Corrective Action Plans

2024-002 – Untimely Reporting of Student Disbursements Auditor Description of Condition and Effect. One student out of forty tested received disbursements that were not reported to the federal government within the required timeframe. As a result of this condition, the College did not fully comply with the requirements to report disbursements within 15 days of disbursing funds. Auditor Recommendation. We recommend that the College implement policies and procedures, including designating an individual to oversee this reporting requirement, to ensure information is submitted to the Common Origination and Disbursement in a timely manner. Corrective Action. During the upload of records to COD, if a file is rejected, the Financial Aid Federal and State Coordinator will work to clear the reject and upload the record again. The process will continue until the record is uploaded successfully. File uploads are occurring weekly. Responsible Person. Lexie Seidel and Emmalee Gilaspie, Financial Aid Federal and State Aid Coordinators. Anticipated Completion Date. Spring 2025.

Corrective Action Plan Xavier complies with the loan disbursement notification rules. During the audit we learned that, while our system was sending the emails to each student with a loan disbursement, our process for copying each individual email to xufinaid was not functioning. Further, the notification report was being overwritten daily, causing us to lose the audit trail for these notifications. We have implemented two steps to be able to document each individual email. 1. The xufinaid@xavier.edu email address is copied on every disbursement notification and each notification email is delivered into the xufinaid inbox in Outlook. Every Wednesday those emails are moved by financial aid personnel into a folder in Outlook where they remain stored. This weekly review allows personnel to know in a timely manner if there are issues with the email delivery process. 2. A log file which saves a list of the disbursement notification emails is saved on a daily basis. It includes the content of each email.

CORRECTIVE ACTION PLAN U.S. Department Education Hobart and William Smith Colleges respectfully submit the following corrective action plan for the year ended June 30, 2024 Name and address of independent public accounting firm: Bonadio & Co., LLP 171 Sully's Trail Pittsford, NY 14534 Audit period: July 1, 2023 - June 30, 2024 The findings from the 2024 schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. FINDINGS AND QUESTIONED COSTS - MAJOR FEDERAL AWARD PROGRAMS SIGNIFICANT DEFICIENCY 2024-001 Timely Return of Title IV Funds Recommendation: We recommend that the Colleges assess and address staffing levels in the Student Financial Aid Department to ensure adequate resources are available to process Title IV fund returns timely. Additionally, the Colleges should develop policies and procedures to ensure timely processing of returns within the required 45-day period. Corrective Action Plan: Additional staffing has been put in place to ensure that we have enough resources to complete title IV refund processing in a timely fashion. A new assistant director (hired in November 2024) will be monitoring the notifications that students have withdrawn and notify the director when title IV refunds are required. The new assistant director is also currently being trained in title IV refund processing and has experience with title IV refunding prior to being hired. The associate director (hired in July 2024) is also an expert in the return of federal funding through EDCONNECT and perform a supportive role in this process. Lisa Hoskey, Director of Financial Aid, is responsible for implementing this plan and can be reached at Hoskey@hws.edu.

Finding 2024-003 Errors in Reporting for NSLDS Condition: Northern Illinois University (the University) did not properly report enrollment changes for certain students who received federal student aid to the National Student Loan Data System (NSLDS) and the internal controls in place did not identify the errors. Corrective Action Plan: University has taken the following corrective actions that will eliminate all material exceptions: 1) The University will correct the software issue which caused some students with the new withdrawal grade code to not have a withdrawal status calculated correctly at the campus level. 2) The University will provide additional training and guidance to address the misinterpretation of withdrawal status effective date reporting which caused an error at the program level. Individual(s) Responsible for Corrective Action: Registration and Records Staff Anticipated Completion Date: June 30, 2025

2024-003 Plan: As of 03/20/2025 this is complete. Objective: Ensure that there is a recorded time date stamp of the notification itself. Process: To implement this in an effective and accurate setup we will execute the Batch Assign Transmittal CM Codes (BATC) process to improve communication code assignment and correspondence management. To implement the Batch Assign Transmittal CM Codes (BATC) process, we will execute the BATC process immediately following the completion of the transmittal, ensuring all necessary parameters are set accurately. Next, we will establish a communication code through the Communication Management Center (CMC), with IT Support responsible for associating an immediate print document with the code. This setup will leverage the options available within the BATC system, including assignment to specific awards, categories, and exclusions as needed. Subsequently, we will utilize BATC to identify recipients for the communication code by setting parameters based on academic year, date ranges, award periods, and award categories. Once recipients are identified, we will verify that all students are included by checking the TA.ACYR file and the relevant code and date fields to ensure no omissions. Following this verification, we will assign the communication code within the CRI system, ensuring the status is marked as "Received" so that the immediate print document can be scheduled as pending correspondence. The next step involves managing the correspondence through the PCB process, with the option to use PCEX if necessary. It's important to ensure that the immediate print document is configured for email distribution. A review of the entire process will then be conducted by the office staff, analyzing outcomes and gathering feedback from team members to document any issues encountered and the resolutions applied. Finally, we will focus on continuous improvement, implementing feedback to address any problematic areas and scheduling a training session if required to cover the BATC and communication code processes. This structured approach aims to streamline operations and enhance accuracy in communication code assignments. This outlines the steps necessary to streamline the BATC process and enhance accuracy in communication code assignments. Regular reviews and adjustments based on team feedback will ensure ongoing improvement.

2024-002 Plan: As of 03/20/2025 this is complete. Objective: Ensure that the Return to Title IV calendar is set up correctly. In order to address the original setup of the Return to Title IV calendar that was done with Colleague specialists in the original setup, we now confirm that the calendar is now correctly established and that the previous issues have been resolved. Initially, the calendar was impacted by the inclusion of four federal holidays, which led to inaccuracies. To rectify this, we conducted thorough research and collaborated closely with Ellucian support to devise a robust annual setup plan that will prevent the recurrence of such errors in the future. Moving forward, we have instituted a proactive approach in which we will meticulously review and manually count the calendar each year prior to the start of the academic year. This ensures that all holidays and relevant dates are accurately reflected in the calendar to align with federal guidelines, effectively mitigating any potential disruptions. Through these measures, we aim to maintain compliance and enhance the overall integrity of our Return to Title IV processes. Objective: Ensure that the Return to Title IV funds are returned within the 45 day timeline. lnorder to address the timely return of funds within the 45-day federal timeframe, we acknowledge that this was our first year utilizing a new system, which presented a learning curve for our team. To address this challenge, we partnered with the Ellucian team to implement an automated notification system that triggers alerts at the 30-day mark whenever a Return to Title IV (R2T 4) calculation has been performed but the associated funds have not yet been returned or transmitted for return. This proactive measure is designed to enhance our operational efficiency and ensure compliance with federal regulations. By enabling timely notifications, we can better maintain the integrity of federal policies and the R2T 4 process itself, allowing our staff to take appropriate action and ensure that funds are returned promptly. Furthermore, we will conduct periodic reviews of this system and its effectiveness to identify any additional improvements, fostering ongoing compliance and strengthening our financial processes in future academic years.

Student Financial Assistance Cluster – Assistance Listing Numbers 84.007, 84.033, 84.038, 84.063, 84.268 Recommendation: We recommend the College review its reporting procedures to ensure that students’ statuses are timely 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: The College will update enrollment status reporting procedures and provide training to staff to ensure changes are reported to NSLDS in a timely manner. Name(s) of the contact person(s) responsible for corrective action: Cathy Mullins, Director of Financial Aid and Scholarships, Keene State College Planned completion date for corrective action plan: March 31, 2025

Student Financial Assistance Cluster – Assistance Listing Numbers 84.007, 84.033, 84.038, 84.063, 84.268 Recommendation: We recommend that the College put a process in place to refund student credit balances that arose from federal funds within 14 days. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The College will update credit balance reporting and monitoring procedures and provide training to staff to ensure refunds are done in a timely manner. Name(s) of the contact person(s) responsible for corrective action: Cathy Mullins, Director of Financial Aid and Scholarships. Keene State College Planned completion date for corrective action plan: April 30, 2025

William Marsh Rice University Response The following is William Marsh Rice University’s Response to the audit of Federal programs in accordance with the Uniform Guidance for the year ended June 30, 2024. Finding 2024-001 – Loan Disbursement Notification Cluster: Student Financial Assistance Cluster Awarding Agency: Department of Education Award Name: Federal Direct Student Loans Award Year: July 1, 2023 – June 30, 2024 Assistance Listing Number: 84.268 Pass-through Entity: Not applicable We acknowledge the audit finding regarding the missing documentation of the loan disbursement notification for the 2023-2024 academic year. The issue began when an automated rule was disabled by a system update. This prevented the loan disbursement notices from being sent to students. Upon recognizing the underlying reason, the loan disbursement notice, which is sent one day after a loan disbursement posts to a student’s account, had its system rules reengaged. This was achieved through a collaborative effort involving the Office of Financial Aid, the Bursar's Office, and Administrative Systems. Notices resumed on September 26, 2024, and we have since conducted spot checks to confirm that the notices are being sent as required. To prevent a recurrence of this issue, we have implemented the following measures: 1. Annual Review: We have updated our staff calendar with an annual reminder to review and request updates to the text and rules of the loan disbursement notice. 2. Documentation: We have ensured that the scheduled disbursement dates and the right to cancel are disclosed in multiple areas, including the all-freshmen notice, other loan/aid award notices, the loan section of our website, and the financial aid section of General Announcements for both undergraduate and graduate students. Prior to and including the 2023-2024 academic year, this information has been updated and made available on an annual basis in these areas. This practice will continue. Effective Date: September 26, 2024 Person(s) responsible for implementation: Paul Negrete, Executive Director for University Financial Aid Services, 713-348-5905 We believe these actions address the audit finding and will help maintain compliance with notification requirements moving forward. Sincerely, Paul Negrete Executive Director University Financial Aid Services

Corrective Action: See above corrective action plans for 2024-001 and 2024-002. Contact Persons: Duane Valencia, Assistant Financial Vice President – Student Finance Jason Kowarsch, Registrar

Corrective Action: Here are the immediate corrective actions taken: • There are now appropriate staffing levels in the Records office. Training is up-to-date as well. • A thorough review of the reporting requirements and a step-by-step guide was made by ITS and the Registrar to ensure NSC reports are correct and meet the NSC requirements. • The missing NSLDS reports for the 2022-2023 academic year have been prepared and submitted. 2023-24 academic year were prepared and submitted as of 2/11/2025. The 2024-2025 academic year will be prepared and submitted by the end of the Spring 2025 semester. • Coordination with the NSC representatives to ensure the validity and accuracy of the reports in compliance with submission requirements and verification of report acceptance. To prevent future occurrences of missed NSLDS reporting, the following steps have been implemented: • Responsibility: The registrar is the primary reporting coordinator to the National Student Clearinghouse, with support from both Student Financial Services and ITS. • Automated Reminders: Calendar alerts and task management reminders are sent monthly to notify responsible staff well in advance of reporting deadlines this includes the Registrar, Student Financial Services and ITS. • Training and Documentation: A standard operating procedure (SOP) has been documented to guide future reporting efforts. However, ITS must make it a priority when there are changes to NSC reporting requirements. This was lacking during the 2022-2024 periods the university failed to report. • Management Oversight: The Vice President for Academic Administration must also ensure that all these processes and departments are working to ensure the student data is being reported correctly and on-time. We are confident that these measures will address the issue of failure to report to the NSC and ensure full compliance with NSLDS reporting requirements in the future. Contact Persons: Duane Valencia, Assistant Financial Vice President – Student Finance Jason Kowarsch, Registrar Completion Date: February 11, 2025

Corrective Action: Financial aid will be processed on or after census day (12th day of enrollment period) for all students identified by the Registrar and financially cleared as enrolled as of that date. The Registrar will ensure students listed as enrolled as of census date, are registered and attending classes. Student Finance has learned to identify anomalies within the Ellucian system that caused the system to not auto-adjust to account for student eligibility. More staff training will be done in Student Finance to review awarding, to prevent this as an ongoing issue. Contact Persons: Duane Valencia, Assistant Financial Vice President – Student Finance Jason Kowarsch, Registrar Completion Date: To be completed by June 1, 2025

Finding 2024-002 Name of Responsible Individual: James Slizewski, Registrar Corrective Action: The University has implemented several corrective actions to address this finding. We have created a comprehensive process document to ensure accurate reporting of student enrollment changes. This document outlines each step of the reporting process in detail, providing clear guidelines and procedures for staff to follow for each type of enrollment report that is required. This document will also outline a procedure for conducting reviews of student status changes to ensure they align with our reported data. These reviews will involve cross-checking the information in our reporting system with data generated by our student information system’s delivered enrollment reporting process to identify discrepancies prior to submitting the report. Additionally, we are seeking training and outside consultation on how to better utilize our student information system more effectively. We will engage with consultants to improve our student information system’s delivered student withdrawal and enrollment reporting processes. By utilizing our student information system’s delivered processes more effectively, we will reduce future enrollment reporting errors. Anticipated Completion Date: February 2025

Finding 2024-001 Name of Responsible Individual: Alexis Ritter, Director of Cash Management Corrective Action: To prevent similar occurrences in the future, we will transition from monthly program reconciliations to weekly FSEOG reconciliations and bi-weekly FWS reconciliations, which will allow for more effectively monitoring of award reversals or negative adjustments. Upon completion of these reconciliations, any excess cash identified will be promptly returned via G-5. Additionally, we will explore the feasibility of automating the notification process for negative adjustments posted in the ERP system, ensuring that we can capture excess cash in a more timely manner. Anticipated Completion Date: February 2025

Corrective Action Plan 2024-003: The University concurs with the finding and has made the required corrections to the COD disbursement dates. The University process when posting Aid has remained consistent each year, this appears to be an isolated incident where CAMS did not pick up the date listed on the disbursement screen for these students and pass that to COD. The University has implemented a control to complete the disbursements each time and then verify the date reflects correctly in COD afterwards. While this should be an automatic process, and has been in previous years, it will be something the University verifies now with each aid posting. Completion Date: August 2024 Contact Person: Megan Morton, Director of Financial Services

Corrective Action Plan 2024-002: The University concurs with the finding. The University has corrected the two Spring 2024 RT24 calculations and initiated additional Pell grant disbursements to the noted students. The University has updated its calculations of the scheduled breaks for the 2024-2025 academic year. Completion Date: August 2024 Contact Person: Megan Morton, Director of Financial Services

Commonwealth: Direct Loan processor will submit monthly reconciliations to Executive Director of Financial Aid or designated campus director for review and approval

ESU: The University acknowledges this is a repeat finding. While a corrective action plan was implemented in May 2024, the audit sample consisted of students from Fall 2023 and Spring 2024, before the updated procedures were in effect. Since then, the University has enhanced its process for identifying when a student ceases participation in a course. Faculty are now required to indicate when a student stops attending. If a faculty member and student agree on issuing an incomplete grade, both must sign a document attesting that the incomplete is a valid final grade. This ensures clarity for the Registrar's Office. Registrar staff now update the National Student Clearinghouse promptly once a student’s last date of activity is confirmed, particularly when a student withdraws from all courses. This process supports timely compliance with the 60-day federal reporting requirement. Additionally, the University is reviewing its procedures for reporting program enrollment effective dates to ensure consistency with NSLDS standards. All updates are submitted through the National Student Clearinghouse. IUP: IUP will set guidelines that all degree clearing must be done with the 45 day time line so the students are reported within the 60 days limit Cheyney: Cheyney University of Pennsylvania extracts current enrollment information, including any enrollment status changes for all students from the University system of record based on the schedule timeline provided to NSC. As of Fall 2024, The Registrar’s Office continues to review NSC information following transmission, particularly for effective dates of completely withdrawn students. The NSC reports enrollments to NSLDS for the University. Cheyney University had previously learned that NSLDS did not receive students' enrollment status changes from NSC in a timely manner due the University HCM2 status and timing of students being reported to NSLDS from COD based on Ed’s approval of the University HCM2 submissions Kutztown: We will shorten our process to 2-3 days to compensate from the (up to) 30 day lag between NSC reporting and NSLDS reporting. We will connect with another PASSHE school (not on the findings report) to ascertain how they keep their submissions timely, and learn best practices. We will renew our cooperative efforts with financial aid to ensure both sides of the equation – NSC and NSLDS – are communicating and that both offices are involved in double checking. Commonwealth: The issues with enrollment reporting were one-time issues related to the integration of the three schools and the implementation of and data migration to a new student information system. Issues have been resolved and Commonwealth University is currently reporting on the prescribed schedule Millersville: The Registrar’s Office will evaluate their procedures and review policies surrounding reporting status changes to NSLDS to ensure the enrollment effective date reported to NSLDS is aligning with the University’s last date of attendance. Primarily, the frequency of submissions to the NSC.

ESU: The University acknowledges this is a repeat finding. In response, updated policies and procedures were implemented in May 2024. The audit sample included students from Fall 2023 and Spring 2024—periods that predated the implementation of the corrective measures. To improve compliance, the University has introduced enhanced reporting mechanisms to identify when a student is no longer participating in any enrolled courses during a given semester. Once a determination is made that a student has withdrawn, University Registrar staff manually update the student’s status in the National Student Clearinghouse. This process reduces the delay between a student’s actual withdrawal and the status update reported to NSLDS. These steps are intended to ensure timely and accurate reporting moving forward. IUP: IUP will set guidelines that all degree clearing must be done with the 45 day time line so the students are reported within the 60 days limit. Cheyney:Cheyney University of Pennsylvania utilizes the National Student Clearinghouse as a third-party service provider for enrollment reporting and provides all enrollment data to NSC, believing that enrollment would be reported to NSLDS in compliance with federal regulations; unfortunately, the enrollment data from the NSC roster which is provided to National Student Loan Data Systems (NSLDS), is only matched to students who currently have existing enrollment records in NSLDS. Student enrollment information is provided to NSLDS from Common Originations and Disbursements (COD). Cheyney University is a Heightened Cash Monitoring 2 (HCM2) institution, and students' Title IV aid/ disbursements are reported differently than advance pay institutions. The student records from COD are only provided to NSLDS upon approval of disbursement from Ed after the University HCM2 submissions are approved. As of Fall 2024, Cheyney University has continued to directly report and upload enrollment for all Title IV recipients to NSLDS from the monthly NSC enrollment rosters. Kutztown: We will target shortening our status change reporting process to 2-3 days to compensate from the (up to) 30 day lag between NSC reporting and NSLDS reporting. We will connect with another PASSHE school that was on the findings report for the last period - but not this period - to ascertain how they avoided the repeat, and to learn additional best practices. We will renew our cooperative efforts with financial aid to ensure both sides of the equation – NSC and NSLDS – are communicating and that both offices are involved in double checking Commonwealth: The issues with enrollment reporting were one-time issues related to the integration of the three schools and the implementation of and data migration to a new student information system. Issues have been resolved and Commonwealth University is currently reporting on the prescribed schedule. Millersville: The Registrar’s Office will review its reporting procedures to ensure that students’ statuses are timely reported to NSLDS as required by Federal regulations. Primarily, the frequency of submissions to the NSC.

Student Financial Aid Cluster – Federal Assistance Listing Numbers 84.007, 84.033, 84.063 and 84.268 Recommendation: We recommend the University review its policies and procedures related to outstanding student refund checks to ensure they are being returned to the Department of Education after 240 days. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The University has developed a policy to identify uncashed Title IV refund checks prior to the 240-day expiration date. The policy includes steps to contact students whose checks did not clear and to return the refunds to the Department within 240 days after the issue date of the check. The procedures will ensure that reviews are completed and returned timely according to applicable regulations. Name(s) of the contact person(s) responsible for corrective action: Lillian Perreira-Talty, Director of Student Accounts (201) 761-6080 Planned completion date for corrective action plan: Completed

Student Financial Aid Cluster – Federal Assistance Listing Numbers 84.063 and 84.268 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 University has updated its policies and procedures for NSLDS submissions via their third-party servicer to ensure relavant information is being captured and reported timely in accordance with applicable regulations. Name(s) of the contact person(s) responsible for corrective action: Kamla Singh-Ramoutar, University Registrar, (201) 761-6051 Planned completion date for corrective action plan: Completed

Reference Number: 2024-021 Prior Year Finding: No Federal Agency: U.S. Department of Health and Human Services State Agency: Agency of Human Services Federal Program: CCDF Cluster Assistance Listing Number: 93.575, 93.596 Award Number and Year: 2301VTCCDD (10/1/2022 – 9/30/2025) 2401VTCCDD (10/1/2023 – 9/30/2026) Compliance Requirement: Eligibility Type of Finding: Significant Deficiency in Internal Control Over Compliance, Other Matters Recommendation: We recommend that the Agency review and enhance procedures and controls to ensure that it verifies U.S. citizenship for all participants and confirm that only eligible participants receive benefits under the program. Views of responsible officials: Management agrees with the finding. Corrective Action Plan: This finding has been corrected as of January 2024 dating back to October 2023. The State is no longer pooling funding sources which means that we can identify cases by their true funding source. This means that only true CCDF cases will be audited going forward and family service cases (protective service) no longer follow CCDF rules including citizenship and identity. Scheduled Completion Date of Corrective Action Plan: December 31, 2024 Contacts for Corrective Action Plan: Karolyn Long, Operations Director karolyn.long@vermont.gov Peter Moino, AHS Director of Internal Audit peter.moino@vermont.gov

The ECU Registrar is creating a new work manual for National Student Clearinghouse (NSC) enrollment reporting, which will correctly outline how Colleague handles enrollment status rules. The ECU Registrar will personally generate each NSC file from Colleague. A member of the Registrar's team will continue to address error report, and also will perform the data checks discussed below. Prior to each NSC enrollment reporting date, the fields in Colleague screen ACLV will be verified as accurate by the Registrar. Each time an NSC enrollment report is generated, but before it is submitted to the Clearinghouse, the following data checks will be performed. Confirm students are showing in the enrollment file for each enrollment status. Spot-check at random 10 students within each enrollment status category to verify statuses are calculating correctly. Compare NSC numbers with ECU institutional enrollment numbers for graduate and undergraduate overall enrolled. ECU has reviewed enrollment submissions through Spring 2025 and will make manual corrections.

Counselors will utilize a Verification check sheet to show their work on verifications and corrections made on FAFSA Processing System (FPS). Counselors will be required to track and verify that the corrections were made appropriately on FPS by verifying those corrections on the updated ISIR. A communication code will be created so that the counselors can track when a correction is made and when the corrected ISIR is received and verified correctly. The Director and Assistant Director can then run lists of all students with the particular communication code to spot-check and review.

Changes to COA for a student are documented and reviewed by the Assistant Director or the Director. A report will be created to view disbursement dates in Colleague and COD to find variances in the dates. This report will be processed weekly. The counselor, Assistant Director, or Director will review disbursements in COD to verify that the COA and disbursement date agree with Colleague.