Corrective Action Plans

Condition: The University did not report certain students' status to the NSLDS in an accurate and timely manner during the fiscal year. Planned Corrective Action: Financial aid identified all the students who were not reported accurately to NSLDS. The University has also put a control in place to ensure that all subsequent enrollment changes are reported accurately and timely. Contact person responsible for corrective action: Cassie Tennant Anticipated Completion Date: Action was completed on August 15, 2024

Student Financial Assistance Cluster - Assistance Listing No. Various. Recommendation: We recommend that the University review its procedures related to outstanding student refund checks that have been outstanding for more than 240 days and return them to the Department. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to the finding: Waldorf University is developing an ACH for student refunds and conducting a quarterly review of outstanding checks that cannot be ACH. The business office has been given additional help, which will help with timely refunds to the Department. Name(s) of the contact person(s) responsible: Duane Polsdofer at 641-585-8121. Planned completion date for a corrective action plan: March 1, 2025. If the Department of Education has questions regarding this plan, please call Dr. Daisy Halvorson at 641-585-8496 or Duane Polsdofer at 641-585-8121.

Finding No. 2024-001 Corrective Action Plan: The University concurs with this finding. The Financial Aid Office has updated procedures and ensures all student files have a thorough examination of all documents prior to document retention review. All MPNs and Perkins-related documents are now identified in this review and subsequently stored separately in secure fireproof storage. The files relating to this finding were not appropriately retained and the current procedure would have identified these for continued records retention. Responsible Official: Dane Fuhrman, CFO Anticipated Completion Date: June 2025

We are in the process of revising our disbursement process to ensure that all Title IV aid disbursements are held until the corresponding aid offer notification has been sent. This will eliminate any timing gaps between the notification process and disbursements. With the financial aid office now near full staffing, we have reinforced training for staff to emphasize the importance of adhering to the revised disbursement timeline. This training includes guidance on managing exceptions and prioritizing compliance in the aid process. While we currently lack the capacity to send aid notifications daily, we are conducting a review of our automated processes to explore solutions for increasing the frequency of aid offer notifications. This may include evaluating potential system enhancements or resource reallocation to support more frequent notifications. We have implemented additional internal monitoring procedures to regularly review the timing of aid offer notifications and disbursements. Any rejected records will be resolved and resubmitted with the same timeframe. This will ensure ongoing compliance and allow for prompt identification and resolution of any discrepancies. The University is committed to maintaining compliance with all federal regulations and ensuring transparency in our financial aid processes. By implementing these corrective actions, we are confident that the risk of future noncompliance has been minimized. Alex DeLonis, Assistant Vice President for Student Financial Services, is responsible for addressing the above item by May 2025.

To address the conditions identified, we are taking immediate and proactive steps to strengthen our internal controls and processes. These include enhancing staffing capacity, providing additional training, and implementing more robust checks and balances to ensure all verification information is accurately and completely submitted to the CPS. The University has opened multiple positions within the department to enhance efficiency.  All current staff will be trained on a continuous basis to ensure knowledge of compliance. We have also engaged an outside consultant to conduct a comprehensive compliance review, ensuring alignment with federal requirements and best practices. Additionally, we are increasing funding for professional development to equip our staff with the skills and knowledge necessary to maintain compliance and ensure the integrity of our processes. Regarding timely submission to CPS, we affirm that all affected students' eligibility was accurately determined, and no Title IV funds were disbursed to ineligible students. We remain committed to maintaining the integrity of the Title IV programs and will take the necessary steps to prevent future occurrences.  Alex DeLonis, Assistant Vice President for Student Financial Services, is responsible for addressing the above item by May 2025.

To address these findings, the University is committed to increasing staffing levels and enhancing training programs to reduce the likelihood of human input errors and ensure the timely resolution of system updates. The University has already hired multiple positions and had various training courses in order to enhance knowledge of compliance. Additionally, we are actively reviewing and revising our internal control procedures, including:  Strengthening review processes to verify the accuracy of enrollment data reported to the NSLDS.  Working with University staff to enhance the functionality of Tableau reports to avoid filtering issues and improve the identification of withdrawn students requiring reporting.  We recognize the importance of accurate and timely reporting to the NSLDS to maintain compliance with program requirements and support the USDE's ability to monitor enrollment status. These corrective actions will help us address the root causes of the issues identified and prevent recurrence in the future.  Alex DeLonis, Assistant Vice President for Student Financial Services, is responsible for addressing the above item by May 2025.

First, we believe the inaccuracies identified in the academic end date and student year reporting were isolated errors, which have not been a historical issue for the University. Second, the delays in reporting Pell and Federal Direct Loan disbursements to the COD were due to capacity challenges, including staffing shortages that impacted our ability to resolve rejected submissions within the required timeframe.  To address these issues, we are taking proactive steps to strengthen our processes and ensure future compliance. These include efforts to fully staff our team, engaging an outside consulting firm to conduct a compliance and best practices review, and increasing funding for professional development to enhance staff expertise and efficiency.  Additionally, the University is working with external consultants to enhance financial aid processing systems. This will gain efficiencies to ensure data is reported within the required timeframes. We remain confident in the overall accuracy and integrity of our processes and are committed to implementing improvements to ensure timely and accurate reporting to the COD moving forward.  Alex DeLonis, Assistant Vice President for Student Financial Services, is responsible for addressing the above item by May 2025.

Finding number: 2024-002 Corrective Action Plan: An internal review of our process for reporting Pell payments to Common Origination & Disbursement (COD) reveals that the vast majority of Pell payments are reported within 2 business of disbursement. The Pell payment in question was disbursed two weeks after our scheduled fall disbursement and reported to COD 12 and 13 days late. The disbursement occurred once the student completed all outstanding financial aid requirements. The procedures for reporting all Title IV payments and disbursements to COD has been reviewed with the staff members responsible for transmitting origination and disbursement records to COD. Procedures have been developed to more readily identify financial aid disbursements that take place outside of the established disbursement date for the term. This corrective action plan was put into place in February 2024. Finding 2024-02 occurred prior to the action plan’s implementation. Timeline for Implementation of Corrective Action Plan: February 2024 Contact Person Mark Boudreau, Comptroller

Finding number: 2024-001 Corrective Action Plan: To ensure that the college is using the same effective date for (unofficial) withdrawal on both the R2T4 calculations and for reporting unofficial withdrawal enrollment changes to NSLDS, the financial aid office will forward the list of students who are determined to have unofficially withdrawn and their associated date of unofficial withdrawal to the registrar's office at the end of each term. The registrar's office will then adjust all students' records in their SIS (Banner) as needed prior to submitting their report to NSC/NSLDS. This corrective action plan was finalized in June 2024. Finding 2024-01 occurred prior to the action plan’s implementation. Timeline for Implementation of Corrective Action Plan: June 2024 Contact Person Mark Boudreau, Comptroller

Responsible Contact Person(s): Sherika Charity, Director of Financial Aid Linsha Xie, Controller Corrective Action Planned: Step 1: The Financial Aid Office and Controller's Office will jointly review the current reconciliation process for federal assistance programs. This will include identifying all steps involved in the reconciliation process, documenting the roles and responsibilities of each office, and pin pointing areas where communication breakdowns have occurred in the past. Step 2: Based on the review, the offices will enhance the reconciliation procedures to address identified weaknesses. This will include developing standardized templates for reconciliations, establishing clear timelines for each step of the process, defining specific procedures for investigating and resolving reconciling differences, and implementing a system of checks and balances to ensure accuracy. Step 3: Formalize communication protocols between the Financial Aid Office and the Controller's Office to facilitate timely and effective information sharing related to federal assistance programs. This will include designated points of contact in each office, regular meetings and reminders for discussing reconciliation issues, and a shared folder for archiving reconciliation working paper and supporting documents. Estimated Completion Date: 6/30/2025

Responsible Contact Person(s): Carla L. Dailey, Director of Financial Aid Corrective Action Planned: NSU Financial Aid Office will ensure that the Direct Loan Notification Process will be sent out timely to all students with Direct Loan disbursements. Additional personnel have been named back-up to ensure notifications are submitted timely. The Student Accounts Office will notify the NSU department via email when disbursement of aid occurs. Calendar notifications can be created to ensure notifications are sent out timely. Estimated Completion Date: 8/31/2025

GMU Responsible Contact Person(s): Alethia Shipman, Director, Student Financial Aid Corrective Action Planned: George Mason will implement the following plan of action: - Management will enhance its communications relating to enrollment reporting in the Registrar and Financial Aid Offices. - Implement corrective actions to ensure that the University reports accurate and timely student enrollment status changes to the National Student Loan Data System. - Management will consider implementing a quality control review process to monitor the accuracy of campus and program-level batch submissions, such as implementing regularly scheduled self-audits of NSC data. Estimated Completion Date: 12/31/2025 NSU Responsible Contact Person(s): Carla L. Dailey, Director of Financial Aid Corrective Action Planned: The University has developed detailed procedures to improve reporting to NSLDS. These procedures include reviewing and updating Colleague system processing, designating staff members in both the Registrar and Financial Aid Offices to process, review and resolve reporting issues, and continued monitoring and verification of reports transmitted to NSLDS from the National Student Clearinghouse. Estimated Completion Date: 8/31/2025 NVCC Responsible Contact Person(s): Angelique Robinson, College Registrar Zina Jemison, Associate College Registrar Corrective Action Planned: Step 1: College Registrar (CR) and Associate College Registrar (ACR) will review National Student Loan Data System trainings, documentation, and initiate training sessions with appropriate NSLDS staff to answer any outstanding questions about the system. Step 2: CR and ACR will review important NSLDS deadlines and incorporate lessons learned from the trainings to set the tone for internal deadline processing changes so that the semi-automated graduation process can be performed in a faster manner. The CR and ACR will also determine which additional team members within the College Records Office will assist in the completion of record updating and reporting requirements within NSLDS, outlining the specific tasks that will need to be done by each participating member and the information system queries that will be used for internal auditing purposes. Step 3: CR and ACR will consult with Financial Aid staff to finalize new internal record adjustment processing deadlines to ensure that the changes in procedures are made in a timely manner and in support of Financial Aid processes. Estimated Completion Date: 6/30/2025 ODU Responsible Contact Person(s): Carrie John, University Registrar Corrective Action Planned: The University is taking corrective action to ensure accurate and timely reporting of student enrollment changes to NSLDS. Corrective actions include enhancing procedures, providing additional training, and improving internal reviews. Estimated Completion Date: 6/30/2026 RU Responsible Contact Person(s): Katie Piper, Registrar Corrective Action Planned: The Registrar's Office has met and completed initial planning and timelines to address procedural changes needed to report the loan data timely. Estimated Completion Date: 12/31/2025 UVA Responsible Contact Person(s): Steve Kimata, Associate Vice President for Enrollment and University Registrar Corrective Action Planned: The University will implement additional controls to ensure the accuracy and timeliness of enrollment data reported to NSLDS. This includes working collaboratively with Student Financial Services and Information Technology Services to monitor and report late withdrawals, review and update the information system process for creating enrollment files, and implement a quality control review to check student status change batches for accuracy and timeliness. Estimated Completion Date: 6/30/2025 VSU Responsible Contact Person(s): Nedra Jones, University Registrar Corrective Action Planned: 1) VSU has implemented an automated alert system to notify staff of upcoming reporting deadlines, cross-referenced information system data with the SCHEV Degree Inventory Report, and are actively collaborating with SCHEV to resolve discrepancies. These items are complete. 2) Additionally, VSU is in the process of implementing the following additional corrective actions: A.) A comprehensive review of current enrollment reporting processes; B.) Closer collaboration with VSU third-party service provider to streamline and improve the enrollment reporting; C.) Designating an individual within the Registrar's Office to oversee National Student Clearinghouse (NSC) and NSLDS reporting duties; and D.) establishing a quality control process to include monthly random sample audits of enrollment data. Additionally, VSU will reconcile student addresses between the information system and NSLDS for Federal Direct Loan borrowers. Estimated Completion Date: 12/31/2025

Responsible Contact Person(s): Sherika Charity, Director of Financial Aid Corrective Action Planned: Step 1: Review and update the FISAP Completion Documentation to clearly identify sources of data. This will include notating the specific data points for reporting enrollment and total tuition and fees from VCCS provided reports and reviewing the FISAP for accuracy before submitting. Estimated Completion Date: 8/30/2025

NSU Responsible Contact Person(s): Sandra Riggs, University Bursar Corrective Action Planned: To prevent delays in the processing of student refunds the University will review the refund process and ensure procedures are distributed to departments that are a part of the refund process. Student Accounts will work with the Financial Aid Office and Housing Office to ensure timely disbursement once all charges have been posted to a student's account. Estimated Completion Date: 6/30/2025 ODU Responsible Contact Person(s): Stephanie Jennelle, Associate Vice President for Budget and Financial Planning Corrective Action Planned: The University is taking corrective action to ensure credit balances are disbursed within the regulatory time frame. Corrective actions include training and cross training Bursar personnel, performing weekly audits to ensure credit balances are processed within the required timeframe, and increasing collaboration between the Bursar’s office and Financial Aid to ensure Title IV funds are released timely. Estimated Completion Date: 12/31/2025

Responsible Contact Person(s): Brad Barnett, Director, University Scholarships and Financial Aid Corrective Action Planned: Implement a "direct loan posting date audit report procedure," which outlines how posting dates in the management application are compared to posting dates in the system. Also add a checklist item to the monthly reconciliation to confirm the new procedure is being followed. Estimated Completion Date: 4/1/2025

NVCC Responsible Contact Person(s): Sherika Charity, Director of Financial Aid Corrective Action Planned: Step 1: Additional training was provided to all relevant financial aid staff focusing on the accurate and timely calculation and return of unearned Title IV funds. This training emphasized the importance of adhering to regulatory guidelines and utilizing the institution's Information System-generated Return to Title IV (R2T4) report. Step 2: Quality control process has been implemented. The Associate Director or Director of Financial Aid will conduct a thorough review and quality control check of all R2T4 calculations prior to the return of funds. Estimated Completion Date: 6/30/2025 ODU Responsible Contact Person(s): Stephanie Jennelle, Associate Vice President for Budget and Financial Planning Corrective Action Planned: The University is taking corrective action to ensure unclaimed aid is promptly returned. Corrective action includes enhancing procedures for processing unclaimed checks containing Title IV funds. These enhancements include modifying the timing and frequency of outreach and follow up due diligence to students to ensure unclaimed Title IV funds are returned timely. Estimated Completion Date: 12/31/2025 RU Responsible Contact Person(s): Allison Pratt, Director of Financial Aid Corrective Action Planned: The accounting, financial aid, and internal audit departments have met to plan corrective actions. As procedure updates were occurring through the fiscal year that was audited, Internal audit initially chose additional sampling periods to test. Procedures are being reviewed and will continue to be updated in accordance with the finding results and Internal Audits' findings. Estimated Completion Date: 6/30/2025

GMU Responsible Contact Person(s): Alethia Shipman, Director, Student Financial Aid Corrective Action Planned: To ensure guidelines are followed, a comprehensive plan of action will be implemented. This plan includes establishing a formal training structure with annual reviews of key procedures, revision of in-person inquiries, and an internal quality assurance review that will be conducted on a monthly basis. Estimated Completion Date: 12/31/2025 NSU Responsible Contact Person(s): Carla L. Dailey, Director of Financial Aid Corrective Action Planned: NSU Financial Aid Office has taken steps to review all verification updates made to students who have been selected for verification. Once a student has been verified, tracking of that student’s correction will be made. A review of changes made will be conducted to ensure that all changes have been entered correctly into the system and that the correction has been imported correctly prior to releasing the tracking hold onto the account. Also, a sample of students will be randomly selected monthly to ensure students who have been selected for verification or who have an ISIR comment code that needs resolution are reviewed for accuracy. Estimated Completion Date: 8/31/2025 ODU Responsible Contact Person(s): Vera Riddick, Director of Financial Aid Corrective Action Planned: The University is taking corrective action to ensure continued efficiency, accuracy, and adherence to federal regulations. Corrective actions include providing intensive training for new Financial Aid verification team members and annual training for all Financial Aid team members, implementing quality assurance reports, and increasing reviews throughout the verification cycle. The University is also exploring other tools to assist with the verification process. The three test cases identified during the audit have been reviewed and federal funds have been returned as warranted. Estimated Completion Date: 12/31/2025 VPISU/ID Responsible Contact Person(s): Nicci Ratcliff, Associate Director for Processing Operations Corrective Action Planned: VPISU/ID updated the system tracking group logic to ensure verification is requested timely and reviewed all 2023-24 verification files ensuring required documents were on file. The University will include a weekly random sample of files flagged for verification and confirm that documentation is complete prior to disbursement. The University will provide additional annual training and a documentation requirements checklist to improve Specialist completion of the verification process and ensure consistent handling and retention of all required documents. Estimated Completion Date: 7/31/2025

NSU Responsible Contact Person(s): Carla L. Dailey, Director of Financial Aid Corrective Action Planned: NSU Financial Aid Office will ensure that the unearned funds for students will be sent to COD timely. NSU will ensure that all files are submitted timely so that this will not be a future issue. A reinforcement of procedures for exporting disbursements and staff training will be maintained as well as ensuring that a back-up staff member is in place. Estimated Completion Date: 8/31/2025 NVCC Responsible Contact Person(s): Sherika Charity, Director of Financial Aid Linsha Xie, Controller Corrective Action Planned: Step 1: Establish clear and documented communication protocols between the Financial Aid Office and the Controller's Office regarding student withdrawals and the return of unearned Title IV funds. This will include designated points of contact in each office, a standardized process for the Financial Aid Office to notify the Controller's Office of requiring a return of Title IV funds, confirming the return by the Controller’s Office, and regular meetings between the two offices to review procedures and address any issues. Step 2: Develop a written policy and procedure. This will include step-by-step instructions for processing the return of funds, including required documentation and timelines, Clear delineation of responsibilities between the Financial Aid Office and the Controller's Office, and contingency plans for staff turnover or absences. Step 3: Conduct periodic reviews and reconciliation of returned Title IV funds to ensure accuracy and timeliness. This will include reconciling returned funds with ED records and identifying any discrepancies or delays in the return of unearned funds. Estimated Completion Date: 6/30/2025 ODU Responsible Contact Person(s): Vera Riddick, Director of Financial Aid Corrective Action Planned: The University is taking corrective action to improve processes to ensure data accuracy and compliance with reporting requirements. Corrective actions include utilizing system functionality and enhancing Office of Student Financial Aid procedures. Differences totaling $325 that were identified during the audit have been returned to the Department of Education. Estimated Completion Date: 12/31/2025

NSU Responsible Contact Person(s): Carla L. Dailey, Director of Financial Aid Corrective Action Planned: NSU Financial Aid Office has created a Certification Form of Countable Days in a Semester that is required to be signed off by the Director of Financial Aid, Associate Director of Financial Aid (Return of TIV Coordinator) and the University Registrar prior to the start of each semester. This process will be included in the annual financial aid set up process. Estimated Completion Date: 8/31/2025 NVCC Responsible Contact Person(s): Sherika Charity, Director of Financial Aid Corrective Action Planned: Step 1: Ensure proper setup of academic and holiday calendars in the information system. This will include the Director of Financial Aid working closely with the Policy Planning Specialist to ensure the academic calendar and holiday calendars are set up properly in the information system to account for all breaks. Step 2: Improved communications during calendar and information system setups. This will include regular scheduled meetings between the Policy Planning Specialist, Associate Director of Financial Aid Information Systems, and the Director of Financial Aid to review the academic and holiday calendar setups in the information system. Make any appropriate updates to the academic calendar and financial aid setups in the information system. Step 3: Run VCCS Custom R2T4 Report and perform R2T4 calculations/adjustments based on the R2T4 policies and procedures. Estimated Completion Date: 6/30/2025

GMU Responsible Contact Person(s): Alethia Shipman, Director, Student Financial Aid Corrective Action Planned: To enhance and ensure the accuracy and timeliness of Return to Title IV (R2T4) calculations and processes, the Office of Student Financial Aid will implement several corrective actions. These include increasing personnel to ensure R2T4 calculations are completed promptly, collaborating closely with the Associate Director of Funds Management to ensure funds are returned in a timely manner, coordinating with the Office of the University Registrar to ensure student withdrawals are coded accurately and promptly, and making necessary adjustments to the schedule and review process for reports to ensure compliance. Estimated Completion Date: 12/31/2025 NSU Responsible Contact Person(s): Carla L. Dailey, Director of Financial Aid Corrective Action Planned: NSU Registrar’s Office has documented procedures for running report(s) to identify all students who withdraw within a specific timeframe. A schedule will be created to ensure that the report is run accurately and timely. This will allow timely processing and submission of data by the Financial Aid Office. The Financial Aid Office will utilize the schedule created by the Registrar to ensure that the list of withdrawn students is completed timely. Estimated Completion Date: 8/31/2025 NVCC Responsible Contact Person(s): Sherika Charity, Director of Financial Aid Lisa Boyko, Associate Director of Financial Aid Corrective Action Planned: Step 1: The Associate of Financial Aid, R2T4, will provide additional training to staff member(s) responsible for performing R2T4 calculations and returns. This will include training on R2T4 guidelines, information system generated reports, and review of the college R2T4 policies and procedures. Step 2: Use VCCS Custom R2T4 Report to identify students who are subject to Title IV adjustments/returns. This will include the staff member responsible for R2T4s will use the VCCS Custom R2T4 to perform appropriate calculations and returns for all student identified. Step 3: The Director/Associate Director of Financial Aid, R2T4, will administer quality control of R2T4s. This will include reviewing the R2T4 report to identify outstanding R2T4s. Periodically running information system generated reverse R2T4 report to identify any R2T4s that were not processed. If any R2T4s are identified as unprocessed, the staff member responsible for R2T4s will promptly perform the R2T4 as outlined in the policies and procedures. Estimated Completion Date: 6/30/2025

Compliance Requirement Finding: Special Test and Provisions – Enrollment Reporting The University had not reported changes of the sampled graduated or withdrawn students to the National Student Loan Data System (“NSLDS”) as required under the Uniform Grant Guidance for the year ended June 30, 2024, accurately or timely. Student Financial Aid Cluster, Assistance Listing # 84.007, 84.033, 84.038, 84.063, 84.268 Corrective Action Plan The finding was due to a lack of a process to correctly backdate administrative withdrawals when a student receives a "W" grade after the withdrawal deadline. This inconsistency led to inaccurate reporting to the National Student Loan Data System (NSLDS) and the academic file. To address this, management has collaborated with the Offices of Campus Technology, Student Financial Services, and the Registrar and has developed and implemented better procedures for handling administrative withdrawals. These procedures will ensure: • Consistent reporting of withdrawal dates to NSLDS. • Ensuring that withdrawal dates are recorded uniformly in both the Registrar’s office and Student Financial Services. • Accurate assignment of "W" grades according to the academic calendar. These new procedures were implemented in the beginning of 2024. The Registrar’s office will continue to submit regular enrollment reports to NSLDS, promptly reporting any changes to student enrollment as required. The Office of the Registrar will be responsible for implementing the corrective action plan, under the supervision of the University Registrar and Director of Institutional Research and Effectiveness. Shannon Bishop Shannon.bishop@converse.edu University Registrar

The corrective action plan for the internal controls over expenses paid (2024-001), is summarized as follows: Corrective Action Planned: The Center will review and update its procedures to ensure the proper payment of allowable expenses. Anticipated Completion Date: December 31, 2024. Responsible: Management and Board of Directors.

The College will examine the document destruction date on student related files related to federal compliance requirements to ensure accuracy of the document destruction date and accuracy of student files. Additionally, the College will closeout the Federal Perkins Loan Program in fiscal year 2025.

Auditor Description of Condition and Effect. During our review of the Fiscal Operations Report and Application to Participate (FISAP), we noted there were errors in the amounts reported. As a result, the College's FISAP was prepared incorrectly and had to be resubmitted to the Department of Federal Student Aid. Auditor Recommendation. We recommend that the College implement a secondary review process over the preparation and reporting of the FISAP to ensure proper and accurate reporting. Corrective Action. The College has performed the necessary steps to correct the error and will amend the reporting process to ensure that a second individual is reviewing the work performed. Responsible Person. Maryann DeCaire, Director of Financial Aid. Anticipated Completion Date. April 30, 2025.

Auditor Description of Condition and Effect. This condition was caused by a lack of detailed review of the Return to Title IV calculation and days used in the Spring 2024 semester. As a result, four students' Return to Title IV calculations were performed using incorrect start dates for the 2024 Spring semester resulting in an understatement in $84 of Pell awards to the students. The College corrected this issue with the Department of Education on July 30, 2024. Auditor Recommendation. We recommend that the College implement a review process to ensure the number of days used in the Return to Title IV calculation is accurate and that the Return to Title IV calculation is being reviewed by a second individual. Corrective Action. The College has performed the necessary steps to correct the error and will develop a process to ensure that a second individual is reviewing the work performed. Responsible Person. Maryann DeCaire, Director of Financial Aid. Anticipated Completion Date. April 30, 2025.