Corrective Action Plans

Management?s Views and Corrective Action Plan The University implemented two new systems (Student Information System ? Workday, and Financial Aid System ? PowerFaids) that each are an important part of managing our Federal Student Aid. Most of the building and configuring of these systems happened prior to FY22 with the full launch in production taking place for the Fall 2021. Understandably, some of the integrations of these two systems were not able to be tested prior to Fall of 2021 (ex: actual disbursement of federal loans) and therefore, required significant time and effort in the Fall and beyond to ensure everything worked and students were able to receive funding while also building out and documenting required communications, processes, and compliance protocols. Additionally, we had turnover within the Associate Director of Financial Aid and Loan Manager role in March 2022. The implementation coupled with this staffing issue created a one-time set of circumstances that are outside of the standard oversight and management of our Federal Student Aid funds and processes. Please refer to the response to each individual finding as follows: Finding 2022-001: Returns of Title IV Funds Award Information Cluster: Student Financial Assistance Cluster Grantor: Department of Education Award Name: Federal Direct Student Loans Award Year: July 1, 2021 ? June 30, 2022 Assistance Listing Number: 84.268 In implementing PowerFaids we were required to set up our own Selection Sets (set group of criteria) for managing all of the disbursements (positive or negative) for each type of fund. For all of our loan funds, we used criteria that included requiring that the particular term have at least half-time enrollment. We used this selection set to disburse (increase or decrease) both the loan to the Student Account (in Workday) as well as to get on the Books with FSA (through COD). We realized that students who took a Leave of Absence or Withdrew from the University needed their own selection set because they would have been updated to have zero credits in the term they took a leave or withdrew. The two instances where we were late in adjustment, we were in the middle of the staffing situation. Documentation had not been written by the Loan Manager at that time. Once we identified the issue with the selection set for students who were withdrawn or on a leave of absence, we reviewed all students with this condition, corrected refunds as appropriate and ensured this was corrected moving forward. The Director of Financial Aid saw a need to have greater oversight on our Federal Funds. She began a process of restructuring the Office as of February 21, 2022 so that the Loan Manager position no longer had direct reports and their main responsibility is the management of federal and private loan portfolios and the federal Pell grant fund. Processes have been documented and all selection sets and processes are managed by this new Associate Director (Loan Manager) who now reports directly to the newly created Director of Financial Aid Systems, Reporting and Compliance April 21, 2022. We do not foresee further issues with return of funds within the required 45-day timeline. The Assistant Vice President, Enrollment Student Services & Director of Financial Aid, Amy Staffier, who can be reached at amy.staffier@simmons.edu, is responsible for the implementation of this corrective action plan.

The College?s Financial Aid office has instituted a reconciliation process that is now completed monthly, with timely and appropriate levels of review of the reconciliations. All previous month?s reconciliations were performed and reviewed, and the monthly reconciliation process is now part of the standard month-end procedures.

Federal Award Findings and Questioned Costs Finding: 2022-001 Name of Contact Person: Karen Harrington, DSS Director Corrective Action/Management?s Response: Agency agrees with the finding and will ensure random reviews of workstations will be completed. Agency will ensure immediate refresher in Unit meetings regarding computer security. Additionally, County DSS will continue with an annual training to review computer security and will ensure computer security is addressed in new employee orientation. Proposed Completion Date: Immediately and ongoing.

Non-Compliance ? Failure to Undergo the Required Single Audit Description of Finding: The auditor found that The Entity did not obtain the required single audit for the year ending September 30, 2021. Statement of Concurrence or Nonconcurrence: Management concurs with this finding. Corrective Action: Management has obtained the required Single Audit for the year ending September 30, 2022, the year in which the interim construction loan was refinanced by the direct loans from the Rural Utilities Service. Management was unaware that the expenditures of the interim construction loan were considered federal expenditures. All of the federal award activity during the September 30, 2021 and 2022 fiscal year ends have been audited as a part of the September 30, 2022 Single Audit. Management will review loan agreements, communicate with oversight agency officials, and consult annually with external auditors about requirements for single audits in the future.

The Controller?s office will implement a process in which an individual will formally document their review of the third-party servicer?s most recent Title IV compliance audit in a memorandum. The memorandum will then be reviewed by another individual other than the preparer. Tara Thomason, Controller and Assistance Vice President, is responsible for addressing the above items by December 2023.

The University will continue to work with our Information Technology to update the process. Matching with the current process for parent loan notification is the initial step. That process does include but does not fully rely on a trigger in the student system communication forms. (no parent loan citing). In an overall process improvement, the goal is to move out of the webfocus engagement to a new automated process. Cari Wickliffe, Assistant Vice President and Director of Student Financial Services, is responsible for addressing the above items by July 1, 2023

The University will implement a two-step review internally to ensure records are reviewed within the required days. The University is filling vacant positions and reviewing additional operations support. Additionally, most of the errors occurred when a student did not answer completely or correctly the high school graduation information on the Free Application for Federal Student Aid (FAFSA), questions 26 and/or 27. The system is set to hold any loan disbursements if this question and associated C Flags are present. Pell disbursement, however, bypasses this control. The University has established a procedure to identify in the extract log errors from attempting to disburse. A hold will be placed on the student account, and if any Pell disbursement is not fully accepted, it will be reversed. Cari Wickliffe, Assistant Vice President and Director of Student Financial Services, is responsible for addressing the above items by August 1, 2023

The University created additional reporting to identify student grade level reported on student system (SGASTDN) to the calculated grade level (ROASTAT) and any blanks. In addition, to the report which was created prior to this citing, training directly from the software provider has been scheduled. The University will review the option of creating a specific budget or packaging group for students in certificate programs. This would afford rules to award only level one loan limits regardless of calculated grade level. Standard cost of attendance (coa) is posted by system processing rules. In certain situations, the coa may be adjusted manually by staff. The student information system does track and log these updates. The University will increase training regarding coa adjustments, strengthen standard posting of changes and why. A report has been created to identify any change to the standard budget component. This will be added as a point of review for the compliance coordinator. The primary risk area is summer since it is a manual process. The use of algorithmic budgeting will assist with changes to coa as well. In addition, the University is working with software provider to establish algorithmic budgeting rules. This option allows cost of attendance (coa) to be completed by enrollment period versus aid periods. The benefit is coa can be estimated at full-time and prior to disbursement adjust coa to part-time. The office of student financial services is working with the University to identify and address additional human resources needed to best address increased volume and greater compliance. Cari Wickliffe, Assistant Vice President and Director of Student Financial Services, is responsible for addressing the above items by July 1, 2023.

Reference Number 2022-001 Ranken Technical College has addressed the recent NSLDS reporting concerns as of 11/01/2022 by changing the withdrawal process and including an additional check on enrollment status before NSC file submission. Enrollment Status ? New SQL script check during NSC file submission for changes in enrollment status. The Registration Transaction Log will be compared to the main detail and program 1 detail of the NSC Transaction Detail Table. This is a staging area for our data before submitting flat file to NSC for further checks/review. Withdrawal Process ? Issue with course dismissal reporting of non-attendance of students in General Education courses. New procedures for handling withdrawal scenarios for students clearly outlined and implemented. Withdrawal of Students ? Graduation ? o Exit Degree ? Students are withdrawn ? o Student withdrawals from major courses 1st 8-weeks ? Do not reschedule 2nd 8-weeks ? Drop current unattended courses & future courses ? Exit Degree o Academic Dismissal ? Drop all future courses ? Exit Degree o Not Authorized to Attend (without attending class) ? Drop all current/future term classes ? Exit Degree o Not Authorized to Attend (attending class) ? Withdraw all current/ Drop future term classes ? Exit Degree o Voluntary Withdrawal ? WF grade in technical class results in NIM in technical WEG. ? W grade in technical class ? contact instructor for appropriate WEG grade. ? Drop future courses ? Exit Degree o Course Exceeds Allotted Attendance Withdrawal (when attendance is posted) * ? Assign WF grade for technical/gen ed class. NIM assigned to technical WEG.? Do not reschedule ? If not current in another course drop all future courses ? Exit Degree o Course Exceeds Allotted Attendance Withdrawal (when no attendance is posted) * ? Do not reschedule ? Drop Courses ? If not current in another course drop all future courses ? Exit Degree ? Student not enrolled in courses during current semester ? o Exit Degree Student must attend the 1st 8 weeks to be allowed registration in the 2nd 8 weeks. The fundamental processes of withdrawal and rescheduling have been changed after extensive review of our past errors. New measures employed will eliminate the issues in withdrawal of students and enrollment statuses. Responsible Parties: Daniel Turpiano, Director of Reporting & Registration, Ranken Technical College djturpiano@ranken.edu

Finding No. 2022-002 ? Report Filed After Due Date Repeat Finding: No ALN and Program: 84.007; 84.033; 84.063; 84.268 ? Student Financial Assistance Cluster Award Amount: $46,751,524 Award Number: N/A Award Year: 7/1/2021-6/30/2022 Criteria: By October 1 the institution should submit its ED Form 646-1, Fiscal Operations Report, and Application to Participate (FISAP) that includes the Fiscal Operations Report for the preceding award year and the Application to Participate for the upcoming award year (FWS, FSEOG 34 CFR 673.3; Fiscal Operations Report and Application to Participate Instructions). Condition / Context: The FISAP for award year 2021-2022 was filed on October 12, 2022. Our sample was statistically valid. Cause: As MATC approached the deadline for FISAP submission, responsible MATC personnel were not aware of the outstanding reporting items and the immediate need to employ an alternative plan to ensure the timely submission of the FISAP. Questioned Costs: Unknown Effect: This electronic report is submitted annually to receive funds for the campus-based programs. The institution uses the Fiscal Operations Report portion to report its expenditures in the previous award year and the Application to Participate portion to apply for the following year. Delays in filing of this report could result in delays with subsequent year funding. Recommendation: MATC should implement a reporting calendar, including deadlines for draft, review and approval of the FISAP to ensure timely filing. District Response: MATC agrees with the finding and has developed, documented and implemented a process and calendar to ensure timely completion of the annual FISAP. Al Pinckney, Executive Director of Financial Aid 12/6/2022

Finding No. 2022-003 ? R2T4 Return Calculation Errors Repeat Finding: No ALN and Program: 84.007; 84.033; 84.063; 84.268 ? Student Financial Assistance Cluster Award Amount: $46,751,524 Award Number: N/A Award Year: 7/1/2021-6/30/2022 Criteria: For returns of Title IV Funding when a student does not complete the enrollment period for which funds were disbursed, the amount of earned Title IV grant or loan assistance is calculated by determining the percentage of Title IV grant or loan assistance that has been earned by the student and applying that percentage to the total amount of Title IV grant or loan assistance that was or could have been disbursed to the student for the payment period or period of enrollment as of the student's withdrawal date. Standard term-based institutions must always use the payment period as the basis for the determination. The unearned amount of Title IV assistance to be returned is calculated by subtracting the amount of Title IV assistance earned by the student from the amount of Title IV aid that was disbursed to the student as of the date of the institution's determination that the student withdrew (34 CFR 668.22(e)). Condition / Context: The auditor selected 21 unenrolled students who had Title IV returns for testing. For each student selected, the return amount was incorrectly calculated because the payment period was not used as the basis for the determination. Our sample was statistically valid. Cause: Unauthorized break periods and start dates were used to determine the base period for calculation. MATC's review process was not effective to detect and correct this error. Staff responsible for calculating R2T4 returns were not properly trained in the requirements. Questioned Costs: $5,097 Effect: MATC has determined that a total of 425 returns were incorrectly calculated, with an estimated net error of $5,097. Recommendation: We recommend MATC re-evaluate its review process for Title IV returns, and provide additional training for management and staff to ensure the calculations and compliance requirements are understood and that control processes are operating effectively to ensure proper returns. District Response: MATC agrees with the finding and has developed, documented and implemented a process and correct the student record errors, provide updated training and update R2T4 procedures to ensure proper calculation going forward. Al Pinckney, Executive Director of Financial Aid 12/6/2022

Finding No. 2022-004 ? Reporting Discrepancies - Enrollment Repeat Finding: 2021-001 ALN and Program: 84.007; 84.033; 84.063; 84.268 ? Student Financial Assistance Cluster Award Amount: $46,751,524 Award Number: N/A Award Year: 7/1/2021-6/30/2022 Criteria: Institutions are required to report enrollment information under the Pell grant and the Direct and FFEL loan programs via the NSLDS (OMB No. 1845-0035). Institutions must review, update and verify student enrollment statuses, program information, and effective dates that appear on the Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS Professional Access (NSLDSFAP). Condition / Context: We selected a sample of 25 Pell and Direct Loan students from the institution's records that had a reduction or increase in attendance levels, graduated, withdrew, dropped out or enrolled but never attended during the audit period. We compared the data in the students' NSLDS Enrollment Detail to the students' academic files and other institutional records and verified that the institution is accurately reporting the significant Campus-Level and Program-Level enrollment data elements that ED considers high risk. Of the 25 sampled, 10 had discrepancies between the status documented in MATC's institutional records and the status reported on the NSLDS. Our sample was not statistically valid. Cause: In April 2021, the National Student Clearinghouse made a change to its reporting process, which resulted in errors in MATC's data uploads. MATC has begun the process of testing and correcting its process, but this was not completed as of June 30, 2022. MATC believes this update error has caused the continued discrepancies between MATC and the NSLDS. Questioned Costs: Unknown Effect: The administration of the Title IV programs depends heavily on the accuracy and timeliness of the enrollment information reported by institutions. Incorrect reporting of enrollment status could result in incorrect distribution of Title IV funds to institutions or individuals. Recommendation: We recommend MATC continues its review process for enrollment statuses, and provide additional training for management and staff to ensure the correct statuses are reported and that control processes are operating effectively to ensure proper returns. District Response: The Office of the Registrar has developed and is implementing an action plan to ensure correct reporting through the National Clearinghouse and NSLDS. The process includes additional staff training, review and update of the submissions process and schedule and enlisting support from specific contacts at the Clearinghouse. These steps were completed by September 2022. Additional steps, including review of the reporting setup the SIS system with the IT department, discussing and resolving existing issues with the Clearinghouse, performing checks of individual current and prior year students to identify and correct additional gaps, incorporating a regular review of a sample of students for proper reporting and hiring additional staff for reporting enrollment ? all to be completed by December 2022. Beginning in 2023, staff will also create and submit an additional report to the Clearinghouse for each submission of graduates and creating a position to lead enrollment reporting. Dr. Sarah Adams, Dean of Enrollment Services 12/6/2022

SIGNIFICANT DEFICIENCY 2022-007 Student Financial Assistance Program Cluster ? Title IV ? Eligibility Condition During testing, it was discovered that two students were over awarded subsidized direct loans. Recommendation We recommend that the institution implement controls to ensure that direct loan award amounts are reviewed for accuracy prior to making awards to students. Actions Taken As of March 23, 2023, the College has begun to implement a review of student awards that will include reviewing all aid and credits that the student is receiving and double checking NSLDS loan amount limits.

SIGNIFICANT DEFICIENCY 2022-006 Student Financial Assistance Program Cluster ? Title IV ? Reporting Condition During testing, it was discovered that COD reflected inaccurate disbursement amounts for two students. Recommendation We recommend that the institution review its reconciliation process and implement controls to ensure that COD records accurately reflect actual disbursements. In addition, we recommend that the institution implement a control to ensure that all completed verifications have been reported to COD. Actions Taken As of March 23, 2023, COD records have been updated for the two students in question. In addition, communication is ongoing with the College?s software provider in order to work towards a control that will ensure that this error does not occur again. Lastly, the College has implemented a review process to ensure that applicable students have completed their verification, and the third-party vendor who completes the verification process has been contacted about setting up a notification system to alert personnel when a student completes their verification.

SIGNIFICANT DEFICIENCY 2022-005 Student Financial Assistance Program Cluster ? Title IV ? Eligibility Condition During testing, it was discovered one student was incorrectly awarded Pell, and two others did not receive Pell disbursements for both eligible semesters attended during the year. Recommendation We recommend that the institution implement controls to ensure that all scheduled disbursements are ultimately posted. In addition, when calculating Pell awards, the Payment and Disbursement Schedule that matches the student?s enrollment status should be carefully selected and applied. Actions Taken As of March 23, 2023, the scheduled Pell awards for the two noted students have been posted and disbursed. In addition, an additional review step has been implemented to take place before any aid disbursements are made.

2022-004 Student Financial Assistance Program Cluster ? Title IV ? Cash Management and Special Tests and Provisions ? COD Reconciliation Condition During testing, it was discovered that Pell and Federal Supplemental Educational Opportunity Grant (FSEOG) funds were drawn down and not disbursed within they required timeframe. In addition, funds were drawn down from Direct Loan sources when they were meant to be drawn from alternative sources. Recommendation We recommend that the institution review its reconciliation process and implement controls to ensure that funding is drawn from correct sources and disbursed within three business days of receipt. Actions Taken Upon request by COD, a repayment of Direct Loan funds was made in order to correct the variance that they noted which was caused by the Alternative Loans that were drawn from the incorrect source. In addition, as of March 23, 2023, a new draw-down process will be implemented. Changes include not drawing down any aid until it is approved by the Director of Financial Aid, confirmation throughout the draw-down process, and better communication between the Accounts Payable/Financial Aid Specialist, Accounts Receivable and the Director of Financial Aid.

SIGNIFICANT DEFICIENCY 2022-003 Student Financial Assistance Program Cluster ? Title IV ? Reporting Condition During testing, items reported within the FISAP were found to be inaccurate or were unable to be substantiated due to a lack of supporting documentation. Recommendation We recommend that all supporting documentation used in the preparation of the FISAP be saved in an easily identifiable location. Actions Taken As of March 23, 2023, all documents used in the preparation of the FISAP will be saved and filed in one location at the time of preparation.

Federal Award Findings and Questioned Costs Finding 2022-01: Special Reporting Federal Program: Student Financial Aid Cluster Federal Agency: Department of Education CFDA Number: 84.007, 84.063, 84.268, 84.033 Views of Responsible Officials and Planned Corrective Actions: We agree with the finding. As of January 2023, we have incorporated and communicated the updates to our policy and procedures to ensure both information systems are reconciled monthly, as well as maintaining appropriate documentation as assigned to both the Finance Department and the Financial Aid Manager.

Name of Responsible Individual: Jason Byrd, University Registrar Corrective Action: Liberty acknowledges that there was one instance in which a student?s enrollment status was not reported within compliance timeframes. Additionally, Liberty recognizes there were 4 months in the year in which there were repeat errors found in the SSCR error files. Liberty University has worked to ensure the enrollment reporting process is handled compliantly and within allowable timeframes. While many processes have been improved over the past two years, it is evident another level of quality control is needed. Therefore, Liberty University?s Financial Aid Office has invested in creating a position that will solely focus on the compliance and quality control of the University?s enrollment reporting. This individual will work collaboratively with the Registrar?s Office and utilize additional reporting from NSLDS to pre-emptively identify errors and student notifications that are in danger of being out of compliance. Anticipated Completion Date: March 31, 2023

2022-002 FEDERAL DIRECT LOAN RECONCILIATIONS Federal Assistance Listing Number: 84.268 Criteria According to 34 CFR 685.300(b)(5), the College must, on a monthly basis, reconcile institutional records with Direct Loan funds received from the Secretary and Direct Loan disbursement records submitted to and accepted by the Secretary. Observation/Condition/Context The College did not perform the monthly reconciliations over direct loans for all months out of the fiscal year. We requested a selection of reconciliations out of the 12 required and were informed that only 8 reconciliations were performed. Questioned Cost There were no questioned costs related to this finding. Cause/Effect The reconciliations were not performed due to a transition of responsible parties over the reconciliations. Direct loan discrepancies may not have been identified and resolved in a timely manner due to the lack of monthly reconciliations. Recommendation We recommend that the College perform direct loan reconciliations monthly to ensure that discrepancies are properly addressed in a timely manner. Planned Corrective Action Effective with the 2021/2022 Direct Loan reconciliations for February 2022 (performed in March 2022), a revised process was implemented to make the process more efficient and accurate. Along with this the Finance Manager took on the responsibility to execute the process monthly and share the results with other relevant teams by the 2nd week of the following month. Since this time the process has continued to be refined and all reconciliations (student level detail and summary) have been completed and shared timely for the remaining portion of award year 2021/2022 and for 2022/2023 through February 2023. Now that the process is firmly in place and effective, cross-training with others in the Business office will take place and be completed by the end of April 2023 to ensure an adequate depth of resources are available to maintain timeliness and accuracy of the reconciliations. Implementation Date The revised process was implemented in March 2022 and was refined since to ensure effectiveness and sustainability of the process going forward. Additional training to add to the depth of resources to perform the process will be completed by the end of April 2023. Responsible Personnel Yvonne Rincon, Director of Accounting Contact Information Email: yrincon@cca.edu

2022-003 NSLDS STUDENT ENROLLMENT STATUS REPORTING Federal Assistance Listing Number: Various; Student Financial Aid Cluster, Department of Education Criteria (1) According to 34 CFR 682.610(b), (1) Upon receipt of an enrollment report from the Secretary, a school 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. (2) Unless it expects to submit its next updated enrollment report to the Secretary within the next 60 days, a school must notify the Secretary within 30 days after the date the school 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 school, 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 school and who received a loan under title IV of the Act has changed his or her permanent address. Observation/Condition/Context The College did not report a change in enrollment status to the National Student Loan Clearinghouse for a student within the required 60 days. During our testing, we noted that 1 of 21 students tested had a change in enrollment status that was late in reporting to the NSLDS. Questioned Cost There were no questioned costs related to this finding. Cause/Effect The College had not performed a review on a timely basis, which resulted in the noncompliance with the cited provisions above. Continued noncompliance may cause a delay in the loan repayment process for the student borrowers that withdraw from the College. Recommendation We recommend that the College implement a procedure to ensure that all student enrollment status changes are accurately reported in a timely manner. Planned Corrective Action The Student Records office will put reminders in place to ensure enrollment reporting is sent out monthly to the National Student Loan Clearinghouse. Implementation Date Spring 2023, as of March 22, 2023 Responsible Personnel Registrar and Director of Financial Aid Contact Information Samantha Dancel Director of Financial Aid Tel: 415.703.9577 Email: sdurant@cca.edu

Views of Responsible Officials and Planned Corrective Actions ? The Registrar's Office will create and make available a procedural guide to running and submitting reports. Redundant staff will be set to receive the notifications of upcoming and delinquent enrollment reports.

2022-001 ? Student Financial Assistance Cluster ? (a) Federal Supplemental Educational Opportunity Grant (b) Federal Work Study Program (c) Federal Perkins Loan Program (d) Federal Pell Grant Program (e) Federal Direct Student Loans, ALN (a) 84.007 (b) 84.033 (c) 84.038 (d) 84.063 (e) 84.268 - Year Ended May 31, 2022 Condition: We tested 40 credit balances and one credit balance was not paid in a timely manner. Corrective Action Plan: The College identified that the student?s refund was not processed timely due to a coding error in the student?s record in our software. This error then prevented the student from being included on the weekly refund report. The College has created and implemented a weekly reporting process to identify these coding errors. When a student is identified as not being coded, a Student Financial Services Counselor adds the code to the student?s record within the College?s software. This process is performed weekly prior to processing the weekly student and parent refunds. Responsible Person for Corrective Action Plan: Student Financial Services Counselors, Laura Doss, Lisa Sabolo and Victoria Menge Implementation Date for Corrective Action Plan: December 2021

3/30/2023 Grant Thornton 10 Almaden Blvd., Suite 800 San Jose, CA 95113 RE: Management?s Corrective Action Plan in Response to Fiscal Year 2022 Item 2022-001 ? Significant Deficiency ? Reporting: Special Reporting 1. Contact person: Syble Allen, Controller 2. Plan of action: The Controller, Director of Institutional Research and Student Accounts Director will all be given copies of the prepared FISAP for review and comment at least 3 days prior to FISAP submission each October 1. 3. Anticipated completion date: This new process will be implemented April 1, 2023.

Finding 2022-002 ? Information Technology General Controls Identification of the federal program: Federal Program: Student Financial Assistance Cluster: Federal Pell Grant Program (Assistance Listing No. 84.063) and Federal Direct Student Loans (Assistance Listing No. 84.268) Federal Agency: United States Department of Education BJC HealthCare Location: Goldfarb School of Nursing Award Periods: January 1, 2022 through June 30, 2022 (included in award year July 1, 2021 through June 30, 2022), and July 1, 2022 through December 31, 2022 (included in award year July 1, 2022 through June 30, 2023) Views of responsible officials and planned corrective actions: BJC HealthCare agrees with the findings as reported. GSON is committed complying with program requirements and meeting program objectives as defined in Section 200.303(a) of the Uniform Guidance, regarding auditee internal controls. To facilitate these requirements, GSON formalized a policy and procedure document regarding access controls to support effective information technology general controls (ITGCs) for the Banner application. A formal user access review will be completed semi-annually and results of the review, including actions taken, will be formally documented. Responsible Parties: David Solovitz, Interim Director Information Technology, Goldfarb School of Nursing Completion Date: The corrective action plan was implemented in Q3 2023.