Corrective Action Plans

2022-004 Significant Deficiency: Return to Title IV Funds (U.S. Department of Education, William D. Ford Direct Loan Program, CFDA #84.268; Federal Pell Grant Program, CFDA #84.063; Federal Supplemental Opportunity Grant Program, CFA #84.007; and TEACH Grant Program, CFDA #84.379) Name of Contact Person Melissa White, Director of Financial Aid is responsible for R2T4 calculations. Corrective Action Planned During the audit, it was noted that the University was unable to provide supporting documentation for the withdrawal date used in calculating the return to Title IV funds for several students who unofficially withdrew. This was due to loss of access to Anthology and the data still being converted into Colleague. Tusculum University will continue the practice that it had prior to Anthology where the professor/registrar enters the last date of academic activity when entering in the grades for the student. Financial aid will run the RGER report out of colleague, which pulls all registration activity, including grades, and check the report daily. Using this report, we will identify any students who have unofficially withdrawn and begin the R2T4 based on the last date of academic activity reported when the grade was entered. If any questions arise when completing this process, financial aid will reach out to academic advisor/professors for clarification. Anticipated Completion Date As of fall 2022, financial aid was processing in Colleague and the RGER is able to be ran.

Corrective Action Plan for University of San Diego Audit finding 2022-002 FINDING 2022-002 - Special Tests and Provisions - Borrower Data Transmission and Reconciliation: Significant Deficiency in Internal Control Over Compliance: See Corrective Action Plan for chart/table Criteria -34 CFR section 685.300(b)(5): On a monthly basis, the University of San Diego must reconcile institutional records with Direct Loan funds received from the Secretary and Direct Loan disbursement records submitted to and accepted by the Secretary. Condition/Context - The University of San Diego operates a law school and an undergraduate and graduate school. A sample of 6 direct loan reconciliations were selected from the population of all reconciliations performed by the University, under both schools during the year ended June 30, 2022. We obtained the supporting schedules used to reconcile the disbursed direct loan funds to the federal government?s records. The University did not complete reconciliations of its direct loan program disbursements for the undergraduate and graduate school. Effect - There is a chance that the University of San Diego?s records may not match the federal government?s records of direct loan disbursement. Cause - The process for reconciling this data was revised during the year ended June 30, 2022, and the change was not reflected in the University of San Diego?s policies and procedures. There was turnover in the position responsible for reconciling this data, and the responsibility did not transfer to another individual, and as a result, the reconciliations were not completed. Repeat finding - This is not a repeat finding. Recommendation - The auditors recommend the University of San Diego revise the existing policies and procedures to accommodate the change. Corrective action plan - Management concurs with this finding. This exception was due to a change in the undergraduate and graduate school monthly reconciliation process that was not subsequently communicated during employee turnover in the Controller?s Office. Management updated the direct lending servicing system reconciliation procedures to accommodate the change in process. Management believes these enhancements will be sufficient to prevent future errors. Anticipated completion date: Completed on September 19, 2022 Persons responsible: Kellie Nehring, Director of Financial Aid Services and Maria G. Sanchez, Controller

Corrective Action Plan for University of San Diego Audit finding 2022-001 FINDING 2022-001 ? Special Tests and Provisions ? Enrollment Reporting: Significant Deficiency in Internal Control Over Compliance "See Corrective Action Plan for chart/table" Criteria ? Direct Loan, 34 CFR section 685.309(b)(2)(i): An institution is required to notify the Department of Education within 30 to 60 days (depending on the method of communication) if it discovers that a Direct Subsidized, Direct Unsubsidized, or Direct PLUS Loan has been made to or on behalf of a student who enrolled at that school but has ceased to be enrolled on at least a half-time basis. Condition/Context ? A sample of 34 federal aid recipient students were selected from system generated reports of students who graduated, reported a physical address change, withdrew, or dropped during the 2021-2022 academic year. The enrollment information and withdrawal, address change, or graduation date per the University?s records was compared to the information reported to the National Student Loan Data System (NSLDS) in order to determine if status changes were reported within the required timeframes. An exception was noted whereby the permanent physical address change for 1 student was not reported within the required timeframe to the NSLDS. Effect ? The NSLDS database did not include accurate information until the point at which it was corrected. This information is utilized by Department of Education, the Direct Loan program, lenders, and other institutions to determine in-school status, deferment, and grace periods of student loans. Incorrect information could result in incorrect deferment, grace periods, billing, and repayment of student loans. Cause ? The University of San Diego contracts with a third-party intermediary to transmit enrollment information to NSLDS. Ultimately, the University of San Diego is responsible for the accuracy and timeliness of its reporting, regardless of whether it uses a third party. For the exceptions noted above, the student status change was not reported within the required time frame or not correctly reported due to the University of San Diego not having effective internal controls established to prevent or detect and correct the non-compliance in a timely manner. Repeat finding ? This is a repeat finding. See 2021-001 Recommendation ? The auditors recommend the University of San Diego revise its policies to establish a requirement that the list of graduates submitted to NSLDS be reviewed prior to and after being submitted to the NSLDS. We also recommend the University of San Diego establish an internal control to identify and report status changes prior to the established deadline. Corrective action plan - Management concurs with this finding. This student had a permanent physical address change before we implemented the change in the process described in finding 2021-001. During the 2021 audit, we identified that the exception to the timeframe for reporting a permanent physical address update was due to an incorrect parameter in the report used to provide the data as a result of employee turnover in the Registrar?s Office. Management amended the report parameters to correctly report students who make permanent physical address changes and believes these enhancements will be sufficient to prevent future errors. Anticipated completion date: Completed on October 15, 2021 Persons responsible: Elizabeth Silva, University Registrar

Finding - Special tests and provisions Condition Four students our of a sample of forty who withdrew from the College had the wrong effective date reported to NSLDS. In these instances, the effective date that was reported to NSLDS was the date that the form was completed rather than the date the student notified the institution of their intent to withdraw which is the required date. We also noted two additional students had changes reported outside the 60 day requirement. Views of Responsible Officials and Planned Corrective Actions To ensure the student effective date is submitted correctly and within the 60-day required timeline, the University has: ? Instructed the Dean of Students staff that the effective date on the student withdrawal/leave of absence form must match the received date. ? Staff in the University Registrar's Office, who are responsible for reporting enrollment status and dates to NSLDS, have been instructed to verify effective date and received date match and to use the receipt date as the effective date entered into our student information system. Status dates are extracted from the SIS for submissions to NSLDS via the NSC. ? The Registrar's Office will provide the Dean of Students Office with the NSC submission schedule to reinforce the criticality of submitting withdrawals and leaves of absence to the Registrar in a timely manner for submission to NSLDS. ? The University contracted with a consultant from the American Association of Collegiate Registrars and Admissions Officers for an analysis of our business practices associated with enrollment status reporting to the NSC. We are awaiting the official formal written report and will provide a copy of the recommendations as an addendum to this response once received. One of the consultant's verbal recommendations was the use of a document management system for form tracking as mentioned below. ? The University is exploring designing a Withdrawal/LOA workflow utilizing our current lmageNow document management system to streamline process and provide improved timely NSLDS notifications. The goal is to design a document workflow which will expedite the approval process and will enable document tracking capabilities and reminder notification options. ? The Registrar's Office is transitioning responsibility of processing Withdrawals/LOAs to the same staff member responsible for NSC reporting. We believe this consolidation will lead to improved understanding of data extraction for the transmission enrollment status files and any W/LOA forms which are approved by the Dean of Students after the data extraction can be addressed. Responsible Official: Mary Lally Completion Date: August 31, 2022

The College has created a selection set in its financial aid software to identify these students so they will be selected for verification.

The College will be providing additional consulting support going forward when a new Director of Financial Aid is hired.

The College will be providing additional consulting support going forward when a new Director of Financial Aid is hired.

The University have reviewed and modified the Financial Aid (F/A) manual to make sure it is up-to-date. F/A manual will be reviewed annually to ensure that it reflects the recent changes, if any, as a part of the institutional practice. After the carefully reviewing our policy regarding the ?Exit Interview?, we concluded that we have the policy and procedure in place. However, there was no consistency on following the written policy and procedures. We will implement the following changes to ensure that BU follows the policies and procedures: 1. Designate personnel in charge of informing Financial Aid department when student exits from the program 2. Designate personnel in Financial Aid department to inform the student and conduct the exit interview 3. Financial Aid department makes sure that the student completes the exit interview and the student?s graduation request won?t be approved until the student completes the exit interview. Financial Aid department will follow up the students who need to complete the exit counseling. Person Responsible for Corrective Action Plan: Sheng Wang, Chief Financial Officer Anticipated Date of Completion: June 30, 2023

The University ensures that Campus IVY reporting writes to NSLDS in timely and correct. The University will send enrollment transmissions to the Campus IVY and make sure the reporting is submitted according to the following schedule to maintain compliance with federal regulations. The University makes sure the current NSLDS enrollment reporting applies its procedures in overseeing submissions to the NSLDS. Fall and Spring Semesters 1) First of Term: 30 days after the term start date 2) Subsequent of Term: 60 days after term start date 3) Subsequent of term: 90 days after term start date 4) End of Term: two weeks after term end date Summer Semesters 1) First of Term: one week after term start date 2) End of Term: two weeks after term end date Information is collected directly from the University Populi system and any adjustments are verified by the Registrar and Financial Aid Officer will send any adjustments electronically to the Campus IVY SURE Reporting Person Responsible for Corrective Action Plan: Sheng Wang, Chief Financial Officer Anticipated Date of Completion: June 30, 2023

The University will make sure the student enrollment status change notifies the Academics and Financial Aid officials in correct so that the officials review all students who withdraw during a germ are identified in timely manner and the refund calculation is correctly made in timely. The University have updated and modified Financial Aid department manual to reflect the changes made to ensure the followings: 1. Regularly (every 2nd and 4th Tuesdays of the month) running the report including the student?s enrollment status, number of units in progress, Program enrolled, Overall GPA, Last Day of Attendance and Attendance Rate. 2. A Physical copy of the JobForm for each Financial Aid student whose status has changed on Populi, which includes the name and date of who made that change and approval will be provided to the Financial Aid department for any necessary corrections. This physical copy would be filed in the student file in Academics and Financial Aid. 3. Create an internal record indicating the changes made regarding the students? enrollment status 4. Designate personnel monitoring and reporting any changes made to students? enrollment status. Person Responsible for Corrective Action Plan: Sheng Wang, Chief Financial Officer Anticipated Date of Completion: June 30, 2023

The institution has reinforced its R2T4 internal training program and continues to monitor module program withdrawals to detect and proceed promptly with any deviation to the application of the regulations for this purpose. Presently we have not found any further deficiencies in the application of the R2T4 module process and will continue to enforce our retraining program to capture any deficiency on time and to be confident that any new staff member with incidence in the calculation of this process is properly trained and validated by our internal control staff

Identifying Number: 2022-001 Finding: Transylvania University did not report 2 withdrawn students who ceased enrollment to the National Students Loan Database System (NSLDS) in a timely manner. Corrective Actions Taken or Planned: This issue occurred because unofficial withdrawals were processed over a period of time, rather than all at once following the completion of a term. The financial aid staff member lost track of which steps had been completed and which had not. In the future, when processing unofficial withdrawals and discovering additional information is needed from a faculty member to complete the process for one student, the university will complete the process in its entirety, including enrollment reporting, for each student as soon as all necessary information is present. Estimated Completion Date: February 28, 2023 Responsible Personnel: Jennifer Priest, Director of Financial Aid

Contact person(s) responsible for corrective action: Stephanny Elias, Associate Vice President of Financial Aid Robert Loconto, Director of Financial Aid June Koukol, Registrar Anticipated completion date: Interim revised notification process implemented and initiated February 8, 2023 Automated notification procedure in process by Registrar's Office and Tech Center and expect completion ready for testing by April 1, 2023 with final implementation by May 1, 2023. Corrective Action: To assure that all withdrawal/LOA applications are accounted for and reviewed for TIV refund calculation, the following plan has been agreed to between the Registrar's Office and Financial Aid. ? The Registrar's Office will run CWIS 1627 weekly, which provides a complete, cumulative list of all students who have filed a petition to withdraw/LOA along with students who have been manually entered into Banner by the Registrar's Office for their withdrawal/LOA's current status. CWIS 1627 will be emailed to the Director of Financial Aid (DFA) at robert.loconto@curry.edu weekly on Wednesday mornings ? The DF A will review the students on CWIS 1627 whose withdrawals/LOA have been processed against the official withdrawal/LOA notification email from the Registrar's Office. The DFA will contact the Registrar to review any students who are listed as processed on CWIS 1627 but there is no official withdrawal/LOA notification email ? The DFA will perform necessary Return to Title IV Calculation (R2T4) for impacted students ? DFA will adjust aid in Banner, accordingly, based on the results of the R2T4 ? Students will receive a revised award letter with cover letter explaining federal aid they were eligible to retain based on their withdrawal/LOA date The Registrar's Office is currently working with Curry's Tech Center to implement an automated process that will email Financial Aid with a student's name, id and official date of withdrawal or leave of absence when a withdrawal/LOA is finalized. The CWIS generated process conducted weekly by the Registrar will be in place until the automated notification process is in production.

2022-003 Student Financial Assistance Cluster ? Assistance Listing No. Various Recommendation: We recommend reviewing the components of the enrollment roster file to ensure the correct effective date is reported correctly for both the "Campus Level" and "Program Level". Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: In August 2021, the College hired a new Registrar who implemented changes to National Student Clearinghouse (NSC) reporting. These changes have been documented and include: 1) Review of error files received from the NSC related to degree verification. Update of student records based upon findings on error file. 2) Using additional report, diploma list, to manually check that graduating students are correctly reported to the NSC. 3) Strict adherence to deadlines contained in the College catalog regarding degree conferrals. 4) Increased communication between departments when student status changes occur between reporting dates. This response is the same as in the FY 2020-21 audit, to be completed by 6/30/22, the end of this audited period. While there were still issues found during the audit, the error rate decreased from 38.7% to 7.5% during FY 2021-22. Processes are still being refined to reduce the errors further. Name(s) of the contact person(s) responsible for corrective action: Michele Peterson Planned completion date for corrective action plan: 06/30/2023

Individuals Responsible for Corrective Action Plan Jeff Scaccia, CPA (Vice President for Finance and Administration) Libby Shull, CPA (Controller) April Baur, (Director of Student Financial Aid) For 1 of 21 students tested, student's Campus Level NSLDS records not found within NSLDS website. Corrective Action Plan: The Registrar?s Office revised its monthly processes and procedures guide to include better monitoring of any potential errors with NSLDS reporting. The Registrar submits an enrollment report on the 15th day of every month to the Clearinghouse. Once an email is received from the Clearinghouse allowing the Registrar to view any errors on the website, the Registrar will check the NSLDS portion of the website to see if any corrections are necessary. These procedures were followed in regard to the finding reported. The College is not aware of why the student?s record was not found within the NSDLS website however, it will be more diligent in its monitoring of this activity going forward. Anticipated Completion Date: March 1, 2023

Individuals Responsible for Corrective Action Plan Jeff Scaccia, CPA (Vice President for Finance and Administration) Libby Shull, CPA (Controller) April Baur, (Director of Student Financial Aid) For 27 of 40 students tested, per review of the COD screenshot provided by the client, the College did not report required Pell disbursements via the COD within 15 calendar days. Corrective Action Plan: It is a compliance requirement to report Pell files to the Department of Education through the COD system. 27 student files were identified as a compliance finding out of the 40 students sampled. This is a repeat finding from the prior year (June 30, 2021), but had not been an issue in previous audits. The Office of Financial Aid has experienced significant turnover in its staffing during fiscal years June 30, 2021 and 2022. This included employing two different Directors, the second of which vacated the position in June 2022. The staffing of the Financial Aid Office has since stabilized and the new Director has implemented practices whereby the office is now receiving and sending files to the COD system daily. This allows for resolving issues/rejects much sooner and within the 15-day timeframe. The Director has also conducted training with financial aid staff to emphasize the importance of sending files and resolving issues in a timely fashion. Anticipated Completion Date: August 31, 2022

Individuals Responsible for Corrective Action Plan Jeff Scaccia, CPA (Vice President for Finance and Administration) Libby Shull, CPA (Controller) April Baur, (Director of Student Financial Aid) Certain key line items within submitted FISAP report did not agree to source documentation. Corrective Action Plan: The College recognizes the importance of completing the FISAP in a timely and accurate manner. The Office of Financial Aid has experienced significant turnover in its staffing during fiscal years June 30, 2021 and 2022. This included employing two different Directors, the second of which vacated the position in June 2022. The staffing of the Financial Aid Office has since stabilized and the new Director assumed the role in August 2022 and has updated the procedures related to preparation of the FISAP report to ensure timely and accurate reporting. Anticipated Completion Date: March 1, 2023

Individuals Responsible for Corrective Action Plan Jeff Scaccia, CPA (Vice President for Finance and Administration) Libby Shull, CPA (Controller) April Baur, (Director of Student Financial Aid) For 1 of 40 students tested, refund was processed outside of the 14-day required time frame from initial date credit balance was created to date credit refund was paid back to the student. Corrective Action Plan: This finding relates to aid that was disbursed in January 2022. A miscommunication occurred between the Financial Aid Office and the Business Office, and the Student Accounts Manager was not made aware the aid had been disbursed and a refund was due to the student. As a result of a similar finding during the June 30, 2021 audit, the College changed its policy as of February 15, 2022. The Student Accounts Manager is now completing timely reviews of credit balances on student accounts and coordinating with the Financial Aid Office to expedite its review of the student?s financial aid to insure all FSA credit balances are refunded to students within the required timeframe. Anticipated Completion Date: February 15, 2022

Individuals Responsible for Corrective Action Plan Jeff Scaccia, CPA (Vice President for Finance and Administration) Libby Shull, CPA (Controller) April Baur, (Director of Student Financial Aid) For 1 of 2 students tested, the student was in V5 tracking group, his Identity/Statement of Educational Purpose form was signed and received as of 11/17/21 which is after first title IV disbursement. Per IFAP verification guide. "No disbursements of Title IV aid may be made until the V5 verification is satisfactorily completed." Corrective Action Plan: The College acknowledges institutions are required to verify applications selected by the Central Processing System for students who will receive or have received need based/subsidized student financial assistance. As permitted in federal regulations (34 CFR 668.54(b)), verification is not required for students who are only eligible for unsubsidized student financial assistance. Students in this situation are noted as ?Selected, not verified? to COD. At Presbyterian College, graduate and professional students only receive unsubsidized federal financial assistance, so only those selected in the ?V4? and ?V5? verification groups are required to complete the verification requirements of these groups. The Office of Financial Aid has experienced significant turnover in its staffing during fiscal years June 30, 2021 and 2022. This included employing two different Directors, the second of which vacated the position in June 2022. The staffing of the Financial Aid Office has since stabilized and the new Director has implemented procedures for the 2023-2024 academic year through Banner (software) setup that prevents disbursement of federal aid with any outstanding fund or non-fund requirements. Any student with V1, V4, or V5 set on the ISIR will automatically populate outstanding requirements. Aid will not disburse until those are fully satisfied. Anticipated Completion Date: March 1, 2023

Management concurs with the finding and recommendations. Isabella Graham Hart School of Nursing (the School) has revised its Enrollment Status Reporting procedures and provided training to ensure changes are submitted and reported on time. The above procedures have been implemented.

Management concurs with the finding and recommendations. Isabella Graham Hart School of Nursing (the School) recognizes that our Student Information System (SIS) used to monitor and manage the credit balances for students is limited in its capabilities. We are in process of implementing a new SIS that has ability to perform the necessary requirements to ensure we are processing any credit balance within the required time permitted. The School has implemented a weekly process of monitoring credit balances through the utilization of a Credit report, along with issuing payments if needed on a weekly basis to students. Implementation of the new SIS in expected to be completed in 2024 and in the interim have begun a weekly manual monitoring process.

2022-005 - Enrollment Reporting Federal Pell Grant Program; Federal Direct Student Loans - Assistance Listing No. 84.063, 84.268 Recommendation: We recommend the University evaluate its procedures and review policies in overseeing submissions to the NSLDS completed by the third-party servicer. Additionally, we recommend the University review its policies and procedures on reporting enrollment and program information to the NSLDS to ensure that all relevant information is being captured and reported timely in accordance with applicable regulations. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Felician University has evaluated and updated our procedures in overseeing submission to NSLDS and notified the appropriate staff. Management will monitor this issue regularly during the year to ensure compliance. Name(s) of the contact person(s) responsible for corrective action: Cynthia Montalvo, Assistant Vice President of Enrollment Planned completion date for corrective action plan: March 1, 2023

From: Daniel Ayala, District Director Center of Student Information Subject: Corrective Action Plan for Audit Finding 2022-001 Finding 2022-001: Enrollment Reporting Submissions for Graduates Views of Responsible Officials and Planned Corrective Actions Due to a changes in record processing and the addition of a new audit report at the National Student Clearinghouse (NSC), additional steps were needed at the institutional level to guarantee the accurate reporting of student graduation status. To ensure correct and comprehensive reporting of students as ?graduated?, the Alamo Colleges District Center for Student Information (CSI) has implemented a three step process: 1) submitting a sixth submission audit per semester (recommended by NSC) which will provide graduated student information to NSC; 2) review of the DegreeVerify exceptions report each semester to identify any needed corrections and/or updates to report to NSC; and 3) completion and review of these processes will be done by a CSI Enrollment Service Professional and CSI Director and documented (signed off) on the monthly compliance certificate form. With these processes in place, CSI will be in line with NSC recommendations and allow the National Student Loan Data System (NSLDS) to align with correct graduation dates. At this time, all needed corrections to student ?graduated? status have been completed. Implementation Date: November 2022 Responsible Persons: Dr. Adelina S. Silva, Vice Chancellor of Student Success;

Federal Program Title: Student Financial Aid Cluster (SFA) ALN Number: 84.007, 84.038, 84.063, 84.268, and 84.379 Recommendation: We recommend that the SFA department work with the campus registrar?s office to develop an alternative process that will enable the student financial aid office to review and correct the last dates of attendance and enrollment status prior to being reported to the Clearinghouse. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned/taken in response to finding: The student financial aid director will coordinate with the registrar to implement a process by which the student financial aid director can review and edit student enrollment effective dates prior to the data being sent to NSLDS. Name(s) of the contact person(s) responsible for corrective action: David Fisher, dlfisher@neo.edu Planned completion date for corrective action plan: June 30, 2023

Federal Program Title: Student Financial Aid Cluster (SFA) ALN Number: 84.007, 84.038, 84.063, 84.268, and 84.379 Recommendation: CLA recommends the institution review student activity logs in Canvas when determining an online student?s last date of attendance. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned/taken in response to finding: Students in the sample have had their records updated to reflect the correct enrollment effective date in NSLDS. Going forward, professors and the student financial aid department will review online course attendance when determining the last date of attendance for online courses. Name(s) of the contact person(s) responsible for corrective action: David Fisher, dlfisher@neo.edu Planned completion date for corrective action plan: June 30, 2023