Corrective Action Plans

The University experienced significant staffing turnover in the financial aid department during the 2023-2024 aid year, resulting in certain established processes to go unfollowed. In June 2024, the University hired a full-time outsourced staffing solution, which has added headcount and stabilized the department staffing. The Director has established clear roles and responsibilities so that established processes are not missed going forward. Additionally, job duties have been reallocated to ensure calculations on official and unofficial withdrawals and exit counseling communications are done monthly going forward.

The University experienced significant staffing turnover in the financial aid department during the 2023-2024 aid year, resulting in certain established processes to go unfollowed. In June 2024, the University hired a full-time outsourced staffing solution, which has added headcount and stabilized the department staffing. The Director has established clear roles and responsibilities so that established processes are not missed going forward. Additionally, job duties have been reallocated to ensure calculations on official and unofficial withdrawals and exit counseling communications are done monthly going forward.

This Repeat Finding has been acknowledged. Union has taken several steps towards making the required changes to ensure compliance with our enrollment reporting responsibilities. This includes implementing process improvements related to our National Clearing House (NSC) submissions and reviewing our academic policies related to academic leaves of absence and withdrawals. Timeliness of Enrollment Reporting Rosters: As of January 2024, Union completed the set-up and configuration of our enrollment reporting services with NSC as our third-party service provider. The new process is administered by the school Registrar, with back-up responsibilities handled by the Assistant Dean, Director of Financial Aid, and the Vice President of Admissions and Financial Aid. Since implementing the new system, Union has submitted our Enrollment Reporting Roster on a regular and timely basis. Under NSC, our submissions have occurred at least once per month and within the 15-day reporting requirement. As a result, we do not anticipate late reporting of Enrollment Reporting Rosters for FY25 or future periods.. Accuracy of Enrollment Status Changes: In order to further improve the timeliness and accuracy of our enrollment report submissions, we plan to make the following changes to our process with NSC. First, we will schedule additional submissions of our Enrollment Roster at key points during the academic year: (1) prior to the start of each semester, (2) immediately after the end of the drop-add period, and (3) during our non-required summer term. Second, we will work with NSC on our system configuration and error correction process, to ensure that enrollment status is accurately reported and that all status errors are resolved correctly and in a timely manner. Enrollment Roster transmissions will continue to take place according to a preset schedule. This process includes email communication from NSC the week prior to an enrollment submission, confirmation of a successful submission, and notification of potential errors. Union’s Registrar, who has 17 years of experience, is also working directly with NSLDS to address errors found in past submissions and working with internal stakeholders in the Academic Office, Financial Aid Office, Bursar’s Office, and IT Department to ensure that all student records accurately and correctly configured.

The College, upon identification of this issue, recalculated the Pell Grant awards and disbursed the eligible amounts to the 4 students. The College also conducted an internal review of students whose payment period was 3 trimesters based on expected enrollment and identified two additional students who only attended the first 2 of the three trimesters; the College recalculated and disbursed the eligible amounts to these two students. Additionally, the College immediately reviewed its procedures and made necessary changes.

Finding 2024-002 Condition The change in student status for 12 of the 25 students tested was not reported to the National Student Loan Data Systems (NSLDS) within 30 days or included in a response to a roster file within 60 days. However, these students were ultimately reported to the NSLDS. Corrective Action Plan The Registrar’s Office remains committed to adhering to the College’s established reporting cadence. To ensure compliance with federal requirements, the College submits enrollment data to the National Student Clearinghouse at least every 30 days, maintaining timely and accurate reporting to the National Student Loan Data System. Name(s) of Contact Person(s) Responsible for Corrective Action: Michael Armato, Registrar James Palmer, Director of Institutional Research Anticipated Completion Date: FY2025

The College, upon identification of this issue, immediately reviewed its procedures and made the necessary changes.

Finding: Special Tests and Provisions – Enrollment Reporting Student Financial Assistance Cluster, Assistance Listing Number 84.268 Federal Direct Student Loans, Assistance Listing Number 84.063 Federal Pell Grant Program U.S. Department of Education Program Year 2023–2024 Type of Finding: Other Instance of Noncompliance and Deficiency Corrective Action: The failure to report certain enrollment status changes to the NSLDS on a timely basis during the fiscal year ending May 31, 2024, was an isolated instance due to turnover in the Registrar’s Office. The University has updated the process for reporting enrollment status changes to the NSLDS and has ensured there is adequate cross-training in the Registrar’s Office to prevent future instances of non-compliance with reporting deadlines. Status: Completed Person Responsible for Implementing: Melissa Delgado, Registrar Implementation Date: 01/01/2025

Management Response: Holy Family University is dedicated to ensuring the accuracy of our reporting to the NSLDS. The following is how we plan to verify the integrity of our reports. The Registrar's Office will compare the list of students pulled in the monthly NSC process to a report showing all students who withdrew that month. This will ensure that we are reporting all withdrawn/graduated students in a timely manner. In addition, the Registrar's Office will verify the potential graduation of students whose grades are changed after the end of the term. If the new grade completes their degree, the student will be reported as "graduated" when we process the next session's graduation applications. This will eliminate the reliance on an external database, as manual updates tend to lack consistency. Lastly, prior to submitting the Graduates Only file to the NSLDS, the Registrar will compare the entire list of graduates to the report showing all students who withdrew throughout the semester. This will be a double check since we will also be checking grade changes, as mentioned above.

Notifications of Disbursements Recommendation: We recommend the College review and strengthen its procedures for notifying students of their Direct Loan disbursements within the required time frame and that documentation of the letters sent is maintained. Explanation of disagreement with audit finding: The Financial Aid Office already has set procedures pertaining to the sending of mass communications to our students whenever Direct Loan disburses. There was an oversight only for the term of Fall 2023 where MCAD failed to launch the communication in a timely manner to disbursement receiving students. Action taken in response to finding: ● The Financial Aid Operations Calendar - will include updated entries concerning the generation of communication for Disbursement Notification. ● Process Update - the sending of the communication will be incorporated into the mass disbursement process at the end of Add/Drop periods during the Fall and Spring terms. Name(s) of the contact person(s) responsible for corrective action: Sherman Lee, Financial Aid Director Planned completion date for corrective action plan: Mar 1, 2025

Perkins Reconciliation Recommendation: It is recommended that the College review procedures in place to ensure accurate reporting of Perkins loan information to comply with Title IV regulations. Explanation of disagreement with audit finding: MCAD had undergone numerous staff transitions within The Business Office. Its previous Perkins Loan Servicer, University Accounting Service (UAS), was derelict in its duty to fulfill the terms of the contract by failing to perform in managing all areas of MCAD’s Perkins Loan portfolio. UAS failed to keep current as well as accurate accounting and funds management records throughout its tenure as the servicer. Action taken in response to finding: ● Changing of Servicer: MCAD has removed UAS and completed the changeover to Heartland Educational Computer Systems Incorporated (ECSI) as its new Perkins servicer. ● Business Office (Student Accounts Manager) will provide close oversight to ensure accountability that ECSI will fulfill its duties and responsibilities as Perkins Loan Servicer ● The Financial Aid Office will partner with the Business Office as another layer of accountability and support to the Business Office as it supervises ECSI. ● Third-Party Assistance: The institution has engaged with CLA to assist with the reconciliation of the Perkins Loan accounts. It is expected that the work CLA has done to assist will come to full fruition and be fully reconciled sometime in 2025. Name(s) of the contact person(s) responsible for corrective action: Mary Alma Noonan, CFO, Brian Braden, Controller and Sherman Lee, Financial Aid Director Planned completion date for corrective action plan: June 30, 2025

Documentation of Review Recommendation: We recommend the College reevaluate its procedures and review policies surrounding controls implemented for Title IV Aid. Explanation of disagreement with audit finding: MCAD Financial Aid already has sound procedures in place that outlines the process for our internal review and audit processes in all areas (ex. Awarding, Reconciliation, and R2T4). Action taken in response to finding: ● The Director of Financial Aid will ensure regular internal review audits will take place throughout the fiscal year. ● Review results will be documented for recordkeeping and to track whether processes and procedures are followed. ● The Financial Aid Operations Calendar will include dates of when internal reviews will take place over the different areas of the department ● The Business Office will be involved for all reconciliation related internal review processes as a third party reviewer to ensure the disbursed amounts on Powerfaids, COD, and G5 are synchronized. Name(s) of the contact person(s) responsible for corrective action: Sherman Lee, Financial Aid Director Planned completion date for corrective action plan: May 1, 2025

FINDING 2024-002 – Special Tests and Provisions – Enrollment Reporting: Material Weakness in Internal Control National University acknowledges the findings and the importance of accuracy and timeliness when completing enrollment reporting to NSLDS. The University has made significant efforts to improve all areas of the enrollment reporting process, and the results of this audit do not reflect those efforts and improvements due to the timing of the FY 23 audit completion in February 2024 and CAP completion in June 2024. The institution has identified two items that have resulted in challenges to accurate and timely enrollment reporting during the audit year. Intent to return: The University has identified a need to improve the understanding and implementation of its intent to return (ITR) process. As a result, the University will conduct a holistic review, including assessment and clarification of the current policy, identification and implementation of technological controls, comprehensive training for ITR, and the development and implementation of a monthly ITR review. National Student Clearing House (NSC) reporting: On October 18, 2024, the institution was notified by NSC that its access to process enrollment reporting on behalf of NU was revoked during July 2024, resulting in a reporting gap. The institution is investigating the root cause of this and submitted a ticket to the FPS/SAIG help desk, but no root cause was able to be identified. The issue was immediately resolved upon notification; however, the reporting gap had a significant impact on the FY 24 enrollment reporting sample. In addition to the above, the institution will continue or take the following steps: • Continued monthly testing of enrollment reporting accuracy to NSLDS conducted by the quality assurance team. • Identification and timely delivery of training for areas of opportunity identified in the monthly reviews to the registrar and data operations teams. • Revise the internal documentation process between quality assurance, data operations, and the registrar teams to ensure clarity of policy and regulatory guidance in areas of identified risk/confusion during enrollment reporting processing. Contact Person Responsible for Corrective Action: • Rob Conlon, AVP Financial Aid Compliance • Sarah Massey, AVP of Operations Student Support and Registrar Operations • Gabrielle Witruke, Associate Director Data Analytics • Melissa Diaz, AVP Operations Advising Anticipated Completion Date: March 2025

Management’s Corrective Action Plan National University acknowledges the findings and the recommendations regarding improving procedures. FINDING 2024-001 – Special Tests and Provisions – Return of Title IV: Material Weakness in Internal Control National University acknowledges the finding and importance of accurate identification and timely and accurate calculation of R2T4s. The University has made significant efforts to improve all areas of R2T4 processing, and the results of this audit show significant gains over the previous year. Given the timing of the FY 23 audit completion in February 2024 with CAP completion scheduled for June 2024, the benefits of the FY 23 corrective action plan have a limited impact on this audit period. This, coupled with the improved results the institution has seen in timeliness such as the late return error rate having decreased from 31% in FY 23 to 13% in the current audit, suggests that NU is pathing towards compliance with R2T4 requirements. Based on this assessment, NU will continue to take the following actions: • Continual assessment of staffing levels and hiring as needed to ensure timely identification and processing of R2T4s. Staffing ratios were established in FY24 and staffing increases were implemented to ensure accurate processing and timely completion. • Continual identification of risks with weekly testing and readouts from Quality Assurance to the financial aid processing team. • Re-training with the R2T4 processing team on the order of returns. • Identification and timely delivery of training for areas of risk identified in the weekly reviews. • Revise internal processes between the Quality Assurance and financial aid processing to better communicate policy and regulatory guidance in areas of identified risk/confusion during R2T4 processing. Contact Person Responsible for Corrective Action: • Rob Conlon, AVP Financial Aid Compliance • Alan Coddington, AVP Student Financial Services Anticipated Completion Date: January 2025

Recommendation: We recommend the District review its reporting procedures to ensure that enrollment and program information is accurately reported to NSLDS as required by regulations. Action taken in response to finding: The District has taken the following actions to address this recommendation: Assess Current Reporting Delays  Review the current submission schedule and identify specific time gaps between when Clearinghouse files are sent and when the data reaches NSLDS.  Work with the Clearinghouse to confirm file submission dates and compare them with NSLDS report uploads.  Document delays and establish a baseline for necessary improvements. Action 1.2: Communicate with NSLDS and Clearinghouse  Contact NSLDS and Clearinghouse support teams to communicate the delays and request any assistance or expedited processes.  Set clear expectations with these parties on how to resolve the reporting issue and prevent future delayed submissions. Establish Clear Reporting Timelines  Work with Clearinghouse to establish a clear, consistent timeline for file submission and confirm the timing of data submission to NSLDS.  Ensure reporting timelines align with NSLDS deadlines to ensure timely reporting.  Update internal policies and procedures to reflect the new reporting timeline and expectations. Staff Training and Awareness  Conduct training sessions for staff involved in the Clearinghouse file preparation and submission process, emphasizing the importance of timely submissions.  Provide regular updates and reminders about deadlines and processes. Automate or Enhance File Submission Process  Implement any necessary technology upgrades to streamline the data submission process.  Explore the possibility of setting up automatic file uploads directly to NSLDS to minimize delays. Implement Monitoring and Reporting System  Set up a monitoring system to track Clearinghouse file submissions to NSLDS, including confirmation that files have been successfully submitted and processed.  After implementing process changes, conduct monthly reviews to verify that student data is being submitted to NSLDS on time.  Track and report submission times Continuous Communication with NSLDS and Clearinghouse  Establish a point of contact at both NSLDS and the Clearinghouse to improve communication regarding file submission issues. Conduct regular reviews to ensure that the institutions’ reporting process aligns with NSLDS requirements. Name of the contact person responsible for corrective action: Dr. Kristina Martinez, Acting Dean of Enrollment Services Planned completion date for corrective action plan: June 30, 2025

Recommendation: We recommend the District review the R2T4 requirements and implement procedures to ensure award adjustments as determined by the R2T4 calculations are being properly adjusted to the student’s account and the correct amounts are being returned to the Department. Response to Recommendation: The District acknowledges the importance of adhering to R2T4 requirements and has taken the following actions to address this recommendation: The District adjusted the student samples as notated by auditors. Samples with discrepancies have been recalculated based on R2T4 requirements and correct amounts have been returned to the Department of Education. Verification of corrected R2T4 calculations was provided to auditors. Action taken in response to finding: 1. Consultant Engagement: o A NASFAA-certified consultant with extensive experience as a financial aid director has been hired to assist the R2T4 team during the 2024-2025 aid year. o The consultant will review all R2T4 calculations to ensure compliance and accuracy. Additionally, a secondary staff member is assisting in reviewing all 2024-2025 R2T4 calculations. 2. Training Initiatives o Provided department-wide training on R2T4 policies and procedures. o Delivered in-depth training sessions specifically tailored for the R2T4 team. o The R2T4 team has successfully completed NASFAA’s R2T4 course series to enhance their expertise. 3. Staffing Adjustments o An Accounting Technician under the direction of the District Business Manager will be assigned to Financial Aid to support R2T4 processing and reconciliation to ensure accuracy and compliance. o Additionally, this Accounting Technician will need to have view-only access to all data and reports available in the Student Financial Aid module contained in Colleague in o order to be effective in providing meaningful analysis and reconciliation of student-level detail to summary ledgers and reports contained in the Fiscal Services module of Colleague and other financial reporting tools. 4. Process Improvements o Instruct the R2T4 team to use the Department of Education’s R2T4 worksheet in the COD system instead of the R2T4 module in Colleague. o This change addresses the lack of automation and checks in the Colleague system, which has been a contributing factor to discrepancies. o Financial Aid has reached out and established rapport and protocols with academic and registrar offices to enhance understanding of academic engagement, registration processes, and data fields. o The department has updated the policy and procedures manual, including cheat sheets to clarify points of regulatory interpretation along with El Camino’s data fields to use. 5. System and Workflow Evaluation o Identified that the R2T4 module in Colleague lacks automation or checks and balances to flag manual input discrepancies. o Future plans include exploring system enhancements or alternatives to improve functionality and reduce reliance on manual calculations. o The District has begun evaluating ways to improve the R2T4 reports to help automate this process as much as possible. Name of the contact person responsible for corrective action: Chau Dao, Director of Financial Aid & Basic Needs Planned completion date for corrective action plan: Implementation Timeline:  Consultant Review: Begin immediately, with ongoing review throughout the 2024-2025 aid year; retain consultant services for 2025-2026 aid year.  Training: Complete with Spring 2025 R2T4 calculation, with periodic refresher sessions scheduled on an annual basis.  Staffing Request: The Accounting Technician position will be assigned no later than July 1, 2025. This position shall be filled by existing accounting staff or, if needed, a new employee.  Process Transition: Full transition to the COD system worksheet for R2T4 calculations with the Fall 2024 term R2T4 calculation.  System Evaluation: Initiate and maintain ongoing discussions with IT and software providers, leveraging opportunities from conferences, networking events, and training sessions to explore and implement improvements. Monitoring and Evaluation:  Conduct monthly audits of R2T4 calculations to identify and address errors promptly.  Maintain ongoing collaboration with the consultant to refine processes and implement best practices.  Evaluate the effectiveness of new training and staffing adjustments after six months and report findings.

2024‐002: Special Tests and Provisions – NSLDS Enrollment Reporting Student Financial Aid Cluster – Assistance Listing No. 84.063, 84.268 Condition: During testing of the enrollment status reporting, we noted that the incorrect enrollment status and effective date was included in NSLDS. Recommendation: The institution should evaluate their procedures and policies related to reporting status changes and effective dates to NSLDS and enhance as deemed necessary to ensure that accurate information is reported to NSLDS. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Howard Community College will work with Records, Registration and Veterans Affairs (RRVA) to conduct a thorough review of the current policies and procedures for reporting student enrollment status changes and effective dates to NSLDS and then subsequently implement process improvements to ensure that our process aligns with federal regulations. Name(s)  of  the  contact  person(s)  responsible  for  corrective  action:  Jessica  Peterson,  Registrar Planned completion date for corrective action plan: June 30, 2026

2024 – 005: Population for Return of Title IV Funds Student Financial Aid Cluster – Assistance Listing No. 84.063, 84.268, 84.007, 84.033 Condition: The College was unable to provide the required population for the students that withdrew during the fiscal year in a timely manner. Recommendation: It is recommended that the College strengthens its internal controls and improves coordination among departments to ensure timely submission of required data for the Return of Funds. This may include implementing a more robust tracking system, providing additional training to staff, and establishing clear deadlines and responsibilities for data submission. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Financial Aid Services will work with the Administration Information Systems department along with other stakeholders to strengthen its internal controls and improve communication. Additionally, Howard Community College will work with AIS to develop and implement a more robust system to track and review the data required to complete the Return of Funds process. Name(s) of the contact person(s) responsible for corrective action: Detra Hooper, Financial Aid Services Planned completion date for corrective action plan: June 30, 2026 If the U.S. Department of Education has questions regarding this plan, please call Detra Hooper, Financial Aid Services Director at 443‐518‐4776.

2024 – 004: Fiscal Operations Report and Application to Participate (FISAP) Reporting Student Financial Aid Cluster – Assistance Listing No. 84.063, 84.268, 84.007, 84.033 Condition: The documents retained by the University to support amounts included in the FISAP did not agree to the FISAP. Recommendation: It is recommended that the College strengthens its internal controls and verification  processes  to  ensure  the  accuracy  of  data  reported  in  the  FISAP.  This  may  include creating a formalized review process for the FISAP and ensuring all supporting schedules used to populate the form are centrally stored. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Financial Aid Services has created a formalized review process for FISAP and created a central location to store data. This review process includes multiple staff members and internal controls for future review. Name(s) of the contact person(s) responsible for corrective action: Detra Hooper, Financial Aid Services Director Planned completion date for corrective action plan: June 30, 2025

2024‐003: Special Tests and Provisions – Gramm‐Leach‐Bliley Act Student Financial Aid Cluster – Assistance Listing No. 84.063, 84.268, 84.007, 84.033 Condition: Certain elements of the College’s information security program were not maintained in written form. 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:  Howard  Community  College  will  work  with  the  Administrative Information Systems (AIS) department to conduct a thorough review of the written information security program to ensure the necessary elements are included and meeting the minimum requirements as outlined in 16 CFR 314.4. Name(s) of the contact person(s) responsible for corrective action: Tyria Stone, Executive Vice President, Finance & Administration

Management agrees with the finding and recommendation. The University will implement a process that ensures notification from the Registrar when a student drops from any course or from the University. A review of R2T4 will be completed at that time if deemed necessary. The process will be reviewed annually by the University to ensure compliance.

Condition: Of the 40 students selected for Return of Title IV (R2T4) testing, 1 student did not have the appropriate amount returned to the federal agency. Planned Corrective Action: To prevent human error from occurring in the future, the Office of Financial Aid has immediately implemented the following process: When a recipient of Title IV grant or loan assistance withdraws from Eastern Michigan University and a Return of Title IV calculation is performed, a Senior Financial Aid Advisor or member of the Financial Aid Management staff will review all required returns completed to ensure accuracy. This review will occur on a weekly basis. Contact person responsible for corrective action: Jennifer Tremewan, Asst. Director Office of Financial Aid Anticipated Completion Date: December 31, 2024

Condition: Of the 40 students selected for enrollment reporting testing, 5 students did not have their status updated appropriately. Planned Corrective Action: The Office of Financial Aid has implemented a process to communicate and confirm with the office responsible for enrollment reporting to verify that enrollment rosters will not be/have not been sent after a semester has officially ended. Contact person responsible for corrective action: Jennifer Tremewan, Asst. Director Office of Financial Aid Anticipated Completion Date: December 31, 2024

Finding Summary: When a recipient of a Title IV grant or loan assistance withdraws from an institution during a payment period or period of enrollment in which the recipient began attendance, the institution must determine the amount of Title IV grant or loan assistance the student earned as of the student’s withdrawal date and must return the amount of Title IV funds for which it was responsible as soon as possible but no later than 45 days after the date of the institution’s determination that the student withdrew (34 CFR 668.22(j)(1)). Annual Single Audit review of Return to Title IV (R2T4) funds found that the return of federal funds was outside the required window. All necessary funds were returned during the 23-24 funding period. While R2T4 calculations were performed within the required time limit, there were three total students with returns that were outside the return window for the 23-24 Academic Year. Corrective Action Plan (CAP): The Associate Director of Financial Aid will be the primary staff member responsible for the R2T4 calculations and returns. If they are unavailable in a given week, the Executive Director will perform the weekly calculations needed. To ensure that the calculations and returns are completed within federal guidelines, the Associate Director will block 2-4 hours at the beginning of each week of the semester to review the prior week’s withdrawals and perform all necessary calculations and returns. At the end of each week, the Associate Director and the Executive Director will meet to review the prior week’s calculations and returns to ensure all returns have been processed through the Department of Education Common Origination and Disbursement (COD) website. A checklist has been created with all the necessary steps for each return, with a sign-off and documentation required to be attached as proof of completion. Anticipated Completion Date: The procedures will be implemented for the 2024-2025 Financial Aid Year. Responsible Parties: Beatrice LaChance

Finding No. 2024-001: Controls Over Student Financial Assistance Special Tests and Provisions – Enrollment Reporting (Repeated from Finding No. 2022-001 and 2023-001) Condition: During the compliance testing of “Special Tests and Provisions” requirements related to Enrollment Reporting, we noted the following exceptions: • Two (2) students were not reported to the Clearinghouse after withdrawing from the institution. Plan: After contacting Jenzabar One, the College has determined it cannot alter the pre-made Clearinghouse report; however, the College can alter its withdrawal process to ensure accurate withdrawal dates are reported in the correct area within the SIS. Admissions and Records will modify withdrawal and school determination dates, so the SIS gathers the correct information to be reported for future reporting. The Registrar will also work with and crosscheck students with Financial Aid to ensure all students who attended, but dropped before census, will be reported to the Clearinghouse. Anticipated Date of Completion: January 2025 Name of Contact Person: Dr. Stephanie Hartford, Provost

Management’s View and Corrective Action Plan: Management concurs with the above finding, and it has been corrected. In the case of A01441826, when the student’s enrollment was captured for Title IV eligibility (02/01), the student was enrolled in 10 credit hours. The student’s 3 credit hour CIS 146 class was deleted on 02/21 and Financial Aid was unaware. This caused the overpayment. In the case of A01454524, enrollment was captured for Title IV eligibility (02/01), the student was enrolled in 13 credit hours, but only 10 of those were in the student’s program of study. The student made an adjustment to their schedule and dropped the class that was out of program and picked up a class in program. This adjustment was not caught by Financial Aid. There is a report in ARGOS to assist with catching the multiple schedule changes. Moving forward there will be more than one person reviewing this report on a bi-weekly basis at a minimum. This report will be saved, and notes will be added so that it will be available to auditors moving forward. Corrective action will be implemented by April of 2025.