Corrective Action Plans

Views of Responsible Officials and Planned Corrective Action The HPU Office of Sponsored Projects (OSP) and Office of Financial Aid work to follow all federal reporting regulations and guidance mandated for the Federal grant & contract programs. For future programs, the Institutional Research, the Office of Sponsored Projects and the Financial Aid Office will generate the reports and will implement layers of review procedure to ensure that the reports are accurate, complete, submitted timely, and if needed, posted in HPU website. For the Institution portion, the Manager for Grants and Contracts will prepare the grant report and this report will be reviewed by the Assistant VP for OSP. For the student portion the periodic reports will be prepared by the staff of the Office of Financial Aid and will be reviewed by the Director of the Financial Aid office. The Business Office will perform a high-level independent review for completeness and accuracy. Finally, moving forward, all the files and documents that support the grant report will be retained. Person Responsible: Manager, for Office of Sponsored Projects & Assistant VP for Office of Sponsored Projects, Director of Financial Aid Targeted Correction Date: June 30, 2023.

Views of Responsible Officials and Planned Corrective Action The HPU Financial Aid Office works hard to follow all federal regulations and guidance mandated for the Title IV Federal Student Aid programs. In regards to the distribution of the Federal HEERF fund to HPU students, the HPU Financial Aid Director relied on reports from the SIS (Banner system), Institutional Research, and Accounts Receivable to determine students eligible for HEERF funds. The HPU Financial Aid Office and Office of Sponsored Projects worked hard, and diligently, to award funds to students and expend Institution portion based on the regulations that were provided at the time and not violating the intent of the program, as evidenced by there not being any non-compliance over allowability of costs charged to Federal HEERF fund. For future awards, the Principal Investigator with the assistance of the Office of Sponsored Projects will review diligently the expenditure to be sure the expenditures are within the allowability and terms and conditions of the federal awards. Both offices will work collaboratively so that the internal controls over allowability are strengthened and that the documentation will be strongly implemented and retained. For future programs, the HPU Financial Aid will work to strategically plan, organize, and disburse funds to students and expend Institution funds within the requirements mandated by the United States Department of Education, including strengthening our internal controls over compliance, and increasing the documentation and maintenance of documentation over our existing internal controls for compliance. Person Responsible: Manager, for Office of Sponsored Projects & Assistant VP for Office of Sponsored Projects, Director of Financial Aid Targeted Correction Date: June 30, 2023.

Contact person(s) responsible for corrective action - Amy Cavelier and Robert Wagstaff, Registrar?s Office Anticipated completion date ? August 31, 2023 Corrective Action The Registrar?s office will ensure proper controls and processes are in place to ensure program-level effective date information is properly and timely submitted to the NSLDS. Timeframe: June through August 2023 Responsible Parties: Amy Cavelier and Robert Wagstaff Goal: Registrar management and staff are working with the College?s Student Information Systems and IT departments to verify when and how the conflicting program-level effective dates were entered. At this point, we believe that the data originating from Jenzabar is correct. Discrepancies were created during the NSC error cleaning process, and data including those discrepancies were reported to the NSC and subsequently the NSLDS. Registrar?s Office management and staff are working with the NSLDS to obtain final student data reports which will be compared to the monthly student data files originally submitted to the NSC, prior to error correction, to identify the discrepancies and the cause of the data errors. The College is transitioning the enrollment reporting responsibility to another member of the Registrar?s Office. This transition will include formal training on the Jenzabar student information system, with a particular focus on NSLDS data reporting, as well as the NSC and NSLDS data submission processes. Our first Jenzabar training sessions have been scheduled for June 30 and July 7, 2023.

Student Financial Assistance Cluster ? Assistance Listing No. Various Recommendation: We recommend the Universities review their reporting procedures to ensure that students? statuses are accurately and timely reported to NSLDS and all errors are corrected within the appropriate timeframe as required by regulations. University of Maine at Fort Kent (UMFK) Condition: During our testing of 40 students, we noted five students at the University of Maine at Fort Kent (UMFK) whose campus enrollment date was not timely reported. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Registrar responsible for reporting campus enrollment during the year under audit left the position on August 15, 2022. The errors noted during the audit have been discussed with both the Interim Registrar and new Registrar to ensure understanding of and compliance with enrollment reporting requirements. In response to this finding, the new Registrar has worked very closely with the National Student Clearinghouse (NSC) to correct and update the required reporting dates through the next several terms. They have confirmed all dates in their calendar. The Director of Financial Aid now also receives reporting email notifications from the NSC as an internal control process for ensuring that reporting is occurring in a timely manner. Name(s) of the contact person(s) responsible for corrective action: Sara Best, Registrar for the University of Maine at Fort Kent Planned completion date for corrective action plan: Completed September 2022 University of Maine at Farmington (UMF) Condition: During our testing of 40 students, we noted for one student at the University of Maine at Farmington (UMF), the enrollment effective date did not match the enrollment effective date per UMF?s records. In addition, for one student, the program enrollment effective date did not match the program enrollment effective date per UMF?s records. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Immediate corrections to the reported dates were made upon notification of the finding. The Assistant Registrar runs the ?Student Clearinghouse File? report in its student system, MaineStreet, that transmits enrollment information to the National Student Clearinghouse (NSC). This reports both the enrollment effective date and the program enrollment effective date. In December 2021 the NSC implemented a new warning code series (1801 ? 1806) that kicks back any inconsistencies with the two dates as reported. To prevent similar errors in the future, a process has been implemented whereby the Assistant Registrar reviews these warnings and makes required corrections. UMF was previously sending a Degree Verify Report, which is a report run in MaineStreet, to the NSC three times a year for May graduates, August graduates and December graduates. We have changed our reporting timeline for graduates and are now sending the Degree Verify Report monthly to pick up any students who get cleared for graduation late. The Assistant Registrar who is responsible for reporting to the NSC is participating in the regular webinars provided by the NSC, to address reporting issues. Person responsible for corrective action: Lisa Beane, Assistant Registrar for the University of Maine at Farmington Planned completion date for corrective action plan: Completed July 25, 2022 University of Maine at Presque Isle (UMPI) Condition: During our testing of 40 students, we noted for two students at the University of Maine at Presque Isle (UMPI), the program enrollment effective date did not match the program enrollment effective date per the University?s records. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Registrar responsible for reporting campus enrollment during the year under audit left the position in July 2022. The errors noted during the audit have been discussed with both the Interim Registrar and new Registrar to ensure understanding of and compliance with reporting requirements. The new Registrar has updated policies and procedures regarding the reporting process and all reporting dates are confirmed in their calendar. The Director of Financial Aid now also receives reporting email notifications from the National Student Clearinghouse (NSC) as an internal control process for ensuring that reporting is occurring in a timely manner. In addition, the student records team at UMPI have received additional guidance and training from the NSC. Name(s) of the contact person(s) responsible for corrective action: Lisa Smith, Registrar for the University of Maine at Presque Isle Planned completion date for corrective action plan: Completed August 2022

Student Financial Assistance Cluster ? Assistance Listing No. Various Recommendation: We recommend the University evaluate its procedures and policies around reporting disbursements to COD to ensure that student information is reported accurately and timely. University of Maine at Presque Isle (UMPI) Condition: During our testing at the University of Maine at Presque Isle, we noted one Pell disbursement that was not reported within the required 15 days and two Pell disbursements where the disbursement date per COD did not match the disbursement date per the student?s account. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Following the May 2022 retirement of the staff member responsible for this task, we implemented a weekly process to ensure timely reporting to COD, as well as timely resolutions to any issues encountered in sending these files. We also trained additional personnel to send these files and identify/resolve issues in the files and to have a documented internal control process to track the sending, receipt and error resolution process of COD files. Name(s) of the contact person(s) responsible for corrective action: Connie Smith, Director of Financial Aid for the University of Maine at Presque Isle Planned completion date for corrective action plan: July 1, 2022 - We implemented the new weekly process as described above to ensure files are sent and issues are resolved in a timely manner. March 1, 2023 - All staff responsible for this new process have been trained to send and review these files.

Upon discovery of the over award, funds were returned for the student immediately. Moving forward, the Financial Aid team will implement a review process at the beginning of each term that will identify students nearing aggregate loan limits to ensure students are not over awarded.

Both the Financial Aid team and Student Accounts team have developed a weekly disbursement and posting schedule. A cut off time for processing will be implemented to ensure both dates are aligned and to accommodate any file response import delays.

We recommend the University review its reporting procedures to ensure that roster file submissions are reported timely to NSLDS as required by regulations.

The University contracted with National Student Clearinghouse (NSC). In the prior year, we identified a data exchange issue between our institution and NSC. We have now resolved that issue.

Springfield College June 30, 2022 Finding 2022-001 Fiscal Operations Report and Application to Participate Corrective Action Planned The Corrective Action Plan (CAP) has three components. First, the Director of Financial Aid will conduct additional training with the staff from the processing unit. The training will review the field in the financial aid management system that must be updated and the importance to the FISAP. This training is scheduled for the week of November 14, 2022. Second, we implemented a work-flow task in our financial aid management system to notify the financial aid counselor to review the academic grade level flag for each term the student is enrolled. This component was implemented on November 3, 2022. Third, prior to submission of the FISAP the Director will develop a report to detect academic grade level inaccuracies. The anticipated completion date for this component is September 2023. Person Responsible for Corrective Action Plan Troy A. W. Davis Anticipated Completion Date September 2023

Condition: There was lack of documentation related to disbursement notices and exit counseling for nine out of thirty-four students tested. Criteria: According to ?668.165, before an institution disburses title IV, HEA program funds for any award year, the institution must notify a student of the amount of funds that the student or his or her parent can expect to receive under each title IV, HEA program, and how and when those funds will be disbursed. Additionally, according to ?682.604, a school must ensure that exit counseling is conducted with each loan borrower and graduate either in person, by audiovisual presentation, or by interactive electronic means. Cause: The College was unable to locate the documents for the students as a result of transitioning softwares. Effect: Certain documentation for disbursement notices and exit counseling was lost during the transition of the College's software. Context: During the compliance audit testing of ALN 84.268 and ALN 84.379, it was determined that documenation to confirm delivery of disbursement notices and performance of exit counseling could not be provided for certain students selected for testing. Recommendation: We recommend all required documentation be backed up to support compliance with certain requirements. View of Responsible Officials and Planned Corrective Action: The College is currently working with their IT department to make sure that all types of communication includes copying the financial aid department email to make sure the College has support for all communications to prevent this in the future.

Finding 2022-003: Policies and Procedures Related to Packaging Student Financial Aid ? SFA Cluster (significant deficiency) Corrective Action: Lyon College has two employees in the Financial Aid office. We do have a process in place to review the packaging of new student aid (FTFT and TXFR), though it is very manual, and requires both FA employees to be involved (in order to separate duties). It is still not foolproof. Our current software will not prevent us from overpackaging subsidized loans in our manual packaging process, but we can run a report to check and see if the field marked `Awards to Report as Need-Based? is greater than the field marked `Original Need?. If any are found, we can make the necessary adjustment. In the packaging of returning students ? the larger group of students - we do not have a review process in place. We will review to see if we can find a practical way, with our current limited personnel, to implement a review process for returning student award packages. The overpackaged student was simply a human keystroke error. Sub (remaining need) was calculated to be $4,484 and we input $4,884, a transposition. This was a returning student who likely did not get reviewed, and we also failed to pick it up in the process described below, comparing original need to awards marked as need. Our current software will not prevent us from overpackaging subsidized loans in our manual packaging process, but we can run a report to check and see if the field marked `Awards to Report as Need-Based? is greater than the field marked `Original Need?. If any are found, we can make the necessary adjustment. The other student was underpackaged with subsidized loans. In this case, the student was packaged on 7/15 based off of the only FAFSA we had available at that time, received on 6/29. On that FAFSA, the student had an EFC of $28,180, and no need. Therefore, all loans ($7,500) were packaged as unsubsidized. A PLUS loan denial came in the next day and the additional $5,000 was also packaged as unsubsidized. On 8/4, a revised FAFSA came in showing an EFC of $5,119. No adjustment was made to reclassify part of the loans as subsidized based on the `need? shown on the revised FAFSA. The Financial Aid Office believes that running the comparison report mentioned above on a regular basis will help us to find over-packaged need-based loans that we either made a mistake on during our initial packaging process, or due to a revised FAFSA that created additional need. Proposed Completion Date: The FAO will begin running the `Original Need vs. Aid Packaged As Need? Report on a monthly basis, and most importantly, in August immediately before aid is originated and disbursed.

Finding 2022-002: Policies and Procedures Related to Withdrawals ? SFA Cluster (significant deficiency) Corrective Action: The ?Timely Reporting? issue resulted from a misunderstanding in the Registrar?s Office regarding the requirements of what had to be reported and by when. We have discussed this issue with that office?s personnel and established procedures designed to prevent it from happening in the future. The ?Funds Not Returned Timely? reflects continued improvements resulting from policies already established to enhance compliance with attendance reporting and tracking of those reports by the Registrar and Financial Aid Offices. The College will continue to reinforce compliance with the attendance monitoring and reporting policy, as well as refine procedures for active monitoring of those reports by these two offices. In particular, the process of evaluating whether students who are on the two-week absence report in any one class are in fact at risk of falling out of enrollment status overall. Proposed Completion Date: June 30, 2023

October 14, 2022 U.S. Department of Education 400 Maryland Avenue, SW Washington, D.C. 20202 Re: Corrective Action Plan Finding 2022-001: Federal Direct Student Loan Enrollment Reporting Program: Federal Direct Loan Programs Assistance Listing Number (ALN): 84.268 Federal Agency: U.S. Department of Education Federal Award Identification Number: P268K22059 Federal Award Year: June 30, 2022 Condition: For 3 of 25 students included in our sample, the enrollment status of withdrawn were reported late (61 days after the determination date of separation). The sample was not a statistically valid sample. Corrective Action Plan Management agrees with the finding, and is committed to strengthening its procedures to avoid similar issues in the future. Beginning in September 2022, a second Registrar?s Office staff member will complete an additional review of the National Student Clearinghouse status for all students withdrawing after a particular semester. This secondary review will be completed at the end of January and at the end of June in order to ensure the 60 day reporting period is met. Nathan Engle Controller

2022-001: Reporting Management?s view and corrective action plan Management concurs that FISAP for the Federal Perkins Loan program contained incorrect amounts for ?Cash on hand and in depository? as of 6/30/22 and 10/31/22. The misstatements were due to clerical errors and insufficient review prior to submission. Management will implement an enhanced review process to validate all amounts reported on the FISAP prior to submission. Implementation date: July 2023 Ronald Keller Vice President for Finance & Controller

2022-003: Enrollment Reporting Management?s view and corrective action plan Management concurs with the findings regarding the delay and insufficient graduation reporting to NSLDS. The University Registrar is aware of the 6-day delinquency in reporting for summer term due to the timing of the degree awards for the May graduates on the East Falls campus. Degree audits will be checked to ensure are awarded in a timely manner. We also will work with NSC to ensure all enrollment reporting schedules are updated in accordance with the academic calendar of the appropriate branch, limiting any issue with the 60-day certification date during our Summer term, as all other terms have been reported correctly. This will happen every semester on a 4?6 week basis, in tandem with enrollment report submissions. This will resolve the 60-day certification issue. Academic Services makes every effort to report clean enrollments accurately and on time. However, we continue to find inconsistencies with the NSC transmissions to NSLDS and are aware of the need for additional oversight of the NSC process as well as the development of a process to audit NSC transmissions to NSLDS. This will also aid in the elimination of reporting errors between NSC and NSLDS, as in the case of the three graduation records. The Office of Academic Services is working to identify resources to address the above action plans. Implementation date: July 2023 Raelynn Cooter Vice Provost for Academic Infrastructure and Effectiveness

Finding 2022-001: Enrollment reporting Condition: For 5 out of 25 students tested for NSLDS reporting, it was noted that these students were not reported within 60 days as required for all schools participating in Title IV aid. Crowe had management perform an independent analysis in order to quantify the total number of students with enrollment reporting issues due to the 5 identified as part of our testing. Through further testing procedures performed and analysis performed by management it was noted that a total of 38 students were not reported timely to the NSLDS. Recommendation: We recommend that the University enhance its review and monitoring of the enrollment reporting to NSLDS to ascertain accuracy and timeliness of the submission. Views of Responsible Officials Management agrees with the finding related to enrollment reporting. Management has taken steps to change the process, adding review of filings by the Office of the Registrar, Financial aid, and Institutional Research. Additionally, a calendar has been created for future reporting dates of enrollment reports and degree conferral reports to be filed with the National Student Clearinghouse. Corrective Action Plan Management is developing a new process for reporting student enrollments. The Office of Institutional Research will review the specifications for reporting from the National Student Clearinghouse (NSC) and National Student Loan Data System (NSLDS) to ensure that the proper data is being reported. The Office of the Registrar will develop an annual calendar of filing dates for enrollment and graduation reports. Reports will be generated by Institutional Research and upon approval of the Registrar submitted to the NSC. Any errors in reporting will be remediated by the Registrar. And the Financial Aid Office will verify that reports sent to the National Student Clearinghouse are accurately reported to the National Student Loan Data System, by auditing both systems with assistance from the Office of institutional Research and Office of the Registrar. This process will be in place by February 2023.

Financial Statements Management?s Response and Planned Corrective Action: On identification of the issue, management confirmed that August 22, 2022 was the only date for which the notifications were not sent out properly. This issue resulted from a lack of sufficient staff and significant turnover around August 2022. Management promptly updated procedures and training to clarify to accounts payable personnel the correct parameters for the Direct Loan notifications and are working to put in place additional review controls. No further action related to the August 22, 2022 disbursements was considered necessary as students who received these disbursements would have received subsequent disbursements in which proper notification was sent. Corrective Action Plan Pages Finding Number: 2022-002 Federal Assistance Listing Number: 84.268 Federal Direct Loans Year Ended: August 31, 2022 Responsible Individual: Joanne Hammond Associate Comptroller Management?s Response and Corrective Action Plan: The College agrees with the finding and recommendation. There were no notifications sent out for direct loan disbursements on August 22, 2022. The College verified that this was the only day affected by reviewing each disbursement date related to the fiscal year 2022 and verifying inputs into the notifications were done correctly. The error was corrected the next day and notifications were appropriately sent since August 23, 2022. A list of all students who received Direct Loans on August 22, 2022 was obtained and reviewed, noting that this affected 909 students. Management promptly updated procedures and training to clarify to accounts payable personnel the correct parameters for the Direct Loan notifications and are working to put in place additional review controls. No further action related to the August 22, 2022 disbursements was considered necessary as students who received these disbursements would have received subsequent disbursements in which proper notification was sent. The above procedures have already been implemented.

Management?s Views and Corrective Action Plan 2022-001 ? Loan Disbursement Notifications Award Information Cluster: Student Financial Assistance Grantor: Department of Education Award Name: Federal Direct Student Loans Award Year: July 1, 2021 ? June 30, 2022 AL Number: 84.268 The University of Massachusetts acknowledges that some students did not receive their notifications informing them of the 30 day right-to-cancel for their Federal Direct Loans within the prescribed timeframe of no later than 30 days before, but no later than 7 days after the date of disbursement. The University has implemented an automated communication process with built in internal reviews that will ensure all borrowers are notified within the required timeframe. For further details regarding the corrective action plan, contact the Assistant Vice President and University Controller, Patrick Hitchcock, at phitchcock@umassp.edu.

Responsible Contact Person(s): Ida Witherspoon, Chief Financial Officer Corrective Action Planned: Send periodic e-mail reminders to program staff responsible for submitting FFATA data to the Federal Reporting Unit for submission to the federal government. Estimated Completion Date: 12/31/2023

The Business Director will establish Google Calendar reminders for upcoming due dates for expenditure reports. See full Corrective Action Plan on district letterhead.

Corrective Action Plan For the Year Ended May 31, 2022 Finding 2022-001 Assistance listing number(s), federal agency, and program name: 84.063, 84.007, 84.033, and 84.268; United States Department of Education (DOE), Student financial aid cluster. Finding type: Noncompliance and significant deficiency in internal control over compliance Statement of condition: Certain student records within the National Student Loan Data System (NSLDS) were identified with inaccurate data elements. Management's review of the enrollment reporting did not detect errors on certain student data elements. Context: Five students were identified with inaccurate data elements reported out of a total of 40 students tested. Cause: The preparer incorrectly input the student's status into NSLDS resulting in inaccuracies in significant Campus-Level and Program-Level enrollment data elements that ED considers high risk. The Institute?s internal control over compliance did not detect and correct the error. Effect: The Institute incorrectly reported certain Campus-Level and Program-Level records in NSLDS which is information that DOE considers high risk and the Institute?s internal controls over compliance did not detect and correct the errors. Recommendation: We recommend management review policies and procedures surrounding enrollment reporting submissions to ensure the accuracy of data elements reported to DOE. A review performed by an appropriate individual separate from the preparer prior to the submission of the enrollment reports to NSLDS may improve the accuracy of enrollment reporting. Status completed Corrective Action Management agrees with the finding. Through internal investigation, it was determined that the issue arose through National Student Clearinghouse (NSC), which reports the Institute?s data to NSLDS. Management will work with NSC to assure graduates are accurately reported as soon as possible within existing external systems. The changes to management?s enrollment reporting procedures will be added to the Institute?s NSC submissions procedure documentation. Contact Jean Weimer Registrar 414-847-3272 jeanweimer@miad.edu submitted 2/23/2023

2022-001 Student Financial Aid Cluster - Assistance Listing No. 84.268 Recommendation: We recommend the College reviews outstanding checks regularly to ensure funds are returned to the Department of Education before 240 days of the original disbursement attempt. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: MCC will implement a process to review outstanding checks on a timely basis which will allow time to contact student and reissue payment. If student can not be found, funds will be returned to the Department of Education either through COD or direct payment prior to the required 240 days. Name(s) of the contact person(s) responsible for corrective action: Lewis Hendrickson Planned completion date for corrective action plan: Prior to Fall 2023

FINDING 2022-004? COD Disbursement Dates Program Name: TEACH Grant Federal Pell Grant Program ALN and Program Expenditures: 84.379 ($9,410) 84.063 ($684,817) Award Number: P379T223315 P063P213315 Federal Award Year: July 1, 2021 to June 30, 2022 Questioned Costs: $-0- Condition Found: The Common Origination and Disbursement System (?COD?) disbursement date did not agree with the disbursement date on accounts for two of the three students receiving TEACH Grants and two of the thirty students receiving Federal Pell Grant funds in our sample. A total of four students were affected by this finding. Corrective Action Plan: The Student Financial Aid Director created a ticket with the third party administrator to have them correct the disbursement dates for the students in question in COD in November 2022. The corrections were made in December 2022. Going forward, the Student Financial Aid Director will verify the disbursement dates agree when the payments are made. Anticipated Completion Date: The corrective action was completed in December 2022. Contact Person: Cliff Bristow, Director of Financial Aid 405-912-9037

FINDING 2022-005 ? NSLDS Reporting Program Name: Federal Direct Student Loan Program ALN and Program Expenditures: 84.268 ($1,119,033) Award Number: P268K223315 Federal Award Year: July 1, 2021 to June 30, 2022 Questioned Costs: $-0- Condition Found: The incorrect enrollment status was reported to the National Student Loan Database System (?NSLDS?) for nine of the forty students selected for testing. Corrective Action Plan: Management agrees with this finding The Student Financial Aid Director corrected the enrollment status and withdrawal date for the students in question in November 2022. Procedures have been improved to ensure the information is communicated timely to the third-party servicer and that third-party servicer reports the changes to NSLDS timely. Anticipated Completion Date: The corrective action was completed in November 2022. Contact Person: Cliff Bristow, Director of Financial Aid 405-912-9037