Corrective Action Plans

Finding 2022-001 ? Special Tests and Provisions ? Enrollment Reporting Name of contact person responsible for corrective action: John Carrescia jcarresc@wagner.edu 718-420-4264 Corrective action: The College has been working diligently across multiple departments to make these historical corrections. We have identified the various groupings of students that require correction, and have worked through our historical data to update the program begin date (campus level data) to be the first day of the earliest semester for which each student began attending their respective program. We have submitted the listings to the National Student Clearinghouse for revision. We currently have a process in place and are working collaboratively with our information technology system analysts to implement controls to ensure the correct program begin date is used for all future students entering the College. We are now in the process of reviewing and updating our program level enrollment data.

Condition: For 2 students tested, the incorrect enrollment status was reported to the National Student Loan Data System (NSLDS). For 2 students tested, the change of enrollment status was not reported within the 60 day requirement. Corrective Action: Fielding concurs with this finding and has taken steps to resolve the deficiency. To resolve the issue of graduated students potentially being reported incorrectly to NSLDS, the University will provide additional training to the staff member who made the processing error (in one instance) and adjust their procedures to contact National Student Clearinghouse (NSC) to manually update records when a degree is retroactively processed to a prior term at a non-standard conferral date (the 2nd instance). In addition, to resolve the issues surrounding potential late reporting of students beyond the 60-day requirements, the University will correct the timeliness of their reporting schedule so that all files are submitted to the NSC by the 10th of the month if not sooner. The University feels that these steps will ensure that reporting requirements are met, as outlined in 34 CFR 685.309(b) of the code of federal regulations. Person Responsible For Corrective Action: Bridget Brady, Registrar Anticipated Completion Date: January 11, 2023

Finding 2022-002 Federal Agency Name: Department of Education Program Name: Student Financial Assistance Cluster FAL #: 84.063, 84.007, 84.268, 84.033 Finding Summary: 34 CFR Section 668.22 states 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. During our testing of compliance with Return of Title IV Funds (R2T4), there was 1 instance out of 38 where the District calculated the incorrect amount to be returned to the Department of Education (ED). Responsible Individuals: Heidi Balster, Director of Student Financial Aid Corrective Action Plan: During each payment period of an award year, the Financial Aid Office will review 20% of all R2T4 calculations (unduplicated) to ensure accuracy of the calculation and students? earned aid. The Financial Aid Office will use the random (RAND) formula in Excel to randomly select the R2T4 student population for testing. Within one week after all midterm grades are posted for the payment period, the Financial Aid Office will randomly select 10% of R2T4 calculations processed and review each calculation to ensure the correct period of enrollment was used in the calculation. After the end of each payment period, within a week after all unofficial withdrawals are processed, the Financial Aid Office will randomly select an additional 10% of R2T4 calculations (unduplicated) and review each calculation to ensure the correct period of enrollment was used in the calculation. If it is determined that a student?s R2T4 calculation is incorrect, the Financial Aid Office will complete the following steps prior to processing a corrected R2T4 calculation: 1. Obtain screenshots of incorrect R2T4 calculation and print copies into the Perceptive Content imaging system 2. Purge the incorrect R2T4 calculation and leave comments in student?s record for reason of purged calculation 3. Update all Title IV aid awards back to original amounts disbursed prior to R2T4 calculation 4. Run the Colleague?s Batch FA Transmittal Register (FATR) process and review aid adjustments 5. Notify the Business Office to have them run the Batch FA Transmittal Update (FATP) process 6. Once FATP is processed, re-run R2T4 calculation with the corrected enrollment Anticipated Completion Date: January 2023

Finding: No. 2022-005- Cash Management Finding: An excess cash balance tolerance is allowed if that balance is less than 1% of the institution's prior-year drawdowns and is eliminated within the next seven calendar days (34 CFR 668.166(a) and (b)). The institution must return immediately any amount of excess cash over the one-percent tolerance and any amount of excess cash remaining in its account within the seven-day tolerance period. Condition: There was one drawdown from the G5 during the year for federal direct loans in which the College was in an excess cash position starting on June 29, 2022, through September 20, 2022. The maximum daily excess cash balance during this time was $51,701. Corrective Action Taken or Planned: Management will review and follow internal control to regularly monitor disbursements and reconcile to drawdowns to ensure applicable requirements are met. Corrective action has been taken to return any amount of excess cash, as of 09/30/2022 completed by the VP of Administration and Finance, William McDonald.

Finding: No. 2022-004 Enrollment Reporting Finding: Institutions are required to report enrollment information under the Pell Grant and Direct Loan programs via the National Student Loan Data System (NSLDS) (Pell, 34 CFR 690.83(b)(2); Direct Loan, 34 CFR 685.309). The administration of the Title IV programs must review, update, and verify student enrollment statuses, program information, and effective dates that appear on the Enrollment Reporting Roster file. The Department of Education lists several certification methods for enrollment reporting, including certifying directly through the NSLDS website, certifying through the NSLDS?s batch enrollment reporting process, or through certification of rosters provided to the National Student Clearinghouse (NSC). Per 2 CFR 200.303, a non-federal entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statues, regulations, and terms and conditions of the federal award. Corrective Action Taken or Planned: The College, more importantly the Financial Aid Director, Erin Hanlon will review its processes and internal controls to ensure that all enrollment information and status changes are reported completely, accurately, and in a timely manner, effective immediately. Additionally, a review of the submitted enrollment data to the NSLDS be performed to ensure current student information and status is properly reflected. Enrollment reporting corrections have been corrected as of 03/29/2023.

2022-002 Eligibility Recommendation: The College implement procedures in order to strictly comply with the requirements of 34 CFR 668.173 as it relates to the return of Title IV funds. Corrective Action Taken: The College's Financial Aid Office has implemented new procedures. When final high school transcripts come in during a semester, the Office will add a step to review the actual graduation date to make sure that the College is not paying a student for an ineligible semester. Anticipated Completion Date: Fall semester 2022.

FINDING - MAJOR FEDERAL AWARD PROGRAM UNIT 2022-001 Special Test and Provisions - Return of Title IV Funds Recommendation: We recommend the College implement procedures to strictly comply with the requirements of 34 CFR 668.32 as it relates to student eligibility. Corrective Action Take: The College has well defined policies and procedures that outline attendance requirements and the process for administratively withdrawing students who have met the criterion for 14 consecutive calendar days of non-attendance. Instructors are required to adhere to the College policies. As referenced in 34 CFR 668.173(c)(2), "The Secretary does not consider an institution to be out of compliance with the reserve standard under 668.173(a)(3) if the institution is cited in any audit or review report because it did not return unearned funds in a timely manner for one or two students, or for less than 5% of the students in the sample referred to in paragraph (c)(1)(i) of this section". This audit indicates that only one student was found outside of the allowable timeframe in the sample. The College understands the necessity to reduce any issues with return of funds and will continue to work with instructors on a regular basis to adhere to the policies and procedures established to stay in compliance with these regulations. Anticipated Completion Date: Fall semester 2022 and ongoing.

2022-002 Student Financial Aid Cluster - CFDA No. 84.268 Recommendation: We recommend the Seminary review its procedures around reporting to COD to ensure timely and accurate reporting. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Seminary will send multiple Title IV Form notices throughout the academic year. Regular reviews will be conducted regarding enrolled students and completed Title IV forms and outreach will occur for any students receiving financial aid that do not have a completed Title IV Form on file. Any students without a Title IV Form will receive a refund within the 14 day period until the Title IV Form has been secured. Name(s) of the contact person(s) responsible for corrective action: Maryjo Lewis, Registrar Planned completion date for corrective action plan: June 30, 2023

2022-001 Student Financial Aid Cluster - CFDA No. 84.268 Recommendation: We recommend the Seminary reevaluate its procedures and review policies surrounding reporting status changes to NSLDS to ensure timely reporting as well as put a process in place to ensure the enrollment effective date reported to NSLDS is aligning with the Seminary's last date of attendance. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Seminary will implement a review of the listing of all potential unofficial withdrawals to ensure effective dates of withdrawal are determined correctly and will also revisit its policies and procedures around NSLDS reporting to ensure all student enrollment statuses are reported correctly and timely to NSLDS as required. Name(s) of the contact person(s) responsible for corrective action: Maryjo Lewis, Registrar Planned completion date for corrective action plan: June 30, 2023

Finding number: 2022-001 Federal agency: U.S. Department of Education (?ED?) Programs: Federal Pell Program and Federal Direct Student Loans Assistance Listing #?s: 84.063, 84.268 Award year: 2022 Corrective Action Plan The College agrees with the finding. The reason for the finding was due to a change in the National Student Clearinghouse reporting policy and process. Students who completed all course requirements but did not apply for graduation were reported as withdrawn to the clearinghouse but were not reported as graduated the following semester when they officially applied to graduate. Moving forward all graduates at the end of a term, including those who were reported as withdrawn will be included in the graduate only file sent separately from the end of term file. Timeline for Implementation of Corrective Action Plan Implemented Fall 2022 Contact Person Jennifer Vincent, Registrar, Bristol Community College

Recommendation: We recommend that the University formally document safeguards for risks identified during its formal risk assessment to demonstrate compliance with the Act. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action in Response to Finding: PSU officials will take the additional steps to document the safeguards and internal control processes that mitigate the risks identified in the formal risk assessment PSU officials had performed for GLBA compliance requirements. Name of the contact person responsible for corrective action: Ryan Bass, Chief Information Officer, and Max Parmer, Senior Information Security Analyst Planned completion date for corrective action plan: June 30, 2023

2022-002 DOCUMENTATION OF REPORT REVIEW Federal Agency: U.S. Department of Health and Human Services Federal Program Title: Foster Care Title IV-E Program Assistance Listing Number: 93.658 Pass-Through Agency: Minnesota Department of Health and Human Services Pass-Through Numbers: 2201MNFOST Award Period: Year-Ended December 31, 2022 Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matter Recommendation: It is recommended the County implement procedures to ensure that reporting policies are being performed as required by federal standards, including having another member of staff review quarterly reports after they have been prepared, and document this review. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The County is going to plan a training and informational session with those involved reporting to ensure policies and procedures are followed around reporting. Name of the contact person responsible for corrective action plan: Joua Yang, Deputy Director Accounting and Finance Planned completion date for corrective action plan: December 31, 2023.

2022-002 ? Student Financial Aid Cluster ? (a) Federal Supplemental Educational Opportunity Grants (b) Federal Work Study Program (c) Federal Perkins Loan Program ? Federal Capital Contributions (d) Federal Pell Grant Program (e) Federal Direct Student Loans (f) Teacher Education Assistance for College and Higher Education (TEACH), Assistance Listing No. (a) 84.007 (b) 84.033 (c) 84.038 (d) 84.063 (e) 84.268 (f) 84.379 ? Year Ended June 30, 2022 Condition: The University did not properly return loan funds subsequent to the R2T4 calculation for no passing grades withdrawal students for 1 out of the 12 students tested (8.3%) due to failing to return the required PLUS loans based on the calculation. Further, the amount of direct student loan funds returned was later disbursed to the student again due to lack of documentation in the University?s system of the unofficial withdrawal. We consider this to be an instance of noncompliance in relation to Special Tests and Provisions. Statistical sampling was not used. Management Response: The error identified above was made on a student?s record who did not officially withdraw from the University. As required by federal regulation, an ?all F?s? report is pulled at the end of each term and a determination is made for all students included on the report whether or not they attended classes until the end of the term. The student identified by the auditors was determined to have not attended the full Fall term. A return of title IV calculation was promptly processed by the Associate Director on the Department of Education?s website. The R2T4 calculation could not be processed via the SIS since the student did not have an official withdrawal date entered. The student loans were returned timely, however, the parent PLUS loan was missed in returning the funds. Subsequently the student contacted our office to challenge the withdrawal date and claimed he had attended classes all term and earned all of the loan funds that were disbursed for the term. There was no documentation in our SIS so the loans were reinstated in error. Corrective Action Plan: R2T4 procedures were updated to include a secondary confirmation of the return of loan funds according to the calculation. This secondary review will be scheduled at the time the R2T4 calculation is processed. Further, the procedure was updated to include entry of notes on the student?s electronic record to avoid reversal if challenged by the student. Responsible Person: Chilwana Thompson, Associate Director Implementation Date: August 1, 2022

2022-001 ? Student Financial Aid Cluster ? (a) Federal Supplemental Educational Opportunity Grants (b) Federal Work Study Program (c) Federal Perkins Loan Program ? Federal Capital Contributions (d) Federal Pell Grant Program (e) Federal Direct Student Loans (f) Teacher Education Assistance for College and Higher Education (TEACH), Assistance Listing No. (a) 84.007 (b) 84.033 (c) 84.038 (d) 84.063 (e) 84.268 (f) 84.379 ? Year Ended June 30, 2022 Condition: In three of the 40 student files tested (7.5%), Subsidized and Unsubsidized Direct loans were not properly awarded. The University under awarded one student $1,000 in Subsidized loans and over awarded the student by $1,000 in Subsidized loans. A second student was under awarded $2,560 in Subsidized loans and over awarded $2,560 in Unsubsidized loans. The third student was under awarded $862 in Unsubsidized loans. Management Response: All of the errors identified by the auditors were a direct result of manual miscalculation of loan eligibility. In two of the instances cited, the students had previous additional unsubsidized loans issued as a result of parent PLUS loan denials. When we received ISIR data these students were flagged with a reject due to aggregate loan limits. In order to calculate each student?s loan eligibility, a manual review of loan information via the U.S. Department of Education?s Common Origination and Disbursement (COD) portal is necessary. The additional unsubsidized loans disbursed as a result of PLUS denial, were manually removed from each student?s loan total to determine current year eligibility. In both instances, the total loan eligibility was correct, however the manual calculation of the subsidized versus unsubsidized split of the loan funds were miscalculated. In the last instance a student was under awarded $862 in unsubsidized loans, the miscalculation occurred due to receipt of an outside scholarship. In the Fall term the scholarship check was received with documentation indicating the disbursement was to be applied to the Fall term in it?s entirety and the Spring disbursement would follow. The outside scholarship caused the student to be over awarded and the student loans were adjusted to remain within cost of attendance limits. Subsequently the Spring term disbursement of the scholarship was received for $862 less than the Fall disbursement. At that time, the student should have been offered the additional $862 in unsubsidized loan funds to bring their total aid back up to cost of attendance. The staff person entering the scholarship payment on the student?s account failed to notify the loan coordinator an adjustment was warranted. Corrective Action Plan: The loan coordinator who made the errors has been in the position for just over a year. In order to prevent future issues in calculating a student?s loan limits and eligibility, the employee attended a loan regulation and processing overview course produced by the National Association of Financial Aid Administrators (NASFAA). Further, a form was developed to help calculate aggregate limits when an ISIR reject occurs in order to avoid missed steps in the calculation process. 2022-001 ? Student Financial Aid Cluster ? (a) Federal Supplemental Educational Opportunity Grants (b) Federal Work Study Program (c) Federal Perkins Loan Program ? Federal Capital Contributions (d) Federal Pell Grant Program (e) Federal Direct Student Loans (f) Teacher Education Assistance for College and Higher Education (TEACH), Assistance Listing No. (a) 84.007 (b) 84.033 (c) 84.038 (d) 84.063 (e) 84.268 (f) 84.379 ? Year Ended June 30, 2022 (Continued) As a result of the outside scholarship error, our procedures for entering an scholarship payment have been adjusted to include a final review of all outside scholarship disbursements entered by the loan coordinator. Responsible Person: Lynette Lambert, Assistant Director/Loan Coordinator Implementation Date: August 1, 2022

Finding Reference 2022-007 Contact Person: Stephani Berry Views of Responsible Officials and Planned Corrective Action: These Pell recipients are from the 2nd Chance Pell Grant Experiment and guidance has been inconsistent in the awarding process, resulting from staffing issues and high turnover. Student credit hours are now determined using the correct Pell Grant Payment Schedule and awarded accordingly. Verification process includes reviewing student's maximum lifetime Pell award percentage of 600%. Anticipated Completion Date: July 1, 2022

Finding Reference 2022-006 Contact Person: Stephani Berry Views of Responsible Officials and Planned Corrective Action: 21-22 semester dates were input incorrectly by a previous DFA and have now been corrected for the 22-23 school year to reflect DOE (per FSA handbook) requirements. Anticipated Completion Date: December 8, 2022

Finding Reference 2022-004 Contact Person: Stephani Berry Views of Responsible Officials and Planned Corrective Action: Registrar Office automatically reports changes in student enrollment information to National Student Clearinghouse, which then goes into NSLDS on a monthly basis. The four students that failed this test for Audit Finding 2022-004 were due to student completion issues and Donnelly College overriding the add/drop policy to retroactively drop students. Registrar clearly provides the information and application process requirements to students who are graduating and will not process their graduation until requirements are met. Once Registrar is made aware of a retroactive drop that overrides the add/drop policy, it is reported on the next month?s automatic report sent through National Student Clearinghouse to NSLDS. Anticipated Completion Date: Resumed by National Student Clearinghouse in December 2022

Finding Reference 2022-003 Contact Person: Stephani Berry Views of Responsible Officials and Planned Corrective Action: This was neglected due to staffing issues and high turnover. Disbursement Letters are sent to students as they request Direct Loan funding amounts. The Disbursement Letter includes the three elements as required by DOE (per FSA handbook). Anticipated Completion Date: October 20, 2022

Finding Reference 2022-002 Contact Person: Stephani Berry Views of Responsible Officials and Planned Corrective Action: This was neglected due to staffing issues and high turnover. Pell and Direct Loan origination records and disbursement records are submitted to the Common Origination Disbursement (COD) either same business day, or next business day. Formal reconciliation process is now completed every 1-2 months in order to verify disbursement dates, amounts, and cost of attendance in COD. Anticipated Completion Date: March 21, 2022

Based on the review and assessment of findings, the Financial Aid Office at West Hills College Coalinga will continue to establish policies and procedures including instructions on completing R2T4 calculations, timelines, and trainings to ensure that the determination date for students that unofficially withdraw are completed within 30 days of the end of the payment period.

Return of Title IV Calculations Planned Corrective Action: We worked with staff to better understand whether the delayed and incorrect R2T4 calculations were a result of knowledge or process deficiencies. After speaking with staff, we determined that both areas are an issue. To address these deficiencies, we are employing the following measures: 1) We have engaged a consultant for group training on R2T4?s. This consultant will also help with process review, to help us understand any areas of weakness. 2) We will have staff re-review the FSA training modules on R2T4?s. 3) We have upgraded to a new financial aid management system. This system allows for automated/semi-automated R2T4 processing, which will help ensure that R2T4?s are completed accurately and in a timely manner. Person Responsible for Corrective Action Plan: Alison Hayes, Assistant Director of Financial Aid Anticipated Date of Completion: N/A- ongoing training and process review.

Responsible Officials Contact Information: Charlotte Outlaw-Yorker Assistant Registrar of Certification and Reporting 718-636-3718 coutlaw@pratt.edu View of Responsible Officials and Corrective Action Plan: Management agrees with the finding and the related recommendations. The Institute will update its NSLDS roster submissions to ensure that student reported program length is in years and not months. The enrollment rosters will be reviewed by a second member of management for accuracy before submission and a periodic check to verify Published Program Length Measurement listed in the NSLDS correctly matches the Institute?s publicly reported program lengths on our website and any that do not match will be updated timely.

Finding 2022-005 Corrective Action Plan The Registrar will review current processes and implement recommendations during FY23. Processes will be revised to review and verify all students are included in the reporting to NSLDS within the required reporting time frame. The Registrar?s Office staff will be trained on new procedures. Responsible Party: Steven Perrotta Vice President for Finance and Administration Phone: (603) 897-8215 Anticipated Completion Date: December 31, 2022

Finding 2022-004 Corrective Action Plan The Director of Financial Aid will review and revise current processes to ensure disbursement notification letters are sent to students within 7 days. Updated procedures will be documented and financial aid staff will be trained on the requirement and new procedures. Responsible Party: Steven Perrotta Vice President for Finance and Administration Phone: (603) 897-8215 Anticipated Completion Date: December 31, 2022

Individuals Responsible for Corrective Action Plan Wanda Spradley, Director Financial Aid and Jennifer Sauer, AVP and Controller Finding 2022-001 Corrective Action Plan: The finding is related to required enrollment information being reported to National Student Loan Data System which can include a variety of part time statuses as well as changes in field of study. All 3 of the students indicated as not being reported were from changes in field of study. The data to be reported includes Classification of Instructional Programs (?CIP?) codes provided by the U.S. Department of Education. The CIP codes were updated in 2020, and the college did not update its registration system. With the old codes used in the enrollment change reporting, the changes were effectively shown as ?not reported?. The Registrar?s office is updating all CIP codes in the Banner database to correct this going forward. Since it is more than halfway through fiscal 2022-23, it may possibly show as an issue next year prior to February 1, 2023. Anticipated Completion Date: February 28, 2023