Corrective Action Plans

Corrective Action Plan (CAP): The College has identified that the dates of enrollment submissions and status changes for the two students identified in the audit were out of compliance (92 days and 66 days). The statuses of both students are correct with NSLDS. Student 1: Student earned all F grades during the fall 2024 trimester. The student's status was changed to withdrawal in the internal student information system on January 17, 2025. This change was not communicated to NSLDS until the March 2025 enrollment report, due to issues with the February 2025 enrollment report. Student 2: Student was a non-returner in the spring 2025 trimester. The student's status was changed to withdrawal in the internal student information system on January 21, 2025. This change was not communicated to NSLDS until the March 2025 enrollment report, due to issues with the February 2025 enrollment report. The College acknowledges this repeat finding and recognizes that, although the gap was narrowed days beyond tolerance, the prior corrective action plan did not fully resolve the underlying cause of late NSLDS reporting. The previous plan relied primarily on manual identification and status-change processes within the student information system, which remained vulnerable to human error and processing delays. To address this gap, the college will implement a secondary review checkpoint that flags students with status changes in the student information system to ensure timely transmission to NSLDS. To prevent additional recurrences, the College has implemented a monthly reconciliation procedure between the Registrar's Office and the Financial Aid Office, replacing the prior plan's reliance on manual status-chang communication alone. Each month, the Registrar's Office provides a student status change report to the Financial Aid Office. The Financial Aid Office then reconciles each status change against the institution's NSLDS submission history to confirm timely and accurate reporting. This added verification step, paired with documented recordkeeping of each reconciliation cycle, directly addresses the root cause of the repeat finding by introducing a cross-office check that does not depend solely on a single manual status update being correctly carried through to NSLDS reporting.

Finding 2025-003: Special Tests and Provisions: NSLDS Reporting Recommendation: The College should develop and implement a formal process for monitoring and updating students' enrollment status in the NSLDS to ensure compliance with reporting requirements. Establish internal controls to track changes in enrollment status and ensure timely updates to the NSLDS. Conduct periodic reviews of the enrollment reporting process to identify and address any inaccuracies or delays. Provide training to relevant staff on the importance of compliance with enrollment reporting requirements and the procedures for accurate and timely updates. Response: The College concurs with Finding 2025-003 and the auditors’ recommendation. To address this finding, the College has implemented the following actions. Corrective Action Responsible Party Target Date Status Execute formal written agreement between FAO and OARR defining data ownership for each NSLDS record type, update timelines, escalation procedures, and monthly reconciliation responsibilities. Agreement reviewed annually. FAO Director/Registrar/VPEMSS 30 days Draft in progress Implement NSLDS Reporting Calendar aligned to the academic calendar, distributed to FAO, Registrar, and VPEMSS. Built-in reminders at 30, 14, and 7 days before each deadline. FAO Director 30 days Being initiated Implement monthly SIS-to-NSLDS reconciliation. The Financial Aid Office (FAO) will reconcile Student Information System (SIS) data against the NSLDS roster, and any discrepancies will be resolved within five (5) business days. Exception reports will be reviewed and certified monthly by VPEMSS. The monthly reconciliation process will be completed before certification by the VPEMSS, and all identified reporting discrepancies will either be corrected or formally documented with an action plan before certification. FAO Director/Registrar 30 days First cycle underway Coordinate with OARR to verify and maintain accurate CIP codes and credential level data for all active programs at start of each academic year. FAO Director/Registrar 60 days In progress Recruit and fill vacant FAO positions to restore NSLDS processing and monitoring capacity. FAO Director/VPEMSS/HRO 90 days In progress Incorporate NSLDS reporting compliance into annual Title IV self-assessment each August. FAO Director/VPEMSS August 2026 Scheduled Primary Responsible Office: Director, Financial Aid Office Oversight Office: Vice President for Enrollment Management and Student Services Overall CAP Completion Target: Within 90 days of the final audit report issuance; NSLDS record updates within 15 days

Finding 2025-002: Special Tests and Provisions: Verification Recommendation: The College should enhance training programs for staff involved in the verification process to ensure they are fully aware of the requirements and procedures. Establish robust internal controls and review mechanisms to ensure that verification worksheets are completed accurately and consistently with ISIRs. Implement a tracking system to ensure that all required corrections to ISIRs are performed in a timely manner. Response: The College concurs with Finding 2025-002 and the auditors’ recommendation. To address this finding, the College has implemented the following actions. Action Responsible Party Target Date Status Reinstate mandatory two-tiered verification file review. No student file in any Verification Tracking Group may be finalized or disbursed without independent review and sign-off by the second FAO staff member. Review logs maintained and submitted monthly to FAO Director. FAO Director/VPEMSS 30 days In progress Implement ISIR Correction Tracking Log. Log captures: date discrepancy identified, date submitted to CPS, CPS confirmation number, and date corrected transaction received. FAO Director reviews weekly. This control directly addresses the gap that led to missed corrections in AY 2024-2025. FAO Director/Student Services Specialist IV 45 days In development Establish mid-year ISIR correction deadline. An internal institutional deadline – set 60 days before the award year closes – will be established to ensure all pending ISIR corrections are submitted before the CPS window closes. FAO Director responsible for tracking FAO Director 30 days Policy and procedure being drafted Mandatory annual FSA verification training for all FAO staff, covering tracking group identification, ISIR-worksheet cross-matching, CPS correction procedures, and the importance of submitting corrections before year-end closure. FAO Director 60 days Scheduled Conduct monthly internal file audits of verified student files. Results reported in writing to the VPEMSS. Shift from quarterly to monthly frequency to ensure errors are caught well before the award year closes. FAO Director 30 days First cycle initiated Revise and redistribute Verification SOP to all FAO staff across all campuses with mandatory sign-off. SOP to include explicit section on ISIR correction deadlines relative to award year closes. FAO Director 30 days In progress Recruit and fill three vacant FAO positions to restore full review capacity FAO Director/VPEMSS/HRO 90 days Recruitment initiated Primary Responsible Office: Director, Financial Aid Office Oversight Office: Vice President for Enrollment Management and Student Services Overall CAP Completion Target: Within 90 days of the final audit issuance

Finding 2025-001: Eligibility Recommendation: We recommend that management establish and implement formal policies and procedures for the administration of the FSEOG program, including clear guidance on the minimum and maximum award limits in accordance with federal regulations. Management should also provide adequate training to Financial Aid Office personnel on applicable federal requirements, perform supervisory reviews of award calculations prior to disbursement, and conduct periodic monitoring to ensure ongoing compliance with established limits. Response: The College acknowledges the findings resulting from the initial year of the Federal Supplemental Educational Opportunity Grant (FSEOG) program's implementation. The College recognizes that the finding resulted from deficiencies in newly implemented award procedures during the first year of the FSEOG program. In light of this, we wish to provide context regarding the situation and the corrective actions undertaken to address the issue. The seven students identified in this finding were awarded FSEOG funds that reflected their significant financial need and the institution's commitment to enabling students to cover both direct and indirect enrollment costs. An internal review conducted by the Financial Aid Office revealed that these awards inadvertently exceeded the $4,000 annual maximum established by program regulations. Following this internal review, prompt corrective measures were enacted, culminating in the issuance of a formal memorandum to the Comptroller in October of FY26. This memorandum directed adjustments to the affected students’ FSEOG awards to ensure compliance with the prescribed annual maximum. This internal monitoring process underscores the College’s proactive commitment to program integrity and fiscal accountability. Furthermore, the unexpended funds were returned to the U.S. Department of Education during FY26. The College remains dedicated to the proper administration of the FSEOG program and has reinforced its internal review procedures. This includes conducting more frequent audits of award ceilings during active disbursement periods to prevent similar errors in future award years. To address the finding, the College will implement the following actions: 1. Establishment of Formal Policy and Standard Operating Procedures (SOPs): Within 30 days, the College will adopt and implement a dedicated section within the Financial Aid Policy and Procedures Manual specifically for the FSEOG program. This document will delineate federal award limitations, selection criteria based on exceptional financial need groupings, and compliance parameters in accordance with 34 CFR 676.20. 2. Staff Training and Competency Review: Prior to the next award cycle, the College will conduct a mandatory training workshop for all counselors and processing staff within the Financial Aid Office. This training will emphasize the identification of the FSEOG-eligible student population, the applicable selection criteria, and the importance of cross-referencing final award packages. 3. Monitoring and Long-Term Quality Control: The College will implement a mandatory two-tiered verification process. Prior to any FSEOG batch disbursement being sent to the Office of the Comptroller for final payment execution, a senior financial aid officer or director must review and authorize a compliance checklist. This checklist will confirm that there are no boundary violations, and any batch disbursement package containing an amount below $100 or exceeding $4,000 per academic year will be flagged for review. Quarterly compliance reviews will be documented and retained as part of the College's internal control records to verify continued compliance with FSEOG award requirements and to provide supporting documentation for future audits. Primary Responsible Office: Director, Financial Aid Office Oversight Office: Vice President for Enrollment Management and Student Services Overall CAP Completion Target: Addressed in Dec 2026

Corrective Action Plan: The annual recertifications were not completed on time due to difficulty obtaining the required tenant information. Stanan will start the process earlier in the year to collect the documentation needed. Stanan’s occupancy specialist and supervisor will closely monitor the timing and progress of all tenant annual recertifications to avoid untimely filings in the future. Anticipated Completion Date: The implementation of training and procedures is expected to be completed by September 30, 2026.

Corrective Action Plan: The return of tenant security deposits were not completed on time due to staff turnover. Stanan’s occupancy specialist and supervisor will closely monitor the timing of the return of security deposits. Anticipated Completion Date: The implementation of training and procedures is expected to be completed by September 30, 2026.

Corrective Action Plan: The annual recertifications were not completed on time due to difficulty obtaining the required tenant information. Stanan will start the process earlier in the year to collect the documentation needed. Stanan’s occupancy specialist and supervisor will closely monitor the timing and progress of all tenant annual recertifications to avoid untimely filings in the future. Anticipated Completion Date: The implementation of training and procedures is expected to be completed by September 30, 2026.

Corrective Action Plan: The annual recertifications were not completed on time due to difficulty obtaining the required tenant information. Stanan will start the process earlier in the year to collect the documentation needed. Stanan’s occupancy specialist and supervisor will closely monitor the timing and progress of all tenant annual recertifications to avoid untimely filings in the future. Anticipated Completion Date: The implementation of training and procedures is expected to be completed by September 30, 2026.

The Child and Family Services Agency (CFSA) concurs with the finding. CFSA has instituted a point-of-payment invoice validation and cost determination process that will allow the Agency to retire the quarterly expenditure reporting process in its entirety. Providers submit invoices that align with their contract schedules and they self-report on a schedule-oriented tool. The CFSA team reviews, validates, and approves each and every invoice. The tool tracks invoiced cost for the entire fiscal year such that by year’s end there is a verified, validated catalogue of reported costs that are used to derive the family-based rate that drive the adjustment claims for these special tests and provisions.

The Child and Family Services Agency (CFSA) concurs with the finding. The June 2025 implementation of STAAND, CFSA’s new system, included safeguards to mitigate the generation of claims for federal reimbursement for payments made to any provider for which there is a critical licensure issue.

The University of the District of Columbia (UDC) agrees with the conditions and recommendations of this finding. Management action plan includes the following steps: • The Office of the Registrar will continue to use National Student Clearinghouse third party reporting tool to report enrollment data to NSLDS. • The Office of the Registrar continues to utilize the "Submission schedule tool" to keep us compliant with the timeframe required for submission of the reports. • Students who have been reported during the first week of courses as "Never Attended - NA" will be dropped from their courses for the term no more than 1 week after the end of attendance verification. • The Enrollment Time Status (Full Time, Part Time, etc.) for student who are enrolled in Summer courses will be updated effective immediately.

The University of the District of Columbia (UDC) agrees with the conditions and recommendations of this finding. Management action plan includes the following steps: The Office of Financial Aid is implementing enhanced controls to strengthen the accuracy and timeliness of its Return of Title IV Funds (R2T4) processes. Moving forward, all official and unofficial R2T4 calculations will be subject to more comprehensive review, replacing the prior practice of reviewing a limited sample. To further support compliance and coordination, automated email notifications will be issued to designated staff responsible for both loan and Pell Grant reporting whenever an R2T4 is processed. This will ensure timely awareness and appropriate action by all relevant parties. In addition, staff calendars will be updated to include critical regulatory deadlines associated with the return of Title IV funds. These calendar controls are intended to reinforce adherence to federal requirements and promote consistency across all cases. These measures are designed to improve oversight, enhance internal controls, and ensure full compliance with federal Title IV regulations. The Office of Financial Aid acknowledges that elements of these controls had been previously identified and implemented; however, these processes will be further strengthened, formalized, and consistently applied to ensure full compliance with federal Title IV regulations.

The University of the District of Columbia (UDC) agrees with the conditions and recommendations of this finding. Management action plan includes the following steps: • The Bursar or designee shall run a report daily of all Title IV disbursements that occurred on the prior business day. • The Bursar or designee will run a report for Title IV funding awarded the previous day for the terms shown on the disbursement report above and select students who had a Title IV disbursement based upon the report above. • The students with the disbursements shall be reviewed in addition to any other student shown having a Title IV Credit balance to determine if a non-refunded Title IV credit balance exist. • Where a non-refunded Title IV credit balance exist, the student shall be included in the list of refunds named Refund Review Report dd/mm/yyyy to be processed following the institution refund process for Title IV Credit Balances. • At the end of the day, the Bursar or designee shall generate a report showing the refunds entered in the system for that day and confirm all previously identified Title IV refunds credit balance refunds were completed and attach said report to the refund review report and save in a designated folder. • The Bursar or designee will complete the batch release process daily to allow refund entered on student records to be transmitted to AP following institutional process. • On the AP check run date, the Bursar or designee shall review the check run notification from AP to confirm all refunds entered in the system since last check run date have been processed successfully. • We will conduct collective training with staff involved in student credit processing as it pertains to Department of Education regulations. Additionally, we will train Staff to ensure understanding of the Corrective Action Plan (CAP) to be taken.

The University of the District of Columbia (UDC) agrees with the conditions and recommendations of this finding. Management action plan includes the following steps: The Office of Financial Aid has recognized irregularities in the student disbursement notification process. The office currently utilizes Banner Communication Management (BCM) as the primary system for delivering required notifications to students. While this system has historically functioned effectively, recent observations indicated inconsistencies that impacted the timely delivery of certain required notices. In response, the office will initiate enhancements to its notification procedures. Specifically, we will implement a supplementary notification process that will include the use of our new platform, Salesforce. The use of Salesforce should help to provide a reliable communication system for our messages. This dual process approach is intended to strengthen reliability and provide redundancy in the delivery of required communications. These improvements are designed to ensure that all disbursement notifications are transmitted within required timeframes, in full compliance with federal Title IV regulations.

The University of the District of Columbia (UDC) agrees with the conditions and recommendations of this finding. The Office of Financial Aid experienced staff turnover, which impacted the timeliness of reporting submissions to the Common Origination and Disbursement (COD) system. This challenge was further compounded by the need to train and cross-train staff to ensure continuity in reporting responsibilities. To address this issue, the office has identified and trained two staff members who are capable of originating and submitting enrollment reporting to COD. Additionally, we have implemented enhanced internal controls, including weekly reporting processes, to ensure compliance with all required deadlines. These measures are designed to ensure that records are submitted within the mandated 15-day timeframe.

Finding 2025-007 MiSACWIS Security Management and Access Controls Management Views MDHHS agrees with the finding. Planned Corrective Action For part a., MDHHS currently has a process in place to review the user narrative describing the incompatible role exceptions within the DSA Michigan Statewide Automated Child Welfare Information System (MiSACWIS) request as part of the approval process. Also, MDHHS added an incompatible role form in the DSA MiSACWIS request with automated routing for appropriate approval on November 11, 2025. In addition, MDHHS provides ongoing education during the quarterly LOSC webinars, where guidance is shared with the LOSCs on security management and access control topics, such as the correct procedures for processing system access requests. For part b., during April 2025, MDHHS updated the renewal processing start date to 15 days earlier to ensure renewal requests are reviewed prior to the annual recertification date. Anticipated Completion Date Completed Responsible Individual(s) Tim Kwast, MDHHS Alana Lowe, MDHHS

Finding 2025-044 Temporary Assistance for Needy Families, ALN 93.558 - Inappropriate TANF-Funded Emergency Foster Care Assistance Management Views MDHHS agrees with the finding. Planned Corrective Action MDHHS redetermined the Foster Care Title IV-E (Title IV-E) eligibility after the birth certificate was received and the youth was determined to be Title IV-E eligible. MDHHS has already reclassified the funds to the appropriate funding source, allowing the department to claim Title IV-E for the eligible placement, and repaying any TANF overpayments. Reconciliations between different fund sources, or recoupments for overpayments, will be created within 30 calendar days of receipt of supporting documentation and approved timely by management. All recoupment and reconciliation records will be approved by management no later than September 30 each fiscal year to ensure compliance with year-end requirements. Anticipated Completion Date September 30, 2026 Responsible Individual(s) Nancy Berger, MDHHS

In May of 2026, the Institute amended its procedures to (1) require the printing of a schedule of student balances after application of Federal Pell Grant and Loan receipts and (2) for all students with a credit balance within 12 days of the Pell receipt indicating the check number and date of the refund to the student on this schedule. This schedule is then to be reviewed for adherence to the required 14-day refund requirement under the Pell program by another staff member.

As reported in the Institutes fiscal 2024 Corrective Action Plan, in May 2025, the Institute revised its current procedures to include having an employee independent from the exit conference process review that any student not enrolled in a new semester or that is enrolled at less than half time status has received proper exit conferencing and that exit conferencing has been properly documented. Two of the findings in the current fiscal 2025 occurred prior to the May revision by the Institute of its procedures. The third finding occurred during a period that the independent party performing the review function was on leave due to a death in the family. The Institute recognizes the importance of ensuring that exit conferences are performed timely and properly documented. Management has met with its staff involved in this process to emphasize its importance. Additionally, an additional staff member has been assigned to perform the review procedures if the staff member responsible is not available to timely perform the procedures.

Recommendation: We recommend that the college review its processes and internal controls related to SAP and ensure procedures are in place to ensure students who are not meeting SAP requirements are properly identified and disbursed aid in accordance with the institution’s SAP policy. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Since December 2025, the College has worked with the SIS Managed Services team (Anthology now Ellucian) to update its SAP policy and ensure compliance with federal regulations. The new SAP policy was fully implemented effective during the Winter 2026 term. As an internal control, at the end of each term when SAP is evaluated, the results are pre-screened by the Coordinator of Financial Aid with oversight from the Director of Financial Aid to ensure accuracy before results are posted live in the system. Additionally, the College has clarified its understanding of Anthology’s treatment of students who are newly enrolled at the College or who have changed into a different program version. These students are designated with a not-calculated SAP which represents a blank or null status until the conclusion of the term when the students receive a passing or failing grade and can be evaluated by the SAP standards. Steps also have been taken to ensure that prior enrollments are linked to ensure integrity of the application of SAP standards based on the cumulative pace, GPA and maximum timeframe. As a further measure to ensure the integrity of awarding Title IV funds only to eligible students, the College has placed students with prior ineligible SAP statuses in a hold group within the SIS and identified these students as not meeting Disbursement Approval Criteria (DAC) thus causing any attempt to disburse funds to them to fail. Name(s) of the contact person(s) responsible for corrective action: Sarajane Viemeister and Denise Reid-Strachan. Planned completion date for corrective action plan: June 30, 2027.

Recommendation: We recommend the College changes its process and controls to ensure exit counseling emails are sent to graduate/withdrawn students throughout the year. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Since August 2025, the College has taken steps in conjunction with its SIS Managed Services team (Anthology) to establish an automated process to notify graduate/withdrawn students to complete the Exit Counseling requirement. Since then the Director of Financial Aid has been spot-checking the notifications to ensure that the exit counseling notification is being triggered for withdrawn students. Going forward, the Financial Aid Office will use the Task Function in Anthology to confirm that the notification has been sent and close the task which will be timestamped with the name of the reviewer. Name(s) of the contact person(s) responsible for corrective action: Sarajane Viemeister and Denise Reid-Strachan. Planned completion date for corrective action plan: June 30, 2027.

Recommendation: We recommend the college review its process and procedures for R2T4 calculations to ensure they are in line with Dept. of Education requirements. We also recommend the college maintain evidence of the formal review process that ensures Return of Title IV calculations are being performed timely and correctly to minimize the likelihood that errors may go undetected and not corrected in a timely manner. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The College will ensure that all Financial Aid policies and procedures are up-to-date; reviewed annually; and revised, as needed. Documentation will also be made for any procedures that are currently being performed by their third-party-servicer, Global including Return to Title IV (R2T4) calculations. As an internal control, the Financial Aid Office will retain records of the Return to Title IV calculations performed by Global; sign-off on the appropriate reports with the date reviewed; include the initials of the Coordinator of Financial Aid and co-signed by the Director of Financial Aid. The Coordinator of Financial Aid will notify Global of funds to be returned by the institution and/or student by completing the established process (GARP) to ensure that the funds are returned to the Department of Education within 45 days of the Date of Determination. Name(s) of the contact person(s) responsible for corrective action: Sarajane Viemeister and Denise Reid-Strachan. Planned completion date for corrective action plan: June 30, 2027.

Recommendation: We recommend the College review internal control reports and implement review controls for work performed by third-party servicers. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Currently, CGCC reviews several weekly reports from its third-party servicer, Global Financial Aid Services which indicates the actions which could not be completed by Global due to missing information, etc. These reports are discussed during the weekly call between Global and CGCC at which time steps are taken to resolve outstanding issues. CGCC also has access to other Financial Aid (FA) Reports in the Global Administration portal including verification, resolution of C-Flags and Unusual/Special Circumstances reviews which are conducted by Global. Going forward, the Financial Aid Office will review these reports monthly to ensure that the students are awarded and their funds disbursed in a timely fashion. As an internal control, documentation of the review of the FA reports will be retained, signed and dated by the Coordinator of Financial Aid and co-signed by the Director of Financial Aid. To further ensure integrity in the administration and awarding of Title IV funds, CGCC will annually request an SSAE 18 Report from Global in October of each year and subsequently, where applicable, a Bridge Letter to cover the intervening period between reports. Name(s) of the contact person(s) responsible for corrective action: Sarajane Viemeister and Denise Reid-Strachan. Planned completion date for corrective action plan: June 30, 2027.

Recommendation: We recommend the college review current processes and procedures for NSLDS enrollment reporting and retain evidence of an internal control that ensures timely and accurate reporting being performed. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: During the past year, the College (CGCC) has worked vigorously to bring NSLDS enrollment reporting up-to-date. The College currently reports enrollment data to NSLDS through the National Student Clearinghouse. The Registrar annually establishes the Clearinghouse reporting schedule based on CGCC’s quarter system, including term start, midterm, and end dates. The schedule is posted in the Clearinghouse system, and Clearinghouse sends email reminders before scheduled reporting dates. The Registrar completes the scheduled reporting process, reviews posting results and error reports when received, and resolves any identified errors promptly to allow the enrollment file to be processed and reported. Going forward, the internal control will be to add secondary review by providing the retained report to the Vice President of Student Services. The report will include the date reviewed/submitted and the Registrar’s initials, and the Vice President will also initial the report as evidence of review. This provides documentation of completion and accountability to help ensure enrollment reporting is completed in a timely fashion. Name(s) of the contact person(s) responsible for corrective action: Catherine Graham. Planned completion date for corrective action plan: June 30, 2027.

Recommendation: We recommend the college review the requirements and implement an internal process and control to specifically monitor the outstanding Title IV funded checks. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: On a monthly basis, as part of the bank reconciliation process, the Business Office generates a report of outstanding student refund checks and reviews it for uncashed items. Uncashed Title IV checks are recorded on a tracking log noting check number, issue date, and amount. When a check remains uncashed for 120 days, the Business Office contacts the student to confirm receipt or determine whether a reissue is needed, and the outreach is documented on the log. The monthly review and log are signed and dated by the preparer; co-signed by the Vice President of Administrative Services, and documentation is retained including months in which no exceptions are noted. At the conclusion of the monthly review process, an email with subject line: Uncashed Refund Checks is forwarded to the Financial Aid Office which includes a spreadsheet listing the students with uncashed refund checks or a note that there were no records for that particular month. Any Title IV check that remains uncashed is canceled by the Business Office. Within 5 - 7 business days of receiving the notification from the Business Office, the Financial Aid Office will notify the third-party servicer, Global Financial Aid Services (herein after referred to as Global) through their established reporting mechanism (GARP) to ensure the funds are returned to the Department of Education no later than 240 days after the date of issuance, as required by 34 CFR 668.164(h). Name(s) of the contact person(s) responsible for corrective action: Sam Draper and Denise Reid-Strachan. Planned completion date for corrective action plan: June 30, 2027.