Corrective Action Plans

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

Views of responsible officials and planned corrective action plan ? Northern Kentucky University will meet the requirements outlined by the U.S. Department of Education for treatment of Federal Aid funds (R2T4) when a student ceases to be enrolled prior to the end of a period of enrollment. The following corrective action will be taken by NKU to ensure compliance: ? The University will return funds within 45 days. ? The University will review its Return of Funds procedures to ensure compliance.

Finding Number: 2022-003 Condition: Of the 40 students selected for enrollment reporting testing, the College did not properly update student enrollment informaion for some students in a timely manner. Planned Corrective Action: The errors are attributed to incorrect programming embedded in the school's learning management system and delays by NSC in relaying information to NSLDS. To correct the findings, Benedict is implementing the following action plan: 1) The reporting process was temporarily moved to another campus office during a staff transition in the Registrar's Office. With a new registrar and assistant registrar in place, the process will be reassigned to the Registrar. 2) The college is scheduling a process maintenance session with representatives from Jenzabar EX to ensure proper coding in the school's learning management system. Individualized training will also be scheduled for the Registrar's staff to ensure a full understanding of the mechanics of the reporting system. 3) As NSC only reports status changes when the subsequent file is received (for example, May status changes are only reported to NSLDS when the June report is received), Benedict's NSC submission schedule will be amended to every 30 days throughout the entire calendar year, thereby ensuring that the triggering event allows NSLDS receipt within 60 days. Contact person responsible for corrective action: Dr. Kimberly Haynes-Stephens, AVP for Academic Support and Assessment; Roberta Davis, Registrar; Monique Rickenbaker, Director of Financial Aid; Chief Financial Officer. Anticipated Completion Date: April 30, 2023.

Finding Number: 2022-001 Planned Corrective Action: Student withdrawal and graduation files will be updated in NSLDS at the time of occurrence. A monthly review of all files will occur in NSLDS at the end of each month. Anticipated Completion Date: 03/01/2023 Responsible Contact Person: Crystal Cook, Financial Aid Coordinator, and Christine Stark, Director

CORRECTIVE ACTION PLAN U.S. Department of Education College of DuPage, Community College District Number 502 (the College), respectfully submits the following corrective action plan for the year ended June 30, 2022. Name and address of independent public accounting firm: CliftonLarsonAllen LLP, Oak Brook, Illinois Audit period: July 1, 2021 ? June 30, 2022 The findings from the schedule of findings, responses, and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. Findings ? Financial Statement Audit: None Findings ? Federal Award Programs Audits: Department of Education 2022-001 ? Enrollment Status Reporting Recommendation: We recommend that the College review its procedures to ensure enrollment status changes are reported to NSLDS accurately, as required by regulations. Planned Corrective Action: The College of DuPage has reviewed and agrees with the enrollment reporting finding and has already taken multiple steps to resolve all issues ensuring complete, accurate and timely reporting. The College has done or will do the following: 1. Short term solution ? To reduce any knowledge gaps going forward, the responsibility of enrollment reporting into NSLDS will now be the responsibility of the Enrollment Reporting Specialist. That position is housed in the Records office and reports to the Registrar. The Enrollment Reporting Specialist will be responsible for all aspects of enrollment reporting to NSC and NSLDS including the aforementioned subpopulation of students. 2. Long term solution(s) ? The Record?s office will work closely with the Information Technology department to automate the process of capturing unofficial withdrawal information from Colleague and reporting it to NSC. That information will then be automatically updated into NSLDS effortlessly and without manual intervention. Additionally, the college is re-examining its policy for allowing students to register for multiple programs of study simultaneously. Contacts Responsible for Corrective Action: Dr. Diana Del Rosario, Assistant Provost, Student Affairs Nishia Ikezoe Heard, Senior Director, Student Financial Assistance, Veterans Services & Scholarships Jill Pierson, Registrar Scott Brady, CFO & Treasurer

The University acknowledges that there were 2 out of the 25 students selected that the change in enrollment status was reported by the University more than 60 days after the enrollment status change. Effective with the Student Enrollment Roster received from NSLDS in January 2023, the business practice has changed with the implementation of the modernized NSLDS Professional Access website. Upon receipt of the Student Enrollment Roster, the file is updated by an algorithm using data from the University?s CRM, Jenzabar. The resulting spreadsheet is uploaded to NSLDS for verification and submittal. The accepted records are updated in NSLDS? database and are removed from the resulting spreadsheet produced by NSLDS. The records that error-out are listed on the resulting spreadsheet. This file is maintained for audit purposes. To ensure accurate enrollment status updates, the records listed on the resulting spreadsheet are updated manually on the NSLDS website. The manual entries are updated in real-time. In addition, the University is updating enrollment status changes manually upon receipt of Action Forms initiated by the student instead of waiting for the next Enrollment Report from NSLDS. This should correct the issue where a change in student status was not captured by NSLDS and reasonably ensure compliance with Federal statutes.

2022-001 Title: Student Financial Assistance Cluster - Assistance Listing Nos. 84.007, 84.033, 84.038, 84.063, 84.379, 84.032 Recommendation: We recommend the Institute review its reporting procedures to ensure that students' statuses are accurately and timely reported to NSLDS as required by regulations. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Student Financial Services is working with the Registrar and IT to review current reporting system. Adjustments will be made to reporting process to ensure accurate and timely reporting of students' enrollment status to NSLDS. Name(s) of the contact person(s) responsible for corrective action: Amanda Burgess, Director of Financial Aid and Tom Kelsey, Registrar Planned completion date for corrective action plan:12/31/2022

BELOW, PLEASE FIND THE CORRECTIVE ACTION PLAN DEVELOPED IN RESPONSE TO THE SINGLE AUDIT FINDING: THE ENTITY CONTRACTED WITH A PRIVATE AGENCY TO ASSIST IN THE SAM.GOV RENEWAL. BY THE TIME IT WAS COMPLETED THE 3/31/23 DEADLINE HAD PASSED. GOING FORWARD THE ENTITY NOW HAS THE NUMBER AND UNDERSTANDS THAT THEY MUST RENEW YEARLY.

Views of Responsible Officials and Planned Corrective Action - Administration concurs with the findings. In the past, the College has reported Campus-Level records, Program-Level records and Other Records to the National Student Clearinghouse (NSC) which in turn transmitted this information to the National Student Loan Data System (NSLDS). NSC historically offers this service to small educational institutions to assist with reporting requirements which may be burdensome due to low staffing levels. The College believes that its reporting to NSC has been reasonably accurate and timely. In fact, NSLDS records no longer reflect the submissions of the College to NSC. The College will research, explore and identify the most efficient method of insuring that complete and accurate data related to enrollment reporting are recorded by NSLDS on a timely basis. Initially the College will explore audit assistance through NSC and if not successful, will further explore direct reporting options to the NSLDS. Anticipated Completion Date: May 31, 2023

Views of Responsible Officials and Planned Corrective Action - Administration concurs with the findings. Effective with the Fiscal Year 2014, the College engaged with a third-party provider which put the Perkins loan processing on a digital platform. The College will review its record storage system of both hardcopy documentation as well as digital document storage and access for protection, preservation and completeness. Further the College will perform an inventory of loan documents currently in storage to identify additional files that are missing master promissory notes. Anticipated Completion Date: May 31, 2023

Finding 2022-001: Special Tests and Provisions: Enrollment Reporting Recommendation: The auditor recommend that the University review and update internal controls to ensure student enrollment status in the National Student Loan Data System (NSLDS) is updated in a timely manner to ensure compliance with Federal requirements. Persons Responsible for Corrective Action: Barbara Wilson, Registrar & Director of Student Records; Pam Barrett, Associate Vice President & Director of Financial Aid Planned Corrective Action: Brenau University contracts with the National Student Clearinghouse (NSC) to perform routine enrollment reporting required by Title IV Federal Student Aid regulations. The University's student information system contains a program designed to compile enrollment data for transmission to NSC in accordance with specifications provided by the National Student Loan Data System (NSLDS). We are conducting a detailed review of the November 2022 NSLDS Enrollment Reporting Guide, and have engaged the University's student information system vendor to review the current software logic and install any modifications necessary to become compliant in this area. Anticipated Completion Date: April 30, 2023

The district will be more aware of meeting expenditure report deadlines. See the full Corrective Action Plan included with the reporting package.

U.S. Department of Education 2022-002 Student Financial Aid Cluster ? NSLDS Enrollment Reporting Assistance Listing No. 84.063, 84.268 Recommendation: We recommend the College review its reporting procedures to ensure that students? statuses are accurately and timely reported to NSLDS as required by regulations. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: With more experienced staff in the Registrar?s Office and with the help from an outside consultant, the procedures for updating a student?s status in the student information system, and for preparing and sending the transmissions to the National Clearinghouse in a timely manner, have been addressed. Name(s) of the contact person(s) responsible for corrective action: Pat Seunarine, Registrar Planned completion date for corrective action plan: June 30, 2023

Finding: 2022-002 Student Financial Assistance Cluster Special Tests and Provisions 84.268 Department?s Response: We concur Corrective Action: This finding was an oversight due to varying schedule conflicts. The Director of Financial aid has scheduled in advance reoccurring monthly reconciliation meetings. Additionally the business office will be trained to attend reconciliation meetings in case of future scheduling conflicts. Contact: Sally Kalstrom Anticipated Completion Date: Immediately

Finding: 2022-001 Student Financial Assistance Cluster Special Tests and Provisions 84.033 Department?s Response: We concur Corrective Action: This finding was an error. To prevent this type of error from occurring in the future the Director of Financial Aid has created a list of checks and balances that must be made before a student may obtain a work-study job. Contact: Sally Kalstrom Anticipated Completion Date: Immediately

Higher Education Emergency Relief Funding (HEERF) ? Assistance Listing No. 84.425 Recommendation: We recommend the colleges reevaluate their procedures surrounding allowable costs and costs being charged to the grant to ensure all are allowable costs. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Clarkson College has reevaluated their procedures surrounding allowable costs and costs being charged to the grant to ensure all are allowable costs. The employee responsible for this finding is no longer associated with the college.

The College reported the students? status to the National Student Clearinghouse (NSC). The NSC in turn is contractually engaged by the College to update NSDLS. We will work with NSC to determine why the students? status was not updated timely and ensure that student status is accurately and timely reported to NSLDS going forward.

REPORTING Fairmont State University, West Virginia State University, Bluefield State University, West Virginia Northern Community College, West Liberty University, Southern West Virginia Community and Technical College, Pierpont Community and Technical College, Concord University, Mountwest Community and Technical College, and Glenville State University Assistance Listing Number 84.425E, 84.425F, 84.425J, 84.425M Fairmont State University (FSU) response In regard to the Annual Reporting of HEERF, the Controller will work with the Financial Reporting Manager to ensure the annual data is accurate and reflects the data reported on the quarterly reporting for the same period. The Controller will perform data entry of all required fields in the annual submission website. Once complete, an email will be sent to the CFO for final review and approval. The CFO will provide email correspondence that the review is complete and the reporting is approved for submission. The CFO will submit the annual report via the reporting website. This action was implemented January 2023. West Virginia State University (WVSU) response WVSU developed and documented an internal control procedure to ensure compliance of HEERF Reporting. This procedure includes a dual review and sign off process by Business and Finance before the report is posted to WVSU?s website. This review includes ensuring accurate forms are being used for reporting. Additionally, screen captures are saved to provide a date/timestamp of when the report was made public. The control was implemented on or before July 1, 2022. Bluefield State University (BSU) response BSU has strengthened internal controls over reporting of HEERF funds to assure that the posting to the University website in a timely manner is documented in writing. BSU posted all reports to the University website on or before the filing deadline. However, we did not receive written documentation from our IT department to document the timely posting. We have revised our internal control procedures to ensure that that we receive and retain documentation of the posting date. BSU inadvertently used incorrect terminology to describe some of the emergency grants to students made from the Student Portion of HEERF funds. The reports selected for testing were for the Student Portion of funds that was reported in a narrative format. The revised reporting form issued by the Department of Education combines the reporting of Student, Institutional and HBCU funds on one standard form. This will eliminate these types of errors in subsequent reporting. West Virginia Northern Community and Technical College (WVNCC) response WVNCC is aware to include the total amount of grants distributed, the estimation of students to receive a grant and the total amount of students to receive the grant from the calculations used to issue Emergency Financial Aid Grants. In addition to reporting the method used to determine award amounts to students prior to the awards being disbursed, WVNCC will also include the method used in future reporting. As an added layer of review, WVNCC will include a third report reviewer from Student Accounts to verify the number and dollar amount of awards disbursed to be included in the report. This action was implemented in January 2023. West Liberty University (WLU) response As of January 2023, federal drawdowns are reconciled and reviewed prior to the drawdown. The signature of the Controller or CFO is on each drawdown with the date of review and approval. The drawdown is then completed usually on the same date as the review and approval. Southern West Virginia Community and Technical College (SWVCC) response SWVCC has enhanced its procedures surrounding the preparing, updating, and reviewing of quarterly and annual reports for the HEERF Education Stabilization Fund (and all other federal awards). The information utilized to prepare the reports is now dated and saved for future reference. The individual compiling the report documents the date the report is completed and submits it to the reviewer. The reviewer documents the date of review and any adjustments made to the report. The review is completed before the report is posted to the institution?s website and all documentation will be maintained for audit review. These procedures are in place as of January 2023. Pierpont Community and Technical College (PCTC) response PCTC?s staff and administration have reviewed the reporting requirements for HEERF funding to ensure quarterly and annual reports are accurate and timely. All staff involved in the reporting process, which includes the offices of Financial Aid, Registrar and Finance, have been directed to document and retain all source data used in the reporting process. A documented review process was put in place in October 2022 to ensure review by a supervisor and a final review by the Vice President of Finance and Administration/Chief Financial Officer or the Comptroller. Evidence of the review process is demonstrated through sign offs and/or e-mail communications. Concord University (CU) response Beginning with the December 2022 quarterly reporting, the coordination and approval of all reports will continue to be documented electronically. Additionally, the level of review/approval for the generated reports prior to posting will also be documented, and all work orders requesting the public posting of approved reports will include a cited reminder of the federal posting deadline for grant compliance. This additional information in the requested work order will ensure all parties involved are aware of and meet the required posting deadline. These steps were taken for the December 2022 Institutional Portion (CFDA #84.425F) quarterly reporting and resulted in a timely posting. The Student Aid Portion (CFDA #84.425E) final reporting occurred during fiscal year 2022. Mountwest Community and Technical College (MCTC) response For student reporting ? Q4 FY2021 and Q3 FY2022 there were no student reports prepared for these quarters. MCTC submitted OMB Control Number 1840-0849 with no expenditures reflected for HEERF I, II, or III Student Portion for FY21 Quarter 4 and FY 22 Quarter 3. All funds were fully expended by the end of FY 22 Quarter 2. Although there were no HEERF Student Portion funds expensed during the Quarters in question, MCTC has acknowledged that the language on the website should have been updated to disclose all funding as awarded and final. As a response to the finding, MCTC will develop a Quarterly Reporting schedule for posting on the website to capture all awarding activity from HEERF I, II, and III from point of initial receipt of HEERF funds through the grant end period, June 30, 2023. For Institutional Reporting ? Q4 FY2021 institutional report was not posted timely within the 10-day reporting requirement. This occurred before the PY corrective action plan was implemented. A corrective action plan was submitted on February 17, 2022 and all subsequent quarterly reports have been submitted timely. Glenville State University (GSU) response GSU implemented and strengthened internal controls surrounding the reporting for both HEERF II and III in February 2022. GSU has created and filled the position of Director of Grants Compliance. This new Director has direct oversight and assurance of GSU?s compliance with all grant reporting requirements. The Director will prepare and maintain a ?Master? checklist for all grants received by GSU. The checklist will be monitored and updated as reporting or compliance steps are met by the Director. The Director will coordinate with the relevant personnel with reporting or compliance responsibility over the grant to ensure the compliance expectations are met timely.

SPECIAL TESTS AND PROVISIONS ? DISBURSEMENTS TO OR ON BEHALF OF STUDENTS Pierpont Community and Technical College (PCTC) Assistance Listing Number 84.007, 84.033, 84.038, 84.063, 84.268, 84.379, 84.408, 93.264, 93.342, 93.364, 93.925 PCTC?s standard procedure for disbursement letters is to have the Information Systems Specialist (ISS) provide letters for review to the Director of Financial Aid before mailing. This was either not done by the ISS or overlooked by the Director. The process has been reviewed and communicated to the current Information Systems Specialist as well as the Assistant Director of Financial Aid. The Assistant Director of Financial Aid is authorized to review letters in the absence of or instead of the Director. This action was implemented January 2023.

SPECIAL TESTS AND PROVISIONS ? BORROWER DATA TRANSMISSION AND RECONCILIATION Pierpont Community and Technical College and West Virginia State University Assistance Listing Number 84.007, 84.033, 84.038, 84.063, 84.268, 84.379, 84.408, 93.264, 93.342, 93.364, 93.925 Pierpont Community and Technical College (PCTC) response Beginning July 1, 2022, PCTC has updated the monthly reconciliation process. The Direct Loan School Account Statement (DLSAS) reports from Common Origination and Disbursement (COD) are downloaded by the 10th of each month, as before, by the Information Systems Specialist (ISS). The reports are now provided to the Assistant Director of Financial Aid (Asst.) and then reconciled to both Banner paid and COD approved Direct Loan disbursements. Reports verifying reconciliation are then completed and saved by the Assistant Director of Financial Aid and reviewed by the Director of Financial Aid for completion and accuracy. PCTC will maintain the documentation of the DLSAS statements each month and the reconciliation report along with evidence of said review. West Virginia State University (WVSU) response After each weekly disbursement, the Financial Aid Technician requests a Year-to-Date SAS Disbursement Detail on Demand Report from COD. The report is compared with the disbursement data within Banner and a COD/Banner Comparison Report is generated. The comparison report is sent to the Associate Director of Financial Aid and Director of Financial Aid to correct and document any discrepancies and if necessary, refers to the monthly DLSAS reports to verify resolution to any found discrepancies. The monthly DLSAS report is reviewed each month by the Director of Financial Aid to confirm consistency between fund disbursement and drawdownsreturn of payments by the Fiscal Office. The Director of Financial Aid and Business and Operations Manager both sign off weekly confirming accuracy. Effective August 2022, policies and procedures have been updated so any corrections applied will be documented, dated and saved by the Associate Director of Financial Aid and/or Director of Financial Aid.

FINANCIAL REPORTING Pierpont Community and Technical College and West Virginia State University Assistance Listing Number 84.007, 84.033, 84.038, 84.063, 84.268, 84.379, 84.408, 93.264, 93.342, 93.364, 93.925 Pierpont Community and Technical College (PCTC) response PCTC?s Assistant Director of Financial Aid (Asst.) will take screen captures of both Banner and the Common Origination and Disbursement (COD) for a monthly reconciliation of the Federal Pell Grant program. Screen captures will be printed, and comparisons will be made by the Asst. All necessary adjustments will be performed to student accounts by the Asst. or Director of Financial Aid (Director) until balanced. The Asst. will sign as an approval on reconciliation documentation and provide to the Director for review and approval. The completed monthly reconciliation information will be retained in the completed reconciliation information file on the shared drive. This process has been implemented as of July 1, 2022. The updated procedure will ensure timely processing of all federal Pell grants to students and updates in the COD system. West Virginia State University (WVSU) response Effective January 2022, WVSU reports information to COD daily. Originations and fund adjustments are imported and exported Monday through Friday for students who meet eligibility requirements by the Financial Aid Technician and the import reports are reviewed by both the Technician and a FA Administrator with corrections being made to any errors and/or rejections. The disbursement process of applying aid to student's accounts occurs weekly throughout the semester after enrollment hours have been confirmed. The disbursement process in Ellucian Banner is completed by the Financial Aid Technician and funds are applied to student's accounts. The Director of Financial Aid proceeds to review the disbursement roster to confirm accuracy of fund sources, fund amounts and enrollment hours after the disbursement process has finished. The Financial Aid Technician sends the disbursement files to COD after the disbursement roster has been reviewed, and loads the response files the following morning. The load response files are reviewed by the Associate Director of Financial Aid and Director of Financial Aid to confirm acceptance. Both the Director of Financial Aid and Business and Operations Manager will sign off weekly confirming accuracy. Policies and procedures were updated August 2022 so that any corrections applied will be documented, dated and saved by the Associate Director of Financial Aid and/or Director of Financial Aid.

FISCAL OPERATIONS REPORT AND APPLICATION TO PARTICIPATE Fairmont State University, West Virginia State University, and West Virginia School of Osteopathic Medicine Assistance Listing Number 84.007, 84.033, 84.038, 84.063, 84.268, 84.379, 93.264, 93.342, 93.364, 93.925 Fairmont State University (FSU) response As of January 2023, the Financial Reporting Manager will complete Part II of the Fiscal Operations Report and Application to Participate (FISAP) submission. The Controller will review and compare with audited financial statements to ensure the correct amounts are recorded prior to approval and submission by the institution. West Virginia State University (WVSU) response This finding was a result of inaccurate reporting. The dollar amounts used for tuition and fees in the original calculation were incorrect. The supporting documentation was updated after submission of the FISAP to include correct numbers. To prevent this from occurring in the future, a dual review will be required for all reporting data. The Office of Financial Aid and Scholarships will verify the Federal Work-Study (FWS) and Supplemental Education Opportunity Grant (SEOG) fund allocations are identified correctly on the FISAP, in regard to transfer of funds, to accurately reflect the allotted fund amounts and amounts paid to student accounts in Banner. These changes were made effective March 2022 and reflected in the FY22 FISAP. West Virginia School of Osteopathic Medicine (WVSOM) response Internally generated reports used to prepare the FISAP from WVSOM?s management system have been modified to ensure accuracy and clarity of the data. Procedures are in place for a secondary review of the report prior to submission.