Corrective Action Plans

FINDING 2022-001 - Specials Tests and Provisions - Enrollment Reporting - Significant Deficiency in Internal Control over Compliance. Response: Cal Lutheran concurs with the exception of one student for whom a permanent address change was not reported within the required timeframe. After investigation, it was determined that the selection criteria for data extraction required adjustment to ensure all students were included in the data extraction and reporting process. Corrective Action Plan: Maria Kohnke, Associate Vice President of Academic Services & Registrar, modified the selection criteria for the data extraction process in the Colleague system to ensure all permanent address changes are extracted and submitted for all students as required. The Associate Registrar is responsible for reviewing and modifying the selection criteria for the data extraction process at the beginning of each year and at each change in criteria. The criterion will be reviewed and approved by the Associate Vice President of Academic Services & Registrar when changes are made. Responsible person: Maria Kohnke. Date of expected correction: September 1, 2022.

Finding 2022-002: National Student Loan Data System (NSLDS) Enrollment Reporting Corrective Action Plan: We concur with the auditor?s finding. We have reviewed our processes related to the enrollment reporting of withdrawing students. The student affairs department will receive training on the requirements related to status change effective dates in accordance with the Department of Education regulations. In addition, the financial aid department and the registrar?s office are working together to confirm student rosters to verify that enrollment reporting is timely and accurate. Contact Person Responsible for Corrective Action: Shana Meyer, VP for Student Affairs; Andy Olsen, Director of Financial Aid; Rhianna Reed, Assistant Registrar Anticipated Completion Date: Corrective action is in progress as of August and will be completed by December.

Finding 2022-001: Federal Pell Grant Over-awards Corrective Action Plan: We concur with the auditor?s finding. We have reviewed our processes related to verifications and have established a review procedure to catch errors. A second person will be reviewing all verification adjustments to ensure accuracy. We are also adding a step to our Pell reconciliation process to verify that the Pell awarded to the student is the same as the amount approved by the Department of Education. Contact Person Responsible for Corrective Action: Andy Olsen, Director of Financial Aid Anticipated Completion Date: Corrective action was completed in September.

Finding 2022-003: Perkin?s Loan Recordkeeping and Record Retention Corrective Action Plan: We concur with the auditor?s finding. We have reviewed our filing processes to ensure that loan files are maintained in an organized manner so all files can be located as needed. The missing file is paid in full. Contact Person Responsible for Corrective Action: Carol Summervill, VP for Finance Anticipated Completion Date: Corrective action was completed in October.

A. Incorrect Calculation of Return of Title IV Funds The student in question has an unusual circumstance because the college canceled the last enrolled class. The student was correctly identified as a withdrawal through an external student information system (SIS) query designed to identify students with unusual circumstances not currently identified by the R2T4 program. Unfortunately, the R2T4 worksheet was not manually added to the SIS due to an inadvertent oversight. We believe this is an isolated incident, but in order to automate the manual process, CFAU requested the Office of Information Technology to incorporate the external query logic into the R2T4 program. The worksheet has been manually added. Note that the internal controls have been substantially strengthened which has reduced the number of students impacted year-over-year. B. Untimely Notification of Grant Overpayment to Students and Secretary The college inadvertently failed to report the student overpayment to NSDLS timely. Due to SIS communication limitations with this last batch for the summer 2022 term, the District was unable to send the notification through SIS and had to send the R2T4 OP notification outside of SIS manually resulting in the late notification. C. Distance Education Courses ? Lack of Formal Process to Determine Accuracy of Student Withdrawal Date With regards to student withdrawal dates as it relates to DE courses, the District will provide communications to all faculty throughout the semester instructing them to assess individual student participation in the class and to exclude students from the class if prior to exclusion deadlines, or drop students if exclusion deadlines have passed. The communications will refer to the Academic Senate guidelines on regular and substantive interaction and use of authentic assessments to ensure that active participation is being effectively evaluated. Communications will be times around core deadlines for enrollment and financial aid processes. The DE Coordinators will be informed of the new standard to supplement the existing required and optional trainings currently provided to teaching faculty. This process will be implemented in Fall 2022. Personnel responsible for implementation: Steve Giorgi Position of responsible personnel: CFAU Financial Aid Manager Expected Date of Implementation: Fall 2022

The District has already developed an automated summer Pell solution. The solution has been tested by the field and Central Financial Aid Unit (CFAU) and will be implemented Summer 2023. Personnel responsible for implementation: Steve Giorgi Position of responsible personnel: CFAU Financial Aid Manager Expected date of Implementation: Summer 2023

Return of Title IV (R2T4) Calculations Planned Corrective Action: The College is now taking additional steps to check R2T4 calculations. While our 3rd party servicer processes R2T4's, our Student Finance Clerk has been trained in this process as well. The Student Finance Clerk will complete the R2T4 internally, and then compare to confirm that dates and calculations match before refunds are completed. There is also an internal countdown between the Registrar and the Student Finance Clerk that tracks withdrawals and the days remaining until R2T4 needs to be completed. Person Responsible for Corrective Action Plan: Lyndsi Romero, Director of Financial Aid Anticipated Date of Completion: June 30, 2023

Finding 2022-003: Internal Control Deficiency Reporting Federal Grantor: United States Department of Health and Human Services Assistance Listing No.: 93.048, Special Programs for the Aging, Title IV, and Title II, Discretionary Projects Summary of Finding: There are no internal controls in place to ensure that reports that are submitted are complete and accurate. The same individual that prepares the SF-425 report, is the same person that reviews and submits the reports. Corrective Action Plan: Internal controls will be implemented to ensure that once the SF-425 report is completed, someone from the accounting department will verify funds being reported are correct and appropriate. Documentation will be maintained to support the review process. Responsible Party: Sonja Landry, Executive Director Anticipated Completion Date: December 31, 2023

Finding 2022-001: Internal Control Deficiency over Activities Allowed/Allowable Costs and Period of Performance Federal Grantor: United States Department of Health and Human Services Assistance Listing No.: 93.048, Special Programs for the Aging, Title IV, and Title II, Discretionary Projects Summary of Finding: Management did not have adequately designed internal controls in place over expenses charged to the federal program. Corrective Action Plan: Internal controls will be implemented to ensure expenditures are appropriately reviewed and approved prior to entering into the expenditure or requesting reimbursement from the federal program. Documentation will be maintained to support that expenditures were reviewed for appropriate period of performance. Management will ensure all duties are appropriately segregated. Responsible Party: Sonja Landry, Executive Director Anticipated Completion Date: December 31, 2023

Finding Number: 2022-003 Common Origination and Disbursement (COD) Dates Not Reflecting Actual Disbursement Dates Planned Corrective Action: date FA office will verify that disbursement date in COD matches the disbursement date on the student account. Person Responsible for Corrective Action Plan: Jean Claude St. Juste, Financial Aid Administrator Anticipated Date of Completion: Immediate

Finding Number: 2022-002 Incorrect Enrollment Reporting to National Student Loan Data System (NSLDS) Planned Corrective Action: Change the academic software set up to more accurately reflect the last date of attendance for DCC Online classes by adding the last date possible for the student to attend at the end of the last week (rather than the beginning of the week only). And, once the term has ended, exit anyone who has not registered (or pre-registered) for the next semester within two weeks of the end of the term. Person Responsible for Corrective Action Plan: Crystal Laidacker, Registrar Anticipated Date of Completion: Immediate

Finding Number: 2022-001 Return of Title IV (R2T4) Calculations Planned Corrective Action: FA Office will review the timing of the withdrawal to verify if the student earned 100% of the disbursed aid. Person Responsible for Corrective Action Plan: Jean Claude St. Juste, Financial Aid Administrator Anticipated Date of Completion: Immediate

Federal Program: ALN 14.218 ? U.S. Department of Housing and Urban Development (HUD) ? Community Development Block Grant (CDBG) ? Entitlement Grants Cluster, CFDA 14.239 - U.S. Department of Housing and Urban Development (HUD) ? HOME Investment Partnership (HOME), CFDA 93.563 ? Title IV-D, U.S. Department of Health, and Human Service - Child Support Enforcement (CSE) Condition per Auditor: Controls in place were not adequate to ensure compliance with 2 CFR 200 Appendix V submission requirements for its self-insurance cost allocation process and annual chargeback plan. Planned Corrective Action: Management agrees and will submit subsequent plans to federal cognizant agency as required by 2 CFR 200. Anticipated Completion Date: 4/30/2023 Responsible Contact Person: Jake Bower and Shauntika Bullard

2022-004 ? Enrollment Reporting Cluster: Student Financial Assistance Sponsoring Agency: Department of Education Award Names: Federal Pell Grant Program and Federal Direct Student Loans Award Numbers: Not applicable Assistance Listing Titles: Federal Pell Grant Program and Federal Direct Student Loans Assistance Listing Numbers: 84.063 and 84.268 Award Year: 2021-2022 Pass-through entity: Not applicable Campus 1 The mismatch between the enrollment effective dates on the campus-level and program-level reports identified by PwC auditors occurred due to a bug in the Campus Solutions system during the calculation of enrollment status change dates. The campus-level status date was sometimes incorrectly set as blank, which was then set to the term start date by NSLDS import process. As of September 14, 2022, the Office of the Registrar has modified the program that creates the NSLDS data file to correct the blank status dates, removing the mismatches that were found by PwC auditors. This ensures that the campus-level and program-level effective dates match. Campus 2 Historically, reporting to the National Student Clearinghouse (the ?Clearinghouse?) of students? enrollment status, e.g., full-time status, has been accomplished via enrollment files. These files are submitted at least every 30 days to ensure changes in enrollment status, especially withdrawals, are captured in a timely manner. To update enrollment status to graduated, two other processes have been relied upon: ? The first process uses Graduates Only files. Relying on the Clearinghouse?s advice, Graduates Only files are submitted for spring quarter only. ? The second process is the degree file submissions to support third-party verification of students? degrees through the Clearinghouse. When a degree file is submitted, the enrollment status should be updated to graduated. The issue exists with the second process where, for a variety of reasons, the Clearinghouse process does not successfully update every enrollment record with a graduated status when the degree file is submitted. These problems typically occur when students have been in more than one Clearinghouse branch, such as medical students in more than one degree program, students receiving their degree in a quarter in which they were not registered, and students who do not have a SSN. The campus began to recognize these problems in the summer of 2022 and had already decided to utilize a feature available in the quarterly Clearinghouse enrollment reporting to send a graduated status, rather than full-time status, whenever a student has graduated. This change, which is scheduled to be implemented in March 2023, will resolve most of the issues in which students may not have been reported to NSLDS as graduated. Effective immediately, error reports will be methodically checked and resolved after degree files are submitted to the Clearinghouse to ensure that enrollment records are updated for every student. By adjusting and coordinating the timing and sequencing of file submissions, the number of ?false? errors will be greatly reduced, and the error resolution process will be manageable. The resequencing of files submission will begin with the Spring 2023 semester. These two steps, in addition to the continuation of enrollment and degree reporting, should eliminate cases of students not being reported to NSLDS as graduated. For inquiries regarding this finding, please contact Cruz Grimaldo (510) 316-2932 and Jerry Lopez at (415) 476-4181 who are responsible for the corrective action.

2022-002 ? Reporting into the Common Origination and Disbursement (COD) System Cluster: Student Financial Assistance Sponsoring Agency: Department of Education Award Names: Federal Pell Grant Program and Federal Direct Student Loans Award Numbers: Not applicable Assistance Listing Titles: Federal Pell Grant Program and Federal Direct Student Loans Assistance Listing Numbers: 84.063 and 84.268 Award Year: 2021-2022 Pass-through entity: Not applicable Management provides robust, on-going training related to disbursement and federal reporting timeframes. Most recently, the COD reporting requirements were reviewed in the monthly Office of Financial Aid and Scholarships management meeting, inclusive of managers within each unit of the office and IT. The student records outside of the normal parameters identified challenges within our current SIS system and staffing limitations. The student information system in place is aging and lacks flexible controls. The Office of Financial Aid and Scholarships is migrating to a new student information system (Oracle SFP) for the 2024-25 academic year. We are reengineering our disbursement process to maximize the enhanced controls and automation within Oracle SFP to ensure compliance with disbursement and federal reporting timeframes. Until a more robust system is in place, management will develop exception reports to identify discrepancies in FAME versus COD disbursement dates beginning with the 2023 summer term. Exception reports will be reviewed bi-weekly to ensure compliance with the required reporting timeline. Additionally, management continues to request additional full-time professional staff to support the administration of federal student aid and ensure regulatory compliance in all areas as federal, state and institutional aid programs continue to expand and evolve. For inquiries regarding this finding, please contact Rebecca Sanchez at (949) 824-8262 who is responsible for the corrective action.

2022-003 ? Return of Title IV Funds Cluster: Student Financial Assistance Sponsoring Agency: Department of Education Award Names: Federal Supplemental Educational Opportunity Grants (FSEOG), Federal Pell Grant Program and Federal Direct Student Loans Award Numbers: Not applicable Assistance Listing Titles: Federal Supplemental Educational Opportunity Grants (FSEOG), Federal Pell Grant Program and Federal Direct Student Loans Assistance Listing Numbers: 84.007, 84.063 and 84.268 Award Year: 2021-2022 Pass-through entity: Not applicable Campus 1 Management provides robust, on-going training related to the Return of Title IV Funds. The Office of Financial Aid and Scholarships staffing levels have not sufficiently adjusted as student aid programs grow in size and complexity. Management is in the process of hiring additional staff and will continue to request additional full-time staff in our annual budget proposals. As additional federal and state financial aid programs are developed, there are simply not enough staff to complete all work required each week. Beginning fiscal year 2024, R2T4 reports will be reviewed in weekly team meetings and prioritized for processing to ensure compliance with regulatory timeframes. Long-term, the Office of Financial Aid and Scholarships is migrating to a new student information system (Oracle SFP) for the 2024-25 academic year. Enhanced controls and automation within Oracle SFP will ensure compliance with Return of Title IV Funds regulatory timeframes. The new student information system will increase efficiency and effectiveness by eliminating previous manual processes. Campus 2 As of October 2022, all disbursements are reported immediately, rather than the previous weekly cadence. Weekly review procedures are, and will be, a continued process to identify discrepancies and reconcile within 30 days. As an effort to address staff changes and the change in disbursement reporting, additional training was provided to staff in October of 2022. For inquiries regarding this finding, please contact Rebecca Sanchez at (949) 824-8262 and Trina Wilson at (530) 752-9278 who are responsible for the corrective action.

Finding No.: 2022-001 ? Special Tests Federal Agency: Department of Education Pass-through Entity: Direct Federal Program: Student Financial Assistance Cluster - Federal Direct Loan Program, Federal Pell Grant Program CFDA Number: 84.268, 84.063 Federal Award Numbers: P268K201616, P063P191616 Federal Award Year: July 1, 2021 ? June 30, 2022 Compliance Requirement: Special Tests, Enrollment Reporting Condition The College generally certifies its enrollment reports through rosters provided to the NSC. Of the sixty (60) students with enrollment changes we selected for test work, we noted the following students whose changes in enrollment status were not timely transmitted to NSLDS. For six (6) students, the College was notified of the student?s status change and the change was not timely reported to NSLDS. The College did not report the status change until 75-88 days following notification of the change in status. View of College Officials The College recognizes the importance of both timely and accurate reporting related to student status changes with respect to federal requirements. The College has been actively working to implement changes in procedure to ensure compliance with federal regulations. Corrective Action The College has updated its reporting schedule to NSLDS to reporting on a monthly basis at a minimum. The College also a manual review procedure that will help to ensure all status changes are reported timely to NSLDS. Additionally, an interdepartmental working group convened to evaluate, test and implement improvements through automation. Due to limitations with the student information system (Workday), the College continues to engage with the software vendor and other users to evaluate possible improvements and efficiencies in an effort to minimize manual processing without introducing additional compliance risks.

The School acknowledges that, following the departure of the previous Registrar in September 2021 and before the arrival of current Registrar in Spring 2022, enrollment files were not sent in a consistent or timely manner to the National Student Clearinghouse (NSC) for reporting to the National Student Loan Data System (NSLDS), nor was internal coding of these students' records done in Jenzabar promptly. Staffing is now stabilized in the Office of the Registrar, and management is better equipped to ensure federal NSLDS information is entered and reported accurately at the beginning of each semester and periodically until the end of term.

Finding 2022-001: Student Notifications a. Comments on Finding and Each Recommendation The University agrees with this finding. Due to turnover in the Student Financial Aid Office algorithms producing automated e-mails were not reviewed and were assumed to work in perpetuity. Action(s) Taken or Planned on the Finding The University has reviewed the Federal notification requirements. The Student Financial Aid office and Campus Technology have met and reviewed the algorithms for notifications and updated the parameters. Additionally, the Student Financial Aid e-mail box has been copied on these notifications and will be reviewed. For inquiries regarding this finding, please contact Christopher Day at (405) 208-5210 who is responsible for the corrective action.

WARNER PACIFIC UNIVERSITY MANAGEMENT?S VIEWS AND CORRECTIVE ACTION PLAN For the year ended May 31, 2022 As required by OMB Uniform Guidance, we have provided below our response and corrective action plan addressing the findings in the ?Report on Federal Awards in Accordance with the OMB Uniform Guidance? for the year ended May 31, 2022. FINDING 2022-002 ? Special Tests and Provisions ? Return of Title IV: Significant Deficiency in Internal Control over Compliance Cause: The University incorrectly based calculations on the default status of full-time rather than adjusting the calculation for part-time students. Corrective Action: The University has modified its procedures for enrollment status to ensure funds returned to students appropriately reflect whether they have full-time or part-time status. The University calculations for select PGS students who withdrew early in the term and were receiving Federal Pell Grant, were processed in error. Also, the University did not update the enrollment level code to match only the number of courses that the student started. The University has corrected all the past R2T4 calculations that were done in error. The University has revised its procedures to prevent this error from reoccurring. Anticipated date of corrective action: September 30, 2022 Name of contact person responsible for corrective action: Douglas Wade, EVP/CFO

FISAP Reporting Planned Corrective Action: The College worked with the Department of Education in the Fiscal Years 2021-22 and 2022-23 to correct errors in the Perkins loan portions of the FISAP and has developed a document retention process for underlying support for future FISAP reports. The Perkins program will cease for Newberry College in Fiscal Year 2022-23. Persons Responsible for Corrective Action Plan: Chief Financial Officer David Sayers, Interim Director of Financial Aid Chris Dominick, and Director of Student Accounts Landee Buzhardt. Anticipated Date of Completion: Fiscal Year 2022-23

Incorrect Pell Calculations Planned Corrective Action: The College has instituted a process to regularly review Pell grant awards to ensure they are paid in alignment with enrollment status. Persons Responsible for Corrective Action Plan: Chief Financial Officer David Sayers and Interim Director of Financial Aid Chris Dominick Anticipated Date of Completion: Fiscal Year 2022-23

Incorrect Return of Title IV Funds Calculations Planned Corrective Action: The College has engaged an individual with appropriate return calculation knowledge to review each calendar set up and recalculate the first few withdrawals to ensure the system is functioning as intended and calculations are being completed accurately. Persons Responsible for Corrective Action Plan: Chief Financial Officer David Sayers and Interim Director of Financial Aid Chris Dominick Anticipated Date of Completion: Fiscal Year 2022-23

Finding No. 2022-007 ? Special Tests ? Perkins Loan Recordkeeping and Record Retention Finding: It was noted that 7 Perkins Loan promissory notes were copies and not the original document. Corrective Action Taken or Planned: The Conservatory will review student files to identify total population of promissory notes that are not originals and review the potential impact. Expected completion June 2023. Responsible person Kathleen Jewett, Director of Student Accounts

Finding NO.2022-010 ? Special Tests ? Disbursement to or on Behalf of Students Finding: The institution does not have a documented Direct Loan quality assurance process. Corrective Action Taken or Planned: New Office of Financial Aid staff are documenting the quality assurance process and having the process reviewed by consultants with expertise in Direct Loan regulations. Expected to be completed April 2023. Responsible person Rebecca Barry-Wolff, Associate Director of Student Financial Planning.