Corrective Action Plans

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.

Finding 2022-001 ? N4. Enrollment Reporting 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. The Goldfarb School of Nursing is at Barnes-Jewish College (GSON) is committed to ensuring that student enrollment changes are reported accurately and timely to the National Student Loan Data Systems (NSLDS) in accordance with federal regulations. Procedures and processes have been implemented (to date) to address and correct GSON enrollment reporting compliance. To facilitate the completeness of the enrollment reporting process, the following steps will be incorporated into the GSON?s procedures: ? A second-tier review of student enrollment status reports (SFRNSLC), as prepared by the GSON Registration Technical Specialist, will continue to be completed by the GSON Registrar before submission of data to the National Student Clearinghouse (NSC). The GSON Registrar will randomly select a sample of students to compare enrollment report data to the student information system (Banner) and document their findings. This control was implemented in October 2022. Responsible Parties: Kristina Rieger, Registrar, Goldfarb School of Nursing at Barnes-Jewish College Edward Gricius, Associate Dean, Student Experience & Development, Goldfarb School of Nursing at Barnes-Jewish College Completion Date: The corrective action plan was implemented in October 2022.

BRIGHAM YOUNG UNIVERSITY-HAWAII Management's View and Corrective Action Plan Finding 2022-001- Non-Compliance with Timely and Accurate Student Enrollment Change Submissions to the National student Loan Data System (significant Deficiency) Grantor: U.S. Department of Education Program : Student Financial Assistance Cluster Assistance Listing #: 84.268, 84.063 Title: Federal Direct Student Loan Program, Federal Pell Grant program Award Years: 7/2021 - 6/2023 Management agrees with the finding and proposes the following Corrective Action Plan Corrective Action Plan: Due to the NSLDS outage as announced by the U.S. Department of Education Federal Student Aid's (FSA) office, we were unable to submit enrollment rosters for the period of July 19,2022 through February 28, 2023. Therefore, we are continuing to implement the following corrective action plan to address both the prior year and current year issues as discussed below. The current year finding is the result of three separate reporting issues. The first issue is a repeat finding from the 2021 fiscal year audit (2021-001) related to inaccurately reporting the status of graduated students. When graduation files were sent to the National Student Clearinghouse (NSC), many could not be processed due to the "G" status not being applied when students were reported as graduated. Because of this, the NSC was not sending graduation information for some students to the National Student Loan Data System (NSLDS). Therefore, to appropriately resolve this issue, Daryl Whitford, Registrar, will regularly access the NSC dashboard, prior to submitting of monthly enrollment report, to promptly identify and resolve any reporting issues to ensure NSLDS has the correct information for students. The second issue is a repeat finding from the 2021 fiscal year audit (2021-001) and is the result of inappropriate configuration of each semester's credit load determinations (i.e., how many credits constitute full time, three quarter time, half time, etc.) into PeopleSoft. As a result of the inappropriate configuration, certain student statuses were reported incorrectly given the number of credit hours the student was attending. To ensure accuracy of each semester's credit load determinations, at the beginning of each semester, Daryl Whitford, Registrar, will review and approve the credit load determinations prior to them being pushed into PeopleSoft. This will ensure that PeopleSoft is configured to communicate the appropriate statuses to the NSLDS. The third issue referenced the reporting of the correct program begin dates. When a student returns from a leave of absence or an internship, PeopleSoft updates the students program begin date for the students return date rather than the original program begin date. Daryl Whitford, Registrar, will perform a review of program begin dates for students returning from a leave of absence to ensure the proper program begin date is reported. In addition, we will review if any PeopleSoft enhancements can be made to provide additional comfort that the program begin dates are accurate in these circumstances. Daryl Whitford, Registrar, who is responsible for enrollment reporting at Brigham Young University- Hawaii will continue to provide training to staff who participate in enrollment reporting to ensure that they are aware of the campus and program enrollment changes to be reported, the details to be reported for each change, and the importance of submitting changes timely. Also, Daryl Whitford, Registrar, will oversee the implementation of a control wherein the University will sample students from each roster submission and trace the information from the batch file back to the supporting documentation to ensure that the information included in the batch roster file is accurate. Timing: Daryl Whitford, Registrar, will be responsible to oversee that the items as noted in the Corrective Action Plan section above will be implemented by July 1, 2023. Signed and Acknowledged Daryl Whitford Registrar

Management Views and Corrective Action Plan Year Ending December 31, 2022 Finding 2022-002 ? Pell Grant Notification Letters Grantor: U.S. Department of Education Program: Student Financial Assistance Cluster Assistance Listing #: 84.063 Title: Federal Pell Grant Program Award Years: 7/2021 ? 6/2023 Management agrees with the finding and proposes the following Corrective Action Plan: Corrective Action Plan This issue is a result of no manual or system controls in place to prevent disbursement of financial aid to a student?s account if a student?s federal financial aid award notification was not yet communicated. This issue was corrected as soon as it was identified by changing our procedures to require Pell notification letters be sent as soon as funds are awarded and before funds are disbursed to a student?s account. As an additional precaution, Pell notification letters will be added to the nightly batch process in PeopleSoft to ensure letters are sent timely. Financial aid staff will also receive additional training in this area. Timing Procedures will be changed in May 2023 by Riley Niemand, Manager of Financial Aid, to require Pell notification letters be sent as soon as funds are awarded and prior to funds being disbursed to a student?s account. During May 2023, Riley Niemand will also provide additional training to financial aid staff in this area. Additionally, Riley Niemand started working with a consultant to add Pell notification letters to the daily batch process. This work is expected to be complete by June 2023. Sincerely, S.Christopher Reitz Director of Financial Services and Controller creitz@ensign.edu 801-524-8109

Management Views and Corrective Action Plan Year Ending December 31, 2022 Finding 2022-001 ? Enrollment Reporting Grantor: U.S. Department of Education Program: Student Financial Assistance Cluster Assistance Listing #: 84.268, 84.063 Title: Federal Direct Student Loan Program, Federal Pell Grant Program Award Years: 7/2021 ? 6/2023 Management agrees with the finding and proposes the following Corrective Action Plan: Corrective Action Plan The prior year corrective action plans were successful in addressing the issues identified in previous audits in enrollment reporting. These additional steps will be taken to address the new issues found during the 2022 audit within enrollment reporting, which resulted in a repeat finding of 2021-001. Grayson Layton, Registrar, will review the College?s policies and procedures surrounding student enrollment and enrollment reporting, starting in May 2023 specifically as it relates to students that have withdrawn that are expected to return in the subsequent semester but fail to reenroll. Any changes in the College?s policies and procedures will be appropriately documented and communicated to the individuals involved in updating student enrollment information in the system. Additionally, Enrollment Services will work with a PeopleSoft consultant and technical staff to customize our Student Information System to allow for the correct reporting of student status to the National Student Clearinghouse (NSC). Technical staff and a consultant will be engaged to perform an evaluation of all systems and practices related to enrollment reporting. The Enrollment Services and Financial Aid and Scholarships Offices will use various NSC and National Student Loan Data System (NSLDS) error reports to ensure student enrollment information, including program level information, is reported in an accurate and timely manner. Timing Grayson Layton, Registrar, will work with consultants and technical staff starting in May 2023 to begin making necessary adjustments to the Student Information System to allow for accurate reporting of student enrollment information and to evaluate systems and practices related to enrollment reporting. They will meet monthly throughout the year to monitor their progress with an expected completion in December 2023. Grayson and Riley Niemand, Manager of Financial Aid, will coordinate the use of NSC and NSLDS error reports to identify students with reporting errors. This process will be complete in June 2023. Sincerely, S.Christopher Reitz Director of Financial Services and Controller creitz@ensign.edu 801-524-8109

Student Financial Aid Cluster: Federal Supplemental Educational Opportunity Grant – Assistance Listing No. 84.007 Federal Work Study Program – Assistance Listing No. 84.033 Federal Pell Grant Program – Assistance Listing No. 84.063 Federal Direct Student Loans – Assistance Listing No. 84.268 Recommendation: We recommend the University review internal control reports and implement review controls for work performed by third party servicers. Action taken in response to finding: The University agrees with the finding and has developed the following corrective action plan. The University is already utilizing Visual Compliance to assess all vendors for suspension and debarment but will obtain and document the review of the SOC 2 report for Visual Compliance annually. Name(s) of the contact person(s) responsible for corrective action: Scott Schlotthauer, Chief Procurement Officer at Oklahoma State University. Planned completion date for corrective action plan: December 2023

Student Financial Aid Cluster: Federal Supplemental Educational Opportunity Grant – Assistance Listing No. 84.007 Federal Work Study Program – Assistance Listing No. 84.033 Federal Pell Grant Program – Assistance Listing No. 84.063 Federal Direct Student Loans – Assistance Listing No. 84.268 Recommendation: We recommend the student financial aid department review its current procedures for evaluating students that did not receive a passing grade in a term to ensure enrollment status changes are determined timely and accurately. Action taken in response to finding: The University agrees with the finding and has developed the following corrective action plan. Procedures are being updated to ensure enrollment changes for students who did not receive a passing grade in a term will have their enrollment status changes reported timely and accurately. Name(s) of the contact person(s) responsible for corrective action: Sheila McGill Executive Director, Financial Aid & Scholarships, Langston University. Planned completion date for corrective action plan: January 2024

Student Financial Aid Cluster: Federal Supplemental Educational Opportunity Grant – Assistance Listing No. 84.007 Federal Work Study Program – Assistance Listing No. 84.033 Federal Pell Grant Program – Assistance Listing No. 84.063 Federal Direct Student Loans – Assistance Listing No. 84.268 Recommendation: We recommend the University review its current procedures for Title IV funds and implement additional procedures to ensure refunds are returned timely. We also recommend the University implement formal review procedures to document the Return of Title IV calculations are being performed to minimize the likelihood that errors may go undetected and not be corrected in a timely manner. Action taken in response to finding: The University agrees with the finding and has developed the following corrective action plan. Procedures for review and return of Title IV funds are being updated to ensure refunds are returned in a timely manner. Return of Title IV calculations are being documented and reviewed by a party independent of the preparer to minimize the likelihood that errors go undetected and/or not be corrected in a timely manner. Name(s) of the contact person(s) responsible for corrective action: Sheila McGill Executive Director, Financial Aid & Scholarships, Langston University. Planned completion date for corrective action plan: January 2024

Student Financial Aid Cluster: Federal Supplemental Educational Opportunity Grant – Assistance Listing No. 84.007 Federal Work Study Program – Assistance Listing No. 84.033 Federal Pell Grant Program – Assistance Listing No. 84.063 Federal Direct Student Loans – Assistance Listing No. 84.268 Recommendation: We recommend that the student financial aid department work to ensure disbursements are reported to COD within 15 days of the disbursement date and that disbursements date reported in COD matches the disbursement date to the student. Action taken in response to finding: The University agrees with the finding and has developed the following corrective action plan. Updated procedures are in place to ensure disbursements are reported to COD in a timely manner in accordance with Federal guidelines. Name(s) of the contact person(s) responsible for corrective action: Sheila McGill Executive Director, Financial Aid & Scholarships, Langston University. Planned completion date for corrective action plan: January 2024

Student Financial Aid Cluster: Federal Supplemental Educational Opportunity Grant – Assistance Listing No. 84.007 Federal Work Study Program – Assistance Listing No. 84.033 Federal Pell Grant Program – Assistance Listing No. 84.063 Federal Direct Student Loans – Assistance Listing No. 84.268 Recommendation: We recommend the University review current processes for reporting to NSLDS and implement procedures to ensure submissions are reported timely and accurately. Action taken in response to finding: The University agrees with the finding and has developed the following corrective action plan. The University will update its NSLDS reporting processes to ensure needed submissions are reported timely and accurately. Name(s) of the contact person(s) responsible for corrective action: Chris Kuwitzky, Vice President for Fiscal and Administrative Affairs, Langston University. Planned completion date for corrective action plan: March 2024

The DCFS is currently working with USDHHS’ Childrens’ Bureau (CB) on a Program Improvement Plan (PIP) related to Adoption Assistance subsidy payments. The PIP requires significant changes to DCFS’ policy that are still being vetted by CB and DCFS management, which will have a significant impact on how this program is carried out. As soon as the policy changes are completed, the DCFS will finalize procedures consistent with policy, the Social Security Act, and Title IV-E. These procedures will include controls to ensure payments made are appropriate per the subsidy agreements with the adoptive parents and federal requirements. In the meantime, the DCFS will be implementing the following: 1. The DCFS is revising the communication with adoptive parents reminding them of their responsibility to inform the DCFS of situational changes that could affect the subsidy agreement. 2. The DCFS is amending its adoption agreement template to more clearly define how and when an adoption subsidy can be suspended or terminated by the DCFS. 3. The DCFS’ Policy, Legal, Quality Assurance, Finance and Adoptions Administration divisions are currently reviewing all forms and policy documents to ensure they are consistent in communicating the preceding steps. The DCFS will include definitions of legal responsibly and financial support to establish the parameters of suspension or termination of subsidy payments. There has been significant progress in this area that has resulted in significant policy changes that are being finalized with assistance and input from the CB. 4. The DCFS will amend its Title IV-E plan related to adoption subsidy payments to include definitions consistent with item 3 above. 5. The DCFS will review its processes, including its information systems, to determine if information captured by permanency case workers can be data mined for review to support continued adoption subsidy payments. 6. The DCFS is creating communication procedures related to appeal decisions of termination and suspension of subsidy payments to adoptive parents to ensure they are aware of their rights to appeal and how the appeal process works.

As of June 30, 2022, the portfolio was transition. Thus, no further corrective action is considered necessary.