Corrective Action Plans

Special Tests and Provisions 240 Day Checks – Assistance Listing No. 84.063, 84.268 Recommendation: We recommend the College design controls to ensure an adequate review process is in place to ensure compliance with reporting requirements. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Financial Aid office along with Student Accounts and the Business Office at Urshan University will collaborate on an SOP which will establish a process of reviewing any outstanding Title IV checks. Checks will be reissued as necessary to ensure the university stays compliant with all Title IV regulations. Name(s) of the contact person(s) responsible for corrective action: Levi Powell, Student Financial Aid Director Planned completion date for corrective action plan: 6/30/2025

Eligibility – Assistance Listing No. 84.063, 84.268 Recommendation: We recommend the College design controls to ensure an adequate review process is in place to ensure compliance with reporting requirements. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Financial Aid office will be implementing an SOP which will document a review process of work done by the third-party processor, to include COD reporting, and Verification procedures. We will also be implementing a process to review students who need to complete their exit counseling. Name(s) of the contact person(s) responsible for corrective action: Levi Powell, Student Financial Aid Director Planned completion date for corrective action plan: 6/30/2025

Special Tests and Provisions R2T4 – Assistance Listing No. 84.063, 84.268 Recommendation: We recommend the College design controls to ensure an adequate review process is in place to ensure compliance with reporting requirements. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Financial Aid office will be crafting a new SOP to address R2T4 audit findings. The team will work more closely with the Registrar and Academic Deans when determining the withdrawal status of a student and make sure that the R2T4 documentation is accurately completed, a review of completed R2T4s will also be conducted. Name(s) of the contact person(s) responsible for corrective action: Levi Powell, Student Financial Aid Director Planned completion date for corrective action plan: 6/30/2025

Special Tests and Provisions Enrollment Reporting – Assistance Listing No. 84.063, 84.268 Recommendation: We recommend the College provide additional resources to ensure all compliance requirements are met. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: A new Standard Operating Procedure (SOP) is being created, which will address enrollment reporting concerns. The Financial Aid office will work with the Registrar to increase communication between offices and eliminate enrollment reporting errors. The Financial Aid office will also improve reporting to the third-party processor, so that timely and accurate information is uploaded to NSLDS. Furthermore, a recurring review of the third-party’s reporting to NSLDS will be instituted. Name(s) of the contact person(s) responsible for corrective action: Levi Powell, Director of Financial Aid Planned completion date for corrective action plan: 6/30/2025

Condition: Of the 40 students selected for enrollment reporting testing, 1 student did not have their program-level status change updated appropriately and another student was not updated from less than half time to withdrawn by the University's third party administrator. Planned Corrective Action: Clearinghouse reporting process has been reassessed, and error reporting will be completed weekly. Training will be done for registrar staff on process, and how to verify information has successfully been accepted by NSLDS. The Registrar's office will work closely with Financial Aid to verify enrollment updates and complete error resolution. Contact person responsible for corrective action: Callie Zake, Senior Director Student Financial Services Anticipated Completion Date: June 30, 2025

Condition: There was a lack of internal controls in place related to the return of Title IV funds. Planned Corrective Action: Director will update academic calendar on COD R2TIV calculator yearly and verify dates and length of breaks are correct. The University will continue to have the Senior Financial Aid Advisor complete R2TIV and the Director will sign off on calculations. Contact person responsible for corrective action: Callie Zake, Senior Director Student Financial Services Anticipated Completion Date: June 30, 2025

Recommendation: CLA recommends the University review its reporting procedures to ensure the students' statuses are accurately reported to NSLDS as required by regulations. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: By reviewing the ordering of internal processes and procedures St. Thomas determined two internal processes ran out of order causing incorrect reporting. Procedural documentation has been updated and training provided to ensure this error is not repeated. Name(s) of the contact person(s) responsible for corrective action: Yuko Kachinsky: yuko.kachinsky@stthomas.edu Planned completion date for corrective action plan: A process error was identified and corrected in August 2024.

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

Verification Planned Corrective Action: We will periodically review students selected for verification with a status of verification not completed to ensure they did not receive need based federal aid. Person Responsible for Corrective Action Plan: Andrea Ruth, Director of Financial Aid Anticipated Date of Completion: 3/22/2025

Incorrect Return of Title IV (R2T4) Funds Calculations and Untimely Returns Planned Corrective Action: When this was identified last year, the Director of Financial Aid Office spent the next year working with the Department of Education as they conducted two separate reviews. The first review was completed and we were notified that everything was good. The second review recently concluded via an exit interview where we were notified that a final report would be sent to us within the next two months. Additionally, the Director of Financial Aid has been working with the IT department, the Registrar’s Office, and our Academic Technology department to streamline the identification of students who need a R2T4 completed. This has been an ongoing process in the midst of the program reviews and getting clarification and guidance from the Department of Education, coupled with the FAFSA issues, continued to cause further delays with R2T4 calculations. Person Responsible for Corrective Action Plan: Andrea Ruth, Director of Financial Aid Anticipated Date of Completion: 3/22/2025

Recommendation: We recommend that the University strengthen its internal controls over reporting student enrollment changes to NSLDS to ensure that enrollment effective dates are reported to NSLDS within 60 days of an enrollment status change and that enrollment is being properly certified every 60 days. Explanation of Disagreement with Audit Finding: There is no disagreement with the audit finding. Action in Response to Finding: Portland State University relies on a third party, National Student Clearinghouse, to report student enrollment status changes to the NSLDS. Fall 2023 and Winter 2024 enrollment certification files were provided to NSC for relay to NSLDS. Despite this, these enrollment files were never provided to NSLDS and as such the students status change, effective September 26, 2023, was not certified within the NSLDS until May 3, 2024. We are researching why these enrollment certification files were never provided to the NSLDS. Name of the Contact Person Responsible for Corrective Action: Nicolle DuPont, Associate Registrar Planned Completion Date for Corrective Action Plan: April 2025

Recommendation: CLA recommends that the University review the requirement and implement a control to monitor outstanding checks throughout the year. In addition, for the checks outstandings greater than 240 days, the University should return the funding to the U.S. Department of Education. Explanation of Disagreement with Audit Finding: There is no disagreement with the audit finding Action in Response to Finding: The process during the current year has been to review the list of checks every 30 days but this has caused a failure in preventing checks from being returned after the 240 day mark. To rectify this, the Accountant II will review the comprehensive list on a monthly basis as well as checks that are in the future to ensure that we are not surpassing the 240 day mark by waiting for the next month to return. In addition, a report has been created to be delivered weekly that looks at all checks that are over 220 days old as a back up to ensure that no check is being missed and going over the 240 days requirement. Name of the Contact Person Responsible for Corrective Action: Megan Looney, Director of Student Financial Services Planned Completion Date for Corrective Action Plan: March 2025

Planned Corrective Action: The financial aid office will report enrollment of unofficial withdrawals/last date of attendance on NSLDS upon completion of the Return to Title IV calculations and when unofficial withdrawals are reviewed at the end of each term. The Registrar's Office will review NSC G (graduated) not applied reports after submitting degree verify files and corrections will be made, if needed, within 30 day period after submission. Anticipated completion date: financial aid has already acted on this beginning Fall 2024. Registrar's office will begin review of "G Not Applied" reportsbeginning Spring 2025. Person responsiblef or correctiveaction: Financial aid MIchelle Lamb, lamb@uwosh.edu, Alison Casady, casadya@uwosh.edu, Julia Bodette, bodettej@uwosh.edu

Planned Corrective Action: As soon as UW-Milwaukee was notified during the LAB review process that enrollment status effective dates were being reported incorrectly, we took action to correct this issue. While a permanent fix to the extract process from PeopleSoft is dependent on Oracle providing a reliable solution to the issue or UW-Milwaukee Information Technology rewriting a custom process and therefore outside of the immediate control of the Registrar’s Office, the Registrar’s Office did immediately start using the “mass correction” feature for the 1800 series warnings provided by the NSC. This will result in enrollment status effective dates which fulfil the Department of Education’s requirements. Since utilizing the “mass correction” option increases the amount of time needed to work through NSC error and warning reports, the Registrar’s Office is hopeful that a more permanent reliable solution on the SIS level will be coming in the future. In the meantime, we will continue to utilize the mass correction option to ensure that enrollment status effective dates are only changed if a student’s enrollment status changes, per the Department of Education’s requirements. UW-Milwaukee Registrar’s Office staff reviewed the records of the five individuals that LAB indicated did not have accurate data reported to the NSLDS. We discovered that the data was reported accurately for enrollment status changes, which would result in a change in effective date. However, it appears that the NSLDS roster request schedule differs from UW-Milwaukee’s enrollment reporting schedule to the NSC. UWMilwaukee reports enrollment information to the NSC on the third Tuesday of each month. It looks like the NSLDS does a roster request at the beginning of the third week of each month. We will investigate if it is possible to adjust our NSC submission schedule to move up by one week, so new data should be available for the mid-month NSLDS roster request. Anticipated Completion Date: May 1, 2025 Person responsible for corrective action: Emily Bach, Records Coordinator UW-Milwaukee Registrar’s Office ecbach@uwm.edu

Planned Corrective Action: UW-Madison’s Office of Student Financial Aid (OSFA) and Registrar’s Office (RO) reviewed the enrollment reporting recommendations cited in Finding 2024-708 and corrected error reports as appropriate. UW-Madison will review procedures to report all changes in student enrollment accurately, completely, and in a timely manner for all instances that require reporting. OSFA and RO will review and update internal procedures to ensure that the date that a student is unofficially withdrawn is communicated and reported consistently between the National Student Loan Data System (NSLDS) and the National Student Clearinghouse (NSC) as appropriate. Prior to the LAB’s review, UW-Madison discovered and corrected issues relating to program enrollment status in NSC and NSLDS. As of November 2024, updates were made for all retroactive instances using appropriate conferral dates and accurate “G - Graduated” statuses. The long-term solution includes the creation of a “Graduates Only Enrollment” file which includes all students who have been reported as enrolled, not withdrawn in a given term and who have earned their degree in each of UW-Madison’s three degree conferral dates. This enrollment file will trigger an enrollment status update that occurs outside of the automatic NSC process. UW-Madison has updated procedures and now uses the NSC extract process to comply with the NSLDS and NSC reporting procedures for program-level enrollment status effective dates. For the beginning of the Fall 2025 term, UW-Madison will update procedures and extract logic from the student information system to ensure accuracy in the reporting of program begin dates. In the meantime, the RO team has reviewed, tested, and updated the process to ensure previously inaccurate program begin dates are corrected. Anticipated Completion Date: September 30, 2025 Person responsible for corrective action: Beth Warner Registrar Office – Division of Enrollment Mangement beth.warner@wisc.edu

Interim corrective actions: These cases involved situations where students dropped courses before withdrawing (officially or unofficially) from all courses. UW-River Falls did not have a system in place to review course participation for courses which students dropped prior to withdrawal, although it has procedures in place to review course participation for enrolled courses at the time of withdrawal and when students are assigned failing grades. For Fall Semester 2024: Existing procedures: 1. Official withdrawals: Students officially withdrawing from the University must complete an electronic form which collects instructor verification of course participation. The Financial Aid office receives this form once it has been processed by the Registrar’s office. Students reported as not having participated in courses have their financial aid adjusted prior to calculating a return to Title IV funds. 2. Unofficial withdrawals: Instructors assigning failing grades to students must report student’s course participation or non-participation and, if available, a last date of course participation. Following the grading deadline, a report listing all students who never participated in classes is run and students found to have failed courses due to non-participation have their financial aid adjusted prior to calculating a return to Title IV funds. Additional procedure instituted: 3. Learning management system review: Students who withdraw (officially or unofficially) and who dropped courses prior to withdrawing had their dropped courses reviewed in the Learning Management System (LMS). Students who submitted assignments as recorded in the system were determined to have begun participation in the course. Students who submitted no assignments were determined to not have participated in the course and financial aid was adjusted prior to calculating a return to Title IV funds. For Spring Semester 2025: Existing procedures: 1. Procedures 1,2, and 3 from Fall Semester 2024 continue to be employed for Spring semester 2025. Additional procedures: 2. Expanding the LMS review to Pell grant students with dropped courses: Students with disbursed Pell Grants who drop courses after the Pell grant census date now have these courses reviewed to determine if the student began attendance before dropping the course, using the same procedure as #3 above.Instructor course participation verification: After the 3rd week of classes for Spring 2025, UWRiver Fall requested that instructors report students who had not begun participation in their courses. This report is currently being reviewed and students with Pell grants will be evaluated to determine if an adjustment to the student’s enrollment intensity is needed to ensure that the disbursed Pell grant is accurate. Student who have begun participation in no enrolled courses will be reviewed for possible return of all Title IV funds. Future additional corrective actions: 1. UW-River Falls will pursue making course participation verification by instructors during the first month of the semester an administrative policy and develop formal procedures for surveying instructors and reporting students found to not have begun participation in a course or courses to the Financial Aid office for adjustments to their disbursed Title IV aid. 2. UW-River Falls will pursue adding an instructor course participation step to the course drop form currently in use by the Registrar’s office. Anticipated Completion Date: Interim actions were implemented in September 2024 and February 2025. Permanent action expected by Spring 2026. Person(s) responsible for corrective action: Cindy Holbrook, Executive Director of Enrollment Management Cindy.Holbrook@uwrf.edu 715-425-3500 Robert Bode, Director of Financial Aid and Military/Veterans Resource Center Robert.Bode@uwrf.edu 715-425-3141 Kelly Browning, University Registrar Kelly.Browning@uwrf.edu 715-425-3342 Responsible Unit Division of Enrollment Mangagement

Planned Corrective Action: Financial Aid will continue to reconcile Direct Loans and the Federal Pell Grant programs with the Department of Education through the Common Origination and Disbursement system. The loan coordinator and Pell Grant manager will confirm SIS amounts reconcile with WISER monthly, at minimum. If there are any discrepancies, the Controller will be contacted to assist with internal reconciliation of funds. Anticipated Completion Date: Will begin corrective action Spring 2025 Person responsible for corrective action: Alison Casady, Director of Financial Aid; casadya@uwosh.edu In conjunction with Direct Loan coordinator: Ashley Hass; hassa@uwosh.edu Pell Grant program manager: Elizabeth Bloedow; bloedowe@uwosh.edu Controller: Mai Lee; Financial Services; leemai@uwosh.edu

Finding 2024-001 Special Tests and Provisions - Enrollment Reporting Compliance and Internal Control Contact person(s) responsible for corrective action – Dennis Madigan, VP of Administration and Finance Anticipated completion date – Completed in July 2024 Corrective Action Federal Student Aid processing has moved to Bay Path University effective 7/1/24. Responsible Party: Dennis Madigan, VP Administration and Finance

Return of Title IV (R2T4) Calculations Federal Supplemental Educational Opportunity Grants; Federal Work Study Program; Federal Pell Grant Program; Federal Direct Student Loans – Assistance Listing No. 84.007; 84.033; 84.063; 84.268 Recommendation: We recommend that the University review the R2T4 requirements and implement procedures to ensure that scheduled breaks and correct withdrawal dates are properly factored into the calculations. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to the finding: Felician University has evaluated and updated our procedures in overseeing R2T4 requirements and will implement procedures to ensure that scheduled breaks and correct withdrawal dates are properly factored into the calculations. Appropriate staff have been notified, and management will monitor this issue regularly during the year to ensure compliance. Name(s) of the contact person(s) responsible for corrective action: Kathy Prieto, Director of Financial Aid Planned completion date for corrective action plan: April 1st, 2025.

Title IV Credit Refunds Federal Supplemental Educational Opportunity Grants; Federal Work Study Program; Federal Pell Grant Program; Federal Direct Student Loans – Assistance Listing No. 84.007, 84.033, 84.063, 84.268 Recommendation: We recommend the University evaluate its procedures and review policies in overseeing student credit balances to ensure credit balances are returned within the required 14-day timeframe. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to the finding: Felician University has evaluated and updated our procedures in overseeing student credit balances to ensure credit balances are returned within the required 14-day timeframe and notified the appropriate staff. Management will monitor this regularly during the year to ensure compliance. Names(s) of the contact person(s) responsible for corrective action: Mariela Henriquez, Director of Student Accounts Planned completion date for corrective action plan: April 1st, 2025.

Common Origination and Disbursement (COD) Reporting Federal Pell Grant Program; Federal Direct Student Loans – Assistance Listing No. 84.063, 84.268 Recommendation: We recommend the University evaluate its procedures and policies around reporting to the COD to ensure that student information is reported accurately and timely. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to the finding: Felician University has evaluated its procedures and policies around reporting to the COD to ensure that student information is reported accurately and timely. Appropriate staff have been notified, and management will regularly monitor this issue during the year to ensure compliance. Name(s) of the contact person(s) responsible for corrective action: Kath Prieto, Director of Financial Aid Planned completion date for corrective action plan: April 1st, 2025.

Federal Pell Grant Program; Federal Direct Student Loans – Assistance Listing No. 84.063, 84.268 Recommendation: We recommend the University evaluate its procedures and review regulations set by the Department of Education around NSLDS to ensure the University understands the definitions for each enrollment information that gets reported. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to the finding: Felician University has evaluated and updated our procedures in overseeing submission to NSLDS and notified the appropriate staff. Management will monitor this issue regularly during the year to ensure compliance. Name(s) of the contact person(s) responsible for corrective action: Erminda Velez, Director of Registration and Records Planned completion date for corrective action plan: April 1st, 2025.

The College will be looking at making some business process changes to review files submitted to NSC (National Student Clearing House) and NSLDS (National Student Loan Data Service) on a monthly basis and perform monthly reconciliation between responsible offices to ensure students are accurately reported to ED/NSLDS. This new implementation will allow the College/Office to better verify each student’s enrollment status, status changes and related effective date visibility of reporting issues in the future. Timeline for Implementation of Corrective Action Plan Implemented Fall 2024 Contact Person: Alaina Marcotte, Director Financial Aid

To ensure that there are no further instances of late return of title IV funds due to withdrawals, the financial aid office has updated their process. As a quality assurance measure, every withdrawal processed by the Registrar’s office will be sent to three individuals in the FA office- Director, Associate Director, and Withdrawal Coordinator. After the final withdrawal report from the Registrar’s office has been processed each semester, all students will be reviewed individually by Director, Associate Director, and Coordinator. The manual review process will ensure that all reported students have been appropriately reviewed and processed within the required timeframe. This updated process will eliminate the human error associated with the finding. Timeline for Implementation of Corrective Action Plan Implemented Fall 2024

2024-002 Notification of Disbursements (Significant Deficiency) Criteria: Institutions are required to report enrollment information under the Pell grant and the Direct loan programs via the NSLDS. The administration of the Title IV programs depends heavily on the accuracy and timeliness of the enrollment information reported by institutions. Institutions must review, update, and certify 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 website in accordance with 34 CFR 690.83(b)(2) and 34 CFR 685.309. Condition: Eleven of the seventeen students selected for withdraw testing for the 2023-2024 academic year required an update to NSLDS enrollment status. The enrollment status for four students was not updated in a timely manner. Enrollment status updates failed to be reported within 60 days of the date of determination after the students were no longer enrolled on at least a half-time basis. Action Taken: As part of completing the institution’s conversion to a new student information system (Colleague), the Registrar’s Office has set up the enrollment management module, which streamlines enrollment and graduation reporting to the National Student Clearinghouse. The University has set an annual schedule of submissions with the National Student Clearinghouse, according to federal guidelines and has been following it accordingly. Responsible Party: Julie R. Allen, Registrar Point of Contact: Julie R. Allen, Registrar allen.jr@lynchburg.edu (434) 544-8223 Expected date of correction: January 1, 2025