Corrective Action Plans

2024-001 Notification of Disbursements (Significant Deficiency) Criteria: Prior to making a disbursement, the school must notify students of the amount and type of Title IV funds they are expected to receive, and how and when those disbursements will be made (often referred to as an award letter or college financing plan) (34 CFR 668.165(a)(1)). Condition: One out of twenty-five undergraduate students selected for disbursement testing for the 2023-2024 academic year was not documented as having been notified prior to the disbursement of Title IV funds. Notification failed to occur after the student's enrollment status changed from half-time to three-fourths time enrollment, making them eligible for additional Pell Grant awards. Action Taken: The University will request assistance from the software provider and consultants to develop a notification process for when a student’s enrollment status changes from half-time to three-fourths time enrollment. Responsible Party: Emily Williamson, Financial Aid Director Point of contact: Emily Williamson, Financial Aid Director Williamson_e@lynchburg.edu (434) 993-8253 Expected date of correction: June 1, 2025

U.S. Department of Education 2024-001 Student Financial Aid Cluster – Assistance Listing No. 84.063 & 84.268 Recommendation: We recommend that the University be utilizing the most current version of software for reporting, and the University reviews withdrawals monthly to ensure that the students are reported correctly to NSC and subsequently to NSLDS. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The University has submitted and reviewed a batch update for the two individuals currently labeled with incorrect statuses and/or effective dates. Name(s) of the contact person(s) responsible for corrective action: Nicole Biddle, Senior Director of Finance Planned completion date for corrective action plan: June 30, 2025

Finding#2024-001: 40 files were sampled, and 18 files were found to have late reporting. We agree with the findings and have put forward an action plan to ensure this is not a repeat finding in the future. 17 out of 18 students that were part of the findings were reported within the 60 days, however, the program and campus level were not matching in NSLDS. Per the NSLDS Enrollment Reporting Guide, both the campus level enrollment reporting and program-level enrollment reporting should be updated every 60 days. To ensure both program and campus-level enrollments are updated within 60 days, our Registrar will be working closely with the National Student Clearinghouse. We are reviewing each report generated by our system to ensure that the main data elements are found in the report which include: - Student current SSN - OPEID - CIP Code - CIP Year - Credential level - Published Program Length Measurement - Published Program Length - Weeks in Title IV Academic Year - Program Begin Date - Program and Campus Enrollment Status - Special Program Indicator - Program and Campus Enrollment Effective Date - Certification Date In addition, we are carefully reviewing the reports and changing the timing of reporting. One of the 18 students that was part of the findings withdrew and was not reported timely. The university will monitor closely with NSC the timing of files and reporting. Finding #2024-001 Action: Implementation of new control: Registrar to review system generated reports to match NSLDS reporting guides and monitor closely the timing of when files are processed and reported to NSLDS. Name of contact person responsible for corrective action plan: Marilyn Payan, University Registrar Anticipated Completion Date: Currently being implemented, to be completed before 12/31/2024.

Finding number: 2024-002 Federal agency: U.S. Department of Education Programs: Student Financial Assistance Cluster Assistance Listing #: 84.268 Award year: 2024 Corrective Action Plan: The Financial Aid Office has a robust policy and procedure for calculating the Return of Title IV (R2T4) Funds. In this particular case, the Financial Aid Counselor who completed the R2T4 calculation inadvertently transposed numbers when adjusting the subsidized student loan that needed to be returned to the U.S. Department of Education. While human error can never be fully eliminated, we take proactive measures in an attempt to avoid mistakes, such as testing the R2T4 process within Banner, our Student Information System (SIS), updating policies and procedures as needed, and providing ongoing staff training. In light of this error, an internal audit will be conducted to review all R2T4 calculations completed to date for the 2024-2025 academic year. Furthermore, staff will be provided additional training on the R2T4 process, reinforcing the importance of attention to detail. The staff member who made the error has been spoken to, and the necessary correction has been made to the student’s account. Timeline for Implementation of Corrective Action Plan: The corrective action plan will be implemented by April 2025. Contact Person Despina Lambropoulos, Director of Financial Aid

Finding number: 2024-001 Federal agency: U.S. Department of Education Programs: Student Financial Assistance Cluster Assistance Listing #: 84.007, 84.063, 84.268 Award year: 2024 Corrective Action Plan: In the Fall of 2023, the Registrar of 25 years retired, and the Assistant Registrar was promoted to replace her. During the transition, the new Registrar got behind in submitting Enrollment Reports for Spring 2024. The result of the first report being behind schedule caused a backlog of Enrollment and Error reports which resulted in a delay for the enrollment reports to be sent to NSLDS. The Registrar has made it a priority to submit enrollment reports and error reports in a timely manner (within 24-48 hours) so that they can be submitted to NSLDS within the 60-day timeframe. Timeline for Implementation of Corrective Action Plan: Corrective action plan began immediately when the next semester began. The action plan appears to be successful as there was no backlog of Enrollment/Error reports for Summer 2024, Fall 2024, and into Spring 2025 semester. Contact Person: Registrar – Shawna Lind

Boston Public Schools has revised its’ eligibility record keeping process to ensure that records are accurate and complete. This adjustment to record keeping practice has been instituted beginning with the FY25 grant application cycle. Anticipated Completion Date: June 30, 2025 Responsible Contact Person: Colin Musto, Assistant City Auditor, Grants Monitoring Unit colin.musto@boston.gov

Purpose: To document Santa Clara University’s Corrective Action Plan relating to finding 2024-001 in its June 30, 2024 Single Audit Report. Finding #2024-002: Criteria The institution shall require each applicant whose application is selected by the Department of Education to verify the information required for the Verification Tracking Group to which the applicant is assigned. If verification reveals that the student information does not match, the institution must submit corrections to the FAFSA. Corrections and updates can be submitted by the student on the web or by the institution using the FSA Access to Central Processing System Online or the Electronic Data Exchange. Statement of Condition During testwork, KPMG selected 40 students that were selected for verification. Of the 40 students selected for verification test work, one student’s information required for the appropriate Verification Tracking Group was not completed and 6 students had inconsistencies for which corrections were not submitted. Corrective Action Planned The University agrees with this assessment and is implementing a new process to ensure verifications will now have a second approver who will ensure verifications are completed correctly. Additionally, we also have added additional training to ensure that appropriate second and third checks are implemented. Name of contact Person responsible for corrective action plan Sandra Hayes, Assistant Vice President for Enrollment Management Anticipated completion date The above measures have already been implemented.

Purpose: To document Santa Clara University’s Corrective Action Plan relating to finding 2024-001 in its June 30, 2024 Single Audit Report. Finding #2024-001: Criteria Institutions must report disbursement data to Common Origination and Disbursement (COD) system within 15 calendar days after the institution makes a disbursement or becomes aware of the need to make an adjustment to previously reported student disbursement data or expected student disbursement data. Institutions may do this by reporting once every 15 calendar days, bi-weekly or weekly, or may set up their own system to ensure that disbursements are reported in a timely manner. Statement of Condition During testwork, KPMG selected 40 students that had Pell Grant or Direct Loan disbursements where the University was required to report student disbursement date to Common Origination and Disbursement (COD) system within 15 calendar days after the institution makes a disbursement or becomes award of the need to make an adjustment to previously reported student disbursement data or expected student disbursement data. KPMG identified 5 of the 40 students were not reported to COD in a timely manner. Corrective Action Planned The University agrees with this assessment and is implementing a new process to ensure Direct Loan and Pell Grant disbursements will now be reviewed after each disbursement (Monday, Wednesday, and Friday) and are reported within the Department of Education's requirements. Additionally, we will ensure that the COD Workday outbound and inbound integrations are monitored daily. Name of contact Person responsible for corrective action plan Sandra Hayes, Assistant Vice President for Enrollment Management Anticipated completion date The above measures have already been implemented.

Corrective Action Plan: To prevent conflicts between student work schedules and class schedules, the Financial Aid Office will verify, at the beginning of each term, that Federal Work-Study (“FWS”) student work schedules do not conflict with their academic schedules. As part of this verification process, department managers hiring FWS students will submit both the student's work schedule and class schedule to the Financial Aid Office. A report has been developed to compare FWS student work hours with their class schedules during each pay period. Any instances of students working during scheduled class time will be communicated to both the student and their supervisor for correction, if the hours were reported in error. If the hours are accurate, the department must provide documentation of a class schedule change, cancellation, or the fund and organization codes to be charged, crediting the FWS funds accordingly. Timeline for Implementation of Corrective Action Plan: This policy will be implemented immediately and applied retroactively to July 1, 2024. Contact Person Todd Wonders, Associate Director of Financial Aid Curt Foster, Comptroller

Corrective Action Plan: The Pell Reconciliation process is currently conducted monthly. A file is generated by the Financial Aid Office and transmitted to the Common Origination and Disbursement (“COD”) system via EdConnect software. Upon receipt of the COD response file, any discrepancies are addressed, and corrected data is resubmitted to COD. In a recent instance, the timing of a student's adjusted award relative to the monthly reconciliation file resulted in a disbursement outside of federal guidelines. While this discrepancy was identified during a subsequent internal audit, the Financial Aid Office acknowledges the need for process improvement. To ensure timely disbursements and prevent future occurrences, the Pell Reconciliation process will be revised to occur multiple times per month. This revised policy has been reviewed and approved by the relevant Financial Aid staff. Timeline for Implementation of Corrective Action Plan: The corrective action plan was implemented as of October 2024. Contact Person Todd Wonders, Associate Director of Financial Aid Curt Foster, Comptroller

Corrective Action Plan: Despite previous corrective actions addressing NSLDS reporting findings, an audit has revealed additional discrepancies in reporting between HCC and the National Student Clearinghouse (“NSC”). Our current database generates a file for submission to the NSC, intended to report all graduates. Upon review of the data transmission process, it has been determined that students enrolled in simultaneous degree programs require specific evaluation of their graduate status due to the NSC's unique parameters for these programs. Consequently, manual updates to NSLDS will be necessary for cases that fall outside the NSC's automated reporting guidelines. To address this systematically, a working group will be established to review and revise campus policies and procedures. This group will collaborate with the IT Enterprise Operations team to develop refined reporting mechanisms that accurately identify and address students in simultaneous degree programs, ensuring timely and accurate NSLDS reporting. Timeline for Implementation of Corrective Action Plan: The corrective action plan was implemented as of October 2024. Contact Person Todd Wonders, Associate Director of Financial Aid Allison Wrobel, Registrar Curt Foster, Comptroller

Corrective Action Plan:. The Student Financial Services Office will work with the Registrar and use reports delivered by Institutional Effectiveness to monitor and determine withdrawals on a regular basis. Additional reports at the end of each semester have been created to assist with identifying students who fail to complete at least half-time attendance. Policy and procedures have been updated to insure proper Exit Counseling notifications. Timeline for Implementation of Corrective Action Plan: Immediately Contact Person: Karrie M. Trautman

Finding 2024-001 Name of Responsible Individual: Cinnamon Bradley, Associate Dean of Student Affairs Corrective Action: We concur. We will review our procedures to ensure proper recording of these changes by NSLDS based on our submission to the National Student Clearinghouse. We will also implement an automated monitoring notification system that will alert us within the established timeframe of status changes to ensure accuracy in both third-party systems. Change in our submission process to the National Student Clearinghouse from 30 days to occur weekly to ensure timely reporting to NSLDS. All student records contained in the NSLDS for the Academic Term will be reviewed every month and the student roster will be reviewed weekly for accuracy in both third-party systems. We will complete the corrective action no later than March 31, 2025. Anticipated Completion Date: March 31, 2025

Finding 2024-001: Return of Title IV Funds For one out of three students tested (33%) who withdrew from the Institute, the Institute could not provide evidence that Institute reviewed the return of Title IV funds calculation. Further, the calculation that was originally performed failed to identify $480 of aid to be disbursed as post-withdrawal. Corrective Action Plan The Director of Financial Aid, Registrar and Student Affairs have instituted a communications protocol for all student withdrawals that include the notification of all required institutional constituents. In addition, as a control practice the Director of Financial Aid reviews a daily enrollment change report to ensure all withdrawals are processed on a timely basis. Contact Person Monique Foster Director of Financial Aid mfoster@erikson.edu Anticipated Completion Date October 2024

Significant Deficiency - Special Reporting Criteria: The College is required to submit the Fiscal Operations Report and Application to Participate (FISAP) annually to receive funds for the campus-based programs. Action Taken: We have incorporated and comunicated the updates to our policy and procedures to ensure both information systems are reconciled monthly, as well as maintaining appropriate documentation as assigned to both the Finance Department and the Financial Aid Manager. Anticipated completion date: This update to our policies have gone into effect February 2025.

Corrective Action Plan We agree with the auditor’s finding as set forth above. Due to turnover in the financial aid department, there was an incorrect understanding of the maximum award process. We have updated the university’s policies and procedures to ensure they are compliant with Title IV requirements and will be assigning this responsibility to a new employee. The University has refunded, through Common Origination and Disbursement, any federal funding associated with the over-awards as noted in this finding. Timeline for Implementation of Corrective Action Plan Prior to June 30, 2025 Contact Person Vice President for Strategic Enrollment, Marketing and Communications

Corrective Action Plan We agree with the auditor’s finding as set forth above. The university has experienced turnover in recent years in the financial aid department. This responsibility has been assigned to a new individual who has the necessary training and experience to ensure that Return to Title IV refunds are completed in the required timeframe. Timeline for Implementation of Corrective Action Plan Complete Contact Person Vice President for Strategic Enrollment, Marketing and Communications

Management’s View and Corrective Action Plan 2024-001 Enrollment Reporting Cluster: Student Financial Assistance Sponsoring Agency: Department of Education Award Name: Pell Grant Program and Federal Direct Student Loans Award Number: Various Assistance Listing Title: Federal Pell Grants, Federal Direct Student Loans Award Year: 2023-2024 Assistance listing numbers: 84.063, 84.268 Pass-through entity: Not Applicable To whom it may concern: The Registrar’s Office has reviewed the finding and concluded the root cause to be a high volume of corrections required for graduated students as communicated by the National Student Clearinghouse (NSC). Students requiring corrections are not included in the National Student Loan Database System (NSLDS) data pulls from the NSC. When necessary, corrections were processed, the applicable students were included in a subsequent NSLDS data pull, resulting in ultimate reporting to the NSLDS outside of the required 60-day window for 31 students. To ensure reporting of graduated statuses within the compliance timeline, Dartmouth has implemented new practices based on the scheduled Degree Verify submissions to the NSC. The revised process was implemented in January 2025 and schedules an assessment of error volume and correction efforts ten days following submission to the NSC. This revised process allows enough time for degree files to be processed by the NSC, provide notification of necessary corrections to the College and result in timely acceptance by the NSLDS. Additionally, we have increased the number of staff in the Registrar's Office who are trained to make these status corrections from one to three. In performing our analysis to assess the total number of students reported outside of compliance, we identified an additional distinct population reported outside of compliance. Active students of the Master’s in Public Health (MPH) program are automatically enrolled in their next term, with an ‘EL’ (enrolled) status. Upon the Guarini Registrar’s Office’s graduation certification, the subsequent term is coded ‘CH’. The ‘CH’ term carries no credits 68 and requires no billing; however, it is reported to the NSC as a ‘Withdrawn’ status for the student. Because the ‘CH’ term is reported after the graduation term, it overrides the ‘Graduated’ status to ‘Withdrawn’ within the NSC. Upon the next NSLDS data pull, the student’s status is then updated from ‘Graduated’ to ‘Withdrawn’ in NSLDS. These statuses were corrected in February 2025 and had no impact on either the student or federal government. An additional 29 students were corrected in February 2025, resulting in a total population of 60 students reported outside of compliance with NSLDS. Per discussion with Gary Hutchins, Registrar and Assistant Dean for the Guarini School of Graduate and Advance Studies, effective immediately, future terms will be deleted for these students upon graduation certification. Deletion of the enrollment records will retain their appropriate ‘Graduated’ status. Sincerely, Eric Parsons Registrar of the College 69

Official withdrawals will be calculated for potential R2T4 upon receipt of notification from the records department. Unofficial withdrawals will be completed within 45 days of receipt of notification from the records department. Financial Aid will keep a record of when a withdrawal is received and when R2T4s are processed. This spreadsheet will be checked on a regular basis. R2T4 calculations will be checked for accuracy in Banner by the director or another staff member before submission.

Annually update the college website with contract and/or cost information regarding the third-party provider. Provide contract information URL to ED for publication in the Cash Management Contracts Database.

Condition: The College did not provide notifications to certain students related to direct loan disbursements. Planned Corrective Action: The Director of Financial Aid will work with our Information Technology department to ensure the criteria used for triggering the notification emails is correct and capturing all the necessary students. Additionally, an exception report will be created to identify students who have not been sent the notification email for the Financial Aid department to review to then send the appropriate notification. Contact person responsible for corrective action: Director of Financial Aid Anticipated Completion Date: May 31, 2025

Condition: The College did not have controls in place to ensure appropriate reporting to COD. Planned Corrective Action: The College has begun training additional individuals on the reconciliation process and has updated its procedures to include what documentation needs to be retained on a monthly basis to ensure accuracy between the amount the College shows as disbursed and the amount the Department of Education shows has been disbursed. Contact person responsible for corrective action: Director of Financial Aid Anticipated Completion Date: June 30, 2025

Condition: Out of 60 students tested for return to Title IV, we identified 24 students whose calculations were performed incorrectly. Planned Corrective Action: The College will work with its Director of Financial Aid to ensure the semester end procedures include steps to identifying those students who unofficially withdrew. Once the students are identified, individuals with the appropriate skills and knowledge would be able to determine if a Return of Title IV calculation is necessary, and appropriately return any funds, as necessary. Contact person responsible for corrective action: Director of Financial Aid Anticipated Completion Date: June 30, 2025

The College implemented a policy on January 1, 2025, that clearly defines the proper enrollment status for the various programs offered. The policy has been reviewed by respective administrators. The staff member that is submitting student enrollment data to NSLDS has been trained accordingly. In addition, reports have been created to check the accuracy of enrollment data prior to submission.

Identifying Number: 2024-007: U.S. Department of Education: Federal Direct Student Loans – 84.268 Finding: During testing of enrollment reporting, it was noted that there were 16 instances in which the student’s status change was certified outside the 60-day reporting requirement. Corrective Action Taken or Planned: We learned that the current process for the submission to the National Student Clearinghouse is not pulling all students that it should be. We are now pulling additional reports to identify those students being missed and are manually reporting them to the Clearinghouse. Contact person: Megan Fischer, Vice President for Enrollment Management Status of finding – The above corrective actions will be implemented beginning January 1, 2025.