Corrective Action Plans

The University acknowledges and agrees with this audit finding. During the months of August and September 2024 (concurrent with PwC’s audit fieldwork), enrollment data was reviewed by the Office of the University Registrar in preparation for the Completers List reporting related to Gainful Employment/Financial Value Transparency requirements. During the Completers List reconciliation process, it was determined by the Office of the University Registrar that all August 2024 graduates needed to have their status dates updated. Those updates took place in early October 2024. The Office of the University Registrar will run a query shortly after each conferral date to compare all graduates using all three program-level match criteria (credential level, CIP, program length) at the time of graduation to data submitted to NSC during the last enrollment file. The Office of the University's Registrar will also compare degree data sent to NSC against the student information system degree awarded data. The Office of the University's Registrar will continue to ensure that all error reports are resolved in a timely manner according to NSC and NSLDS timing guidelines. These processes were initiated for December 2024 graduates. The Office of the University Registrar will complete these comparison processes within 30 days of each degree conferral date and will take immediate action to directly update NSC and NSLDS if any discrepancies are found. Primary responsibility for implementing the corrective action plan for this finding rests with Amy Hammett, University Registrar and Associate Vice Provost for Student Information Systems, 216-368-4310

Project Legal Name: Positively Third Street HDFC HUD Project No.: 012-EE287 Audit Firm: CohnReznick LLLP Period covered by the audit: July 1, 2023 through June 30, 2024 Corrective Action Plan prepared by: Name: Matthew LoCurto Position: CFO Telephone Number: 212-453-5257 The following is a recommended format to be followed by the auditee for preparing a corrective action plan: A. Current Findings on the Schedule of Findings, Questioned Costs and Recommendations 1. Finding 2024-1 a. Comments on the Finding and Each Recommendation Management agrees with the finding and recommendation put forth by the auditors Action(s) Taken or Planned The $93,461 of residual receipts noted in the 2023 audit and cited as a finding in the 2024 report was deposited into the residual receipt account on January 10, 2025. Our new Controller has established procedures to ensure that that the proceeds stemming from the retroactive budget based rent increase are used for their intended purpose prior to the end of the fiscal year that they are received. B. Status of Corrective Actions on Findings Reported in the Schedule of the Status of Prior Audit Findings, Questioned Costs and Recommendations N/A

Corrective Action Plan: The Registrar’s Office will conduct a comprehensive review of the scheduled enrollment reporting dates currently listed in the National Student Clearinghouse (NSC). This review will focus specifically on calculating a fifty-day schedule of enrollment reporting to ensure enrollment reports are submitted within the required time frame as mandated by the National Student Loan Data System (NSLDS). The reporting date adjustment will allow additional days for NSC to report to NSLDS within the required sixty-day reporting period to maintain compliance. NSC emails a “Delivery Receipt” each time an enrollment report is submitted to the Registrar, Associate Registrar and Technology Support Specialist in the Registrar’s Office. The Executive Director of Institutional Research and Assessment will be added to the email notification and will have access to review enrollment report submissions. The Registrar will also be creating a calendar with a schedule of when the NSLDS enrollment files will be sent to help ensure the files are submitted on-time. Timeline for Implementation of Corrective Action Plan: The review of scheduled enrollment dates will begin immediately. Adjustments to the dates will be made as needed to ensure adherence to the sixtyday reporting requirement. Contact Person: Monique Lopez, Registrar and Simone Backstedt, Director, Financial Aid

Individual/s Responsible for Corrective Action Plan: Wanda Spradley, Director of Financial Aid Corrective Action Plan: The Institute agrees with the finding and is aware of the regulation that governs verification of Title IV Federal Student aid application set forth in 34 CFR Part 668 (34 CRF 668.56). The student’s record in questioned was verified and properly disbursed, the parent tax return that was prepared by a tax preparer left blank a line item regrading IRA deductions and payments and no schedule was prepared by the preparer as such this line item was not properly verified. The Financial Aid Office has updated its policy and procedures to institute a two factor review system on students selected for verification. The first check will be completed by the Senior Financial Aid Counselor, and second and final look is completed by the Director of Financial Aid. Anticipated Completion Date: February 28, 2025

Individual/s Responsible for Corrective Action Plan: Susan Kennon, Registrar Corrective Action Plan: The Institute agrees with the finding. The sudden departure of the former registrar in early September 2023 placed a gap in services and processes on the newly appointed registrar that took several months to resolve. There was a lack of continuity in reporting due to technological deficiencies that required a team of resources beyond the one office. Once technological deficiencies were addressed, reporting had not been performed since September 2023 and the first enrollment report submitted under the new registrar caused data issues as it was for a new semester (Spring 2024). The corrective action plan includes: • Continued student information system (“SIS”) training with Ellucian-Banner software personnel to include permissions-based access to data and software upgrades. o Access to data is permissions-based and our IT department monitors this to make sure registrar staff has the correct access. • Sweet Briar has authorized additional training for Registrar staff who are not familiar with the Banner SIS to ensure proper coding of student records. • Working with the National Student Clearinghouse (“NSC”) to resolve issues with data uploads and training on how to resolve errors. • Consistent reporting per the NSC transmission schedule so data is reported correctly and timely. • Consistent reporting of separated students (withdrawn and graduated) within 30 days of departure. • The registrar has conducted several reviews of SIS databases and tables to ensure the data is consistent with the Crosswalk provided by the National Student Clearinghouse, especially in enrollment status based on hours taken in a semester. • Creation of a manual with step-by-step directions on how to generate a report, submit the data to the NSC, and how to resolve errors on the NSC portal so the loss of a key person in the registrar’s office assures compliance with reporting and continuity. Anticipated Completion Date: Several training sessions have been completed by the Registrar since February 2024. Additional training on reporting was completed on March 4, 2025, and another training is scheduled for late March 2025. The assistant registrar has been trained on how to generate a report and resolve issues to allow for continuity in reporting. A recent review of processes (February 2025) helped us discover that there was a coding issue that was incorrectly reporting graduated students as withdrawn in subsequent reports. At least one student in this audit had this finding. Training and review of records is ongoing.

The finding has been remediated concerning status changes during required academic periods as of June 30, 2024. The University has improved staff access for enrollment reporting to the National Student Clearinghouse (NSC) to meet the compliance requirements of NSLDS for status changes reported during the semester the student is enrolled. The University continues to adjust reporting timelines to ensure accurate and timely reporting of status changes to NSLDS for status changes reported outside of required academic periods in which the student is enrolled.

Views of Responsible Officials and Planned Corrective Actions: The College agrees to the finding. An error report from the Clearinghouse had been sent to the College with respect to the affected students' enrollment statuses and was not addressed on a timely basis. The College has reviewed its policy and will add a secondary review process to its enrollment reporting to address all received error reports. The Assistant Registrar will address all error reports timely and make the appropriate corrections to the enrollment reporting. Since the NSLDS monitors the programs of attendance and the enrollment status of Title IV aid recipients, as the independent check and balance, the Financial Aid Office will review the NSLDS error reports for enrollment discrepancies and collaborate with the Registrar's office for their timely correction in the Clearinghouse.

Views of Responsible Officials and Planned Corrective Actions: The College agrees with the finding. A corrected ISIR came in after verification was complete and instead of going through the normal process of being reviewed and repackaged by the director, the student record was accidentally filed away. This happened due to human error. We have a process in place to monitor corrected ISIR transactions to ensure that the EFC (SAI effective for award year 2024-25 and later) agrees with our documentation. The student record is then given to the director for final review and repackaging. We have added an additional step now whereby the Pell Grant administrator also reviews the output report for ISIR imports on a weekly basis.

Management acknowledges this finding and will change the procedure to verify enrollment status changes to ensure that there are no issues of files not transferring from the National Student Clearinghouse (NSC) to the National Student Loan Data System (NSLDS). Currently, the Financial Aid Director confirms status changes in NSLDS at day 50, and as part of the process change a second status check will occur with a separate Financial Aid staff member before the 60 day timeframe has passed to ensure that no students were missed in the file transfer or that status changes occurred after the initial check. This plan will be overseen by Erin Teves, Director of Financial Aid, and will be implemented immediately.

2024‐002 – Reporting Student Withdrawal Date in the National Student Loan Data System (NSLDS) (Significant Deficiency) Criteria: The College is responsible for submitting timely, accurate and complete responses to Enrollment Reporting roster files and for maintaining proper documentation in accordance with 34 CFR Section 685.309(a)(2). Condition: From a population of 208 students that withdrew officially or unofficially during the fiscal year, we tested 22 and noted that withdrawal dates were submitted untimely for all 22 students and the incorrect date was reported for six students. Action Taken: We concur with this finding. The Office of the Registrar reports the withdrawal date via Clearing House. However, the withdrawal date is overridden by any subsequent enrollment updates. Moving forward, the Office of Financial Aid will ensure that withdrawal dates for R2T4 calculations are accurately reported. The updated enrollment information will be saved in the student’s electronic file to maintain proper documentation and compliance. Responsible Party: Sharon Murphy, Registrar Point of Contact: Sharon Murphy, Registrar (smurphy@columbiasc.edu) Expected date of correction: January 2025

2024‐001 – Incorrect Calculation of Title IV Funds Refunds (Significant Deficiency) Criteria: The total number of calendar days in a payment period or period of enrollment includes all days within the period that a student was scheduled to complete, except that scheduled breaks of at least five consecutive days are excluded from the total number of calendar days in a payment period or period of enrollment and the number of calendar days completed in that period. Condition: From a population of 208 students that officially or unofficially withdrew from a payment period, we tested 22 and noted that ten students required refund calculations. From these calculations we noted the following: 1. Thanksgiving break of five days was deducted incorrectly from total days in three calculations. 2. Spring break of nine days was deducted incorrectly as five days in one calculation. Action Taken: We concur with this finding. The Office of Financial Aid conducted an internal review of all Return of Title IV (R2T4) calculations for the 2023‐2024 academic year. Two students within the audit sample had been corrected prior to the audit; however, their disbursements were not updated in the Common Origination and Disbursement (COD) system at the time of the request. To prevent future discrepancies, we have collaborated with PowerFAIDS to ensure that the appropriate number of days associated with Thanksgiving and Spring Break are accurately assigned to students. Additionally, each financial aid counselor will complete the R2T4 calculation within three days of receiving a withdrawal notification email. Upon completion, the calculation will undergo a review by the Associate and/or Senior Director of Financial Aid to verify accuracy. Responsible Party: Lola Kennedy, Senior Director of Financial Aid Point of Contact: Lola Kennedy, Senior Director of Financial Aid (lkennedy@columbiasc.edu) Expected date of correction: January 2025

Management concurs with the finding and is implementing the following corrective actions: -Disbursements to or on behalf of students: Student Financial Services (SFS) has updated the Financial Assistance Terms and Conditions, which is required to be certified annually by all students receiving aid, to include consent to receive electronic communications. In accordance with the requirements of the Clery Act, the Annual Campus Security and Fire Safety Report (ASFSR) is posted and available on the WU Police Department website. The WU Police Department has partnered with the Office of the Executive Vice Chancellor for Administration and the Office of Information Technology to establish responsibilities and timelines that will ensure students, faculty, and staff are notified, prior to October 1 of each year, that the most recent ASFSR is available on the website. Additionally, the University's Internal Audit Department will follow-up quarterly to ensure implementation of this action plan. Student award notifications are delivered to students electronically through an automated process that identifies aid awarded but not yet disbursed. For the rare occasions that a student may have aid awarded and disbursed in the same day, therefore bypassing the overnight award notification process, SFS has implemented the review of a pre-disbursement daily report to identify students who have an aid offer but were not provided an aid notification. -Enrollment reporting: The Office of the Registrar has updated its procedures to include off-schedule enrollment submissions through NSLDS. On the completion of the National Student Clearinghouse graduate-only file and corrections, an ad-hoc enrollment submission request will be completed. -Return of Title IV funds: To ensure compliance with its internal policy, SFS has updated procedures to complete a formal R2T4 calculation within the student aid system on all withdrawing Title IV students. To monitor that no students are missed as part of the routine procedures, a new report has been created to identify withdrawn Title IV students. This report will be compared bi-weekly to the student aid system to confirm that R2T4 calculations have been completed. -Additional: SFS depends on multiple departments across campus to compliantly deliver federal Title IV aid. SFS will develop an annual training plan for campus partners to ensure they have the knowledge and resources to administer federal aid in compliance with federal regulations. SFS has hired an Associate Director of Operations and Training who will develop this training during calendar year 2025. The University's Internal Audit Department will follow-up quarterly to ensure implementation of this action plan. Completion Date: June 30, 2025 University Contact and Responsible Party: Michael Runiewicz, Assistant Vice Provost & Director of Student Financial Services, (314) 935-5900

Corrective Action Plan: Due to a sudden and unanticipated staffing shortage, R2T4 calculations were performed beyond the required timeframe. A staff member has been hired and one of their main tasks is to do R2T4 Calculations. We reached out to the faculty to get the last day of academic related engagement. In cases where we are unable to get the last day of academic related engagement, the federal guidelines allow schools to use the midpoint of the payment period for the R2T4 calculations. All policies and procedures relating to R2T4 processing have been reviewed and updated, and a review of all prior year calculations will be performed as well, to ensure compliance. Additional staff have been hired and trained in the process, and calculations are being performed. Adequate and trained staff will ensure that all required calculations are performed accurately, and according to required timelines. In addition, the Financial Aid Office has transitioned from SAM to the Colleague Financial Aid System (starting in 2024-25) which will provide a more automated and integrated process, with enhanced internal controls.

Corrective Action Plan: These initial Pell overpayments were incurred in the “early” Pell disbursements that occurred a week before the semester started and the first two weeks of the semester. The enrollment was reported correctly, but part of the issue was the current FA system (SAM) was not programmed to adjust the amount disbursed based on the student’s current enrollment at the time of disbursement. For the Spring 2024 semester, testing was done on SAM to disburse aid based on current enrollment for the early Spring 2024 disbursements. This change reduced the amount in overpayments if students drop below ½ time for the semester, or withdrew completely. In addition, the Financial Aid Office transitioned from SAM to the Colleague Financial Aid System (starting in 2024-25). Colleague is already programmed to disburse aid based on current enrollment status, so this will not be a recurring issue in the future. Early Disbursement and Overpayment Notes: • For Fall 2023 semester, the first early Pell disbursement was based on 25% of a student’s semester award based on full-time enrollment. If a student is currently enrolled ½-time or higher when this disbursement is processed, they will receive the 25% award amount. If a student is enrolled in less than ½-time status (.5 units to 5.5 units), they will receive a $500 Pell disbursement to account for the lower Pell grant award for less than ½-time students. • For Spring 2024 semester, after testing in SAM, we were able to disburse the early disbursements based on the current enrollment before Census which lowered the overpayment amount significantly. • We understand students add/drop courses through the first two weeks of the semester. The final Pell grant award for the semester is adjusted to the student’s enrollment status on Census day. Students who are ½-time or higher at Census will not be a Pell overpayment for the semester since their Pell grant award will be at 50% or higher. • For students who were enrolled at ½-time or higher at the time the early disbursement was processed, but then dropped to less than ½-time or withdrew completely by Census day, they will be considered a Pell overpayment. o These types of overpayments are unavoidable. o Example: Currently, if a student is scheduled a $500 disbursement for the early 25% disbursement, and is enrolled ½ time, they will receive $500. With the change to actual enrollment (1/2 time for this case), the student will receive $250 instead of $500. If the student drops below 1/2-time or withdraws completely by census, the highest overpayment amount will be $250 instead of $500.

The Registrar’s Office has already conducted an audit of the NSU Graduate programs to determine the length of each program. The Registrar (Amy Dunn) will provide the Assistant Director of Institutional Effectiveness (Morgan Grovenburg) with a spreadsheet of programs with their program length by February 14, 2025, and the Assistant Director of Institutional Effectiveness (Morgan Grovenburg) will make sure future submissions to the Student Clearinghouse match. The Registrar (Amy Dunn) and her team will input the correct program lengths in Banner (SFACPLR) by March 14, 2025.

Instructions for preparing R2T4 records include the appropriate steps for calculating institutional charges. A clerical error transpired and boxes that should have been unchecked were not. We have conducted training with Student Financial Services staff (Counselors: Katie Spencer, Isaac Palmer, Trace Taylor) or management (Director, Cindy Bendabout and Assistant Director, Kriston Gerler) who will be checking for accuracy of records prior to preparing letters for students. Title IV Reporting Specialist (Heather McWilliams) will audit previous week R2T4 records using the automated WD report that is generated weekly on Monday evening. This will ensure that withdrawn students are identified, R2T4 calculations are performed, and funds are returned in a timely manner.

Northeastern State University will make changes to our information security policy during the Spring 2025 semester to reflect all 14 elements of the GLBA standard. While there is a GLBA policy pending in the policy committee for campus approval, there is a desire to keep the information security policy as the central document for NSU's cybersecurity policy. The current information security policy is being worked on by NSU's ITS department in conjunction with an external vendor who is supplying our virtual Chief Information Security Officer. This work is expected to be completed by the end of March and will be submitted to our campus policy committee in April for approval of the modified document which will contain all 14 of the elements as specified in the GLBA standard and brought to our attention during the annual audit.

Banner aid year is set up prior to academic year schedule dates being available. Default dates associated with terms on STVTERM are used prior to official dates being established for the upcoming academic/aid year. Once dates are established by the institution, Student Financial Services staff (Functional Technologist, Vicki Ryals and Title IV Reporting Specialist, Heather McWilliams) and management (Director, Cindy Bendabout and Assistant Director, Kriston Gerler) will audit the following forms for accurate SAY/ AY periods: • RORTPRD • RORSAYR • RFRDEFA • RPRLOPT • RPROPTS • RORPRDS • RPRLPRD Audit of dates in Banner will be performed prior to originations being established for aid year. This will ensure accurate information is reported in Banner and COD for student records.

Michigan Reconnect Expansion Refund Calculation Error. Auditor Description of Condition and Effect. The student development fees and the technology fees that were required to be included in the scholarship refund calculation were missed for one student. As a result of this condition, one refund calculation for the grant was incorrect, resulting in an underpayment of $752. It is our understanding that on December 16, 2024, the College refunded this amount to the U.S. Department of Treasury for those affected by this calculation error. Auditor Recommendation. Management has already taken appropriate corrective action by updating the returns for the student impacted by the refund calculation error. However, we recommend that the College implement a review process to ensure that any correction is being reviewed by an independent second individual. Corrective Action. The College has performed the necessary steps to correct the error and will amend the refund calculation process to ensure that a second individual is reviewing the work performed. Responsible Person. Ruth Carlson, Director of Financial Aid. Anticipated Completion Date. December 16, 2024.

Michigan Reconnect Expansion Calculation Error. Auditor Description of Condition and Effect. The College’s review process for the Michigan Reconnect Grant scholarships is performed by manually reviewing a select group of students before funds are disbursed. Two students who were not a part of this selected group had tuition costs mistakenly included with their fees. As a result of this condition, two students’ scholarship calculations were incorrect, resulting in an overpayment of $3,054 to those students. It is our understanding that on October 30, 2024, the College completed the F4F Reconnect refund worksheet and mailed a check with the amount to be returned to the U.S. Department of Treasury. Auditor Recommendation. We recommend that the College follow the review processes they have in place and include formal documentation showing the preparer is a separate individual from the reviewer. Corrective Action. Upon discovery of the Michigan Reconnect Expansion calculation error, the College went through and made corrections to all student accounts affected. To prevent a similar problem arising in the future, the College has modified their review process to now require two signoffs, one to document the preparer and one to document the reviewer. Responsible Person. Ruth Carlson, Director of Financial Aid. Anticipated Completion Date. October 30, 2024.

Cost of Attendance Input Error. Auditor Description of Condition and Effect. There was an input error in the summer transportation component of the cost of attendance calculation. Instead of the on-campus students being designated with their own rate ($405), it was instead set to "All students 2023-2024." As a result of this condition, eight students received more aid than they were eligible to receive, resulting in loan adjustments of $2,858. It is our understanding that on September 23, 2024, the College updated and sent the changes to the Common Origination and Disbursement (COD) system. Auditor Recommendation. We recommend that the College implement a review process to ensure the inputs used in the cost of attendance determination are accurate and that the COA calculation is being reviewed by an independent second individual. Corrective Action. Upon discovery of the cost of attendance input error, the College went back through all summer non-on-campus students to determine if their aid was greater than it should have been and made updates to the COD system, as necessary. Responsible Person. Ruth Carlson, Director of Financial Aid. Anticipated Completion Date. September 23, 2024.

American University (the University) will conduct additional training with student advisors, members of the Office of the University Registrar (OUR) and members of the Office of Financial Aid (FA) to stress the importance of following the current policies and procedures for reporting changes in student enrollment statuses accurately and timely. To assist with timely reporting to the National Student Loan Data System (NSLDS), members of the OUR have applied for access to the system will report student status changes directly opposed to waiting for the service provider to report changes on the University’s behalf. Finally, the University will develop reports to be utilized by OUR and FA on a regular basis to monitor student enrollment status changes as well as the disbursement of financial aid, including loans. Date of completion: June 30, 2025

Enrollment Reporting – The College will review and update current procedures to ensure timely processing and monitoring of NSLDS reports. Internal reports will be run simultaneously to make sure all students are captured and their status is correctly reported. Anticipated Completion Date - December 31, 2024. Responsible Contact Person for Planned Corrective Action Plan - Mireya Perez, Chief Financial Officer

Return of Title IV Funds - The College will review and update current written policies and procedures to ensure the correct amount of days are used for the academic term in the timely return of Title IV funds calculation. Anticipated Completion Date - December 31, 2024. Responsible Contact Person for Planned Corrective Action Plan - Mireya Perez, Chief Financial Officer

Condition: The University did not return Title IV aid in a timely manner during the fiscal year. Planned Corrective Action: The University resolved immediately upon identification. The University checked all students and found no other student affected. It was an isolated incident that led to the modification of controls for accurate reporting going forward. Contact person responsible for corrective action: Cassie Tennant Anticipated Completion Date: The university completed this action on June 24, 2024