Corrective Action Plans

Condition: There were no monthly direct loan reconciliations performed. Criteria: Per SFA requirements, the College is required to reconcile the COD data files with the College?s financial records. Cause: Turnover in the staff and Director positions of the College. The new employees were not aware of this requirement. Effect: Noncompliance with SFA requirements. Perspective: There has been high turnover in the SFA department, including a time where there was not a Director in place. The new Director came on in the fall of 2022 and will begin performing the monthly reconciliations as required. Recommendation: We recommend that the direct loans are reconciled at least monthly between the COD and the College?s general ledger. Views of Responsible Officials and Planned Corrective Actions: Dodge City Community College staff involved have received training and been made aware of requirements. Monthly reconciliations will be performed immediately.

Condition: We examined a sample of Title IV aid recipients to verify that information reported on the Enrollment Reporting roster file sent to the National Student Loan Data System (NSLDS) matched the student's academic files and found instances where students received Title IV aid during a semester but the status of withdrawn or graduate were not reported correctly or timely on the NSLDS Enrollment Reporting roster files sent during that semester. Criteria: Per the NSLDS Enrollment Reporting Guide, a school should report all students that NSLDS includes in its request to the school on a roster file. This includes timely and accurate reporting of the status of the student of withdrawn or graduate. Cause: The status of the students were not timely and accurately reported to NSLDS. Effect: Students could potentially not be placed in grace or repayment status when they should be. Perspective: There has been high turnover in the SFA department, including a time where there was not a Director in place. The new Director came on in the fall of 2022 and has taken charge and completed the backlog of reporting, implemented new procedures, and sent two staff to training. They are current as of the spring 2023 reporting. Recommendation: We recommend that personnel in charge of enrollment reporting be diligent in reviewing the roster file to ensure that all appropriate students are shown and attendance changes are reported in a timely and accurate manner. Views of Responsible Officials and Planned Corrective Actions: Dodge City Community College staff involved in enrollment reporting to the NSLDS have reviewed the NSLDS Reporting Manual to better understand and accurately report the student's enrollment status. They have completed the backlog of reporting, implemented new procedures, and sent two staff to training. They are current as of the spring 2023 reporting.

2022-007: Student Financial Aid Cluster ? Assistance Listing No. 84.268 Recommendation: We recommend that the University review its processes and procedures related to determining the grade level of the student for determining the Subsidized Direct Loans and Unsubsidized Direct Loan amounts. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The University will complete a review of the population of student class level for the fiscal years 2021-2022 and for the year 2022-23. The errors identified resulted from a data report writing issue that has since been corrected. Name(s) of the contact person(s) responsible for corrective action: Benjamin Soman Planned completion date for corrective action plan: 05/01/2023

2022-011: Student Financial Aid Cluster ? Assistance Listing No. 84.063, 84.268 Recommendation: We recommend that the University update its processes and procedures related to reviewing the information submitted to COD to ensure compliance with the stated criteria. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The University will complete a review of all students who received Title IV aid during 2021-22 and 2022-23 to ensure disbursement dates are accurate. In addition, the University has completed training to ensure future origination and disbursements submissions are timely. Name(s) of the contact person(s) responsible for corrective action: Benjamin Soman Planned completion date for corrective action plan: 06/30/2023

2022-010: Student Financial Aid Cluster ? Assistance Listing No. 84.007, 84.033, 84.038, 84.063, 84.268, 84.379 Recommendation: We recommend that the University update its processes and procedures related to reviewing the information posted to NSLDS to ensure the accuracy of the data. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The University will complete a review of all students who received Title IV aid during 2021-22 and 2022-23 to ensure enrollment data is accurate. Name(s) of the contact person(s) responsible for corrective action: Benjamin Soman Planned completion date for corrective action plan: 09/30/2023

2022-003: Student Financial Aid Cluster ? Assistance Listing No. 84.007, 84.033, 84.038 Recommendation: We recommend the University review its policies and procedures for the filing of the FISAP to ensure that there is sufficient time in the process to meet the due date in accordance with the stated criteria. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The University has scheduled data gathering and reconciling processes to ensure timely 2023 filing. Name(s) of the contact person(s) responsible for corrective action: Benjamin Soman Planned completion date for corrective action plan: 08/31/2023

2022-001 Awarding of Direct Loans and Pell Grants Recommendation: We recommend the College evaluate its policies and procedures for identifying transfer credits and other changes made after the initial packaging to ensure that federal awards are revised as needed. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned/taken in response to finding: Beacon is implementing a new comprehensive software system (Jenzabar One) which ? paired with NetPartner and PowerFAIDS ?will better identify changes in student status. The system will also include InfoMaker software which the financial aid office will use to pull information needed to double check for late changes in student eligibility. Full implementation of the new software is now estimated to occur in December 2022. In the interim, enhanced procedures have been put in place by the Financial Aid Office to prevent further issues: a. Requesting an updated anticipated graduation list from the Registrar at the beginning of each term to confirm students are awarded appropriately b. Requesting a final graduation list from the Registrar at the end of each term to identify any students whose graduation plan has been delayed and making immediate adjustments to their aid eligibility, if needed. c. Performing a finalized review of all graduating students prior to the end of the academic year to ensure proper adjustments have been made. d. Requesting updated reports from the Registrar of any student receiving credit for transfer coursework prior to the start of each semester and making adjustments immediately to their aid eligibility; e. Prior to disbursement, a second review of all students is being performed to identify students whose grade-level conflicts with determination level for pending loans f. A final review prior to the end of each term is conducted so late adjustments can be made if needed. Name(s) of the contact person(s) responsible for corrective action: Daphne Parks, Vice President of Processing at FAS; Stephanie Knight, Director of Enrollment Services & Financial Aid, Beacon College; Carrie Santaw, Registrar, Beacon College Planned completion date for corrective action plan: Interim measures ? already implemented. Software implementation is scheduled to go live in December 2022.

Finding 2022-008 MiSACWIS Security Management and Access Controls Management Views MDHHS agrees with parts a., b., d., and e. of the finding. DTMB disagrees with part c. of the finding. For part c., although MDHHS and DTMB had not fully documented all database specific configuration standards until after the audit period, DTMB disagrees that during the audit period the system contained potentially vulnerable database configurations and disagrees that DTMB cannot ensure the security of the data. DTMB has been and continues to implement the manufacturer?s recommendations regarding security configurations. In addition, the databases reside in restricted trusted internal security zones, protected by firewalls, which are specific to each application and database, in conjunction with intrusion protection, antivirus software, and SOM standard security safeguards. Planned Corrective Action For parts a. and e., MDHHS will continue to provide training for LOSCs via quarterly webinars to emphasize the proper procedures for granting access and how to review and compare access to DSA approved requests. For part b., MDHHS will add an Incompatible Role form into the DSA Michigan Statewide Automated Child Welfare Information System (MiSACWIS) request with automated routing for appropriate approval. This would ensure that documentation was maintained, and appropriate approvals secured in all situations. For part c., DTMB developed an organization-wide framework for database security configuration management. For part d., MDHHS has implemented a quarterly report in MiSACWIS that will identify any financial authorization that was approved by the same person that created the authorization. Anticipated Completion Date a. and e. Corrective action is ongoing. b. MDHHS has not yet determined an anticipated completion date because implementation is dependent on funding, approval, and prioritization of proposed system changes. c. DTMB anticipates having compliance documentation by September 30, 2023. d. MDHHS will receive the first quarterly report on September 30, 2023, and will perform a review of the transactions identified on that report during October 2023. Responsible Individual(s) a., b., and e. Alana Lowe and Deon Nelson, MDHHS c. Heather Frick and Nathan Buckwalter, DTMB d. Alana Lowe, MDHHS

Finding #2022-001: Pacific understands finding #2022-001 and we agree that the University will modify internal controls to ensure accurate and timely reporting of student status changes to the National Student Loan Data System (NSLDS). The University has adjusted the completion/graduation process and procedure to capture students (within the 60 days required to transmit status change to NSLDS) whose degree have been awarded. The university will correct error reports within the 10-day period to ensure the student status is updated within the 60-day requirement to transmit status change to NSLDS. Finding #2022-001 Action: The Office of the Registrar concurs with the audit test work of enrollment reporting which noted while there is a process in place to correctly submit information to NSLDS, during the audit test work the engagement team noted that three student's information was inaccurately reported to NSLDS. The University's control failed in detecting that inaccurate information was reported to NSLDS. It was discovered in December 2022 that the Registrar staff did not review the error report from the clearinghouse to ensure students? final status to NSLDS during the required reporting period. Per the 2022 Enrollment Reporting Guide, ?After the institution submits the Enrollment Reporting roster to NSLDS, NSLDS evaluates the enrollment Reporting roster and provides the institution an Error/Acknowledgement file. If errors are identified, institutions have 10 days to correct the errors and resubmit to NSLDS.? While the University acknowledges the critical nature of taking corrective action on this finding, it also notes incorrect reporting of ?G ? for ?W? statuses results in no harm to individual students in their loan repayment start dates nor financial loss to the U.S. Department of Education?s federal loan program. The University agrees with this statement and, as of July 2022, has adjusted the completion/graduation process and procedure to capture students (within the 60 days required to transmit status change to NSLDS) who have been awarded their degree but files appear in the clearinghouse error report. The University will correct error report and resubmit within 10-days and ensure in NSLDS that the update is complete. Person(s) responsible: Karen Johnson University Registrar

RE: HELP HOUSING FOR THE DISABLED, INC. 26900 Euclid Avenue Euclid, Ohio 44132 SUBJECT: Corrective Action Plan 042EH430 HELP HOUSING FOR THE DISABLED Reporting Period Ending Date ? June 30, 2022 Finding 2022-001 CFDA: 14.157 Section 202 Direct Loan Criteria: Internal controls over compliance should be in place to ensure the deposit of surplus cash amounts into the residual receipts account occurs within ninety days after year end. Condition: A deficiency in internal control over compliance existed due to the prior year excess surplus cash amount not being deposited into the residual receipts account within ninety days after the end of the annual fiscal period for which the surplus cash was calculated. Recommendation: The Project should establish procedures to ensure that surplus cash is deposited within ninety days after the end of the annual fiscal period for which the surplus cash is calculated. CORRECTIVE ACTION: Management has agreed to implement the process of depositing surplus cash on the day the audited financial statements are issued. Thorough review of financial statement notes and conversations with audit team during the review process will establish the amount of funds to be deposited. Once this internal review is complete and audited statements are issued the internal management team will routinely make the required deposit and follow up by providing payment confirmation to the outside audit team. This accountability confirmation process will ensure that the deposit is made timely and routinely. Any questions regarding this plan should be directed to: Belinda Glavic Grassi MA, CPA Chief Financial Officer Help Housing for the Disabled, Inc. (216) 432-4810

Finding number: 2022-04 Federal agency: U.S. Department of Education Programs: Student Financial Assistance Cluster CFDA #: 84.268 Award year: 2022 Corrective Action Plan: Upon review of this finding the University found the dates of determining the Return to Title IV funding were incorrectly calculated. The Return to Title IV has been recalculated and the University found additional federal direct loan funds to be returned. The unearned direct loan funds were immediately returned. The University completed a sample review for Return to Title IV calculations and did not find any similar instances. The University views this as an isolated instance. Additional procedures have been implemented for a secondary reviewer of Return to Title IV to ensure the accuracy of calculations and the return of funds in a timely manner. Timeline for Implementation of Corrective Action Plan: Fiscal year 2023 Contact Person Stephanie King Executive Director of Student Financial Services

Finding number: 2022-003 Federal agency: U.S. Department of Education Programs: Student Financial Assistance Cluster CFDA #: 84.063 and 84.268 Award year: 2022 Corrective Action Plan: Upon review, the students identified in this finding did not appear on the Return to Title IV funds report the Student Financial Services Office generates to identify and return unearned funds to the Department of Education. The University has updated procedures where a secondary report has been created and is evaluated on a weekly basis to ensure funds are returned in a timely manner. The University did not find any additional instances of this situation. Timeline for Implementation of Corrective Action Plan: Fiscal year 2023 Contact Person Stephanie King Executive Director of Student Financial Services

Finding number: 2022-002 Federal agency: U.S. Department of Education Programs: Student Financial Assistance Cluster CFDA #: 84.063 and 84.268 Award year: 2022 Corrective Action Plan: The University evaluated both student records to determine the cause for the late reporting to NSLDS. The first student reported in this finding completed their degree requirements after the conclusion of the semester and the enrollment status reporting to the National Student Loan Clearinghouse. The policy of the University is to manually update NSLC however, the student was inadvertently missed in this process. The University office responsible for reporting enrollment status changes has determined this to be an isolated instance. The second student in this finding did not have their change in enrollment status updated in the early May reporting to NSLC as the student?s status did not change until two weeks later. The student?s record was rejected on the June NSLC report and not re-reported until the fall semester report. The office responsible for reporting enrollment status changes have updated their procedures to identify and review rejected student enrollment records. Rejected enrollment records will be evaluated by the reporting office and manually update NSLC with the accurate enrollment status to ensure proper updates are completed in a timely manner. Timeline for Implementation of Corrective Action Plan: Fiscal year 2023 Contact Person Stephanie King Executive Director of Student Financial Services

Compliance requirement - Special tests and provisions ? Gramm-Leach Bliley Act- Student Information Security Institutional Comments on Findings and Recommendations: (a) The institution agrees with the auditor on this finding. The Information Security Program Coordinator's functions were not specified in a formal written contract, therefore, the consultant does not have a detail for the functions and responsibilities of his designation. (b) The institution agrees with the auditor on this finding. The Institution has yet to comply with, needs to terminate and correct some of the nine elements that are included in the FTC (Federal Trade Commission). Actions Taken or Planned: 1. A contract with the IT Program Coordinator is being finished with a breakdown of the responsibilities expected for the GLBA requirements. We should be starting it in May 2023. 2. There has been progress in the action plan where a set of estimated time of completion is provided. We will keep doing so and monitor every aspect of the risk assessment to cover and safeguard each area found with a document that indicates any advances. 3. The Institution with the IT Coordinator will keep monitoring each step for the progress and any delay with a task report where it will show any advance or delay for the pending findings so that we can track the development closely until finished. 4. Finally, we will continue with the efforts to document and complete the corrections to the risk assessment results.

Compliance requirement - Special tests and provisions ? Enrollment Reporting Institutional Comments on Findings and Recommendations: (a) The institution agrees with the auditor on this finding in that there was one (1) case where the information of enrollment of this student was not available for examination. After multiples student search, the institution was unable to locate through the NSLDS the reported status update for said student. (b) The institution also agrees with the auditor in that there were (6) six cases where he noted that institution failed to report the student's status before the thirty (30) day deadline for the NSLDS web reporting. (c) The institution also agrees with the auditor in that there was one (1) instance where the institution submitted one (1) of its's enrollment report updates after the 15 days required timeline. Actions Taken or Planned: The institution would continue to submit its Enrollment Reports monthly in order to notify changes of student status to the Department of Education on a timely basis and to maintain the information of student's enrollment status more effectively.

Compliance requirement ? Special test and provisions - Return of Title IV Funds Institutional Comments on Findings and Recommendations: I. Compliance Requirements ? Applicable After a Student Begins Attendance: a. The institution agrees with the auditors on this finding in which there were two (2) cases where the auditors noted that the institution failed to determine that the students withdrew within 14 days after the student's last day of attendance. II. Compliance Requirements ? Applicable for a student who does not begin attendance: b. The Institution agrees with the auditors on this finding in which there was one (1) case were the student did not comply with the Incomplete course requirement and an unofficial withdrawal was not performed. Before the audit process was completed, the institution performed a R2T4 calculation and returned to the US Department of Education, the $439.00 associated with this finding. This process was evidenced to the auditors for their records. c. The Institution agrees with the auditors on this finding in which there was one (1) case were the student had stopped attending the enrolled courses without completing at least 60% of the payment period. Before the audit process was completed, the institution had returned to the US Department of Education, the $581.00 associated with this finding. This process was evidenced to the auditors for their records. d. The institution agrees with the auditors that in the cases mentioned in item b and c in that it failed to determine that the students withdrew within 14 days after the student's last day of attendance. e. The institution agrees with the auditors that in the cases mentioned in item b and c in that it failed to return Title IV funds after the 45 days' time frame. Actions Taken or Planned: The institution is aware of the importance to comply with Return of Title IV funds (R2T4) reporting requirements and deadlines. Also, the relation to students last day of attendance (date of withdrawal) vs date of school's determination that the students withdrew and the date of the return of any Title IV funds resulting from an R2T4 calculation. The issues as related to these findings were identified as ones being an oversight and lack in compliance with some of the academic processes as required by R2T4 and has already been discussed with the Academic Dean of the institution who in turn has revisited these matters with Faculty and administrative staff under her supervision including the Registrar. The already instituted task force that meets every Friday of each week to identify and review cases that could affect the R2T4 procedure and requirement has continued to review and evaluate information received from the faculty through the Academic Dean and from information the Registrar's office receives of students that are not attending classes in order to process all applicable withdrawals to assure that the return of Title IV funds procedures and the return of funds if any, are processed timely within the 14 days requirement of the student's last day of attendance and within the 45 days from the date that the institution determined that the student withdrew. Before the audit process was completed, the institution had returned to the US Department of Education, the $439.00 and $581.00 associated with this finding. This process was evidenced to the auditors for their records.

Compliance requirement ? Other ? Policies and Procedures requirements. Institutional Comments on Findings and Recommendations: 1 The institution agrees with the auditors on this finding in which the current University Catalog containing the updated general disclosures for enrolled or prospective students were not updated on time for the fiscal year. 2 The institution agrees with the auditors on this finding in which the Drug and Alcohol Abuse Prevention Program did not fully comply with the distribution requirement in writing for each student. It also agrees that the institution did not perform a recent biennial review of its Drug and Alcohol Abuse Prevention Program. Actions Taken or Planned: The institution has already updated, published, and distributed its Catalog to accurately represent the vision and goals, our academic offerings and administrative policies and procedures of our operation. As related to the institutions Drug and Alcohol Abuse Prevention Program, the same was also updated, revised, published, and distributed to all active students and staff. The updated Drug and Alcohol Abuse Prevention Program is also available for distribution for all prospective students and any potential employees through the Admissions and Human Resources offices respectively. The same would also be posted on the Web page of the institution. Evidence of both issues were submitted to the auditors.

Finding: 2022-001 Federal Program: Disbursements to or on Behalf of Students Name(s) of the contact person(s) responsible for the corrective action: Vandeen McKenzie, Executive Director Financial Aid John Hanson, Director of Financial Aid, Prescott Karen Williams, Director of Financial Aid Operations Santonio McPhee, Associate Director of Financial Aid Operations View of Responsible Officials: Financial Aid management will establish a control check to monitor that student disbursement notices are being sent within the required timeframe. The control check is comprised of a report generated directly from the University?s student information system and a manual review of the output to confirm notices are being sent. This review will be completed at the start of the new aid year and monthly thereafter.

Area: Special Tests and Provisions Views of Auditee and Planned Corrective Action: PIU agrees with the finding. PIU will implement monitoring controls over the monthly direct loan reconciliation process performed by the third-party financial aid private consultant. Anticipated Completion Date: May 31, 2023 Name of Contact Person and Title: Celia Atoigue, Director of Finance

Area: Special Tests and Provisions Views of Auditee and Planned Corrective Action: PIU agrees with the finding. PIU will implement procedures to improve its knowledge of special test and provisions required for the federal programs under the SFA cluster. PIU will coordinate with its vendor, FA Solutions, to improve on its knowledge on this item since they are the vendor that processes all financial aid for PIU. Anticipated Completion Date: May 31, 2023 Name of Contact Person and Title: Celia Atoigue, Director of Finance

Area: Special Tests and Provisions Views of Auditee and Planned Corrective Action: PIU agrees with the finding. PIU will improve its controls over the timely determination of whether a student has ceased attendance for purposes of computing a return of Title IV funds. Anticipated Completion Date: May 31, 2023 Name of Contact Person and Title: Celia Atoigue, Director of Finance

Area: Reporting Views of Auditee and Planned Corrective Action: PIU agrees with the finding. PIU will implement review controls over reports required to be submitted for the programs under the SFA cluster. Anticipated Completion Date: May 31, 2023 Name of Contact Person and Title: Celia Atoigue, Director of Finance

Area: Cash Management Views of Auditee and Planned Corrective Action: PIU agrees with the finding. PIU will review the requirements of the Uniform Guidance and understand the cash management principal requirements. Once this is done, PIU will implement procedures and update the Business Office Manual. Anticipated Completion Date: May 31, 2023 Name of Contact Person and Title: Celia Atoigue, Director of Finance

2022-004 NSLDS Enrollment Reporting Student Financial Aid Cluster ? Assistance Listing No. 84.268, 84.063, 84.007, 84.033 Auditors? Recommendation: The University must review their enrollment reporting policies and procedures to ensure accurate reporting. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The transition to new SIS will ensure that: 1. The student statuses within the system will update automatically based on changes in the student's schedule and enrollment. 2. The school will report the information from the SIS monthly to the National Student Clearinghouse for update to NSLDS to ensure timely and accurate updates to student statuses. Additional action taken: New procedures were created to follow-up on error files received from National Student Clearinghouse. These files will be reviewed by both the registrar?s office and the financial aid office within 10 days of receipt. This ensures multiple individuals know how to review and correct any data discrepancies to mitigate impact from staff turnover. Name(s) of the contact person(s) responsible for corrective action: Rusty Hassell, Chief Enrollment Officer; Stephen Waers, Chief Academic Officer, Rachal Wortham, Director of Financial Aid Quality and Compliance; Natalie Brown, Registrar Planned completion date for corrective action plan: Implementation complete April 2023. System transition complete August 2023

2022-002 Disbursement Date Reporting to COD Student Financial Aid Cluster ? Assistance Listing No. Various Auditors? Recommendation: The University must review their policies and procedures to ensure accurate reporting to COD.Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Implemented multistage review process to highlight differentials between COD and system disbursement date. Fiscal Year 2022 dates are accurate. Further, implementation of new SIS, Ellucian Colleague will correct the discrepancy issue due to automated functions that will align disbursement dates. Name(s) of the contact person(s) responsible for corrective action: Rusty Hassell, Chief Enrollment Officer; Rachal Wortham, Director of Financial Aid Quality and Compliance; Amanda Schmidt, Director of Student Accounts Planned completion date for corrective action plan: Fiscal year 2022 are corrected and accurate as of March 2023. System transcription complete August 2023.