Corrective Action Plans

FINDING 2022-003 ? Subsidized Loan Allocation Condition Found: The amount of Subsidized and Unsubsidized Federal Direct Loans awarded was incorrect for one of the fifty-four students in our sample that received Federal Direct Loans. Corrective Action Plan: The Financial Aid Director updated reallocated $1,407 of unsubsidized loan funds as subsidized loan funds on August 3, 2022. Procedures will be improved to ensure that subsidized loan eligibility is reviewed before awarding unsubsidized loans. Anticipated Completion Date: The corrective action was completed on August 3, 2022. Contact Person Tirzah Knight, Director of Financial Aid 918-335-6252

FINDING 2022-002 ? Federal Direct Loan Exit Interview Condition Found: A Federal Direct Loan exit interview was not completed by nor were instructions sent to the student on how to complete an exit interview when the student graduated from the University. This omission occurred for one of the sixty students in our sample. Corrective Action Plan: Federal Direct Loan exit interview information was sent to the student in question on August 3, 2022. Procedures will be improved to ensure Federal Direct Loan exit interviews are completed or information is sent to students when they cease enrollment at the University. Anticipated Completion Date: The corrective action was completed on August 3, 2022. Contact Person Tirzah Knight, Director of Financial Aid 918-335-6252

FINDING 2022-001 ? NSLDS Reporting Condition Found: The incorrect last date of attendance was reported to the National Student Loan Database System (?NSLDS?) incorrectly for two of the sixty students selected for testing. Corrective Action Plan: The Financial Aid Director updated the withdrawal dates in NSLDS for the student in question on August 3, 2022. Procedures will be improved to ensure that the correct withdrawal date is reported in NSLDS. Anticipated Completion Date: The corrective action was completed on August 3, 2022. Contact Person Tirzah Knight, Director of Financial Aid 918-335-6252

Finding 2022-001 - U.S. Department of Education (USDE). Title IV Student Financial Aid Programs (material weakness}: We observed the following conditions in connection with our testing of the various U.S. Department of Education, Title IV, Student Financial Assistance Programs. a. Three (3) out of 60 students tested had missing official transcripts with total questioned costs of $36,516. b. Twelve (12) out of 26 students tested did not have refunds given to students within the required 14 days. c. Two (2) out of six (6) students tested for R2T4 did not have Title IV funds returned to the Federal government within the required 45 days. The University should implement corrective actions to ensure that the above findings are resolved and will nor recur in future periods. Corrective Action - The College concurs with the finding. The College continues to be challenged with finding qualified staff in the Financial Aid Office and Business Office. The College will be working closely with staffing companies to identify qualified personnel. The College is working diligently to ensure all positions are filled to ensure compliance with all federal and state regulations. We understand the seriousness of these findings and implementing appropriate strategies to minimize and/or eliminatefurther auditfindings. TheCollege plans to start implementing these strategies beginning July 1, 2023.

Finding 2022-001 - U.S. Department of Education (USDE}, Title IV Student Financial Aid Programs (Significant Deficiency): We observed the following conditions in connection with our testing of the various U. S. Department of Education, Title IV, Student Financial Assistance Programs: ? Title IV awards for six (6) of twelve (12) students sampled for Return of Title IV (R2T4) did not have funding returned within the required 45-day time frame with total questioned costs of $18,768. ? The College had differences in the following programs which were not reconciled to the general ledger: Program Description Federal Work-Study Federal Direct Student Loans ? FISAP Work-Study totals did not match general ledger totals. Recommendation - We recommend the College implement corrective actions to ensure the above findings are resolved and do not recur in future periods. Moreover, internal controls over compliance with Federal program regulations should be revisited to ensure adequate supervisory controls, quality assurance reviews of compliance steps, technical training of staff, and adequate procedures are being followed for compliance purposes. Corrective Action - The Office of Financial Aid understands the seriousness of these findings and are implementing appropriate strategies to minimize and/or eliminate further audit findings, including: ? Conduct monthly reconciliations between the Business and Financial Aid Offices reviewed and approved by the Vice President of Finance and Administration. ? Provide specialized Title IV training for the Financial Aid staff through resources and services provided by our auditors, The Wesley Peachtree Group, CPAs to improve and ensure processes align with federal reporting guidelines.

Finding 2021-002 ? U.S. Department of Education (USDE), Title IV Student Financial Assistance Programs (Significant Deficiencies): We observed the following condition in connection with our testing of the various U. S. Department of Education, Title IV, Student Financial Assistance Programs: a) Two (2) out of 60 students selected for R2T4 testing did not have his/her funds returned to the U.S. Department of Education within the required 45 days. b) The College had differences in the following programs which were not reconciled to the general ledger: Federal Work Study, Federal Pell Grant, Federal Direct Student Loans and Federal Supplemental Educational Opportunity Grant (SEOG). Recommendation: The College should implement corrective actions to ensure that the above findings are resolved and does not recur in future periods. Moreover, internal controls over compliance with federal program regulations should be revisited to ensure adequate supervisory controls, quality assurance reviews of compliance steps, technical training of staff, and adequate procedures are being followed for compliance purposes. Corrective Action ? a) The two (2) students cited were oversights and the R2T4 funds have been returned. Official Withdrawal Notifications are scheduled bi-weekly, and the Unofficial Notifications are scheduled for the end of the semester. b) As previously mentioned, the College experienced significant turnover in the Business Office, responsible for the reconciliations, during 2022. We are in the process of replacing staff and recently hired a new CFO. The required reconciliations will be completed on a timely basis going forward.

(Significant Deficiency) We observed the following conditions in connection with our testing of the various U. S. Department of Education, Title IV, Student Financial Assistance Programs: 1. Enrollment status reporting to NSLDS for four (4) students tested was not provided as required by Federal regulations. 2. The Center did not provide the Common Origination and Disbursement (COD) funding report for the entire 2021-2022 award year for Federal Direct Loans. As of the report date, the Center had requested it from the U.S. Department of Education. Recommendation ? The Center should implement corrective actions to ensure that the above findings are resolved and do not recur in future periods. Moreover, internal controls over compliance with federal program regulations should be revisited to ensure adequate supervisory controls, quality assurance reviews of compliance steps, technical training of staff, and adequate procedures are being followed for compliance purposes. Corrective Action ? The enrollment information was provided to the FA auditor and several inquiries were made for verification and no timely response was received from the FA auditor. Three versions of the COD reports were provided along with several inquiries for confirmation that the report is what was needed. No timely response was made to our request. Management further explained that it takes 24 hrs. to receive the revised report if what was submitted was not what was needed, again no timely response from the FA auditor.

Finding 2022-006: Material Weakness - Federal Direct Student Loan Enrollment Reporting Repeat of Prior Year Finding 2021-004 Condition: For 12 students tested, the incorrect enrollment status was reported to the National Student Loan Data System (NSLDS). For 21 students tested, the effective date of the change of enrollment status that was reported to NSLDS did not match the University's records. For 11 students tested, the change of enrollment status was not reported within the 60 day requirement. For 6 students tested, in the program-level record, the student's program begin date that was reported to NSLDS did not match the University's records. For 9 students tested, in the program-level record, the program length reported to NSLDS did not match the University's records. For 1 student tested, in the program-level record, the program the student was enrolled in, and the related Classification of Instructional Programs (CIP) code, reported to NSLDS did not match the University's records. Corrective Action: Briar Cliff will work with Ellucian on a review of the setup and processes that the Registrar's Office currently follows and we will work with Ellucian for recommendations on implementing a process/procedure that ensures the Registrar's Office has been trained and is in compliance. Person Responsible for Corrective Action: Matt Thomsen VP of Enrollment; Todd Knealing VP of Academic Affairs Anticipated Completion Date: 8/1/2023

Finding 2022-005: Perkins Loan Recordkeeping and Record Retention Condition: For 1 borrower selected for testing, the University was unable to locate the original signed MPN. Corrective Action: Briar Cliff University has maintained all records related to Perkins loan, even though these loans have been discontinued since September 2017. The University has no intentions to delete or remove any documents until the time is appropriate. The current staff unfortunately was not employed when these records were originally collected or reviewed. Person Responsible for Corrective Action: Ann M. Oatman - Interim VP of Finance Anticipated Completion Date: 4/1/2023

Finding 2022-004: Significant Deficiency - Return of Title IV Funds Calculations Condition: For 3 students selected for testing, the amount of the title IV refund was calculated incorrectly. Corrective Action: The errors were made because the incorrect terms dates were entered into Colleague by the Registrar's Office. Moving forward, the Financial Aid office will work with the Registrar's Office to ensure the term dates are entered correctly in Colleague. After the Registrar's Office enters the term dates in Colleague, the Associate Vice President of Student Financial Systems will review the entries for accuracy. Person Responsible for Corrective Action: Matt Thomsen - VP of Enrollment; Todd Knealing VP of Academic Affairs Anticipated Completion Date: 8/1/2023

Finding 2022-002 - U.S. Department of Education (USDE). Title IV Student Financial Aid Programs: We observed the folfowing conditions in connection with our testing of the various U.S. Department of Education, Title IV, Student Financial Assistance Programs. ? We noted in our testing that one (1) out of twenty-five (25) students selected for R2T4 testing did not have his/herfunds returned to the U.S. Department of Education within the required 45 days. Corrective Action - Management concurs with observation. The College has implemented corrective actions to ensure that the above finding is resolved and will not recur in future periods.

Finding 2022-002 - U.S. Department of Education (USDEJ. Title IV Student Financial Aid Programs (deficiency}: We observed the following conditions in connection with our testing of the various U.S. Department of Education, Title IV, Student Financial Assistance Programs: 1. One (1) out of 10 students tested did not have timely or accurate enrollment reporting to the National Student Loan Data System (NSLDS). 2. One (1) out of 60 students tested was overpaid Pell funds. The over awarded funds were subsequently returned. 3. One (1) out of 60 students tested was not eligible for but was awarded Federal Supplemental Educational Opportunity Grant (FSEOG). The University subsequently returned the ineligible grant amount. 4. One (1) out of 60 students tested showed a discrepancy during verification testing where we observed tax documents submitted with an incorrect social security number. The questioned cost is $5,195. 5. Two (2) out of Five (S) students tested did not show the returned amount on the student's statement of account during R2T4 testing. Both statements of account were subsequently updated with the returned amounts. Corrective Actions - 1. NSLDS reporting is actively reconciled monthly with our financial aid servicer and, as of August 18, 2022, the University confirmed 97.18% reported. The University will continue to actively monitor this reporting to ensure accuracy and timeliness. 2. The University will monitor and review the process of enrollment more thoroughly with the third-party financial aid processor to ensure all non-enrolled students are not included in payment batches. The University has moved to a new third-party financial aid processor in a further effort to ensure compliance with Title IV regulations. 3. The University will monitor and review the process of enrollment more thoroughly with the third-party financial aid processor to ensure all non-enrolled students are not included in payment batches. The University has moved to a new third-party financial aid processor in a further effort to ensure compliance with Title IV regulations. 4. The University will monitor and review the process of verification more thoroughly with the third-party financial aid processor to ensure all applicable steps are taken and that all information is accurate. The University has moved to a new third-party financial aid processor in a further effort to ensure compliance with Title IV regulations. 5. The University has implemented a new student information system, as well as processes to ensure that Title IV transactions are applied timely to student ledgers. The University also notes that, in the case of this finding, the Title IV funds were returned timely and accurately.

Finding 2022-001 U S DOE Title IV Student Financial Aid Programs (significant deficiency): The auditors observed the following conditions in connection with our testing of the various U.S. Department of Education, Title IV, Student Financial Assistance Programs. a) One (1) out of six (6) student files tested did not have their Title IV funds returned within the required 45 days. b) Two (2) out of sixty (60) student files tested did not have their refund issued within the required 14 days. The college should implement corrective actions to ensure that the above findings are resolved and will not reoccur in future periods. The College?s Corrective Plan: (a) The College accepts the auditor?s recommendation. The College?s Registrars Office and Financial Aid Office will coordinate and communicate relating to student enrollment to ensure that information is reported timely. (b) The College accepts the auditor?s recommendation. The Business Office has reviewed its information retrieval process to ensure that the correct parameters are being used for information retrieval purposes

A. Comments on Findings and Recommendations: We agree with the finding and recommendation. B. Actions Taken or Planned: By November, the Vice President of Financial Aid will update the Withdrawal Checklist to include a final enrollment field to notate the number of hours enrolled. The Withdrawal Checklist will also include a checkbox to notate that all financial aid has been updated to the proper enrollment status prior to completing the R2T4 calculation.

Finding 2022-001 ? U.S. Department of Education (USDE), Title IV Student Financial Aid Programs (Significant Deficiency): We observed the following conditions in connection with our testing of the various U.S. Department of Education, Title IV, Student Financial Assistance Programs. ? Two (2) out of five (5) students tested for R2T4 calculations and refunds did not have funds returned back to the U.S. Department of Education within the required 45 days. Auditor?s Recommendation ? The University should implement corrective actions to ensure that the above finding is resolved and will not recur in future periods. Corrective Action ? With regard to the return of funds back to the U.S. Department of Education, employee turnover at the University caused this delay. The University returned all funds as required and is currently filling positions with competent employees to handle these processes.

Name of Responsible Individual: Melanie Mason, Director of Student Financial Aid Corrective Action: In the event any future award requires separate reporting on the FISAP, these awards will receive unique award codes in our Colleague system. During the process of developing the FISAP report, the Director of Financial Aid will generate Colleague reports to identify these awards and include in the report. Award totals per code will be validated by the Office of Finance for the University. Anticipated Completion Date: September 30, 2023

Name of Responsible Individual: Melanie Mason, Director of Student Financial Aid Corrective Action: The University will transition from a manual review process to an automated electronic process utilizing a combination of both Informer and Colleague reports. The process will compare components of the Cost of Attendance to the student?s current billing as of the census date. Each Financial Aid counselor will run the automated report for their students and freeze each student?s award budget. This freeze process will prevent any further changes to the award budget for the student. Confirmation of this review will be provided to the Director of Financial Aid by each counselor. The Director will verify the process has been completed. Anticipated Completion Date: March 31, 2023

Description of Finding: There was a sample of forty (40) students for which enrollment changes were reported to NSLDS. There was one (1) instance where the student information was rejected, and for which a correction was not made within the required 10 days. Corrective Action Plan: Uploads to the National Student Clearinghouse are now reviewed through a report which performs a pre-check for common errors in an effort to reduce the number of enrollment errors overall. The reject reports are monitored with every upload and are managed using the outlined best practices from the National Student Clearinghouse directly. The reject reports are managed within 10 days of receipt with any changes captured within the same timeframe. The responsible parties are Adam Evans at aevans@laverne.edu. This will be corrected by July 1, 2023.

2022-003 Student Financial Assistance Cluster ? Assistance Listing No. 84.038 Recommendation: We recommend the University evaluate its procedures around the retention of Perkins loans records to ensure that all records for open loans are being properly maintained. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The University will continue to identify open loan records with missing master promissory notes. As such loan records are identified, the University will take necessary measures to request permission to assign these loans to the Department of Education. As this work is ongoing, all current loan records will continue to be stored securely in the Bursar?s area. Name(s) of the contact person(s) responsible for corrective action: Rita Lambert, Bursar Planned completion date for corrective action plan: August 31, 2023

2022-004 Student Financial Assistance Cluster ? Assistance Listing No. 84.268 Recommendation: We recommend the University review all R2T4 calculations to ensure the correct net disbursed amounts are entered for all Title IV aid. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Office of Financial Aid will recalculate the R2T4 with the correct net disbursement amount and request the additional funding directly through COD. Going forward, the Office of Financial Aid will perform a secondary review of all R2T4 calculations prior to processing for accuracy. Name(s) of the contact person(s) responsible for corrective action: Robert Forest, Director of Financial Aid Planned completion date for corrective action plan: March 30, 2023

2022-002 Student Financial Assistance Cluster ? Assistance Listing No. 84.063, 84.268 Recommendation: We recommend the University review its policies and procedures to ensure accurate effective dates are reported in both the campus and program level records submitted to the NSLDS. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Registrar?s Office will review National Student Clearinghouse (NSC) information following transmission, particularly for effective dates of completely withdrawn students. The NSC reports enrollments to NSLDS for the University. Name(s) of the contact person(s) responsible for corrective action: Gerard J. Donahue, Registrar Planned completion date for corrective action plan: June 30, 2023

Finding number: 2022-001 Federal agency: U.S. Department of Education Programs: Student Financial Assistance Cluster CFDA #: 84.007, 84.033, 84.038, 84.063, 84.268 Award year:2022 Corrective Action Plan: An external consultant (Higher Education Assistance Group) was contracted to bring current NVU?s required reporting for enrollment and student program status changes through the Spring 2022 term. This work was complete September 9. Letters/Notifications were issued to United Educators (August 10) and impacted students (week of September 5). Ongoing, NVU has received support from the registrar at our sister institution Community College of Vermont (CCV). CCV?s registrar has coordinated with the National Student Clearinghouse and submitted the first of term enrollment file for Fall 2022 on 10/3/22. NVU plans to hire a registrar soon and ongoing enrollment reporting will fall within the responsibilities of this new hire. Additionally, the Vermont State Colleges System registrar team will perform monthly checks to confirm that enrollment reporting for NVU has been completed. Timeline for Implementation of Corrective Action Plan: September 2022 Contact Person Sharron Scott, CFO

Audit Firm: J&J CPA LLC Certified Public Accountants & Consultants Audit Period: October 1 2021 to September 30 2022 Finding No: 2022-002: CFDA No: 84.063 Program Name: Pell Grant Compliance Requirement: Disbursements ? Over award / Inaccurate recordkeeping Criteria According to Federal Register (86 FR 33245) an institution must submit Pell Grant, Iraq and Afghanistan Service Grant, Direct Loan, and TEACH Grant disbursement records to COD, no later than 15 days after making the disbursement or becoming aware of the need to adjust a previously reported disbursement. Cause Disbursements were originally authorized, processed and registered correctly on the student?s ledger; however, apparently the student had used portion of the same award year in another university resulting in an automatic system adjustment. Even though disbursements were requested and approved yet again the Finance Office was involuntary not notified of what had happened and of the new disbursement date. Recommendation The Institution must reinforce disbursement control procedures to ensure that COD and Institution?s disbursement records match. Such a procedure could be to perform weekly examination of disbursement and trace dates between COD and student?s ledger. Management Response and Corrective Action Plan The finding has been detected and the institution has already established all the necessary measurements to assure that the Title IV Office is following all the policies and regulations that rule the Pell Grant Program. Recommendation from the auditor will be taken and the institution will perform weekly examinations of the disbursements tracing dates between the COD system and the student?s ledger ensuring that all disbursements are correctly posted and that it accurately shows all the activity performed on the COD system.

Audit Firm: J&J CPA LLC Certified Public Accountants & Consultants Audit Period: October 1 2021 to September 30 2022 Finding No: 2022-001: CFDA No: 84.063 Program Name: Pell Grant Compliance Requirement: Disbursements ? Reporting disbursements within 15 days and inaccurate recordkeeping Criteria According to 34 CFR 668.164 an institution must disburse during the current payment period the amount of title IV, HEA program funds that a student enrolled at the institution, or the student?s parent, is eligible to receive for that payment period. Cause Both disbursements were made on the same date; however, inadvertently the correct steps were not performed in ED Express in order for the return to be processed. Recommendation The Institution must reinforce disbursement control procedures to ensure that all disbursements are correctly posted and the amounts between COD and student?s ledger are a match. Management Response and Corrective Action Plan The finding has been detected and the institution has already established all the necessary measurements to assure that the Title IV Office is following all the policies and regulations that rule the Pell Grant Program. The monthly evaluation, verification and reconciliation will include an internal audit performed by another office responsible for comparing the COD system with the student ledger to reinforce the actual disbursement control procedures ensuring that all disbursements are correctly posted and that the student?s ledger correctly shows all the activity performed on the COD system. The institution already refunded the questioned cost of $3,247.50

2022-Single Audit 01 Department of Social Services Title IV-E Adoption Assistance A sample of 40 children that received Title IV-E adoption subsidies during FY2022 was tested for compliance with the above criteria and the observations were noted below. ? 40 out of 40 children - Met the eligibility requirements, had special needs that prevented them from being placed without a subsidy, and could not return home. ? 40 out of 40 children - RDSS made reasonable efforts to place the children without the subsidy or waived the requirement as it was not in the best interest of the child. ? 40 out of 40 children ? The adoption assistance agreements were signed prior to the final adoption decree, the authorized amounts were in line with the State?s rates, and payments were issued in accordance with the agreements. ? 9 out of 40 children ? Sufficient evidence of the completion of the required criminal background and child abuse and neglect registry checks for the adoptive parents and adult household members was not in the adoption case files. The home studies and report of investigations narrative indicated the required checks were completed for the adoptive parents and household members but did not identify when they occurred. Also, in some cases, it was not noted if the adoptive parents met the eligibility requirements for the criminal record checks. As such, the auditors were unable to confirm when the checks occurred, and supporting documentation was not provided prior to the completion of fieldwork. In addition, during the initial file review, documents such as court orders, negotiation documents, and annual affidavits were missing from some of the files. The Adoption Unit was ultimately able to retrieve and provide the missing items. However, an opportunity exists to improve the adoption case file documentation. Recommendations: ? We recommend that the Children, Families, and Adults (CFA) Deputy Director develop and implement a quality control process to ensure that the required documentation is maintained in the adoption case files. ? We recommend that the CFA Deputy Director develop and implement standard documentation requirements for documenting the completion of the background checks in the adoption case files. Explanation of disagreement with audit finding: n/a ? no disagreement Action planned/taken in response to finding: Audit Recommendation: We recommend that the Children, Families, and Adults (CFA) Deputy Director develop and implement a quality control process to ensure that the required documentation is maintained in the adoption case files. RDSS Corrective Action Plan: The Reunification and Permanency Program Manager or designee will conduct quarterly adoption case reviews using the VDSS Guidance Section 3.9.3 - Adoption Records. The quarterly case sample represents 10% of the case and all cases will be reviewed at least once annually. Any findings will be documented to include corrective actions, person responsible and timeframe for correction. The Reunification and Permanency Program Manager or designee will review cases to confirm corrections. Audit Recommendation: We recommend that the CFA Deputy Director develop and implement standard documentation requirements for documenting the completion of the background checks in the adoption case files. RDSS Corrective Action Plan: All RDSS Adoptions files must include the VDSS Adoption File Checklist and the child?s adoptive family documentation. The required adoptive parent documentation includes: o Criminal Background Check Results - Licensed Child Placing Agencies ( Non-Conviction and/or Conviction Letter); Local Department of Social Services (Office of Background Investigations Determination Letter) o Sworn Statement of Affirmation o Child Abuse and Neglect Central Registry Check results for adoptive parent and adult household members. The Adoption and Resource Families Supervisors are responsible for monitoring compliance with documentation requirements for completion of the background checks, including insuring that documentation is requested from child ?placing agencies and third parties. Standard documentation requirements regarding background checks will be included in the quarterly review by the Reunification and Permanency Program Manager or designee. Name(s) of the contact person(s) responsible for corrective action: Brinette Jones, Deputy Director, Division Children, Families and Adults Lavinia Hopkins, Reunification and Permanency Program Manger Planned completion date for corrective action plan: Ongoing, beginning 2nd quarter 2023 If there are any questions regarding this plan, please contact Brinette Jones at (804) 646-4543.