Corrective Action Plans

2022-003 Significant Deficiency: Exit Counseling (U.S. Department of Education, William D. Ford Direct Loan Program, ALN #84.268) Name of Contact Person: The Director of Financial Aid, Christin Mustard, is responsible for the corrective action for this finding. Exit counseling letters are generated by the Financial Aid Counselors, who report to the Director of Financial Aid. Corrective Action Plan: King University concurs with finding 2022-003, that exit interviews were not sent to students as required upon withdrawal from the university or dropping below halftime enrollment status. This functionality was handled by previous staff who are no longer with the university. These duties were not clearly assigned in our policies and procedures, which resulted in inconsistencies in sending out exit letters as required. We now have established clear policies and procedures to correct this finding. These are as follows: As part of the withdrawal process, the Financial Aid Counselors will send exit letters within the required timeframe upon receiving notification from the Office of Registration and Records that a student has withdrawn from the University. The counselors will also utilize the Daily Load Report and a series of selection sets to identify students who have dropped below halftime enrollment, and will send the exit letters as required by federal regulations. Anticipated Completion Date: The Financial Aid Office has reviewed all students who have withdrawn or dropped below halftime enrollment status in the 2021-22 and 2022-23 award years to ensure that exit letters were sent. This corrects these findings.

2022-004 Significant Deficiency: Awarding Eligibility (Federal Pell Grant Program, ALN #84.063) Name of Contact Person: The Director of Financial Aid, Christin Mustard, is responsible for the corrective action of this finding. Financial Aid packaging is performed by the Financial Aid Counselors, who report to the Director of Financial Aid. Corrective Action Plan: We concur there were instances where King failed to calculate/disburse Federal Pell Grant funds appropriately based on their updated Enrollment Status/EFC. We found that the Pell distribution fund was locked, which prevented the Pell recalculation when the higher ISIR transaction was loaded. In addition, there was not a report in place to alert the Financial Aid office of students enrolled in both traditional and modular courses. As a result, those students were not being identified/monitored effectively for enrollment changes. King is currently updating its policies and procedures to capture and monitor enrollment status of traditional students enrolled in a combination of traditional and modular courses. This will ensure that Pell Grant is awarded correctly based on enrollment status and modular courses for which the student verified. Additionally, we will ensure that Pell Grant award distributions are unlocked so that the Powerfaids system will update the Pell award amounts correctly according to EFC changes from subsequent ISIRs. Anticipated Completion Date: All Pell findings have been reviewed, and errors that could be corrected have been resolved.

2022-002 Significant Deficiency: National Student Loan Data System (NSLDS) Report (U.S. Department of Education, William D. Ford Direct Loan Program, ALN #84.268 and Federal Pell Grant Program, ALN #84.063) ?Did not supply status updates to NSLDS in a timely manner. Name of Contact Person: The Director of Registration and Records, Whitney Cleland, and the Director of Institutional Research and Assessment, Jason Thead, are responsible for the corrective action plan for this finding. Corrective Action Plan: King University uses the National Student Clearinghouse to report enrollment changes to NSLDS. Effective Fall 2022, King University will submit enrollment data uploads to the National Student Clearinghouse at least every 30 days. The first of term submission will occur within 21 days of the start date of the term. Monthly enrollment reporting will correspond with module drop/add periods and will occur no later than 10 business days after a module drop period ends, per the Academic Calendar. Additionally, and as a part of the enrollment submission process for the National Student Clearinghouse (NSC), which provides data to NSLDS, an exception report is generated for each enrollment file prior to submission. This exception report is verified and remedied before data is submitted to NSC. Once data is submitted to NSC, an error report is generated from the NSC system. For any students who have status or level changes, the Director of Institutional Research and Assessment verifies all dates with an internal report, called the Enrollment Analysis by Course report, to ensure dates are accurately reported to the NSC. This report is also used by the Office of Financial Aid to ensure withdrawal dates are consistent. This internal report and process ensures that the dates used for all offices are the same, which remedies any communication issues between offices. Additionally, notices are sent by Financial Aid for adjustments to withdrawal dates, which are corrected in our database management system (DBMS). These additional steps allow the DBMS to accurately and collectively capture all applicable students, and the exception and error reports allow the institution to ensure the correct information is reported. We believe a portion of the untimely reporting to NSLDS is a result of the reporting delays between the National Student Clearinghouse and NSLDS, as documented in GENERAL-22-64 beginning July 25, 2022. The Dear Colleague letter and subsequent updates describe issues with enrollment functionality, which affected enrollment reporting. King conducted a review on a sample of students and found that students were reported correctly to the Clearinghouse but were not appearing in NSLDS. A more frequent enrollment schedule should remedy this issue. We also attribute these delays to changes in leadership/staffing during that timeframe. The enrollment reporting steps were outlined by the prior Registrar when this process transitioned to the Office of Institutional Research, but this staffing transition could have resulted in inaccurate data being captured and reported during a window of time in Fall 2021 (when the reporting responsibility transitioned). Additionally, it was discovered that incorrect coding in the CAMS database management system (DBMS) was causing exclusions based on a missing field. These exclusions began in Summer 2021 due to added majors that were not correctly created. Anticipated Completion Date Per above, effective Fall 2022, enrollment data is now uploaded to the National Student Clearinghouse at least every 30 days. Furthermore, the missing fields in the DBMS have been remedied, and the institution is working with NSC and NSLDS to correct previously misreported records by February 2023.

2022-001 Significant Deficiency: National Student Loan Data System (NSLDS) Report (U.S. Department of Education, William D. Ford Direct Loan Program, ALN #84.268 and Federal Pell Grant Program, ALN #84.063). Incorrectly reported student enrollment status. Name of Contact Person: The Director of Registration and Records, Whitney Cleland, and the Director of Institutional Research and Assessment, Jason Thead, are responsible for the corrective action plan for this finding. Corrective Action Plan: King University uses the National Student Clearinghouse to report enrollment changes to NSLDS. Effective Fall 2022, King University will submit enrollment data uploads to the National Student Clearinghouse at least every 30 days. The first of term submission will occur within 21 days of the start date of the term. Monthly enrollment reporting will correspond with module drop/add periods and will occur no later than 10 business days after a module drop period ends, per the Academic Calendar. Additionally, and as a part of the enrollment submission process for the National Student Clearinghouse (NSC), which provides data to NSLDS, an exception report is generated for each enrollment file prior to submission. This exception report is verified and remedied before data is submitted to NSC. Once data is submitted to NSC, an error report is generated from the NSC system. For any students who have status or level changes, the Director of Institutional Research and Assessment verifies all dates with an internal report, called the Enrollment Analysis by Course report, to ensure dates are accurately reported to the NSC. This report is also used by the Office of Financial Aid to ensure withdrawal dates are consistent. This internal report and process ensures that the dates used for all offices are the same, which remedies any communication issues between offices. Additionally, notices are sent by Financial Aid for adjustments to withdrawal dates, which are corrected in our database management system (DBMS). These additional steps allow the DBMS to accurately and collectively capture all applicable students, and the exception and error reports allow the institution to ensure the correct information is reported. We believe a portion of the untimely reporting to NSLDS is a result of the reporting delays between the National Student Clearinghouse and NSLDS, as documented in GENERAL-22-64 beginning July 25, 2022. The Dear Colleague letter and subsequent updates describe issues with enrollment functionality, which affected enrollment reporting. King conducted a review on a sample of students and found that students were reported correctly to the Clearinghouse but were not appearing in NSLDS. A more frequent enrollment schedule should remedy this issue. We also attribute these delays to changes in leadership/staffing during that timeframe. The enrollment reporting steps were outlined by the prior Registrar when this process transitioned to the Office of Institutional Research, but this staffing transition could have resulted in inaccurate data being captured and reported during a window of time in Fall 2021 (when the reporting responsibility transitioned). Additionally, it was discovered that incorrect coding in the CAMS database management system (DBMS) was causing exclusions based on a missing field. These exclusions began in Summer 2021 due to added majors that were not correctly created. Anticipated Completion Date Per above, effective Fall 2022, enrollment data is now uploaded to the National Student Clearinghouse at least every 30 days. Furthermore, the missing fields in the DBMS have been remedied, and the institution is working with NSC and NSLDS to correct previously misreported records by February 2023.

In response to Federal Award Finding 2022-002, updates to the National Student Loan Data System (NSLDS) will occur monthly to reflect Federal Financial Aid enrollment status changes and include the following procedures: 1) Financial Aid Coordinator will review enrollment roster on NSLDS monthly for accuracy, print and sign monthly report. a. A monthly enrollment report will be pulled and cross-referenced with NSLDS Certification Report by additional Student Services staff member. b. If student data is missing or incorrect, the Financial Aid Coordinator will contact NSLDS to address. Missing or incorrect data will be reported to the Student Services Coordinator and Director in writing. 2) Financial Aid Coordinator will identify due dates to ensure compliance for 15 day window for reporting and maintain a calendar noting load dates to ensure deadlines are met. 3) Financial Aid Coordinator will submit monthly report to Student Services Coordinator for review. 4) Instructors will receive additional training addressing submittal of timely withdrawal forms. 5) Student enrollment status change will be updated upon receipt of student withdrawal form. Copies of the withdrawal form and status change will be placed in student's financial file. 6) Student Services Coordinator will review withdrawal form and status change documentation for reporting accuracy and timeliness, sign and date copy of status change form. Data between FOCUS Postsecondary Student Data System and NSLDS will be compared to ensure accuracy. The procedures noted above will ensure timely updates and accuracy in the National Student Loan Data System. The Financial Aid Coordinator will finalize all edits.

Management Views and Corrective Action Plans 2022-001- Reporting on the Fiscal Operations Report and Application to Participate ("FISAP") Point of Contact- Robert Friedman, Director of Student Finance, (646-592-6255) Management agrees with the current year finding, which is related to the prior year finding, and the recommendations to enhance controls to include a reconciliation process, to ensure completeness and accuracy of the FISAP. In addition, management will process a request to make the necessary corrections through the COD website and follow the procedures for submitting changes onto the FISAP. The University's Controller's Office or its designee in conjunction with the Office of Student Finance will perform a review of the FISAP reconciliation prior to filing. We believe this finding will be rernediated prior to the University filing the September 2023 FISAP after completing a full reconciliation of the Perkins fund and through collaboration with the Perkins Portfolio office.

Finding 2022-008 Corrective Action Plan: In our effort to enhance our ability to access older Perkins Loan records, we will engage our information technology consultants to research our information collection system. Currently our ability to access older Perkins Loan records is restricted due to system constraints. The findings from this engagement will be recorded and memorialized for the record. Anticipated Completion Date: June 30, 2023

Finding 2022-004 Corrective Action Plan: The Financial Aid division has revised its compliance process to ensure the effective administrative and internal control oversight of the notification of the Direct Loan disbursements. As a part of this revised compliance process, students receiving financial aid while attending one or more other institutions will be ?singled out? for a detail review in accordance with the National Student Loan Data System (?NSLDS?) Student Transfer Monitoring Process. The Director of Financial Aid will perform periodic reviews to ensure the new process is being effectively executed in a timely and accurate manner. An internal review will be performed Spring 2023 with the Director of Financial Aid, Data Coordinator and neutral third party selected from another division within the University (documentation of these compliance tests will be memorialized for the record, June, Oct, Feb). Anticipated Completion Date: June 30, 2023

Finding 2022-007 Corrective Action Plan: To enhance the internal controls over the applicable compliance requirements of the enrollment reporting requirement to ensure that all status changes are submitted to the NSLDS website within the required timeframe, the Registrar?s office in coordination with the Information Technology Division will develop a ?flag based? process to capture and review all enrollment status changes on a monthly basis. This new reporting process will enhance the Registrar?s ability to review and accurately submit timely notifications to the National Student Loan Data System (?NSLDS?). These monthly reviews will be recorded and memorialized for the record. Anticipated Completion Date: June 30, 2023

Finding 2022-003 Corrective Action Plan: The University has made the necessary changes to the staff and to the review process including, but not limited to, the hiring of both a Senior Financial Aid Counselor and a Director of Transfer Students. The new Director of Transfer Students will have the necessary access/ability to generate the information and update the system to improve the University?s capability to monitor requirements of Title IV aid to ensure enhanced compliance. This will eliminate the challenge created by multiple financial aid counselors being assigned the responsibility for initiating the process, generating the information, and updating the system on a weekly basis. In addition, the Director of Financial Aid will receive alerts when the process has been completed, and perform periodic reviews, using sample populations, to ensure the process is being done timely and accurately. As this is a repeat finding, the University?s corrective action plan is being implemented immediately?Spring 2023. An internal review will be performed using Spring 2023 data with the assistance of the Director of Financial Aid, Director of Transfer Students and a neutral third party selected from another division within the University (documentation of these compliance tests will be memorialized for the record, June, Oct, Feb). Anticipated Completion Date: June 30, 2023

The University will revise processes to ensure that notifications are received as required by the Code of federal regulations. 1) Perform a review of (implement enhancements to) current processes to ensure appropriate notification to students.

The University will review processes to ensure that adequate internal control exists to mitigate risks related to collection of required verification documents are collected. 1) Ensure that staff are trained on the required verification documents to be collected. 2) Perform periodic review of student files to verify completeness of records.

The University will perform a risk assessment that is inclusive of the requirements outlined in the GLBA.

1. Review the necessary submission dates required by ISBE. 2. Submit expenditure reports regardless if financial activity occurred. 3. Place several reminders one week prior to the end of the quarter to ensure timely reporting. See the full Corrective Action Plan included with the reporting package.

Finding: The University incorrectly calculated Federal Direct Subsidized Loan funds for one student resulting in an under award. Corrective Actions Taken or Planned: The Associate Director of Student Financial Aid reviews each student?s need-based aid to correctly calculate the amount of Direct Subsidized Loan each student should receive, with the TEACH Grant being treated as non-need-based aid. In addition, the Associate Director of Student Financial Aid will reassess a student?s calculation when summer term is awarded. The internal policies and procedures have been updated to ensure the need-based calculations are properly performed and reviewed. Person Responsible: Sara Sroka (ssroka@dbq.edu) Anticipated completion date: 10/19/2022

Finding: The University did not timely or accurately report enrollment changes to the National Student Loan Data System (NSLDS). Corrective Actions Taken or Planned: The Registrar?s Office submits a monthly report to the National Student Loan Clearinghouse. For a brief period of time the process for this was inconsistent. After a review of the procedures the issue has been fixed. Also, to ensure withdrawn dates during the semester are being reported on a timely basis Financial Planning will manually enter dates of withdrawn students to National Student Loan Data Systems (NSLDS). Students who have withdrawn at the end of the semester will be manually entered and monitored closely by the Registrar?s Office who will adjust reporting schedule to ensure timely reporting of withdrawn dates. Person Responsible: Sara Sroka (ssroka@dbq.edu) Anticipated completion date: 10/19/2022

See corrective action plan for chart/table.

As part of the assignment of Perkins Loans, we noted that the assignment process required the submission of original promissory notes for each loan to be assigned. As a result, the University began collecting and digitizing its historic loan records to maintain copies for retention and compliance purposes. The assignment process is currently underway and is required to be completed by June 30, 2023. The University is on track to meet that federal imposed deadline. Quinnipiac University agrees with the finding. A small percentage of the remaining loans to be assigned originated over 10 years ago. As it relates to this finding, we were unable to locate promissory notes for six students with loans originated 10 to 30 years ago. Due to their age, we believe the finding may be related to office moves and departmental reorganizations over the years. As a result of this finding and the federal assignment process in general, Management and Financial Aid have performed a comprehensive review of the remaining student records waiting to be assigned for completeness. As a result of this review Management and Financial Aid have identified all loans that are missing original promissory notes. As part of the assignment process, in lieu of original promissory notes alternative documents supporting the existence of these loans have been provided to the Perkins loan assignment processor. Any loans that are not accepted during this appeals process will be purchased by the University at the conclusion of the assignment process, which is planned to be completed by June 30, 2023. If the Office of Management and Budget have questions regarding this plan, please reach out to Stephen Allegretto, the Associate Vice President for Finance and Controller, who is responsible for ensuring this corrective action plan is implemented, at 203-582-7962.

FINDING 2022-001 Contact Person Responsible for Corrective Action: Colby Shank Contact Phone Number: 317-921-4765 Views of Responsible Official: Ivy Tech Community College disputes this audit finding. The College has an effective internal control system to ensure compliance with requirements related to the Special Tests and Provisions ? Return of Title IV Funds compliance requirement. The College previously determined that the Return of Title IV Funds (R2T4) is high-risk due to the large number of transactions, the College?s modular term-based system, and the manual nature of R2T4 calculations. Therefore, a robust quality control review process was implemented. College personnel regularly monitor the error rates and nature of errors discovered through the quality control review to identify, correct, and eliminate calculation errors. The claimed errors outlined in Finding 2022-001 relate to the interpretation of how a correction recalculation is determined. In correction calculations, aid previously returned as a result of the initial calculation in the 2021-2022 academic year was considered no longer disbursed and was included in the correction calculation as ?aid that could have been disbursed.? In certain scenarios, this can result in different return amounts than if the aid had been included in the calculation as ?aid disbursed.? In the absence of explicit guidance on how to handle these scenarios within the Federal Student Aid Handbook, College interpretation and precedent has been to treat aid previously returned under the original calculation as aid that could have been disbursed. Volume 5, Chapter 2 of the 2021-2022 Federal Student Aid Handbook states that ?any undisbursed Title IV aid for the period that the school uses as the basis for the R2T4 calculation is counted as aid that could have been disbursed.? Ivy Tech confirmed this interpretation as valid via a third-party financial aid expert who facilitated a discussion with a representative of the USDOE. This USDOE representative confirmed the accuracy of the calculation and the alignment with the Federal Student Aid Policy Implementation and Oversight Directorate. During this discussion, the representative stated that the results of the original calculation could not be ignored, and that including aid that is no longer disbursed as ?aid that could have been disbursed? is the proper way to perform a correction calculation. The auditors state the College should have performed the following actions: ?The College should have considered the original amount of aid to be returned that had already been posted to each student?s account. The College should have posted the additional amount of aid to be returned to the students? accounts based upon the net difference between the original calculation and the corrective calculation performed for each student.? This methodology would have produced inaccurate return amounts under the interpretation of guidance from Federal Student Aid from which the College was operating during the review period. Only posting the ?net difference? between the original calculation and the correction calculation would have resulted in too few funds being returned to Federal Student Aid for many calculations during the review period. Specifically, a difference in return amounts occurred when the amount of unearned charges (institutional charges for the period multiplied by the percentage of unearned Title IV aid) was less than the calculated amount of Title IV aid to be returned. Under the R2T4 calculation formula, the amount of unearned charges can effectively create a ?cap? on the amount of Title IV aid to be returned by the school. At Ivy Tech Community College, this cap is most often reached when students receive disbursements of federal student loans prior to withdrawing. Because a relatively small percentage of Ivy Tech students receive federal student loans, most correction calculations performed during the review period by Ivy Tech under our interpretation of the guidance resulted in accurate return amounts. This issue only impacted a subset of students who received a correction calculation during the review period. Description of Corrective Action Plan: Upon receiving new guidance from the Chicago/Denver regional office of Federal Student Aid, Ivy Tech has modified the way in which it performs R2T4 correction calculations. Aid returned as a result of the original calculation will remain in the correction calculation as ?aid disbursed? instead of ?aid that could have been disbursed.? The College is no longer following prior guidance received by an expert consultant, a representative of Federal Student Aid that advised the College to include aid that has already been returned as ?aid that could have been disbursed.? The calculation change will be monitored for correctness through the College?s previously established internal controls and quality assurance process for the R2T4 process. Financial aid staff have been trained on the calculation change. Ivy Tech will review all students during the review period who received a correction calculation and will cover with institutional aid any federal grant aid that otherwise would not have been returned under the new guidance from Federal Student Aid. Anticipated Completion Date: 3/31/2023

Corrective Action Plan for the Year Ended June 30, 2022 Finding 2022-004: Significant Deficiency - Non-compliance with Reporting Requirements for Disbursements Condition/Context: For 2 of 25 students selected for testing, the disbursement dates did not agree between the student?s institutional account and the data reported to COD. The students had disbursements that were later refunded. It was noted that the students were disbursed without a valid MPN on file, resulting in students being disbursement that were not eligible at the time of disbursement. The College ultimately obtained the signed valid MPNs and then re- disbursed the funds, as a result the student account original disbursement date and the COD disbursement date differ. Actions Taken: To ensure that this problem does not recur for 2022-2023, disbursement rules have been instituted in Colleague that would prevent funds disbursing if a student hasn?t completed an MPN. The frequency of exports from Colleague to COD has been increased. In addition, Direct Loan and Pell rejects are being corrected each week so that if funds are disbursed and a Colleague or COD error is received, the disbursement is corrected and re- exported before the 15-day time limit. Name(s) of Contact Person Responsible for Corrective Action: Joseph Gilchrist, Interim Financial Aid Director Anticipated Completion date: June 30, 2023

Corrective Action Plan for the Year Ended June 30, 2022 Finding 2022-002: Significant Deficiency ? Direct Loan Reconciliation Condition/Context: The College was not able to provide the three monthly reconciliations for November 2021, February 2022, or April 2022 when requested for the audit in the summer of 2022. The Institution noted that the reconciliations had not been performed timely, and subsequently the Institution had a consultant complete these reconciliations. The auditors were unable to obtain evidence of or confirmation from the Institution on if review of the reconciliations occurred. The sample was not a statistically valid sample. Additionally, the College discovered that Direct Loan reconciliation hadn't been done correctly in the past due to staff turnover. A consultant was given the task of doing a complete 21-22 reconciliation in June 2022. This consultant discovered 16 students had been awarded $177,816 in error. The cause of this was that rules had not been setup correctly in Colleague, and consistent reconciliation by correcting Colleague and COD errors wasn't completed in a timely manner. The auditors obtained the listing of students awarded incorrectly. Actions Taken: For the $177,816in direct loans incorrectly disbursed that was identified, SMC returned the loans and replaced with institutional aid for the impacted students. Beginning with July 2022, the Assistant Director/Systems Specialist reconciles direct loans every month. The Executive Director of Financial Aid and the VP of Enrollment Management review these reports at the end of each month. In addition, a system adjustment has been implemented for 2022-2023 to ensure reconciliation is done monthly. The Assistant Director/Systems Specialist utilizes Colleague variance reports that tract Direct Loans disbursed year to date, the number that COD (Servicer for U.S. Department of Education) has approved, and the students that make up the variance, if any. In addition, COD and Colleague errors that occur during the import/export of Direct Loans to and from COD are corrected on a consistent basis. Reconciliation documentation is then forwarded to the Executive Director for review. Name(s) of Contact Person Responsible for Corrective Action: Joseph Gilchrist, Interim Financial Aid Director Anticipated Completion date: June 30, 2023

Corrective Action Plan for the Year Ended June 30, 2022 Finding 2022-005: Significant Deficiency - Education Stabilization Fund ? Higher Education Emergency Relief Fund - Reporting Condition/Context: For three of the four quarterly reports selected for testing, two for the student portion and one containing both institutional and student portion reporting, the auditors noted that some of the information reported did not agree to the support provided, two of those reports also did not agree to the drawdowns from G5, two of those reports had required information missing, and two of those reports were posted late. ? Student portion report - for quarter three of calendar year 2021 the amount of emergency grants to students of $1,133,392 did not agree to the underlying support of $1,078,437 or drawdowns from G5 of $954,932. The number of eligible students and the number of students who received an emergency financial aid grant were missing from the report. ? Student portion report - for quarter four of calendar year 2021 the amount of emergency grants to students of $1,745,664 did not agree to the underlying support of $1,735,664 or drawdowns from G5 of $1,902,140. The number of eligible students was missing from the report. The report was posted to the Institution's website on January 24, 2022 after the required deadline of January 10, 2022. ? Combined report - for quarter one of calendar year 2022 the amount of emergency grants to students of $405,000 was reported for the institutional portion of HEERF but should have been for the student portion, the same amount was also reported for the institutional portion as covering student outstanding account balances and lost revenue. The report was posted to the Institution's website on July 8, 2022 after the required deadline of April 10, 2022. The report for quarter two of calendar year 2022 report was not submitted timely and was in process during the audit and therefore, was not selected for testing. The annual report had several items that did not agree to the underlying support. How many students received HEERF emergency financial aid grants, amount disbursed directly to students for emergency financial aid grants, amount of grants disbursed to students from all HEERF funds, total institutional funds used did not include amounts for room and board refunds that were reported in quarterly reporting during calendar 2021. Action Taken: The staffing changes in the Business Office and the Financial Aid office resulted in learning curves for the new employees regarding how to report expenses for HEERF. Saint Mary?s reached out to the Department of Education and alerted them to the late filing of the reports and received acknowledgment of the late filings. SMC has since filed reports which have properly accounted for all funds spent that were awarded through the HEERF program. The only report still needed is the annual report for 2022 which will be filed in a timely manner. This has been noted on our calendar with enough time to be properly filed. Name(s) of Contact Person Responsible for Corrective Action: Susan Collins, VP for Finance and Administration Anticipated Completion date: March 2023

Corrective Action Plan for the Year Ended June 30, 2022 Finding 2022-006: Significant Deficiency ? Control Environment Condition/Context: It was noted during the audit, that there were gaps in the internal control structure of the College, that was no longer adequate to ensure compliance with federal regulations and compliance requirements. Action Taken: The staffing changes in the Business Office and the Financial Aid office resulted in learning curves for the new employees. Both offices have started projects to document procedures so that when turnover occurs, there is a blueprint in place to assist the new employees. SMC will also review the internal controls in place for federal reporting to determine how they can be strengthened. Name(s) of Contact Person Responsible for Corrective Action: Nicole Yu, AVP/Controller and Joseph Gilchrist, Interim Financial Aid Director Anticipated Completion dates: Documenting procedures is on ongoing project. Revised internal controls for federal reporting will be in place by June 30, 2023.

Corrective Action Plan for the Year Ended June 30, 2022 Finding 2022-003: Significant Deficiency - Enrollment Reporting Condition/Context: Of 25 students tested, the status date for one student selected was not reported accurately on the campus level reporting in National Student Loan Data System (NSLDS). The College used the degree conferral date of 8/20/2021 rather than the end of the term/last date of attendance of July 4, 2021 that was used for reporting program level information for this student, and consistent with how other students were reported. Additionally, for two students, reporting at the program level was late, not within 30 days or included in a response to a roster file or within 60 days. The students were reported as graduated effective August 20, 2021 with the earliest certification date of October 31, 2021 at the campus level and December 3, 2021 at the program level. Action taken: In order to ensure compliance in 2022-2023, the Office of the Registrar has increased the degree of reporting frequency to National Student Clearinghouse (NSC), so as to meet the 60-day requirement in NSLDS. It has also have gained access to the National Student Loan Data System to monitor alignment with information submitted by SMC to NSC. Name(s) of Contact Person Responsible for Corrective Action: Tracey Donaldson, AVP and Registrar Anticipated Completion date: June 30, 2023

Corrective Action Plan for the Year Ended June 30, 2022 Finding 2022-001: Significant Deficiency- Return of Title IV Funds Condition/Context: During the audit it was noted that the College provided a list of students that withdrew during the fiscal year and this differed from data that was reported internally to the Audit Committee on the number of students that withdrew in Fall 2021 and Spring 2022 (through April). The number of students that withdrew, the number of student?s that required an R2T4 calculation and the amount of the return all varied. The auditors discussed this with management who confirmed that the list provided to the auditors was complete and that the information reported to the Audit Committee was incorrect. From the withdrawal population the College did provide, a sample of 9 students were selected for testing for return of Title IV funds, of which 5 students did not require Title IV refunds and 4 students did require Title IV refunds. For the population of students with Title IV refunds, the calculations and refunds for 3 students were performed late, and for 1 of those students the calculation was also incorrect (excluded SEOG funds from the calculation). For the 3 students with refunds that were late, 100% of their Title IV funds were returned and then later re- disbursed before the R2T4 calculation and return occurred. Actions Taken: Subsequent to the 2021-2022 single audit fieldwork, SMC had a Financial Aid Services consultant review all R2T4 cases and 1 additional error was identified requiring the return of an additional $17.00. In the future, all R2T4 refund calculations will be performed by the Assistant Director/Systems Specialist who has received substantial training. In addition, the Assistant Director?s refund calculations will be reviewed by the Executive Director of Financial Aid for accuracy. System adjustments have also been made so that if funds are reversed they are re-disbursed at the amount the student is eligible for after the R2T4 calculation is completed. Name(s) of Contact Person Responsible for Corrective Action: Joseph Gilchrist, Interim Financial Aid Director Anticipated Completion date: June 30, 2023