Corrective Action Plans

November 17, 2022 To: Chair of the Audit Committee From: Debra Martin, Vice President for Finance and Administration RE: Response to Baker Tilly Audit Communication ? Uniform Guidance Audit Findings Finding 2022-003: Enrollment Reporting Program: Federal Direct Loan Program Assistance Listing Number (ALN): 84.268 Federal Agency: U.S. Department of Education Federal Award Identification Number: P268K221157 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: Five of the twenty-five students who were tested had incorrect statuses, status dates or program information reported to NSLDS. One student was reported correctly as graduated on the campus level reporting but was not reported as graduated on the program level. Two other students that graduated were not reported as graduated on campus or program level reporting. Two students were reported with the status effective date on both the campus and program level reporting that did not agree to the University?s system support, subsequently for one student the registrar changed the system date noting it had not been updated in error. The sample was not a statistically valid sample. Cause: The University?s processes did not ensure accurate reporting to NSLDS. 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. Questioned costs: Not applicable Context: Not applicable. Recommendation: It is recommended that the University review policies and procedures in place to resolve reporting issues in a timely manner to facilitate compliance with Title IV regulations. Management?s Response: The University agrees with the recommendation and will review system and business processes contributing to these errors and implement corrective measures. Correction Action: MSMU will add an additional enrollment and degree report to our current schedule of one per month. This will allow for more frequent enrollment reporting that will correct this type of enrollment reporting error going forward. In addition, Registrar?s Office will update procedures to verify status start dates for any enrollment changes to specifically match the student?s enrollment in the student information system. MSMU will continue to explore the possibility of reporting directly to the NSLD rather than having to abide by the Clearing House policies. In the meantime, when graduating a student Registrar staff will check to see if the student is currently enrolled at MSMU, and if they are not, the staff member will go to the Clearing House and manually mark that program as graduated with a G. The Registrar?s Office will have multiple staff members verify the degree data uploaded to the Clearing House.

November 17, 2022 To: Chair of the Audit Committee From: Debra Martin, Vice President for Finance and Administration RE: Response to Baker Tilly Audit Communication ? Uniform Guidance Audit Findings Finding 2022-001: Significant Deficiency - Return of Title IV Fund Calculations Program: Student Financial Assistance Cluster Assistance Listing Number (ALN): Various Federal Agency: U.S. Department of Education Federal Award Identification Number: Various Federal Award Year: June 30, 2022 Criteria: 34 CFR 668.22 requires that when a recipient of Title IV grant or loan assistance withdraws from an institution during a payment period or period of enrollment in which the recipient began attendance, the institution must determine the amount of Title IV grant or loan assistance that the student earned as of the student's withdrawal date in accordance with Federal regulations and return the unearned portion of the grant or loan funds to the Title IV programs as soon as possible but no later than 45 days after the withdrawal date. Condition: Two students of five students tested had incorrect/missing calculations. One student was disqualified during the term after the first 8 week session in the Associate Degree of Nursing and could not continue into the second 8 week session. The University did not note the disqualification and withdrawal timely and did not perform an R2T4 calculation as required and the $2,473.53 of direct loans calculated by the auditor was not returned. One student's number of days attended (numerator) was calculated incorrectly at 25 days but should have been 26 days and therefore $59.53 too much Pell was returned. The auditors noted that a total of four students withdrew from the Associate Degree of Nursing program from the population file provided, and two students were not selected by the auditors. The University reviewed these students and noted one student completed more than 60.01% although the auditors learned that the student was disqualified at the end of the first 8 week session and therefore should have had an R2T4 calculation and return, and one student the R2T4 calculation was performed, however the auditor noted the number of days attended (numerator) was calculated incorrectly at 51 days but should have been 52 days and included a negative amount of Pell grant that ?could have been disbursed?. The University noted that an estimated term end date of May 7, 2022 was input in the system and was not updated to the actual term end date of May 6, 2022. As this could impact all students who withdrew during the Spring 2022 term, the auditors noted 21 students in the population file provided who withdrew during spring 2022, and four of those students were noted as withdrawing before 60% and were not tested by the auditors. The University reviewed these students and noted two additional students with incorrect denominators used in their calculations, the auditor reviewed only the denominators for these students and agrees. The sample was not a statistically valid sample. Cause: The University?s controls surrounding completing timely and accurate refund calculations did not operate as designed and resulted in exceptions. Effect: The calculations of funds to be returned to the Department of Education did not occur or were incorrect. Questioned costs: Questioned costs of $2,301.70 (ALN No. 84.268), and $59.53 (ALN No. 84.063) were noted during testing. Context: Exceptions were noted for 2 of the 5 students selected for testing. There were a total of 33 students who withdrew during fiscal year 2022 that received Title IV aid. Recommendation: It is recommended that University personnel review the calculations generated by the University's software system to ensure they are timely and accurate. It is also recommended that the control structure be reviewed to ensure all student who withdraw during a term are identified in a timely manner. Management?s Response: The University will review withdrawal controls and procedures so that students who withdraw are identified and correctly processed in a timely manner. The University will also engage our software system Consultant to examine system settings to ensure accurate and timely Return of Title IV calculations occur. Further, management reviewed and performed the same recalculations for the remaining 28 students in the population. Of those, 24 had no findings or errors and the remaining only had a small amount of excess available Pell funding or loan eligibility. The Pell amounts were awarded and students with loan availability were notified and asked to respond if they wished to borrow the additional funds. All amounts were not material. Correction Action: The Registrar?s Office will provide the Financial Aid Office with final academic calendars in advance to ensure that proper start and end dates of academic periods are correct in the Financial Aid System. Multiple employees (as opposed to a single person) in the Financial Aid office will be tasked with confirming the accuracy of the calendar set-up in advance of the start of each semester. We have also reminded the Nursing department of timely communication of student disqualifications to the Registrar?s office to assist in recognizing students who may fall into this category. In addition to these steps, the University is exploring systematic changes in colleague that will split the ADN and ABSN programs into two separate 8 week sessions with separate start/end dates, as opposed to one 16 week semester that has two sessions within. An RT24 output report will now be automatically generated and reviewed by the Director of Financial Aid every two weeks. Furthermore, the University will apply the same refund calculation policy to ADN students who are academically disqualified, as we do all other student populations. This will ensure accuracy when determining the number days attended and earned amounts of federal aid when processing R2T4 calculations. The University will dedicate additional resources, staff and technology, to manage withdrawal notifications and to process then in a timely manner.

2022-001 - Non-compliance Specific steps to be taken to correct the situation (including a timetable for performance of the CAP) or reason why corrective action is not necessary (including disagreement with the finding): NTMA has recently adopted a new student financial management system that will assist in determining correct calculated awards and is a State of the art financial aid packing system. We are retiring Transcripts, a very antiquated system that was not set up to provide the error free outcomes required. Jenzabar Financial Aid, our new SMS, enacts group processing and direct data imports from the DoE, manages funds to and from the COD system. Flexibility to award using federal and institutional methodologies, automates COA calculations etc.. Jenzabar is a Financial Aid System built by financial aid people. It was set up in manner that is meant to be more compliant and more robust streamline process. It has automated the entire financial aid process. In addition, we are also considering the use of a servicer and requiring financial aid staff to take an additional continuing education and they will be attending virtual workshops that the DoE offers each year.

The institution does not dispute this finding. This was an isolated incident and no further instances of this nature occurred. There was a personnel change in the staff member responsible for completing refund calculations. The automated notice for this particular student's withdrawal had been sent to the prior employee, who by that time was no longer with the college. The new individual did not see the notice and was not aware that a refund calculation was required. There was a brief window when all notifications were switched to the new staff member, and this particular status change was processed during that transition. The refund has now been processed and all unearned aid for the term has been returned. We have two personnel trained on completing/reviewing R2T4 calculations to serve as a checks-and-balance within the department. This finding was reviewed with all staff members in the department to ensure compliance moving forward.

The institution does not dispute the finding. This was an isolated incident and no further instances of this nature occurred. There was a delay in processing the refund as the R2T4 was completed just before our holiday break. The staff member that handles the return in COD would have completed it upon return to the office in early January but then she was out of the office for longer than anticipated due to symptoms resulting from a positive diagnosis of Covid. Upon her return, she completed the refund and it posted to the ledger 19 days late. Each position within the department has now been cross trained so that any one staff member's extended absence does not impact the operation and our ability to maintain regulatory compliance. This finding as reviewed with all staff members in the department to ensure compliance moving forward.

The institution does not dispute this finding. This was an isolated incident and no further instances of this nature occurred. The staff member mistakenly thought that a PLUS denial from a prior academic year was for the academic year in question, thereby awarding additional Unsub for an independent student. Once the error was found, the ineligible Unsub amount was returned. Staff was provided proper training with respect to reviewing documentation to confirm accuracy of awards being packaged. This finding was reviewed with all staff members in the department to ensure compliance moving forward.

Return of Title IV (R2T4) Calculations Planned Corrective Action: The Office of Financial Aid and Scholarships will develop procedures to conduct secondary reviews of R2T4 calculations going forward to address any issues related to calculations. Responsible staff will continue to attend regular virtual seminars conducted by the Department of Education and national, regional, and state associations of financial aid administrators for ongoing training. The Director of Financial Aid and Scholarships will develop a working group to discuss current University policies related to attendance, roster drops, and withdrawals to improve reporting to ensure timely returns. The group will include representation from the office of Financial Aid and Scholarships, the office of the University Registrar, the office of the University Provost, and Anderson Central. Additionally, because the University has adopted Workday for its new campus-wide ERP the financial aid system of record has changed from PowerFAIDS. The Director will work with our outside consulting partner to develop reports and notifications necessary to ensure compliance since the delivered R2T4 process within Workday is not fully functional. Person Responsible for Corrective Action Plan: Director of Financial Aid and Scholarships, Michael Sapienza. Anticipated Date of Completion: Continuous process

Name of Responsible Individual: Sammara Evans, Director of Institutional Research Corrective Action: On March 21, 2023, Howard assigned Ms. Sammara Evans, the Director of Institutional Research, as the lead for quarterly and annual HEERF reporting. The areas with access to the information required to complete the quarterly and annual HEERF reporting have now been added to the Education Stabilization Fund (ESF) site as editors. This list of editors on the ESF site includes representatives from the Financial Aid Office, the Bursar?s Office, Enrollment Analytics and Grants & Contracts. These offices can now receive notifications regarding submission deadlines and have access to update the information for each report. Prior to the quarterly or annual report due date, the Director of Institutional Research will request the necessary information from each department and is aware of her responsibilities to do so. HEERF reporting responsibilities have been defined. Anticipated Completion Date: March 31, 2023

Name of Responsible Individual: Benjamin Carmichael, Compliance Officer and Roderick Johnson, Assistant Director for Compliance Corrective Action: There was one credit balance in the sample (from September 2021) that was not processed within 14 days. It was completed on the 20th day after the refund was created on the student?s account. Note that the record identified in the sample was during the time of the cyberattack. While this does not absolve Howard of demonstration of administrative capability, the bursar team could not have performed their function during this time. Anticipated Completion Date: December 31, 2021

Name of Responsible Individual: Roderick Johnson, Assistant Director for Compliance Corrective Action: The finance and financial aid divisions will collaborate to improve the internal controls that are in place to ensure there is a three-day turnaround for draws and refunds. The policies and procedures for cash management were updated in July 2022. Anticipated Completion Date: June 30, 2023

Name of Responsible Individual: Benjamin Carmichael, Compliance Officer Corrective Action: Loan disbursement notifications are now the responsibility of the Office of Financial Aid (Financial Aid). Notifications are now being sent out through Ellucian Banner (Banner) when a student has been awarded. The disbursement notification documentation is now electronic and does not require manual actions from Howard University employees to be completed. The following areas identified in the audit have been addressed: ? Notifications are immediately sent out electronically when the student is awarded, allowing Howard to meet the required notification timeline for notification. ? Each notification is addressed to the specific person (i.e., parent, student) who is responsible for paying back the loan. ? The name of the student, exact amount of the disbursement and the date of disbursement is generated on the notification as well. Bi-semester reviews have been completed by the Associate Director for Compliance (Financial Aid) to ensure the loan disbursement notifications are being generated in the required timeline and includes all federally required information listed above in each notification. Spring 2022, Summer 2022, and Fall 2022 reviews have been completed thus far with no significant issues identified. The policies and procedures for loan disbursement notifications were updated in April 2022. These will be reviewed annually. Anticipated Completion Date: April 30, 2022

Name of Responsible Individual: Benjamin Carmichael, Compliance Officer and Roderick Johnson, Assistant Director for Compliance Corrective Action: The Enrollment Reporting process is supervised by the Office of the Registrar (Registrar), which is responsible for providing enrollment reports to Howard University?s third-party servicer, National Student Clearinghouse (NSC), who then submits the report to the National Student Loan Data System (NSLDS). The departure of a key registrar personnel resulted in miscommunication and neglect of the enrollment reporting duties. The issue has since been remedied, but due to the time lag, will take an additional fiscal year for improvements to be observed. Anticipated Completion Date: March 31, 2023

See corrective action plan for chart/table.

See corrective action plan for chart/table.

See corrective action plan for chart/table.

See corrective action plan for chart/table.

The Student Accounts Office will return funds to students within 14 days of the disbursement of Title IV funds when those funds create a credit balance on the student account. New procedures have been added within the department to review for credit balances upon their creation to ensure refunds are processed timely for all students owed a refund. Individuals Responsible for Corrective Action Plan: Susan Childs, Associate Vice President for Finance & Controller, 919-508-2033 Completion Date: September 2022

FINDING 2022-008 ? Pell Award Calculation ALN and Program Expenditure: 84.063 ($484,684) Award Number: P063P213976 Federal Award Year: July 1, 2021 to June 30, 2022 Questioned Costs: $181 Condition Found: The amount of Pell grant awarded was calculated incorrectly for one of the twenty-nine students who received Pell in our sample. The student was awarded Pell grant funds as if the student was enrolled full-time when the student was enrolled ? time. Corrective Action Plan: The School returned the $181 in question to the Department of Education in December 2022. Communication will be improved between the various offices on campus. Anticipated Completion Date: The corrective action was completed on December 13, 2022. Contact Person Valorie Quesenberry, Financial Aid Coordinator 513-763-6659

FINDING 2022-006 ? Authorization to Hold Credit Balances ALN and Program Expenditures: 84.063 ($484,684) Award Number: P063P213976 Federal Award Year: July 1, 2021 to June 30, 2022 Questioned Costs: None Condition Found: For three of the twenty-eight students in our sample, the School held Title IV credit balances for longer than fourteen days without written authorization. Corrective Action Plan: The credit balances were returned to the students in question before the end of the academic year. The financial aid office will follow-up with the cashier to ensure that, in the absence of a signed authorization to hold credit balances authorization, the credit balance refunds requested are processed timely. Anticipated Completion Date: The corrective action was completed in November 2022. Contact Person Valorie Quesenberry, Financial Aid Coordinator 513-763-6659

2022-002: Missing Entrance Counseling Documentation - Student Financial Aid Cluster - Assistance Listing #s 84.007, 84.033, 84.063, 84.268 - Grant Period - Year Ended June 30, 2022 Condition Found: During our student file testing, we noted one student out of 40 did not have documentation in their file to verify that entrance counseling occurred before the disbursement of loans. We consider the missing entrance counseling to be an instance of noncompliance with the Eligibility Compliance Requirement. Corrective Action Plan: We have updated our Loan checklist procedures to include printing the Master Promissory Note and Entrance Counseling confirmation off of the Common Origination and Disbursement website. Those print outs will be included in the student loan application packet and will be kept with the other student loan documents in the student?s file. Responsible Person for Corrective Action Plan: Eric Johnson ? Director of Financial Aid Implementation Date of Corrective Action Plan: 10/6/2022

2022-001: Late Return of Title IV Financial Aid - Student Financial Aid Cluster ? Assistance Listing #s 84.007, 84.033, 84.063, 84.268 - Grant Period - Year Ended June 30, 2022 Condition: During our Return of Title IV Fund testing, we noted that the College did not return Title IV Student Financial Aid for one out of twenty-five students tested until after 45 days when the student ceased attendance. We consider the untimely calculation and Return of Title IV Student Financial Aid to be an instance of noncompliance relating to the Special Tests and Provisions Compliance Requirement. Corrective Action Plan: We have updated our Intercession Procedures to include an early date to return Title IV Student Financial Aid, to occur prior to the 45 days when a student would cease attendance. With the earlier to occur date this will prevent this noncompliance issue from happening again. Responsible Person for Corrective Action Plan: Eric Johnson- Director of Financial Aid Implementation Date of Corrective Action Plan: 10/6/2022

FINDING 2022-009 ? R2T4 Calculations ALN and Program Expenditure: 84.063 ($484,684) 84.268 ($149,449) Award Number: P063P203976 P268K223976 Federal Award Year: July 1, 2021 to June 30, 2022 Questioned Costs: 84.063 ($1,167.43) Condition Found: All seven of the R2T4s completed by the School during the fiscal year were reviewed. The following items were noted: ? One R2T4 was calculated correctly, but $1,533.02 of Federal Grant funds were returned instead of $1,617.45 as required by the R2T4 calculation. ? One R2T4 was calculated correctly; however Federal Pell Grant funds totaling $1,083 were not returned to the Department of Education as required by the R2T4 calculation. ? One R2T4 was calculated correctly, but the funds were not returned timely. The correct amount of funds were returned before audit fieldwork began. Corrective Action Plan: The Student Financial Aid Director returned $84.43 of Federal Pell funds for the first student in question in November 2022. A total of $1,083 of Federal Pell Grant funds were returned for the second student in question on November 4, 2022. Procedures will be improved to ensure that the R2T4, funds are returned timely. Anticipated Completion Date: The corrective action was completed in November 2022. Contact Person Valorie Quesenberry, Financial Aid Coordinator 513-763-6659

FINDING 2022-007 ? NSLDS Reporting ALN and Program Expenditures: 84.268 ($149,449) Award Number: P268K223976 Federal Award Year: July 1, 2021 to June 30, 2022 Questioned Costs: None Condition Found: The incorrect effective date of an enrollment status change was reported to the National Student Loan Database System (?NSLDS?) for one of the twenty-eight students selected for testing. Corrective Action Plan: The Financial Aid Director updated the withdrawal date in NSLDS for the student in question in November 2022. Procedures will be improved to ensure that the correct withdrawal date is reported in NSLDS. Anticipated Completion Date: The corrective action was completed in November 2022. Contact Person Valorie Quesenberry, Financial Aid Coordinator 513-763-6659

CFDA Numbers: Various Program: Student Financial Assistance Cluster Corrective Action: The Registrar's Office has implemented a comparison process where graduates are verified against the National Student Clearinghouse grad only file. Implementation Date: 8/21/22 Corrective Action: The Registrar's Office has implemented a process to verify SSNs on record and correct student records. Implementation Date: 1/20/22 Corrective Action: The Registrar's Office will develop a business process to review term withdrawals for program/campus level discrepancies. Implementation Date: 6/12/23 Contact Person: Scott Campbell and Amanda Fijal

Finding 2022-002: Reporting Corrective Action The University has reviewed its reporting process. The responsible department has strengthened its process and controls to include an audit process to ensure the timeliness of reporting disbursement to meet the requirement of 15 days. Anticipated Date of Completion: June 2023