Reporting: After submitting the end of term enrollment file for semester, the Registrar's Office (Assistant Registrar) submits a Graduates-Only Enrollment File to National Student Clearinghouse (NSC) for that semester. Any degrees conferred after the graduates only file will be entered manually on the NSC website. This process will report a graduated status for any student who graduated at the end of that semester. NSC will pass the graduated status along to NSLDS on the next student status change confirmation report (SSCR). Withdrawal Students Reporting: Formal withdrawals during the semester are reported on the next subsequent of term enrollment file that is sent to NSC. Students who formally withdraw between semesters, are reported manually to the NSC website. The clearinghouse will pass the withdrawn status along to NSLDS on the next SSCR. While the above procedures were in place for the 2021-22 fiscal year, staff turnover in the Registrar?s Office made it difficult to maintain and submit the appropriate files and manual entries to NSC. Management does not foresee this to be an issue moving forward. New staff members have been hired and trained on the appropriate procedures to ensure these internal controls are in place and effective for the required enrollment reporting. If the Assistant Registrar position would become vacant in the future, the Registrar would be responsible for NSC submissions until the position could be filled. Name(s) of Contact Person(s) Responsible for Corrective Action: Sara Zucker (Registrar), Michael Saunders (Assistant Registrar) Anticipated Completion Date: January 2023

College's Response: We concur. 2021-22 Audit indicated that two Pell Grant disbursements were not reported within the 15-day timeframe stipulated in Federal Register Volume 82, Number 122. The origination records were resolved and sent to COD (processing platform) 16 days after Pell paid to the account. Both instances involved a professional judgment review allowing the college to award additional Pell to families. This process can create delays. Corrective Action Plan: An automated report runs daily to identify disbursement dates 5 days old that have not been acknowledged by the Department of Education. This allows us an additional 10 days to confirm all disbursements are reported and accepted within the 15 day requirement. An additional step has been added to confirm if the origination record is rejected, the Pell record is locked preventing disbursement prior to having an accepted origination record. Responsible Party: Joseph Weglarz, Executive Director, Student Financial Services Proposed Completion Date: January 26, 2023

CASE FILE REVIEWS Federal Agency: U.S. Department of Health and Human Services and U.S. Department of Agriculture Federal Program Title: Medical Assistance Program (Medicaid Cluster), Temporary Assistance for Needy Families (TANF), Title IV-E Foster Care and State Administrative Matching Grants for Supplemental Nutrition Assistance Program (SNAP Cluster) Assistance Listing Number: 93.778, 93.558, 93.685 and 10.561 Pass-Through Agency: Minnesota Department of Human Services and Minnesota Department of Agriculture Pass-Through Numbers: 2205MN5ADM, 2201MNTANF, 2201MNFOS and 222MN101S2520 Award Period: Year-Ended December 31, 2022 Type of Finding: Significant Deficiency in Internal Control over Compliance Recommendation: It is recommended the County perform case file reviews on a more representative sample of the total clients served and that adequate documentation be retained of those reviews. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The County will conduct a training session for health and human services staff regarding procedures required for case file reviews. Name of the contact person responsible for corrective action plan: Anne Lindseth, Health and Human Services Director Planned completion date for corrective action plan: December 31, 2023