Corrective Action Plans

2024-002 Significant Deficiency: Federal Work-Study (FWS) Underpayment (U.S. Department of Education, Federal Work-Study Program, ALN #84.033) Name of Contact Person Melissa White, Director of Financial Aid, is responsible for ensuring that Federal Work Study students are properly paid for hours worked. Corrective Action Planned During the audit, it was noted that Tusculum errantly miscalculated hours worked and wages payable results in student receiving fewer Title IV funds than what they may have earned or be eligible for. Once found, the missing hours were added to the next payroll and the students were paid. To ensure this error does not occur again in the future, financial aid has created a secondary check system that includes keeping an additional excel that confirms that each timesheet has been paid for each student and that their full hours worked have been paid. We have also reinforced with supervisors the urgency of making sure timesheets are submitted in a timely manner so that the error does not occur again as the timesheets in question were late timesheets. Additional training for supervisors and constant reminders to supervisors are also ongoing. Anticipated Completion Date 10/15/2024

Corrective Action Plan: The identified conditions relate to students who graduated off-cycle. To mitigate the risk of future status change reporting issues, the College is implementing an additional monthly review process that will generate a report of students who have separated from the College. This report will be reconciled with student status changes transmitted by the National Student Clearinghouse (NSC) to the National Student Loan Database System (NSLDS), and any necessary corrections will be made immediately. Timeline for Implementation of Corrective Action Plan: These corrective actions are being implemented in Spring 2025.

Finding 2024-003 – U.S. Department of Education (USDE), Title IV Student Financial Aid Programs (Significant Deficiencies): We observed the following conditions in connection with our testing of the various U.S. Department of Education, Title IV, Student Financial Assistance Programs. 1) The College did not reconcile the following programs between the Office of Financial Aid and the Business Office. Per 34 CFR 685.300(b)(5). a. Federal Pell Grant Program b. Federal Direct Student Loans c. Federal SEOG d. Federal Work-Study (FWS) Program 2) The Office of Financial Aid submitted unreconciled expenditures within the Fiscal Operations Report and Application to Participate (FISAP) for the programs below: a. Federal Pell Grant Program b. Federal Work-Study (FWS) Program c. Federal SEOG 3) Thirty-two out of 60 students had a credit balance on their account created by Title IV program funds longer than 14 days. 34 CFR 668.164(h)(1). Auditor's Recommendation – The University should implement corrective actions to ensure that the above findings are resolved and will not recur in future periods. Corrective Action – Refunds – The refund non-compliance is contributed to the institution’s ERP (Jenzabar) not being operational for about 7 months. This hindered the staff’s ability to properly review and process student refunds timely. The institution has a process in place to ensure compliance of distribution and is also enhancing the student refund module to improve timeliness of refund distribution. Federal Reconciliations and FISAP – The non-compliance is contributed to the institution’s ERP (Jenzabar) not being operational for about 7 months. This hindered the staff’s ability to properly reconcile federal funds timely and assurance in accuracy in completing the FISAP. In addition, the software enhancements for the Accounting modules, the institution has purchased a system enhancement for Financial Aid to be able to centralize FA processing and generate Federal Reconciliations and FISAP report. The Jenzabar Financial Aid software will assist the institution with maintaining compliance with all external federal reporting.

Corrective Action Plan: In March of 2024, the College created a policy that implemented scheduled disbursement dates to ensure the timely recording of disbursement dates. The finding for June 30, 2024, single audit occurred before the new policy was in effect. The number of findings also decreased, and students audited after the corrective action was put into place were done correctly. To continue to mitigate this from occurring in the future, the College has implemented a report that will show differences in the date Direct Student Loan funds are disbursed in Powerfaids versus the date the funds are applied to a student’s ledger, and date shown as disbursed in COD. All differences will be investigated and rectified on a biweekly basis. Timeline for Implementation of Corrective Action Plan: Implemented in March 2024 Contact Person Lynn Comtois Director of Financial Aid

Condition: The notifications related to the direct loan borrowers did not include information on the right to cancel or instructions on how to cancel the loans. Planned Corrective Action: Missing notifications to students was a result of a coding error in the automated process that was resolved on September 5, 2023. Notifications to parents didn’t begin until the Summer 2023, with an automated procedure being implemented in the Fall 2023 semester. A coding issue was identified and resolved in the automated procedure to notify parents in early January 2024. Contact person responsible for corrective action: Kent McGowan, Assistant Director, Office of Financial Aid Anticipated Completion Date: This finding was corrected as of January 2024.

Reporting – The University will review and update current procedures to ensure timely processing and monitoring of NSLDS reports. Internal reports will be run simultaneously to make sure all students are captured and their status is correctly reported. Anticipated Completion Date - September 30, 2024; Responsible Contact Person for Planned Corrective Action - Tina Baskin, Executive Director of Financial Aid & Enrollment Services

2024-005 Student Financial Assistance Cluster – CFDA Nos. 84.063, 84.033 and 84.268 – Credit Balances Recommendation: We recommend that the University reevaluate its process to ensure that credit balances on student accounts due to the application of title IV funds are refunded within 14 days. Explanation of disagreement with audit finding: There is no disagreement to the audit finding. Action taken in response to finding: ERP (Banner) system was being used to generate reporting for credit balances. A glitch was discovered using this process due to application of payment. Student Accounts change the reporting method to Argos, which provided a more accurate and timely report of all credit balances regardless of the disbursement term. Name(s) of the contact person(s) responsible for corrective action: AVP of Student Accounts, Carold Boyer-Yancy & Senior Associate Director of Operations, Lindsay Sands Planned completion date for corrective action plan: December 2024

2024-004 Student Financial Assistance Cluster – Federal Assistance Listing Nos. 84.007, 84.063, and 84.268 – Outstanding Refund Checks Recommendation: We recommend the University review policies and procedures around outstanding student refund checks to ensure the checks are returned to the ED prior to the 240-day deadline. Explanation of disagreement with audit finding: There is no disagreement to the audit finding. Action taken in response to finding: The Assistant Controller will implement review procedures for timely reconciliation of bank and ledger accounts & maintain an accurate listing of those discrepancies. This information will be timely shared with respective teams to address. Name(s) of the contact person(s) responsible for corrective action: Assistant Controller, Clifton Smith, II. Planned completion date for corrective action plan: July 2025

2024-003 Student Financial Assistance Cluster – Federal Assistance Listing Nos. 84.063, and 84.268 – Enrollment Reporting Recommendation: We recommend the University evaluate its procedures and review policies in overseeing submissions to the NSLDS completed by the third-party servicer. Additionally, we recommend the University review its policies and procedures on reporting enrollment information to the NSLDS to ensure that all relevant information is being captured and reported timely in accordance with applicable regulations. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Registrar’s Office will review and strengthen the enrollment report to ensure it pulls all required information according to the needs of the National Student Clearinghouse (NSCL) and the National Student Loan Data System (NSLDS). The Registrar’s Office will continue to work with the National Student Clearinghouse (NSCL) and National Student Loan Data System (NSLDS) on the specific enrollment submission scenarios that require a different submission/update requirement. Name(s) of the contact person(s) responsible for corrective action: University Registrar, Dr. Genita Mangum Planned completion date for corrective action plan: December 2025

Action taken in response to finding: A formal review of will take place of NSLDS reporting. Written policy with a monthly checklist will be developed to be in compliance with the regulation for student statuses. Name(s) of the contact person(s) responsible for corrective action: Patrick Farley Planned completion date for corrective action plan: June 30, 2025

Action taken in response to finding: To address the identified deficiencies in WAU’s written information security program and ensure compliance with 16 CFR § 314.4, the following actions have been taken: 1. Approval of the Information Security Program: o Action: We have updated the written information security program as formally approved by the appropriate individual within the institution, Rosalee Pedapudi, ITS Director. This step designates a qualified individual responsible for overseeing and implementing the information security program as a requirement under 16 CFR § 314.4(a). 2. Design and Implementation of Safeguards: o Action: According to 16 CFR § 314.4(c), institutions must implement safeguards to control identified risks, including encryption of customer information in transit and at rest. We have documented specific safeguards to control the risks identified through the institution's risk assessment, including a policy mandating the encryption of customer information both on the institution's systems and during transmission. As such, the university encrypts Non-Public Financial information both at rest and in transit using industry-standard encryption protocols (e.g. VPN). Where encryption is not feasible, compensating controls are implemented to protect sensitive data. The university also requires Multifactor Authentication (MFA) for systems that process, store, or transmit protected financial information. Access is governed by the principle of least privilege, with privileged access granted by authorized university officers, ensuring that only approved personnel can access sensitive data. 3. Regular Testing and Monitoring of Safeguards: o Action: According to 16 CFR § 314.4(d), WAU is required to regularly test and monitor the effectiveness of their safeguards to ensure the security of customer information. We have established procedures for annual penetration testing through Applied Technology Services and monitoring of the effectiveness of the implemented safeguards. Name(s) of the contact person(s) responsible for corrective action: Rosalee Pedapudi Planned completion date for corrective action plan: July 15, 2025.

Action taken in response to finding: The University has SAP policies and procedures in place to determine student’s eligibility for Financial Aid that complies with Federal regulations, including qualitative (GPA), quantitative (pace of completion) and maximum timeframe standards. The SAP finding may be due to system error with the Colleague ERP when the SAP report was run. The University will evaluate our SAP procedures and perform internal audits to identify gaps or inconsistencies and implement corrective actions as needed. Training will be provided to financial aid staff on SAP requirements and procedures to ensure consistent application and understanding. Name(s) of the contact person(s) responsible for corrective action: Alfred Taylor Planned completion date for corrective action plan: June 30, 2025

Action taken in response to finding: Washington Adventist University (WAU) is evaluating its current internal control and will make the necessary improvements so as to assure accuracy and compliance with the laws and regulations applicable to WAU. Furthermore, WAU will map internal control to improve segregation of duties where possible and follow the Committee of Sponsoring Organizations of the Treadway Commission best practices for small business. Name(s) of the contact person(s) responsible for corrective action: Alfred Taylor Planned completion date for corrective action plan: June 30, 2025.

All graduate and withdrawn student files will be reviewed on a monthly basis to verify any status changes are reported to NSLDS within regulatory timeframes. Training and professional development will be required for responsible staff to ensure a compliance schedule is developed. Personnel will be evaluated to ensure existing policies, procedures, and processes are followed and supported through corrective action where needed.

Uniform Guidance Corrective Action Plan Year ended June 30, 2024 Federal Finding #2024-001 Returns of Title IV funds are required to be deposited or transferred into the student financial assistance account or electronic fund transfers initiated to the Department of Education as soon as possible, but no later than 45 days after the date the institution determines the student withdrew. Quinnipiac University agrees with the finding. For one student who withdrew during the 2023 – 2024 academic year, the Direct Loan funds awarded to that student were not returned to the student financial assistance account within 45 days after the University determined the student withdrew. For one student who withdrew during the 2023 – 2024 academic year, the Pell and Direct Loan funds awarded to that student were not returned to the student financial assistance account within 45 days after the University determined the student withdrew. The finding is attributed to programs previously being reconciled monthly or when enough authorized funds became available within G5. At the time the above students withdrew, there were not enough authorized funds to process the net total of draw downs and returns so a batch was held until more funds were available, which resulted in returns surpassing the 45 day threshold. In December 2023, Management implemented additional steps within the reconciliation process of Title IV awards in order to prioritize the return of any unearned Title IV awards so that they are remitted to the student financial assistance account within G5 in a timely manner. The students mentioned above withdrew prior to these additional steps being implemented. If the Office of Management and Budget have questions regarding this plan, please reach out to Stephen Allegretto, the Associate Vice President for Finance and Controller, who is responsible for ensuring this corrective action plan is implemented, at 203-582-7962.

The District's budget report related to the ESEA Title IV program be reviewed to ensure that appropriations and resulting balances accurately reflect remaining program funds available.

2024-001 Enrollment Reporting (Significant Deficiency), Department of Education, Student Financial Aid Cluster, Special Tests and Provisions Condition: The College did not report student enrollment data to the National Student Clearinghouse within the minimum required timeframe. Criteria: 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 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 (34 CFR 685.309(b)(2)(i)). Cause: The College does not have adequate procedures in place to ensure students’ enrollment statuses are updated on NSLDS timely. Effect: Enrollment data was not reported timely or accurately to the Department of Education thus, the Department could not properly service the students’ loans. The accuracy of the Title IV student loan records depends heavily on the accuracy of the enrollment information reported by institutions. Context: From a population of 42 students that withdrew officially during a term, we tested 5 students and noted that all 5 were not reported timely. Recommendation: We recommend that the College put procedures in place to ensure that any changes in student enrollments are properly tracked and updated to the NSLDS. Management Response: When the Registrar’s Office is notified of a student’s withdrawal (official or unofficial), within 24 hours the student’s record in the National Student Clearinghouse will be manually flagged as withdrawn with their last date of attendance. Party responsible: Sherry A. Phelps Office phone: 540-828-5313 Email address: sphelps2@bridgewater.edu Expected date of correction: This problem was corrected on 6/27/2024 when it was brought to my attention and since that date the required information has been correctly reported directly into the National Student Clearinghouse within 24 hours of the date of determination of a student’s withdraw from the college.

Federal Program: U.S. Department of Education Federal Direct Loan Program, Federal Assistance Listing 84.268 Criteria: The University is required to comply with 36 CFR Section 685.309(b). Condition: During our testing of 40 students for eligibility, we noted three students in which the students' status change was not timely reported to the National Student Loan Database System (NSLDS). Corrective Actions Taken or Planned: For the year ended June 30, 2024, three students were reported late to NSLDS. Each student, after being identified, were then reported to NSLDS with the correct status and date. The Office of Institutional Research will work with the Registrar’s Office to ensure that students are reported in a timely manner. The Director of Institutional Research has provided the following steps that will be taken when a student is reported as withdrawn: 1. View the student's transcript in Ellucian to see if he/she withdrew or is back-dated as never enrolling. 2. Update Excel file for the term enrollment accordingly. 3. Update National Student Clearinghouse (NSC) file that will be submitted on the next due date. 4. Manually update the student's enrollment in National Student Clearinghouse 5. Manually update the student's enrollment in NSLDS Name of Responsible Person: Daniel Donner, Director of Financial Aid Completion Date: August 13, 2024

Finding 2024-001 Federal Program: U.S. Department of Education Federal Pell Grant Program, Federal Assistance Listing 84.063 Criteria: The University must comply with 34 CFR 690.61(a)(1). Condition: During our testing of 40 students for eligibility, we noted one student who was eligible for a Pell grant, but was not awarded nor disbursed a Pell grant. Upon further analysis, there were four additional students that were eligible for a Pell grant and were not awarded nor disbursed a Pell grant. Corrective Actions Taken or Planned: For the year ended June 30, 2024, it was found that some students were not awarded eligible Pell grants. After the initial students were discovered, the University reviewed all students that were active for the 2023-2024 award year and reviewed their most current Institutional Student Information Record (ISIR) to determine which students may not have been awarded Pell grants correctly. Affected students were then awarded as needed and funds applied to their account. Going forward, the University will review subsequent student ISIRs and run additional reports to ensure students are awarded the correct amount of Pell grants. This additional review will capture those who would have previously been missed. Name of Responsible Person: Daniel Donner, Director of Financial Aid Completion Date: August 13, 2024

Federal agency: U.S. Department of Education Programs: Federal Direct Student Loans Assistance listing #: 84.268 Award year: 2024 Corrective Action Plan: Previously, this was an ancillary work task for a staff member in a different department. CU has since hired an experienced Registrar and begun training an Associate Registrar. The dedicated department now updates Clearinghouse on the required monthly basis. All previous records have been corrected. Timeline for Implementation of Corrective Action Plan: Completed Contact Person: Mark Hartonchik, CFO

Finding number: 2024-002 Federal agency: U.S. Department of Education Programs: Federal Direct Student Loans Assistance listing #: 84.268 Award year: 2024 Corrective Action Plan: These findings are from Fall 2023. College Unbound has corrected this as of Spring 2024. The new practice, started February 2024, is to run a weekly report every Friday of disbursements made during that week. Every student on that disbursement list receives and email that a disbursement has been made and instructions how to review their account in their online student portal. We have been replicating this process for over 12 months now and will continue to do so in the future. Timeline for Implementation of Corrective Action Plan: Completed Contact Person: Mark Hartonchik, CFO

Finding number: 2024-003 Federal agency: U.S. Department of Education Programs: Student Financial Assistance Cluster Assistance listing #: 84.063 and 84.268 Award year: 2024 Corrective Action Plan: This finding was the result of failure to fully execute a professional judgment (PJ) calculation. We processed a PJ on the now-closed FAA access but failed to import the updated EFC into our system. As FAA is now closed, we cannot show the updated EFC. College Unbound does regular monthly checks to ensure that no student exceeds cost of attendance or need. This one was a PJ done sloppily. Timeline for Implementation of Corrective Action Plan: Completed Contact Person: Mark Hartonchik, CFO

Dear Mr. Waguespack, The University of Louisiana at Monroe acknowledges receipt of the audit finding related to Noncompliance and Inadequate Controls over Direct Loan Monthly Reconciliations. We appreciate the opportunity to respond and outline the corrective actions the university has taken or plans to implement to address the issue. Corrective Action Plan: The Financial Aid Office will be reaching out to Common Origination and Disbursement (COD) for assistance in correcting this issue with the monthly account statement. The discrepancies were identified each month, however the reason for the discrepancy and how we corrected the error was not documented. We will adjust our policies and procedures to add these steps to the reconciliation process in addition to the secondary reconciliation of the account statement that will be completed. To address this issue, the university has implemented or is in the process of implementing the following corrective actions: 1. Action Taken or Planned: • Work with COD to correct issues with accessing monthly account statements. • Implement a process to add a secondary monthly reconciliation of account statements, in addition to the current method of reconciling each month using the annual report. This will ensure that no loan discrepancy is missed in the reconciliation. • Train the new Functional Analyst how to document discrepancies on the monthly report. • Add a designated column to the discrepancy list identifying the exact amount in question and the reason why it does not match COD. • Send response emails documenting reconciliation has been reviewed, issues have been cleared, and how each issue was cleared. 2. Implementation Timeline: April 1, 2025 3. Responsible Party: Various members of the Financial Aid team. Director Marla Herrington and Functional Analyst Lacie Campbell will be responsible for the implementation and execution of the corrective action. 4. Ongoing Monitoring and Compliance: When the Director sends the email confirming the corrections have been completed, the Director will copy the Associate Director of Customer Service, Erica Hopko, on the email alerting her to verify that all components have been addressed and that the discrepancy has been clearly explained. The university is committed to maintaining compliance with all applicable regulations and strengthening internal controls to ensure the integrity of our financial aid processes. Please do not hesitate to reach out if any further clarification is needed.

We have reviewed the audit findings from your letter dated January 24, 2025, and appreciate the time and effort of your staff in assisting us in improving our operations. Please find our response to the finding below. Finding: Inaccurate Reporting of Student Enrollment Status Management concurs with the finding noted in the report. Corrective Actions: 1. The Registrar's Office created a new National Student Clearinghouse (NSC) reporting schedule to ensure compliance. Completion Date: August 30, 2024 2. The new NSC reporting schedule will be published on the Registrar's website for accountability and information purposes. Estimated Completion Date: February 15, 2025 3. Programming changes to PeopleSoft will be completed whenever new degree programs are created to ensure that students are reported correctly to the NSC. The Registrar's Office will update its policies and procedures, as well as NSC reporting instructions based on these changes. This will ensure that students are reported correctly to the NSC. Estimated Completion Date: April 1, 2025 4. The Office of Financial Aid granted access to National Student Loan Data System (NSLDS) enrollment corrections to the Registrar’s Office. Completion Date: January 27, 2025 5. The Registrar's Office will create new policy and procedures to manually correct NSLDS enrollment data for any enrollment transactions (retroactive drops or withdrawals) taking place after the final NSC submission for each term that has been sent. Estimated Completion Date: May 16, 2025 Responsible Personnel: University Registrar If you have any additional questions or concerns, please do not hesitate to contact me.

We have reviewed the audit finding from your letter dated January 14, 2025, and appreciate the time and effort of your staff in assisting us in improving our operations. Please find our response to the finding below. Finding: Control Weakness over Direct Loans Monthly Reconciliations Management concurs in part with the finding noted in the report. Response: LSUHSC-NO is committed to continued fiscal responsibility in all facets of our University, including our participation in, and administration of, the Federal Direct Student Loans program. As evidence of our commitment, LSUHSC-NO has a three pronged reconciliation approach when administering these federal dollars: 1) the Office of Financial Aid (OFA) completes a monthly reconciliation between loan disbursements recorded in PeopleSoft and the federal Common Origination & Disbursement (COD) system, 2) with each drawdown request from the OFA, the Sponsored Project office compares the "Net Draws" in G6 to "Cash Receipts" reported in COD to ensure the drawdown of federal funds is appropriate, and 3) the Accounting Services office completes a monthly reconciliation whereby the activity in the federal systems (G6 and COD) are reconciled to the activity in our ledgers and sub-ledgers. The noted finding is in relation to the reconciliations performed by our Accounting Services office. Due to staffing transitions in LSUHSC-NO's Office of Financial Aid, there was a delay in the completion of the monthly reconciliations for the months of July 2023 - September 2023; therefore, these reconciliations were not finalized until November 2023. LSUHSC-NO believes that it has fully complied with the requisite federal regulations and has exercised appropriate controls over the administration of these federal dollars. The Federal regulations state that "schools must, on a monthly basis, reconcile institutional records with the Federal Direct Student Loan Funds received and disbursement records submitted ...” 34 CFR 685.300(b)(5). The regulations do not specify when monthly reconciliations must occur. Additionally, it is of note that the monthly reconciliations tied out exactly and contained no errors. Therefore LSUHSC-NO believes that its monthly reconciliations were in compliance with the regulations as written. However, we do recognize that timely reconciliations are an important control feature and our direct loan reconciliation procedures should be revised to ensure that the reconciliations are prepared and reviewed timely. Corrective Action: 1. Accounting Services will modify its procedures governing the reconciliation of federal direct loans to ensure that the reconciliations are prepared and reviewed within 45 days of month end. Responsible Personnel: Executive Director of Accounting Services Anticipated Completion Date: January 31, 2025 If you have any additional questions or concerns, please do not hesitate to contact me.