Corrective Action Plans

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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