Corrective Action Plans

Finding 2022-004: Information on the Federal Program Federal Agency: United States Department of Education (ED) Program Name: Student Financial Assistance Cluster AL: 84.268 - Federal Direct Student Loans Federal Award Identification Number: N/A Federal Award Year: Year Ended May 31 , 2022 The College will implement a control procedure to ensure disbursement notification letters are sent to every student who received direct loan disbursement, within 7 days, to be in compliance with the requirement described above. The College supplies to the student a notification of each disbursement via a Statement of Account. The College has added a clause in the Terms and Conditions which addresses the cancelation of loans. Estimated Completion Date: December 31 , 2022 Contact Person: Pamela A. Bernstein Director of Business and Registrar Affairs thomasmorecollege@hotmail.com 603-324-1420

WorkNet Pinellas, Inc. management and MIS Team reviewed the monitoring issue with the WIOA team and provided training on the subject. WorkNet Pinellas, Inc. has improved the enrollment process, hired an eligibility specialist and implemented Quality Control (QC) processes to include a review by the eligibility specialist, Career Counselor, and WIOA Lead or MIS QC prior to enrollment to ensure eligibility and accuracy and to ensure "training services be limited to individuals who are unable to obtain other grant assistance for such services including Federal Pell Grants."

Federal Direct Loans and Pell Grants Reconciliations Planned Corrective Action: Implement a procedure where Pell Grants and Direct Loans are reconciled by student using reports from CAMS as well as COD. Person Responsible for Corrective Action Plan: Anna Peters Anticipated Date of Completion: May 31, 2023

Inaccurate Return of IV (R2T4) Funds Planned Corrective Action: A review of all R2T4s performed for students in our on-line program will be completed. The review will include recalculating Pell Grants for students that did not begin attendance in courses. It will also include adding the break between modules into the dates on the R2T4. Person Responsible for Corrective Action Plan: Anna Peters Anticipated Date of Completion: May 31, 2023

Finding 2022-001 Student Financial Assistance Program Cluster -Department of Education Federal Financial Assistance Listing/CFDA #84.038 Federal Perkins Loan Program Reporting Material Weakness in Internal Control over Compliance Finding Summary: The information reported on the FISAP was incorrect. Responsible Individuals: Robert Hoover, Director of Financial Aid and Deb Theill, Student Accounts Loan Coordinator Corrective Action Plan: The figures reported were corrected with no negative impact to the report or institution. Responsible parties will incorporate a second round of review to analyze data entry and eliminate errors moving forward. Anticipated Completion Date: Updates Completed 9/1/2022

Finding 2022-004 Student Financial Assistance Program Cluster - Department of Education Federal Financial Assistance Listing/CFDA #84.268 Federal Direct Student Loans - 2021/2022 P268K211430 Federal Financial Assistance Listing/CFDA #84.063 Federal Pell .Grant Program - 2021/2022 P063P201430 Special Tests & Provisions: Enrollment Reporting Significant Deficiency in Internal Control Finding Summary: Two instances were noted where enrollment effective date reported to the National Student Clearing House as first effective was not the same as the student's last date of attendance. Responsible Individuals: Kristi Bagstad, Registrar Registrar's Office Corrective Action Plan: The financial aid office will establish a review process to spot-check and confirm that the Enrollment Effective date will coincide with the Last Day of Attendance reported for student records. Anticipated Completion Date: Ongoing

Finding 2022-003 Student Financial Assistance Program Cluster - Department of Education Federal Financial Assistance Listing/CFDA #84.268 Federal Direct Student Loans - 2020/2021 P268K211430 Federal Financial Assistance Listing/CFDA #84.063 Federal Pell Grant Program - 2020/2021 P063P201430 Reporting- Common Origination and Disbursement System Material Weakness in Internal Control over Compliance and Noncompliance Finding Summary: Three instances were noted where Title IV funds were applied to the student account but were not processed in COD within the required time frame. Another two instances were noted where Title IV funds were applied to the student account but were not processed in COD at all. Responsible Individuals: Robert Hoover, Director of Financial Aid on behalf of the vacant place of Loan Coordinator position Corrective Action Plan: The financial aid office has reconciliation and exception report processes to identify and correct COD records promptly. Vacancies in Summer 2021, Fall 2021, and Spring 2022 posed challenges to reviewing and completing said process/reports. The office recently underwent system enhancement and utilization training during the Summer of 2022. These combined with the processes in place and having the Loan Coordinator (newly retitled Services Coordinator) will strengthen these areas further. Anticipated Completion Date: Ongoing

Finding 2022-002 Student Financial Assistance Program Cluster - Department of Education Federal Financial Assistance Listing/CFDA #84.268 Federal Direct Student Loans - 2021/2022 P268K211430. Special Tests & Provisions: Return of Title IV Funds Material Weakness in Internal Control over Compliance and Noncompliance Finding Summary: One instance was identified where the Return of Title IV calculation was not completed. Another instance was identified where the Return of Title IV calculation was completed using the incorrect withdrawal date. Additionally, one instance was identified where the Return of Title IV calculation was completed, but the funds were returned late. The University did not perform a Return of Title IV calculation for students who completed an interim course and then withdrew during the spring semester. The incorrect withdrawal date was used to calculate the amount of aid to be returned. Process to ensure that funds were submitted in a timely manner were not followed. Responsible Individuals: Robert Hoover, Director of Financial Aid and Kristin Harrington, Assistant Director of Financial Aid Corrective Action Plan: The Financial Aid office has undergone systems enhancement training during Summer 2022. Updating processes specific to the Return of Title IV Funds that will lend in the identification and processing timeline/steps associated with the complex process of identifying, calculating, and returning Title IV funds. After consultation with auditors, the FA Office will conduct calculations (as it relates to interim coursework) moving forward so that future issues, of this nature, will be avoided. Anticipated Completion Date: 10/21/2022

Enrollment Reporting to NSLDS Planned Corrective Action: Errors may have occurred due to transition in staff and insufficient processes related to identifying student non-attendance. Error reports from the National Student Clearinghouse are reviewed after every submission and errors are corrected. Second, processes related to identifying students who have stopped attending classes were strengthened during the Fall 2022 semester. Person Responsible for Corrective Action Plan: Chris Vetter - Interim Provost Anticipated Date of Completion: December 30, 2022

Finding number: 2022-001 Federal agency: U.S. Department of Education Programs: Student Financial Assistance Cluster Assistance Listing Number: 84.063 and 84.268 Award year:2022 Corrective Action Plan: To ensure complete and comprehensive National Student Loan Data System (NSLDS) reporting compliance as outlined in 34 CFR 685.309(b)(2) and in 2 CFR Part 200, Appendix XI Compliance Supplement, the College undertook a formal review of its NSLDS policies, processes and reporting procedures.- Our review acknowledges that areas in our current procedures could result in reporting inaccuracies, and we ascertain that these areas of our policies and procedures have now been formally updated to safeguard our future compliance. Changes and additions to current procedures will include a process of more timely reconciliation of monthly enrollment submissions, a more structured reconciliation of withdrawals and graduates, an annual review of the Department of Education's NSLDS Enrollment Reporting Guide, as well as an annual review/update of our internal policies and procedures. Additionally, the Director of Title IV Compliance will be responsible for enhanced bi-annual trainings of the College Registrar and of the Assistant Dean of Academic Services and Retention on the requirements and importance of NSLDS reporting. As these positions are key to data accuracy, NSLDS reporting functionality and our subsequent compliance with Federal regulations, it is paramount to note that whenever administrative turnover occurs, the new employees must be fully trained in the requirements of NSLDS reporting.

2022-003 Significant Deficiency: National Student Loan Data System (NSLDS) Report (U.S. Department of Education, William D. Ford Direct Loan Program, ALN #84.268 and Federal Pell Grant Program, ALN #84.063) Name of Contact Person Melissa White, Director of Financial Aid is responsible to upload data to clearinghouse Corrective Action Planned During the audit, it was noted that Tusculum reported the incorrect date to NSLDS for the withdrawal date. Anthology reported the status date instead of the true withdrawal date. Therefore, if a student withdrew on January 1st but the status was not updated until January 4th. The report would pull January 4th instead of the true withdrawal date of January 1st. Tusculum University has since converted back to Colleague which pulls the true withdrawal date versus the status date. Colleague was the system used in the prior to Anthology that correctly reported withdrawal dates. With this conversion back, and the data exporting the true withdrawal date versus the status date, all student withdrawal dates should pull correctly. Anticipated Completion Date The University begun conversion back to Colleague in August 2022. The Majority of conversion from Anthology back to Colleague has been completed for this section to pull correctly as of March 2023.

2022-002 Significant Deficiency: National Student Loan Data System (NSLDS) Report (U.S. Department of Education, William D. Ford Direct Loan Program, ALN #84.268 and Federal Pell Grant Program, ALN #84.063) Name of Contact Person Melissa White, Director of Financial Aid is responsible to upload data to clearinghouse. Corrective Action Planned During the audit, it was noted that Tusculum did not supply status updates to NSLDS in a timely manner, within the 60-day window. Due to staffing changeover and system conversions, the data and personnel were not available to provide timely notifications to NSLDS. With conversion back to Colleague from Anthology, the data element this error has been resolved. As for personnel, the Director of Financial Aid shall export and upload the data to clearinghouse. If the Director of Financial Aid is not available to upload the data, then the Associate Director of Financial Aid shall upload the data the moment that notice if given that the Director of Financial Aid is unable to upload the data. Anticipated Completion Date The University begun conversion back to Colleague in August 2022. The Majority of conversion back to Colleague which should have this issue resolved as of March 2023.

2022-001 Significant Deficiency: National Student Loan Data System (NSLDS) Report (U.S. Department of Education, William D. Ford Direct Loan Program, ALN #84.268 and Federal Pell Grant Program, ALN #84.063) Name of Contact Person Melissa White, Director of Financial Aid is responsible to upload data to clearinghouse. Corrective Action Planned During the audit, it was noted that Tusculum reported student enrollment status at changes in enrollment incorrectly. Tusculum University has undergone a system conversion from Colleague to Anthology. With this system version, Anthology reported student enrollment status by program version instead of student type. This caused the data to pull incorrectly when being exported out of the system to report to Clearinghouse. Tusculum University has since started conversion back to Colleague. Colleague pulls student enrollment based off of student status. Colleague was previously utilized by Tusculum and correctly pulled enrollment status by student to properly report to Clearinghouse. With this conversion back, and the data exporting student type versus program version, all student enrollment status should pull correctly. Anticipated Completion Date The University begun conversion back to Colleague in August 2022. The Majority of conversion from Anthology back to Colleague has been completed for this section to pull correctly as of March 2023.

2022-005 Significant Deficiency: Return to Title IV Funds (U.S. Department of Education, William D. Ford Direct Loan Program, CFDA #84.268; Federal Pell Grant Program, CFDA #84.063; Federal Supplemental Opportunity Grant Program, CFA #84.007; and TEACH Grant Program, CFDA #84.379) Name of Contact Person Melissa White, Director of Financial Aid is responsible for R2T4 calculations. Corrective Action Planned During the audit, it was noted that the University used the incorrect number of total days in the payment period or period of enrollment in calculating the percentage of payment period and/or period of enrollment completed. To correct this measure, Financial Aid has created a two-step measure where the Director of Financial Aid creates the calendar and the Associate Director of Financial Aid checks the calendar. In addition, when performing each R2T4, the Director of Financial Aid shall perform the initial calculation on the R2T4 form found in the student aid handbook. Then, the Associate Director of Financial Aid will also perform the calculation within Colleague independently of the hand done calculation by the Director of Financial Aid. Once finished with the preliminary calculation in Colleague, the Associate Director will then compare the calculation to the hand done calculation on paper by the Director of Financial Aid. If the information matches, then the Associate Director will process the changes in Colleague to the student?s account. If both do not match, both Director and Associate Director will review the calculation a third time and determine where the difference is coming from. Only once both Associate Director and Director of Financial Aid have matching numbers will the account by adjusted by the Associate Director of Financial Aid. Anticipated Completion Date The R2T4 calendar was fixed for fall in fall 2022 and the spring 2023 calendar was fixed in spring 2023.

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

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

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

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

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

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

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

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

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

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

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