Corrective Action Plans

The process to determine students who withdraw during the semester has been updated to include running a withdrawal list through RGER weekly. The list will be given to the Financial Aid Counselors to work on Mondays. Part of the review will be to verify the start and end dates of the term used during the process. The Director or Assistant Director will review the lists and R2T4 forms (ROFW) to verify accuracy and timely processing.

Loan notification letters/emails to students and/or parents were set up and made operational in July 2024 with the assistance of a consultant. Further updates/changes were made in August 2024.

Identifying Number: 2024-002 Finding: Federal Program: U.S. Department of Education - Student Financial Aid Cluster: Federal Direct Loan Program, 84.268 Criteria: The University is required to comply with 36 CFR Section 685.309(b). Condition: During our testing of unofficial withdrawals and student status changes for graduates, we selected four and 22 samples, respectively, and we noted one instance in each testing section where a student’s status change was not timely reported to the National Student Loan Database System (NSLDS). Cause: The University did not have controls in place to ensure students' classification were being properly reported to the NSLDS. Effect: Student status changes were not reported within the required timeframe under federal regulations. The provisions of 34 CFR Section 685.309(b) were not followed and thus two students were not reported timely and subsequently not placed into loan repayment status in a timely manner. Questioned Costs: There were no questioned costs associated with this finding. Recommendation: We recommend that the University implement a control to ensure data is being reviewed for accuracy by the appropriate personnel before roster files are submitted to the NSLDS. In addition, we recommend that the University submit roster files on a regular basis. Corrective Actions Taken or Planned: Regarding the status change for the identified graduate, management implemented a new process for reporting student enrollments. The Office of Institutional Research reviews the specifications for reporting from the National Student Clearinghouse (NSC) and National Student Loan Data System (NSLDS) to ensure that the proper data is being reported. Reports are generated by Institutional Research and upon approval of the Registrar submitted to the NSC. Any errors are remediated by the Registrar. And the Financial Aid Office verifies that reports sent to the National Student Clearinghouse are accurately reported to the National Student Loan Data System, by auditing both systems with assistance from the Office of institutional Research and Office of the Registrar. This process was implemented in February 2023. However, the timing of that fix occurred after the student in question had already graduated, meaning they were not included in the corrective measures. For the Return of Title IV (R2T4) calculation process, management has updated our procedures to ensure that student enrollment status is promptly updated when an R2T4 is completed. Specifically, a required step was added in the R2T4 process where a designated box is checked in the system, flagging the student’s account for withdrawal status reporting. This change helps ensure timely and accurate reporting of enrollment status to NSLDS. Completion Date: October 1, 2024 Responsible Official: Robert Giesting, Executive Director of Institutional Assessment and Learning

Finding #: 2024-001 – Special Tests and Provisions – Return of Title IV Funds Description of Finding: One record from the return to Title IV sampling of 12 students tested, had funds returned beyond the required timeline for an unofficial withdrawal. The record received a non-completed course grade for the fall 2023 term, but the return of funds based on the unofficial withdrawal was not performed until July 2024. The cause of the delayed return was the irregular non-completed course grade that was applied by faculty. The grade type was not incorporated into control measures for prompt identification. The University of La Verne concurs with this finding. Corrective Action: The reporting criteria used to identify non-completed courses are being modified to include all grade codes that meet the non-completed criteria, regardless of their appropriateness to the enrollment type. This revision is to ensure that any irregular grade reporting would still be captured. Secondly, all staff who perform return to Title IV calculations are expected to complete the Federal Student Aid training modules on return to Title IV funds to reinforce the staff knowledge base. Lastly, with the recent onboarding of a Financial Aid Compliance Manager, additional quality assurance steps are being added to include random sampling and secondary review of return to Title IV records for accuracy and timeliness. The responsible party is Laura Evans at levans2@laverne.edu. This will be completed by December 2024.

Federal Direct Student Loans – Assistance Listing No. 84.268 Recommendation: We recommend the University evaluate its procedures around packaging and awarding students to ensure loan eligibility is reassessed prior to disbursement. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The University has strengthened its procedures to ensure student loan eligibility is reconciled after awarding. The Direct Loan project manager will conduct additional reviews to verify continued eligibility. Name(s) of the contact person(s) responsible for corrective action: Fatima Sulaman Planned completion date for corrective action plan: 3/17/25

Federal Pell Grant Program – Assistance Listing No. 84.063 Recommendation: We recommend that a review is implemented to ensure calculations of Pell awards are using the correct EFC. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The University has implemented a review process to ensure Pell Grant awards are calculated using the correct EFC/SAI. Financial Aid staff will conduct periodic quality control checks to verify that EFC/SAI values are accurately applied in award determinations. Name(s) of the contact person(s) responsible for corrective action: Fatima Sulaman Planned completion date for corrective action plan: 3/17/25

Federal Pell Grant Program & Federal Supplemental Education Opportunity Grants – Assistance Listing No. 84.063 & 84.007 Recommendation: We recommend the University implement policies to review all student award packages at the start of the academic year to ensure no over awards exist. In addition, we recommend the University implement procedures for adjusting aid when an outside scholarship is received by the student. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The University has implemented enhanced procedures to review all student award packages at the start of the academic year to ensure compliacne with federal overaward regulations. Additionally, the new staff member that is responsible for adding outside scholarships to student accounts has received training to ensure they review for potential over awards. Name(s) of the contact person(s) responsible for correcitve action: Marivic Delacruz and Renato Aguilar Planned completion date for corrective action plan: 3/17/25

The University understands the importance of timely R2T4 calculations. The committee review of all R2T4’s every other Wednesday did not properly catch the mistake in the two R2T4’s that were late. Even though the original calculations were done on-time, the committee did not meet before the campus closed for the two-week Christmas/New Year’s break, due to several of the members having been away from the campus while traveling. As a result, when the committee met in January, they found an error in the denominator calculation. It was returned to the processor to correct the dates and re-calculate, and when the committee met again both were corrected. However, this caused the process to stretch past the 45-day requirement. While this indicates that the committee reviews and corrects R2T4’s properly, this certainly caused these two to be late. The University will change the committee meetings to every Wednesday, instead of every other Wednesday. This will shorten the time that any changes/mistakes are recognized and corrected. In addition, if a member is unable to meet, the remaining members will still meet and review all withdrawals. The University believes this will prevent R2T4’s missing the appropriate deadlines established by regulation. This process will begin immediately, and will be the responsibility of the Executive Director of Student Financial Services, Tiffany McCann.

Views of Responsible Officials: SCC has taken measures to strengthen internal controls. We have begun running a withdrawn/change report weekly. SCC has improved communication by implementing an email between Registrar and Financial Aid as well as Student Accounts. We have enhanced the process of monitoring the withdrawn students and ensuring the R2T4 calculations and the notification process have all been completed and compliant.

Views of Responsible Officials: The College will conduct an audit of status change protocols; reporting procedures to the National Clearinghouse; and pursue National Clearinghouse procedures for uploading to National Student Loans Data System (NSLDS).

Views of Responsible Officials and Planned Corrective Action: DHS concurs with this finding. Corrections have been made to the affected quarterly reports for SFY2024. New program codes for Placement and Residential Licensing expenditures were not included in prior reporting for Administrative Costs. Documented procedures for quarterly financial reporting will be revised to include more specific instructions for reporting expenditures and additional levels of review prior to report submission. Additional training on completion of quarterly financial reporting is being developed for DCFS Finance and Managerial Accounting-Grants Management staff. Anticipated Completion Date: April 30, 2025 Contact Person: Tiffany Wright Director, Division of Children and Family Services Department of Human Services 700 Main Street Little Rock, AR 72201 (501) 396-6477 Tiffany.Wright@dhs.arkansas.gov

Views of Responsible Officials and Planned Corrective Action: DHS concurs with this finding. Corrections have been made to the affected quarterly reports for SFY2024. New program codes for Placement and Residential Licensing expenditures were not included in prior reporting for Administrative Costs. Documented procedures for quarterly financial reporting will be revised to include more specific instructions for reporting expenditures and additional levels of review prior to report submission. Additional training on completion of quarterly financial reporting is being developed for DCFS Finance and Managerial Accounting-Grants Management staff. Anticipated Completion Date: April 30, 2025 Contact Person: Tiffany Wright Director, Division of Children and Family Services Department of Human Services 700 Main Street Little Rock, AR 72201 (501) 396-6477 Tiffany.Wright@dhs.arkansas.gov

Finding Reference Number: 2024-001 Description of Finding: Inaccurate effective dates for unofficial withdrawals according to NSLDS enrollment reporting requirements Statement of Concurrence or Nonconcurrence: We agree with the finding. Corrective Action: Miles Community College will take corrective action, by adding to our end of term SAP processing the step of updating National Student Clearinghouse with last date of attendance according to the grade roster from the instructor. This will be done prior to the processing of the R2T4’s. Name of Contact Person: Danielle Dinges, Director of Financial Aid & Admissions, 406-874-6182, dingesd@milescc.edu Projected Completion Date: As this is an action that needs to be completed at the end of each term, it will be completed in December, May and July/August.

2024-002 Enrollment Reporting Finding: The College did not accurately report enrollment dates at the program level to the National Student Loan Data System (NSLDS). Corrective Action Taken or Planned: The identified reporting errors are due to software defects that occurred after system upgrades, resulting in data improperly exporting from our system to the Clearinghouse. In collaboration with our system’s vendor the offices of the Registrar and Student Financial Services are correcting these defects and updating internal procedures to include substantial testing of the reporting function following all system upgrades in the future. These offices are in the process of manually correcting any student reporting affected from fiscal year 2024. As noted in the finding, these errors did not cause any questioned costs. Anticipated Completion Date: June 2025 Person(s) Responsible for Corrective Actions: Carla Minchello – Director of Student Financial Aid, Office of Student Financial Services Sara Smith - Manager, Student & Academic Systems, Office of the Registrar

2024-001 Enrollment Change Reporting Finding: The College did not accurately report enrollment changes at the program level to the National Student Loan Data System (NSLDS). Corrective Action Taken or Planned: The identified reporting errors are due to unique circumstances in which the date of determination and effective date for students’ withdrawals occurred in two separate academic periods (winter session and spring session). The methodology for tracking these students internally changed in fiscal year 2024, resulting in the reporting error. This methodology was not used in prior fiscal years and as such no prior year data was affected. The College updated procedures again in fiscal year 2025 to ensure that this unique circumstance was properly captured by our system’s reporting structure going forward, and is in the process of manually correcting any students in NSLDS with similar circumstances from fiscal year 2024. As noted in the finding, these errors did not cause any questioned costs. Anticipated Completion Date: April 2025 Person(s) Responsible for Corrective Actions: Carla Minchello – Director of Student Financial Aid, Office of Student Financial Services Sara Smith - Manager, Student & Academic Systems, Office of the Registrar

Program: AL 93.658 – Foster Care Title IV-E; AL 93.658 – COVID-19 Foster Care Tile IV-E – Allowability & Eligibility Corrective Action Plan: Resource Developers (RD) will increase initial and annual billing trainings with child care subsidy providers and assist them with any billing needs they have. Contact: Bryan Gilliland Anticipated Completion Date: 06/30/2025

Program: AL 93.658 – Foster Care Title IV-E – Allowability Corrective Action Plan: The agency will update the grant reconciliation process to include steps to review journal entries on the general ledger prior to moving costs to grant to ensure journal entries are proper. The cost in question will also be removed from the grant. Contact: Ann Murphy Anticipated Completion Date: 02/28/2025

Program: AL 93.566 – Refugee and Entrant Assistance State/Replacement Designee Administered Programs – Allowability & Eligibility Corrective Action Plan: The department will retrain staff on OEA requirements to run SAVE and provide documentation in NFOCUS. The department will also provide reeducation on status verification documentation requirements. Contact: Sara Bockelman Anticipated Completion Date: 12/31/2025

Temporary Assistance for Needy Families – Assistance Listing No. 93.558 and Foster Care Title IV-E - Assistance Listing No. 93.658 Recommendation: Management uses full time equivalent reports to determine what percentage of time spent should be allocated to the federal grant. During testing of payroll expenses, we noted that one employee was not listed on the full time equivalent report for one month. We recommend that management implement a review process that compares the employees on the full time equivalent report to the list of active employees to ensure all employees are included in the full time equivalent report. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned/taken in response to finding: The CFO will review the full time equivalent reports to ensure all employees are included in the full time equivalent reports. Additionally, general ledgers will be reviewed for all Federal spending against the full time equivalent reports to ensure consistency. Name(s) of the contact person(s) responsible for corrective action: Laura Stein, Chief Financial Officer Planned completion date for corrective action plan: March 31, 2025

Condition The University did not notify the National Student Loan Data System (NSLDS) in a timely manner for 2 withdrawn students in our sample of 25 students. Upon further review of all students who withdrew, a total of 16 of 72 students who withdrew were not reported to the NSLDS. The sample was not a statistically valid sample. Corrective Action Plan Corrective Action Planned: The University implemented a new Student Information System (SIS) [Jenzabar One] and Financial Aid System [Jenzabar Financial Aid] in 2024. The system processes require a student social security number in both systems. This condition will safeguard enrollment records sent to the National Student Clearinghouse (NSC) will be complete and communicated to the National Student Loan Data System (NSLDS) correctly. These systems were in place starting the 2024-25 academic year. Name(s) of Contact Person(s) Responsible for Corrective Action: Tom Kendziora, Director of Financial Aid Completion Date: March 5, 2024

Student Financial Aid Cluster – Late Return of Credit Balance Assistance Listing No. 84.268 Recommendation: We recommend the College review and revise its policies for identifying and paying credit balances to ensure that it is paid to the student or parent as soon as possible, but no more than 14 days after the occurrence. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Parent Plus loan recipients that meet the criteria for the refund will be identified by Financial Aid, Accounts Receivable will process vouchers the first week of classes and Accounts Payable will process the refunds that are identified to be sent the first week of classes and within 14 days of disbursement of the IV loans. Name(s) of the contact person(s) responsible for corrective action: Jennifer Hutton Planned completion date for corrective action plan: February 2025

Student Financial Aid Cluster – Verification Assistance Listing No. 84.063, 84.268, 84.033 Recommendation: The College should review the procedures surrounding the verification process to ensure all necessary support and documentation is obtained and retained in the student files. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: A procedure was implemented for a staff member to review completed verifications prior to disbursement of Title IV aid. WASHINGTON COLLEGE CORRECTIVE ACTION PLAN YEAR ENDED JUNE 30, 2024 (56) Name(s) of the contact person(s) responsible for corrective action: Jennifer Gallagher Planned completion date for corrective action plan: February 2025 U.S.

Student Financial Aid Cluster – Common Origination and Disbursement (COD) Reporting Assistance Listing No. 84.063 Recommendation: We recommend the College evaluate its procedures and policies around reporting Pell disbursements to 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 finding: Created procedures that will identify when an award does not fully disburse and to ensure that the correct amount disbursed is what we report to COD. Name(s) of the contact person(s) responsible for corrective action: Jennifer Gallagher Planned completion date for corrective action plan: February 2025

Student Financial Aid Cluster – Gramm-Leach-Bliley Act Assistance Listing No. 84.063, 84.268, 84.007, 84.033 Recommendation: We recommend the College ensure its written information security program addresses the required minimum elements as outlined in 16 CFR 314.4. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The College has since implemented corrective measures, including updating its written information security program to align with GLBA requirements, enhancing documentation, publishing written policy within the college policy portal and strengthening oversight. Name(s) of the contact person(s) responsible for corrective action: Irv Bruckstein Planned completion date for corrective action plan: February 2025

Student Financial Aid Cluster – National Student Loan Data System (NSLDS) Reporting Assistance Listing No. 84.063, 84.268 Recommendation: We recommend the College review its reporting procedures to ensure that students’ statuses are accurately and 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: With the hiring of a permanent registrar, there has been adequate training on enrollment submissions and establishment of timely updates to the Clearinghouse in accordance with the institution's reporting schedule and as updates occur. Also, the Registrar's Office and the Office of Financial Aid are working more closely to ensure timely and accurate updates for enrollment and withdrawal dates. Name(s) of the contact person(s) responsible for corrective action: Kelly Rowett-James Planned completion date for corrective action plan: February 2025