Corrective Action Plans

The Methodist College Registrar has been working with NSC to get the college relinked to the correct college in their system, which was fixed 11/2023. The registrar redeveloped database query to pull the old data that had been deleted by NSC due to FERPA and began sending accurate file submissions to NSC in June 2024. Files generated and submitted under the College’s new processes are taking roughly one week to process from initial submission, through error correction, and finalization.

Corrective Action Plan for Finding 2024-003 (Foster Care) Finding 2024-003: The County’s current policies and procedures are not operating effectively to ensure that only eligible recipients are receiving payments. Specifically, the following deficiencies in internal control over compliance were identified: 5 of 40 cases tested, the LDSS-4810 re-determination checklist was not completed. 4 of 40 cases tested, the LDSS-4810 re-determination checklist in the selected case file was completed but not signed off by both the case worker and supervisor. This is a repeat of the finding in the prior fiscal year's audit report, 2023-002. Corrective Action Plan: The Department of Children and Family Services will reeducate staff on how to properly complete the LDS-48009 and LDSS-4810 forms so that they can be provided upon request. Please see below for specific department plan: The Department of Children and Family Services will conduct a review of current forms to ensure that they are being completed and filed correctly. This will be complete by January 31, 2026. Management’s Response: The department agrees with the findings and will reinforce existing policies and procedures within the Department to ensure that all documents are properly retained and signed.

Corrective Action Plan for Finding 2024-002 (Adoption Assistance) Finding 2024-002: The following instances of noncompliance with Uniform Guidance were identified: In 5 of 40 cases tested, subsidy payments were not supported by adequate documentation in the case file. Specifically, the files did not contain documentation related to the continuation of assistance until age 21, as a result of a disability. The County’s current policies and procedures are not operating effectively to ensure only eligible recipients are receiving payments. This is a repeat of the finding in the prior fiscal year's audit report, 2023-001. Corrective Action Plan: The Department of Children and Family Services will update our IVE Adoption Subsidy Process to ensure compliance. Please see below for specific department plan: The Department of Children and Family Services will reeducate staff on existing policies and procedures and update the IV-E Adoption Subsidy Determination process to ensure compliance. Contact person responsible for the corrective action plan: Megan Rooney Anticipated completion date of corrective action: March 31, 2026 Management’s Response: The Department agrees with the findings and will make the necessary updates in our processes and procedures to ensure compliance.

Responsible Official’s Response and Corrective Action Planned: We agree with the finding and recommendations. Thomas University has upgraded its student information system from CAMS to Jenzabar. Thomas University Financial Aid office has an add and drop Report process that runs every day to identify changes in enrollment. Jenzabar has intergraded process that updates the R2T4 withdraw date based on the date input by the Registrar as the Last Date of Attendance according to the Withdraw Record. All Withdraw Records are shared with Financial Aid and the dates are reviewed for accuracy prior to completing calculation. Students are identified as Online or On-Campus students determined by Site. Based on the students’ Site, the number of break days are entered. Jenzabar automatically adjusts any award determined by the calculation process built in Jenzabar. Planned Implementation Date of Corrective Action: This process was created and implemented February 5, 2025. Person Responsible for Corrective Action: Derek Haskins, Director of Financial Aid

Responsible Official’s Response and Corrective Action Planned: We agree with the finding and recommendations. Thomas University has upgraded its student information system from CAMS to Jenzabar. The Financial Aid module Jenzabar Financial Aid has been configured by the Director of Financial Aid with a group process to identify enrollment level changes. This process is programmed to adjust the student scheduled Pell to reflect the updated Pell amount based on the Pell table. This process will reduce the Pell amount if the hours adjust down even when the Pell has already disbursed. This process will also increase the Pell when the hours increase. This process is on a scheduler that runs daily. Planned Implementation Date of Corrective Action: This process was created and implemented 10/01/2024. Person Responsible for Corrective Action: Derek Haskins, Director of Financial Aid

The School will put additional resources in place to ensure monthly reconciliation going forward. Anticiapted date of completion by November 2025

Corrective Action Plan (CAP) Institution: Westchester Community College New York Program Audited: Assistance Listing Number & Title: 84.063 – Federal Pell Grant Prepared for: Submission to Single Audit reporting package through the Federal Audit Clearinghouse (FAC) and Aid, Director, Financial Management Group – Federal Student Aid Date: August 27, 2025 1. Finding Reference • Audit Report Section: [Insert Finding Number/Reference] Finding 2024-001: Refunds of Title IV Funds Calculation and Disbursement Errors (Significant Deficiency - Special Tests and Provisions) • Description of Finding: Summarize the audit finding clearly as stated in the audit report. During the Fall 2023-2024 semester, 125 Pell Grant refund checks totaling $144,576 were issued incorrectly due to failures in the newly implemented student financial aid reporting system. • Errors Identified: 1. 10 checks totaling $11,087 were cashed, with only $1,233 returned to the college. The remaining $9,854 is considered questioned costs. 2. 51 checks totaling $56,263 were cashed, and accounts were later adjusted with student cooperation. 3. 64 checks totaling $77,226 were stopped before payment. 2. Root Cause Analysis • Cause of Noncompliance: Explain why the issue occurred (e.g., lack of internal controls, insufficient training, system error). System and operational failures due to inadequacy of the new student financial aid reporting system. • Contributing Factors: List any secondary factors (e.g., staff turnover, policy misinterpretation). 1. Data integrity issues – Automatic updates resulted in unauthorized entries and inaccurate data. 2. Communication failures – Early reports by staff of system errors were not addressed in a timely manner, resulting in delayed communication. 3. Disbursement errors – Scheduled disbursement dates canceled and rescheduled as a result of system’s inability to package students correctly. 4. SFP processing was inconsistent with US DOE COD system data. 5. Compliance date reporting errors due to SFP processing. 6. Training on the new SFP system was insufficiently provided by the vendor. In-person and self-paced training modules also not provided by the vendor. 7. SFP system contributed to incorrect financial aid packaging, requiring manual reprocessing 8. The SFP system was not aligned with unique community college scheduling features (e.g. parts of term such as winter session, 8-week semesters). 3. Corrective Action Plan Planned Corrective Measures: Detail the specific steps WCC management will take to correct the deficiency. To mitigate further damage, WCC reinstated the prior software system in April 2024, however, since the ISIRs were already determined, manual adjustments were made to students. This required additional corrective action steps: • Manual Data Corrections – Financial aid counselors manually reviewed data on approximately 6400 students and made corrections, student by student. • Reconciliation with G5 Data – Financial aid data had to be manually reconciled with G5, the federal payment system. • Compliance Adjustments – Transaction dates for compliance reporting were corrected. • Award Authorization – Student award amounts required manual verification, authorization, and approval. • Bursar’s Office Delays – Due to system errors, Bursar’s Office delayed processing refunds to prevent further financial discrepancies. • Parallel setup of on-prem financial aid system in March 2024 to prepare for the 2024-25 academic year. • Extraction of 2023-24 academic year financial aid data from SFP system and import into on-prem financial aid system. • Discontinue use of SFP on approximately 7/1/2025. • Responsible Party: Name/Title of the person(s) responsible for implementing corrective action. Garrett McAlister, Vice President of Information Technology; Dawn Gillins, Acting Vice President of Administrative Services/CFO; Dr. Erik Fortune, Assistant Vice President of Administration; Dr. Sandra Ramsey, Director of Enrollment Services; Nicola Howard-Brown, Acting Director of Financial Aid; Richard Cruz, Manager of Fiscal Operations; Garth Walcott, Program Administrator- Bursar Operations; Brian Murphy, former VP of Administrative Services/CFO; Dante Cantu, VP of Student Affairs; Anita Cook, former Director of Financial Aid. • Resources Required: Identify resources such as additional staff, training, IT system upgrades. Additional financial aid professional staff, IT/SFP system consultants. • Timeline: Expected completion date(s) for each corrective measure. Financial aid system remediation and awarding is complete. 2023-24 student financial aid data extraction/import for future reference in process. 4. Monitoring & Follow-Up • Ongoing Oversight - Describe how WCC will monitor to ensure corrective actions remain effective: WCC has a fully documented academic year financial aid project plan that is followed to ensure the timely implementation of tasks. • Internal Review Mechanisms: WCC will include periodic reviews aligned with standard DOE reporting timelines. Increase reconciliation frequency between G5 and COD. Increase periodic reviews, reports to leadership, and internal audit spot checks. 5. Evidence of Implementation • Documentation: List the types of evidence that will be maintained (e.g., revised policies, training logs, updated system reports). Project plan to revert back to previous system, training schedules, policy updates as they occur, and relevant updated system reports. • Retention: Confirm that documentation will be retained in accordance with federal regulations. WCC confirms that documentation will be retained in accordance with federal regulations. 6. Management Certification I certify that the corrective actions described above will be implemented as stated and monitored to ensure full compliance with federal requirements. Signed: Belinda S. Miles Name: Belinda S. Miles, Ed. D. Title: President Date: August 29, 2025

Contact Person: Travis Mickey, Registrar Views of Responsible Officials and Planned Corrective Action: There is no disagreement with the audit finding. The College will collaborate with NSC to evaluate the errors in the file transmissions and to develop procedures to minimize further errors in the future. More specifically, the College will review the reporting procedures for withdrawn and graduating students to ensure the correct information is transmitted to NSLDS. Anticipated Completion Date: 6/30/2025

Cambria County has continued with the following actions which include: maintaining a list of reporting due dates for all fiscal and administrative staff; engagement of external consultants and temporary fiscal staff to support reporting functions if there is staff departure; retain and support existing County staff to maintain institutional knowledge until a dedicated competent Fiscal Officer who is invested in child welfare and county government employment is identified. The department will continue to ensure audit components are included for submissions. The department maintained and will continue communication with oversight entities to ensure transparency regarding reporting timelines, submission delays, fiscal status and corrective actions taken to uphold integrity. These delays were not due to negligence, but rather a strategic and collaborative effort to ensure accuracy and completeness of all required documentation. The department prioritized the integrity of submissions to meet federal audit standards and reimbursement eligibility. These submissions were completed to ensure compliance and to position the CYS department for improved timeliness in the 2025 audit year. The department

Cambria County has continued with the following actions which include: maintaining a list of reporting due dates for all fiscal and administrative staff; engagement of external consultants and temporary fiscal staff to support reporting functions if there is staff departure; retain and support existing County staff to maintain institutional knowledge until a dedicated competent Fiscal Officer who is invested in child welfare and county government employment is identified. The department will continue to ensure audit components are included for submissions. The department maintained and will continue communication with oversight entities to ensure transparency regarding reporting timelines, submission delays, fiscal status and corrective actions taken to uphold integrity. These delays were not due to negligence, but rather a strategic and collaborative effort to ensure accuracy and completeness of all required documentation. The department prioritized the integrity of submissions to meet federal audit standards and reimbursement eligibility. These submissions were completed to ensure compliance and to position the CYS department for improved timeliness in the 2025 audit year. The department prioritized accuracy and completeness, ensuring required audit components were included.

Finding 2024-001: Non-compliance with Special Tests and Provisions: Disbursements Condition For 3 of 25 students selected for testing, the disbursement dates did not agree between the student’s institutional account and the data reported to COD. Each student had disbursements that were later partially or fully refunded. The sample was not a statistically valid sample. Recommendation It is recommended that policies, procedures and effective controls are put in place to verify that the disbursement dates for federal funds are matching between the student account detail and the COD system. Corrective Action The Foundation will ensure that policies, procedures and effective controls are in place to verify the matching of the disbursement dates for federal funds between the student account detail and the COD system. Anticipated completion date of implementing the corrective action plan will be immediate.

Finding #2024-001 – Significant Deficiency and Other Noncompliance. Applicable federal program: U. S. Department of Education, Student Financial Assistance Programs Cluster, Assistance Listing #84.063, Federal Pell Grant Program, Assistance Listing #84.268, Federal Direct Student Loans, Contracts #003556 and G03556, Contract years: 05/05/21 – 12/31/26. Recommendation: Emphasize the importance of accurately reporting enrollment status. Planned corrective action: Management agrees with audit finding #2024-001. The Financial Aid Coordinator is responsible for reporting enrollment status changes, certifying enrollment every 60 days, and responding to NSLDS Roster files within 15 days, all through the NSLDSFAP website. To enhance the accuracy of these enrollment reports, the Institute is implementing a new double-check process. Henceforth, the Financial Aid Coordinator will print all enrollment status changes or enrollment report rosters prior to making any online updates or certifications. These printed reports will then be given to the Director of Operations for verification. Only after this verification will the Financial Aid Coordinator proceed with the necessary changes or certifications on the NSLDSFAP website. All printed reports will be retained by the Financial Aid Coordinator for documentation. Responsible officer: Cody Lopasky, President. Estimated completion date: June 1, 2025.

The Department will enforce policies and procedures to ensure that compliance with the requirements. New internal controls are expected to be implemented to address these findings.

The Department will enforce policies and procedures to ensure that compliance with the requirements. New internal controls are expected to be implemented to address these findings.

The Department will enforce policies and procedures to ensure that compliance with the requirements. New internal controls are expected to be implemented to address these findings.

The Department will enforce policies and procedures to ensure that compliance with the requirements. New internal controls are expected to be implemented to address these findings.

The Department has ramped up recruiting efforts by advertising positions on external websites such as indeed. The accounting department has recently increased the wages of existing staff and the starting wages of all positions in an effort to attract and retain qualified staff.

The Department has hired a new audit firm that specializes in the audits of Tribes. Our new audit firm has demonstrated a commitment to allocating the necessary resources to complete our audits in a timely manner.

The College has spent a significant amount of time in FY 2025 evaluating their IT controls and policies, and procedures. New internal controls are expected to be implemented to address these findings.

The finding resulted from a manual error. The University will evaluate the existing review process to ensure it operates with the level of precision necessary to detect such discrepancies. Additionally, targeted training will be provided to staff, where applicable, to reinforce proper review procedures and reduce the risk of future manual errors.

The Financial Aid Office has added system controls that will assure that disbursements that are recorded on PeopleSoft is recorded on COD to assure that the Pell reporting requirements are executed in compliance with Federal statutes. The process consisted of creating automation that and reducing the manual intervention so that the issues preventing the Pell disbursement from being recorded on COD is reduced. We are adding automation for processing: FABATCH, ATB automation, and Citizenship automation.

Student Registration and Financial Services (SRFS) and the office of Student Financial Aid (SFA) will review existing policy/practice around updates to disbursement records. We will make any necessary changes to controls to ensure all disbursements are included for reporting to the COD within the required timeframe.

Student Registration and Financial Services (SRFS) and the office of Student Financial Aid (SFA) will continue collaboration with school partners and the office of the Provost to reinforce university policies and procedures by continuing to provide training to individuals involved in the process of updating student’s enrollment. The office of the University Registration (OUR) and SFA will collaborate to use existing school partner meetings, and internal functional partner meetings to conduct training. OUR generated its first Enrollment Reporting out of the new system (Banner Student) in Summer 2022. We expect to achieve steady state processing, when moving from the main frame to ERP system within five years of go-live. SRFS will review school partner access through audit reports to determine error rates and assess risk. SRFS will review existing policy/practice around student activated drops/withdrawals/Penn Leaves of Absence and make recommendations.

Student Registration and Financial Services (SRFS) and the Office of the University Registrar (OUR) will continue collaboration with school partners and the office of the Provost to reinforce university policies and procedures. Over the course of the last year (as the newly implemented system entered its second year), the university has increased the number and expertise level of employees in the OUR and offered entry level training to key stakeholders. OUR generated its first Enrollment Reporting out of the new system (Banner Student) in Summer 2022. We expect to achieve steady state processing, when moving from the main frame to ERP system within five years of go-live. SRFS will increase the depth of the training sessions by working with school registrars to help bolster their understanding and expertise. The SRFS and OUR will use various monitoring reports and data to identify areas of concern and to inform training offerings.

Pacific Union College transmits enrollment information to NSDLS through the National Student Clearinghouse (NCS), a third-party organization. PUC was faced with an unprecedented series of events related to data reporting to the National Student Clearinghouse between January and May 2024. During the month of February 2024, the College Registrar resigned without notice and the Director of Institutional Research tragically passed away within one ten day period. At that time the Director of College Admissions was asked to serve as the emergency Registrar and emergency IR Director. The above events led to some gaps in reporting to the NSC during the months noted above including some gaps in reporting that had occurred before the Registrar resigned. Communication with the NSC began immediately and during this time a series of reporting deadlines were “forgiven” by the NSC liaisons in support of PUC during a difficult series of one time events. Since the above dates PUC has been consistent and timely with all reporting to the NSC and the college anticipates that current staffing levels and cross training will prevent any such occurrences in the future.