Corrective Action Plans

Inaccurate Return of Title IV Funds (R2T4) Planned Corrective Action: A master schedule has been created that includes the starting date, ending date, and break dates for each term. The break dates provided and used previously were not accurate and the master schedule provides the document all departments will use going forward. This will fix the issue involving the incorrect number of days used in the R2T4 calculations. Per the auditor?s recommendations, the institution has hired an experienced professional with over fifteen years of experience in Title IV processing to complete the R2T4 calculations. Person Responsible for Corrective Action Plan: Wes Brothers, Financial Aid Director Anticipated Date of Completion: Completed 3/9/2023

Finding: 2022-001 Student Financial Assistance Cluster Special Tests and Provisions Department?s Response: We concur Corrective Action: This finding was due to human error. The spreadsheet was copied from the last year, and dates were updated to be the current year. The past year may have had a holiday which caused the G5 funds to be received an additional day before the disbursement date. When updating the dates to the current year, the 4 days was not caught. The form was only reviewed by the Director of Financial Aid. To prevent this error from occurring in the future, 3 members of the Finance Team will review and approve the Disbursement schedule so that there are 3 sets of eyes reviewing the dates. These 3 members will include the Director of Financial Aid, and any 2 of the following: Accounting Manager, Staff Accountant, Registrar, or Business Office and Bookstore Manager.

Finding 2022-001 - Enrollment Reporting Federal Program - Student Financial Assistance Cluster Federal Agency - U.S. Department of Education Pass-Through Entity - Not Applicable ALN - 84.007, 84.033, 84.038, 84.063, 84.268 Federal Award Year - June 30, 2022 Criteria: Title IV regulations (34 CFR 685.309(b)) require that upon receipt of an enrollment report from the Secretary, institutions must update all information included in the report and return the report to the Secretary: (i) in the manner and format prescribed by the Secretary; and (ii) within the timeframe prescribed by the Secretary. Unless it expects to submit its next updated enrollment report to the Secretary within the next 60 days, an institution must notify the Secretary within 30 days after the date the institution discovers that: (i) a loan under Title IV of the Act was made to or on behalf of a student who was enrolled or accepted for enrollment at the institution, and the student has ceased to be enrolled on at least a half-time basis or failed to enroll on at least a half-time basis for the period for which the loan was intended; or (ii) a student who is enrolled at the institution and who received a loan under Title IV of the Act has changed his or her permanent address. Condition/Context: The change in student status for 6 of 25 students tested was not reported to the National Student Loan Data System (NSLDS) within 30 days or included in a response to a roster file within 60 days. A statistical sample was not used. Cause: The College failed to follow its procedures for reporting student status changes. Effect: The accuracy of Title IV student loan records depends heavily on the accuracy of the enrollment information reported by institutions. If an institution does not review, update, and verify student enrollment statuses, effective dates of the enrollment status, and the anticipated completion dates, then the Title IV student loan records will be inaccurate in NSLDS. Questioned Costs: None. Recommendation: The College should review its policy on enrollment reporting to NSLDS. Views of Responsible Officials and Planned Corrective Actions: Graduated Student Reporting: After submitting the end of term enrollment file for semester, the Registrar's Office (Assistant Registrar) submits a Graduates-Only Enrollment File to National Student Clearinghouse (NSC) for that semester. Any degrees conferred after the graduates only file will be entered manually on the NSC website. This process will report a graduated status for any student who graduated at the end of that semester. NSC will pass the graduated status along to NSLDS on the next student status change confirmation report (SSCR). Withdrawal Students Reporting: Formal withdrawals during the semester are reported on the next subsequent of term enrollment file that is sent to NSC. Students who formally withdraw between semesters, are reported manually to the NSC website. The clearinghouse will pass the withdrawn status along to NSLDS on the next SSCR. While the above procedures were in place for the 2021-22 fiscal year, staff turnover in the Registrar?s Office made it difficult to maintain and submit the appropriate files and manual entries to NSC. Management does not foresee this to be an issue moving forward. New staff members have been hired and trained on the appropriate procedures to ensure these internal controls are in place and effective for the required enrollment reporting. If the Assistant Registrar position would become vacant in the future, the Registrar would be responsible for NSC submissions until the position could be filled. Name(s) of Contact Person(s) Responsible for Corrective Action: Sara Zucker (Registrar), Michael Saunders (Assistant Registrar) Anticipated Completion Date: January 2023

College's Response: We concur. 2021-22 Audit indicated that two Pell Grant disbursements were not reported within the 15-day timeframe stipulated in Federal Register Volume 82, Number 122. The origination records were resolved and sent to COD (processing platform) 16 days after Pell paid to the account. Both instances involved a professional judgment review allowing the college to award additional Pell to families. This process can create delays. Corrective Action Plan: An automated report runs daily to identify disbursement dates 5 days old that have not been acknowledged by the Department of Education. This allows us an additional 10 days to confirm all disbursements are reported and accepted within the 15 day requirement. An additional step has been added to confirm if the origination record is rejected, the Pell record is locked preventing disbursement prior to having an accepted origination record. Responsible Party: Joseph Weglarz, Executive Director, Student Financial Services Proposed Completion Date: January 26, 2023

CASE FILE REVIEWS Federal Agency: U.S. Department of Health and Human Services and U.S. Department of Agriculture Federal Program Title: Medical Assistance Program (Medicaid Cluster), Temporary Assistance for Needy Families (TANF), Title IV-E Foster Care and State Administrative Matching Grants for Supplemental Nutrition Assistance Program (SNAP Cluster) Assistance Listing Number: 93.778, 93.558, 93.685 and 10.561 Pass-Through Agency: Minnesota Department of Human Services and Minnesota Department of Agriculture Pass-Through Numbers: 2205MN5ADM, 2201MNTANF, 2201MNFOS and 222MN101S2520 Award Period: Year-Ended December 31, 2022 Type of Finding: Significant Deficiency in Internal Control over Compliance Recommendation: It is recommended the County perform case file reviews on a more representative sample of the total clients served and that adequate documentation be retained of those reviews. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The County will conduct a training session for health and human services staff regarding procedures required for case file reviews. Name of the contact person responsible for corrective action plan: Anne Lindseth, Health and Human Services Director Planned completion date for corrective action plan: December 31, 2023

FINDING 2022-004: Untimely Paid Credit Balance A. Comments on Findings and Recommendations: In response to the untimely paid credit balance, Brillare Beauty Institute agrees with the Single Audit Finding 2022-003. B. Actions Taken or Planned: Brillare Beauty Institute had resolved the student account credit balance issue but not in the required time. Brillare Beauty Institute hired an additional Financial Aid Officer in February 2022 to help with administering the Title IV program. The new position gave the institute the ability to have an additional set of eyes reviewing many of our processes to ensure compliance. At the time of this error, training of the new employee was still in process.

FINDING 2022-003: Under awarded Federal Direct Subsidized Loan A. Comments on Findings and Recommendations: In response to the under awarded Direct Subsidized Loan, Brillare Beauty Institution agrees with the Single Audit Finding 2022-002. B. Actions Taken or Planned: Brillare Beauty Institute has resolved the 2021-2022 award year regarding the under awarded Direct Subsidized loan. The 2021-2022 financial aid award year was re-opened and the under award loan amount was reallocated from Direct Unsubsidized to Direct Subsidized in Common Origination and Disbursement. Brillare Beauty Institute hired an additional Financial Aid Officer in February 2022 to help with administering the Title IV Direct Loan program. At the time of this error, training of the new employee was still in process. Also, Brillare Beauty Institute has contracted with a new 3rd Party Financial Aid Servicer as of December 2022 and as part of this transition, both reviewed and strengthened our Federal Direct Loan policies and procedures.

FINDING 2022-002: Over awarded Pell Grants A. Comments on Findings and Recommendations: In response to the under awarded Pell Grant, Brillare Beauty Institute agrees with the single audit finding 2022-001. B. Actions Taken or Planned: Brillare Beauty Institute has resolved the student under award Pell grant issue. The student was given a check by the Institute to rectify the under-awarded Pell Grant amount to be received. Brillare Beauty Institute has contracted with a new 3rd party Financial Aid Servicer as of December 2022 and as a part of this transition, both reviewed and strengthened our Pell grant policies and procedures. This revision took place after the student's 2021-2022 Pell grant disbursements.

A. Comments on Findings and Recommendations: 2022-001 - Missing Proof of Loan Entrance Counseling. It seems that the student may not have completed entrance counseling. When this student started, MCU was contracted with Weber as its Third- Party Servicer who used to check entrance counseling before processing our students. Since 2020, MCU has been contracted with Campus Ivy whose platform now requires the Financial Aid Department to upload the entrance counseling proof before processing can occur. B. Actions Taken or Planned: 2022-001 - Missing Proof of Loan Entrance Counseling. The student in question has now performed the required Entrance Counseling. Since May 2020, MCU's updated entrance counseling process with Campus Ivy has helped mitigate a risk of gaps with regard to the completion of entrance counseling. MCU will perform an internal review on current students enrolled before May 2020 to ensure entrance counselings are complete.

A. Comments on Findings and Recommendations: 2022-003 - Untimely Enrollment Status Reporting. The Financial Aid Department has a consistent procedure surrounding NSLDS updates, but like many schools, encountered some technical issues over the summer when the NSLDS platform was updated. B. Actions Taken or Planned: 2022-003 - Untimely Enrollment Status Reporting. MCU switched over to Campus Ivy performing its NSLDS reporting in December 2022 which helps eliminate the duplication of efforts in updating CORE and NSLDS. This should also help to close any potential gaps in reporting.

A. Comments on Findings and Recommendations: 2022-002 - Incorrect Refund Calculations. This seems like a simple administrative error surrounding the break and that the break should have been included. The Financial Aid Operations Administrator was still in their final R2T4 training phase at this point in 2022, having taken on the task during the prior year. B. Actions Taken or Planned: 2022-002 - Incorrect Refund Calculations. The Financial Aid Department has updated their internal procedures for R2T4's to make them even more robust, adding further emphasis on the scheduled trimester break section within its R2T4 template. This should help further mitigate the risk of mix up when performing a few at the same time. MCU will refund the resulting overage to the student.

Finding 2022-001 ? Underawarded Pell Grants: During the audit, it was noted that two students were not awarded the full amount of their allowable Pell grants. It was recommended that the school credit the appropriate students? accounts $1,077. The Institution agrees with the finding. The school has made the appropriate corrections to the student accounts and both students have received their additional funding. The Institute recognized that our 3rd party Servicer was not disbursing the correct amount of Pell grant funds and requested that they complete a full audit of disbursements, the error on their end has been corrected and should not lead to additional findings moving forward.

Finding 2022-003 ? Late Refunds: During the audit, we noted two students who did not have refunds returned to the Department in a timely manner. The Institution agrees with the finding. The Institute acknowledges that the lag time between registration and financial aid did contribute to this issue. Similar to the resolution above, the director will continue to monitor these issues and work between the financial aid and business offices to ensure that refunds are made in a timely manner.

Finding 2022-002 ? Incorrect Refund Calculation: During the audit, one student had an incorrect refund calculation resulting in $1,592 that should be returned to the Department of Education. The Institution agrees with the finding. The erroneous action happened due to administrative oversight, the refunds to the Department have been completed in the amount of $211.00 Pell grant and $1,381 in Subsidized Direct loan funds. The school understands the importance of calculating the Title IV refund correctly, as a new financial aid administrator and director move into these roles, more oversight from the director position will be initiated.

Finding 2022-004-- Inaccurate Program Data to NSLDS Management Response: Beloit College?s IT and Registrar?s Office identified the issue in the software system causing the incorrect dates to populate and are working to correct it. Because the Registrar pulls the program information out of the software system, the correct information will be provided as soon as the software issue is remedied. After the software issue is fixed, the Financial Aid Office will audit program level data for accuracy no less than once per semester. Anticipated Completion Date March 1, 2023 Contact Person: Betsy Henkel, Director of Financial Aid henkelb@beloit.edu, 608-363-2662

Finding 2022-003 -- Incorrect Enrollment Reporting to NSLDS Management Response: Management agrees with this finding. The Registrar and Financial Aid Office share a report to process mid-semester withdrawals. An additional column was added to this shared report to more clearly display the date the Registrar should be reporting to the NSLDS when a student withdraws mid-semester. Furthermore, the Financial Aid Office will audit the effective dates reported for mid-semester withdrawals to verify the Registrar is reporting the correct dates. Anticipated Completion Date December 1, 2022 Contact Person: Betsy Henkel, Director of Financial Aid henkelb@beloit.edu, 608-363-2662

Finding 2022-002-- Late Enrollment Reporting to NSLDS Management Response: Management agrees with this finding. Beloit College?s Registrar will exercise the option to use the ad hoc NSC reporting tool to ensure that timely enrollment reporting updates are received by NSLDS. Anticipated Completion Date October 15, 2022 Contact Person: Betsy Henkel, Director of Financial Aid henkelb@beloit.edu, 608-363-2662

U.S. Department of Education 2022-003: Student Financial Aid Cluster ? Student Eligibility and Awarding ? Assistance Listing Number: Various Recommendation: We recommend that the College implements a process that will ensure all Title IV funds are awarded at proper amounts. Action taken in response to finding: This student was awarded an incorrect amount because a subsequent ISIR transaction was received but the Pell was not recalculated on the basis of the new information. After this discovery, we have taken the following actions in response: ? We examined our ISIR import process to make sure that our means of communicating locked transactions was functioning correctly. We found that our system for monitoring new transactions was deficient; if a set of conditions were aligned, a new transaction could slip by our notice. Implemented by August 2022. ? We added another layer of review wherein the output of both the messages we receive from our third-party verification partner and our internal reports associated with importing ISIRS are examined on a regular basis. New transactions on students with a current locked transaction are reported to staff members for further review. Implemented by August 2022. ? We wrote an ad hoc report that allows us to identify subsequent ISIR transactions and will run it regularly to reduce the likelihood of this issue occurring again. Implemented by August 2022. Name(s) of the contact person(s) responsible for corrective action: Alysa Borelli, Dean of Enrollment and Student Services. Planned completion date for corrective action plan: The corrective action plan was implemented by August of 2022.

U.S. Department of Education 2022-004: Student Financial Assistance Cluster ? 240 Days Outstanding Check ? Assistance Listing Number: Various Recommendation: We recommend the College to update its procedures and procedures for processing and monitoring refund checks to ensure compliance with the Title IV requirements. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: During the 2021-22 aid year, the financial aid and fiscal services departments have been working hard together to clean up and streamline the process by which we handle stale-dated ?financial aid checks? (Title-IV funds processed through BankMobile) as well as ?student refund checks? (non-Title IV funds processed through our district office). In our review, we found that three students had Title IV aid incorrectly processed as ?student refund checks? whose initial disbursement date was more than 240 days before the date of discovery. As a result, we reported those checks to the auditors when asked for outstanding Title IV checks. We have taken the following actions in response to this item: ? We have developed a ?Time Out / Reversal? workgroup that includes members of both the financial aid and fiscal services department to ensure that reissuance of checks does not occur automatically (pre-existing, but this workgroup allows us to address this issue). ? We have trained the workgroup members specifically on the importance of the 240 day limit. Implemented by September 2022. ? We continue to improve the communication between the financial aid and fiscal services. department. We currently hold meetings every two weeks to bring up any common issues and solve problems related to the administration. Implemented by September 2022. Name(s) of the contact person(s) responsible for corrective action: Alysa Borelli, Dean of Enrollment and Student Services. Planned completion date for corrective action plan: The corrective action plan was implemented by August of 2022.

U.S. Department of Education 2022-001: Student Financial Assistance Cluster ? NSLDS Enrollment Reporting ? Assistance Listing Number: 84.007, 84.033, 84.063, 84.268 Recommendation: We recommend the District review its report procedures to ensure that the enrollment and program information is accurately reported to NSLDS as required by regulations. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Repeat finding was unavoidable as we were unaware we were out of compliance until we were over half-way through the current year (21-22). Alysa Borelli, Dean of Enrollment Services contacted the National Student Clearinghouse (NSC) for guidance on what was causing our NSDLS errors and since has restructured when Solano is supposed to report to NSC. Solano has not been reporting in the correct part of the month for the NSDLS roster to pick up an accurate enrollment snapshot, which is the root cause of all of the findings under this header. Solano has received updated training for all staff who are responsible for submitting to NSC. Additionally, the staff member that used to submit who was not submitting at the correct time as removed from this task and replaced. Solano will be following the new protocols starting with Spring 2023 semester and does not expect this to be a repeat finding. It was known that 2nd year findings were unavoidable. Name(s) of the contact person(s) responsible for corrective action: Alysa Borelli, Dean of Enrollment and Student Services. Planned completion date for corrective action plan: All training and adjustments to our processes was completed in December 2022.

Finding 2022-001 ? Special Tests and Provisions ? Enrollment Reporting (Student Financial Assistance Cluster) Contact Person: Christina F. Villanueva, Registrar, Office of the Registrar Current Status: Corrected Anticipated Completion Date: October 17, 2022 Condition: For two of 40 students selected for testing, campus and program-level data did not agree between the University?s records and the information submitted to NSLDS with regards to the date of the withdrawal. The withdrawal date reported to NSLDS is obtained from the date the student?s enrollment status is changed in the ERP system. The University did not have effective procedures in place to ensure the student?s enrollment status date agreed to the date the student withdrew from courses. Corrective action: To ensure discrepancies between the actual course withdrawal date and the student?s enrollment status date are identified, the University has created an automated process that currently runs every 30 minutes. This process identifies students who are not actively enrolled but have an eligible enrolled status. It also compares the course withdrawal date to the enrollment status change date. If a discrepancy is identified, a notification is sent to the Registrar?s Office and School of Law notifying them of the need for further review and correction.

TOCC RESPONSE TO 2022-002 Submission of Single Audit Reports (Material Weakness). We agree with the finding. To improve TOCC?s financial reporting process and ensure timely completion of our annual single report, the TOCC will take the following steps: 1. The Dean of Finance, Controller, and an additional contracted expert are developing and implementing a project plan that outlines all necessary tasks and timelines for completion. That information will be used by the President and Administrative Council in a report to the Board of Trustees semi-annually; 2. The group will arrange regular check-ins and progress reviews to ensure that all tasks are on track. 3. TOCC will make more use of the Data Management System?s technology and automation tools to streamline the process of financial reporting, reduce the workload, and decrease potential for human error resulting from manual processes; 4. To ensure compliance with the latest financial regulations and requirements, administration will provide finance and accounting staff with needed training and professional development. 5. Additional accounting support has been and will be employed to review procedures and to assist with tasks as the need indicates. 6. TOCC?s adherence to this corrective action plan will ensure that the audit will be completed by the single audit deadline of March 31, 2024.

2022-001 Federal Agency: Department of Education Federal Programs: Federal Supplemental Educational Opportunity Grants (FSEOG), Federal Pell Grant Program, Federal Direct Student Loans Assistance Listing Numbers: 84.007, 84.063, 84.268 Condition Special Tests and Provisions - Return of Title IV Funds The Purdue Fort Wayne campus did not properly design or implement an effective internal control system to ensure compliance with the requirement for timely return of funds related to the Special Tests and Provisions - Return of Title IV Funds. Specifically, there was a lack of timeliness in initiating a return of Title IV funds, causing a return to be issued more than 45 days after the date the University became aware of student's withdrawal date. Views of Responsible Officials and Corrective Action Plan Contact Person Responsible for Corrective Action: Ron Herrell, Director of Financial Aid Contact Phone Number: 260-481-6242 The PFW Office of Financial Aid has an established Return of Title Four Aid (R2T4) policy and underlying control structure in place to ensure compliance with the R2T4 requirements. The PFW Office of Financial Aid will enhance its current R2T4 policy and procedure to include a step-by-step process to completing an R2T4. This will ensure that in the absence of the Assistant Director of Loans (who is currently responsible for R2T4 calculation completion) a succession list determining who is next in line to complete R2T4 calculations will be established to ensure these are completed in the 45-day window. Anticipated Completion Date: December 2022 Once the Corrective Action Plan is completed, Purdue Internal Audit will conduct a follow-up review to ensure the corrective action plan is fully implemented and being followed consistently.

Return of Title IV Funds (R2T4) Planned Corrective Action: Monthly meetings have been scheduled for the academic year to review completed R2T4?s. The director of financial aid and director of student financial services are also conducting additional training with staff to go over the areas of non-compliance that occurred. We have met with leadership on campus to address the issues with attendance tracking so that timely return of Title IV funds can be completed. Reminders have been sent to professors on attendance policies and procedures. These reminders include updated training materials. We have developed additional reports that will allow the University to monitor if attendance is being tracked by individual professors. Areas of non-compliance will be reported to the vice president for academic affairs and accreditation for follow up. Person Responsible for Corrective Action Plan: Kevin Reed, Director of Financial Aid, and Kylie Pruitt, Director of Student Financial Services Anticipated Date of Completion: October 15, 2022

Loras College Corrective Action Plan For the year ended June 30, 2022 February 9, 2023 Finding 2022-002: Significant Deficiency - Return of Title IV Funds Assistance Listing Number: 84.063 Federal Agency: U.S. Department of Education Condition: The auditors noted that refunds were calculated incorrectly for three of five students selected for testing. Recommendation: The College should review its procedures to ensure that refunds are calculated correctly and timely and any returns are made within the required timeframe. Corrective Action: Management has reviewed internal processes and procedures to ensure that all refunds are calculated correctly and sent back or provided to the student as a post withdrawal disbursement when appropriate and within the required timeframe as stated in the federal student aid handbook. Procedures are clarified to include a student withdrawal date based on formal withdrawal by the student and despite the Loras policy to refund all charges back to the student if they fully withdraw in the first week of classes, a return of Title IV funds will be calculated to be certain the student receives any federal aid that has been earned. If a student withdraws before the 60% point of the semester, the last date of attendance as reported by faculty will be used to calculate the return of funds. All refund calculations will be completed using the Common Origination and Disbursement R2T4 calculator along with the Colleague R2T4 calculation and will then receive a final review by the Director of Student Accounts to ensure the correct type and amount of aid earned by the student and the correct type and amount of all federal funds is sent back in the timeframe outlined by the regulations. Anticipated completion date of implementing the corrective action will be immediate. Sincerely, Mary Ellen Carroll, Ph.D. Senior Vice President