Corrective Action Plans

FINDING 2024-009 Name of Responsible Individual: Tracy Jenkins, Student Account Billing Coordinator Corrective Action: Wheeling University worked with ECSI regarding Perkins information. With the Perkins program ending, we realized that we needed to move in the direction of closing out Perkins files/information. The University is currently working with ECSI so that we are able to submit Perkins information/files to the Department of Education. We are gathering information (promissory notes, bankruptcy details, payment information, etc.) to assist ECSI with the process. Anticipated Completion Date: June 2025

Name of Responsible Individual: Lori Kestner, Human Resources Generalist Corrective Action: The payroll Process for Federal Work Study: Student punches in on a computer or cell phone to log in and out when working at the start of their shift and the end of their shift. Timecards can be approved by their supervisor/manager daily, weekly, or by the pay period which is every two weeks. The pay period ends on a Friday with the payroll processing to begin on the following Monday. On that Monday, all timecards must be corrected/updated and approved before they can be processed. Timecards with errors cannot be processed. Each Monday the supervisor/manager must log into the student timecard and "approve" the card for the pay period that ended on the past Friday. When the supervisor/manager opens the card on Monday it defaults to the current pay period and not the previous pay period that needs to be approved. The supervisor/manager must select the "previous" pay period in order to approve the card to be processed. In the case of the student in question, the supervisor/manager did not select the correct pay period and therefore approved the future timecard. As the payroll manager, I would have emailed him, the manager, that the card to be processed had not been approved. Upon that, he went back and approved the pay period that was to be processed. The approval on the next pay period that he mistakenly approved should have been removed. It was not. The process for card approvals is to check on the Monday of payroll the cards that are still in need of updates/corrections and approvals. A report is run and shows what cards our still without approval and with errors. The payroll manager communicates to the manager and the student that there are errors on the card and/or it still needs to be approved. Payment for that card cannot be made until errors are corrected and the card is approved. It is the supervisor and manager’s responsibility to ensure timecards are corrected and updated for processing. This error can be resolved with the supervisor/manager accountable for the accuracy of the time cards. Before processing a report, can be run by the payroll manager of the date/time of approval. All supervisors and managers who are responsible for the approval of timecards will be reeducated on the process and sign off that they understand their role. Those who do not adhere to the process will have additional training. As new supervisors and managers are hired, the process will be part of their on-boarding. Anticipated Completion Date: January 2025

FINDING 2024-010 Name of Responsible Individual: Tyler Hosey, Senior Accountant Corrective Action: The University acknowledges the FISAP report was filed with incorrect data and not amended in a timely manner. The University has developed a series of internal controls and procedures to ensure that the data provided for the FISAP will be accurate going forward. All balance sheet accounts will be reconciled on a monthly basis and all revenue will be recorded on the ledger in the time period that it is earned. A monthly income statement and balance sheet will be generated to determine how much federal aid revenue has been reported throughout the year. The accounting software has a built-in process that will be run on a regular basis to make sure all entries are properly posted. This will ensure accurate reporting in the future. Anticipated Completion Date: June 2025

Name of Responsible Individual: Tracy Jenkins, Student Account Billing Coordinator Corrective Action: The University acknowledges that we were not in compliance during fiscal year 2024 with the federal guidelines to refund the student credit balances in a timely manner for the students in question. There was significant employee turnover at the University in the business office during fiscal year 2024 and training of new employees was ongoing at that time. This resulted in the delay in the student refunds within the sample selection that the auditors chose during fiscal year 2024. Since then the new and current staff members have been fully trained on their duties and responsibilities. Everyone involved has been informed of the student refund policies and requirements per the Title IV regulations. There have been procedures implemented to prevent this from being a repeat audit finding in the future. Anticipated Completion Date: July 2024

Name of Responsible Individual: Dylan J. Nowakowski, Director of Financial Aid Corrective Action: After Colleague was properly set up for Financial Aid for R2T4’s, the Director discovered that the calendars did not match the actual publicized academic calendar. Had the calendar been accurate with the correct dates of breaks of five days or more, then the R2T4 would have been accurate. The calendar in Colleague has now been corrected. For the years moving forward this will be verified before any R2T4 is calculated and submitted. All breaks that are five days or more are accurate. At Wheeling, we have a comprehensive R2T4 policy. This policy outlines how to count calendar days in a semester and provides clear instructions on what to do when a student withdraws during a break. Anticipated Completion Date: July 2024

The University has taken the following steps to improve the accuracy and timeliness of enrollment reporting with respect to federal requirements. Summer withdrawals will now be reported directly to the National Student Clearinghouse (the Clearinghouse) as a service provider for transmissions of its enrollment reporting changes to the NSLDS at the time of withdrawal, ensuring timely and accurate reporting. The Registrar’s Office will submit a manual enrollment status change to the Clearinghouse. Since this audit finding was identified in the fall of 2024, the University had already reported all summer 2024 withdrawals during the first fall roster submission.

Management agrees with the finding and in concurrence with the recommendations the Registrar’s Office processes and documentation will be updated as follows: Major change process: If a request is submitted to drop a major while a student is on leave, the effective date will be recorded as the date of the leave rather than the date the change was initiated. Leave of absence process: All withdrawals will be reported to the National Student Clearinghouse (NSC) manually within 2 weeks of being processed to avoid any delays or issues with the regularly scheduled Peoplesoft delivered report. If due to the schedule, a W status is reported via the delivered report instead of by hand, the person responsible for enrollment reporting will verify the status with the NSC, including program-level data. Ongoing training will be provided and a senior member of our staff will audit the major change and leave of absence processes moving forward. This corrective action plan has been implemented as of January 2025.

Management agrees with the finding and in concurrence with the recommendations we have reviewed the federal verification definitions, and the importance of selecting the correct verification status in the COD system, with staff who participate in the federal verification process to ensure they understand the federal definition of number of family members in college. Ongoing training will be provided and a senior member of our staff will audit the verification process moving forward. This corrective action plan has been implemented as of January 2025.

Incorrect Enrollment Reporting to National Student Loan Data System (NSLDS) Planned Corrective Action: Our records indicate that the student's account at Simpson University was reported to the National Student Clearinghouse (NSC) on several occasions while the student was enrolled. It is the duty of the NSC program to ensure the accurate transmission of information to the National Student Loan Data System (NSLDS). Once the data leaves Simpson University, the university does not track its progress to other entities. It is recommended that any necessary adjustments be discussed directly with the NSC, particularly if issues arise from their data transfer to third parties. To ensure accuracy, various methods can be implemented, such as conducting random data audits to verify that the information sent to NSC matches that in the NSLDS. This process can be quite exhaustive. Alternatively, a sample audit might involve reviewing a certain error threshold; for instance, if 300 records are submitted, a check of 15-30 records could be performed, reflecting an error tolerance of approximately 5-10%. Another option is for the reporting body to collaborate with NSC in identifying any errors or complications that may affect the correct data transmission. Simpson University maintains evidence that all data submissions to the NSC have been properly reported, accepted, and timely without any discrepancies. Person Responsible for Corrective Action Plan: Adrienne Currington, Registrar Anticipated Date of Completion: Next NSC reporting cycle

Incorrect and Untimely Returns of Title IV Funds (R2T4) Calculations Planned Corrective Action: The University agrees with these findings. It was determined that these issues primarily resulted from a critical staff shortage in the Financial Aid Office during the audit period. This shortage significantly impacted our ability to complete R2T4 calculations accurately and withing the required timeframe. To address these findings, the institution will prioritize the recruitment and onboarding of additional qualified staff to alleviate workload challenges and support timely processing of R2T4s. Concurrently, we will provide comprehensive training to all financial aid staff, focusing on federal regulations, calculation methods, and deadlines. To reduce errors, we will establish a robust quality assurance process that includes a secondary review of all R2T4 calculations before finalization. Person Responsible for Corrective Action Plan: Shondra Dickson, Director of Financial Aid Anticipated Date of Completion: September 1, 2025

2024-001 Incorrect Pell Disbursement Amount - Student Financial Aid Cluster Assistance Listing Number 84.007, 84.033, 84.063, 84.268, Grant Period - Year Ended June 30, 2024 Condition Found During our student file testing we noted two students out of forty were not disbursed the correct Pell Grant award. Based on the student’s enrollment status and need, the College under awarded the students by $716. We consider this to be an instance of noncompliance relating to the Eligibility Compliance Requirement. Corrective Action Plan The Financial Aid Office will implement a more comprehensive process to review schedule and FAFSA change reports to identify any impact on Pell awards for affected students. Responsible Person for Corrective Action Plan Heather Kleekamp, Director of Financial Aid Implementation Date of Corrective Action Plan January 2, 2025

Financial aid will use an exception report created by IT to identify all currently enrolled students who are not included in the NSLDS Enrollment Report received every 60 days. Financial aid will use this exception report to verify all enrolled students who have current or previous loans are reported correctly to NSLDS. The Financial Aid Dept will add a task to the August financial aid calendar to manually add/update all incoming 1L students' enrollment in NSLDS who have a current loan originated or showing previous loans in NSLDS. Financial Aid department will use the Enrolled Student Report for the fall semester from the student information system, Sonis, along with the actual disbursement report from Dept of Education's software, EDExpress, to identify students whose enrollment needs to be updated with NSLDS.

2024-001 Assistance Listing Number(s), Federal Agency and Program Name: 84.063, 84.007, 84.033, and 84.268; United States Department of Education (DOE), Student financial assistance cluster. Finding Type: Noncompliance and material weakness in internal control over compliance relating to special tests. Criteria: The Institute is responsible for designing, implementing, and maintaining internal control over compliance for special tests and provisions and for accurately and timely reporting significant data elements under the Campus-Level and Program-Level records within the National Student Loan Data System (NSLDS) that DOE considers high risk. Statement of Condition: Management implemented controls that specifically addressed the some of the circumstances surrounding prior year finding 2023-001. Management's review of the enrollment reporting did not detect errors on certain student Program-Level data elements or timely reporting. Certain student records within the NSLDS were identified with inaccurate Program-Level data elements and not timely reported. Questioned Costs: There were no questioned costs. Context: 9 students were identified with inaccurate Program-Level data elements and not timely reported out of a total of 27 student statuses tested. The Campus-Level data elements were accurately and timely reported. Cause: The Institute’s internal control over compliance did not detect and correct the errors. The preparer incorrectly reported graduate file impacting the student's effective dates and statuses during submission process to NSLDS resulting in inaccuracies in significant Program-Level enrollment data elements that ED considers high risk. The Institute’s internal control over compliance did not detect and correct the error. Effect: The Institute incorrectly reported certain Program-Level records in NSLDS which is information that DOE considers high risk and the Institute’s internal controls over compliance did not detect and correct the errors. Recommendation: We recommend management review policies and procedures surrounding enrollment reporting submissions to ensure the accuracy of Program-Level data elements reported to DOE. A review performed by an appropriate individual separate from the preparer prior to the submission of the enrollment reports to NSLDS may improve the accuracy of enrollment reporting. Management’s Response: Management agrees with the finding. Through internal investigation, it was determined that the date field issues found in 2023 also impacted “special” files, which include graduate data files and are processed differently in-house. This error has been fixed so that both fields will always be the same and accurate using the same method as the 2023-001 finding. The registrar will now confirm both the student-level and program-level data fields upon submission to NSC. Status: Completed January 2024 Contact: Mark Fetherston Vice President for Enrollment Management 414-847-3215 markfetherston@miad.edu

The College has promptly engaged with Federal Student Aid regarding proper corrective actions. The Financial Aid Office has conducted a review of disbursement policies and procedures to prevent future occurrences.

The Financial Aid department will continue to review and update the reporting procedures. The Director of Financial Aid will review the origination and posting of loans with staff and train them to ensure that dates are consistent and in compliance with Title IV regulations.

The departments involved in the enrollment reporting process are continuing to review and enhance the workflow in order to report accurately. Monthly submissions by Information Technology Systems (ITS) will be completed in a timely manner to allow for prompt communication of corrections that are required, which are communicated to Admissions and Records by the National Student Clearinghouse (NSCH). Admissions and Records will ensure that error reports provided by NSCH are returned to NSCH within 10 business days to allow for a timely submission to the National Student Loan Database (NSLDS). Staff in Admissions and Records has been specifically assigned to complete error reports to contribute to a prompt submission. The Admissions and Records department will collaborate and communicate with the Financial Aid department to identify students with error codes in NSLDS in an effort to correct them. The Admissions and Records and Financial Aid departments will work with the Internal Auditor to perform semiannual reviews of NSLDS data to ensure accuracy of student records.

The District and its Financial Aid department will continue to review and enhance the workflow and procedures of Return to Title IV. The goal of these efforts has been to meet the compliance requirements of Return to Title IV. The District has developed a schedule with specific dates per term for when calculations will be completed, when requests will be made to Accounting to return the District portion of funds within 45 days, and provide ample timelines that can ensure funds get returned within compliance. The District has included the various department areas and staff that are involved in the process to ensure the schedule is consistent and that the funds are returned in the appropriate time frame. The Financial Aid department will continue to meliorate the task of the Return to Title IV calculations. This task is a work function of the Financial Aid Coordinator position. While staff has been trained to perform this function, the District is currently in recruitment to fill the Financial Aid Coordinator position. While the Coordinator will be expected to perform the calculations, they will be submitted to the Director of Financial Aid for review and to ensure accuracy.

Condition: The University does not have controls in place for review of Return of Title IV calculation. Planned Corrective Action: All R2T4 calculations will be reviewed by a second individual within the Calvin Financial Aid Office. Calculations will not become final until both individuals agree with the specifics of each calculation. Contact person responsible for corrective action: James Koeman, Director of Financial Aid Anticipated Completion Date: Already completed as of the 24FA term.

Management acknowledges that there was an error with one over award of subsidized loan on a student. Student was given $448 (gross) over the aggregate subsidized limit. The overage was sent back to the Direct lender. Since the student graduated, the $448 was covered by a grant. A survey of all students was completed and no other students were discovered to have been over their aggregate subsidized limit. • A student’s aggregate subsidized amount on NSLDS from his FAFSA record was listed at $17,948, allowing only $5,052 in remaining to reach the $23,000 aggregate limit on subsidized loan. Student was given $5,500 when it should have been $5,052. The $448 should have been given as unsubsidized loan. Student had previous loans from another school. (Powerfaids will catch this error if all of the historic loans were processed within our database.) • The student ISIR record did have Comment code 258: “Based upon data provided by the National Student Loan Data System (NSLDS) and your grade level, we have determined that you may have received a total amount of undergraduate student loans that is close to or equal to the loan limits established for the federal loan programs. Therefore, your eligibility for additional student loans may be limited.“ • The Federal processor usually sends a post-screening after federal aid is disbursed with warnings of limits: 255, 256, 258. 260 ad 261. This would cause a C-code on the student record. We did not receive a subsequent ISIR record on said student. Corrective Action Plan: Include in the Quality Assurance rules one for the ISIR codes associated with NSLDS overawarding of loans whether it be annual limits or aggregate limits. We will monitor these codes regularly during packaging season and subsequent to loan disbursing.

January 16, 2025 U.S. Department of Education 400 Maryland Ave SW Washington, DC 20212 Transylvania University respectfully submits the following corrective action plan for the year ended June 30, 2024. Name and address of independent public accounting firm: Blue & Company, LLC 250 West Main Street, Suite 2900 Lexington, Kentucky 40507 The findings from the schedule of findings and questioned costs (the Schedule) for the year ended June 30, 2024 are discussed below and are numbered consistently with the numbers assigned in the Schedule. Identifying Number: 2024-001 Finding: Enrollment Reporting. The enrollment status for students who completed their graduation requirements in May 2024 was incorrect for more than 30 days. Corrective Actions Taken or Planned: This issue occurred because enrollment and degree verify files sent to the National Student Clearinghouse (NSC) at the end of a term were processed in a particular order and student enrollment data overwrote student graduated status data. To correct the impacted students, the university registrar requested that NSC reprocess the May 2024 degree verify file, which should have been processed last. To prevent a future recurrence, the registrar has modified the file upload schedule to reflect the correct order of processing and has updated office procedures to clarify that the degree verify file should be uploaded last, following the submission of all term enrollment data. In addition to altering the file submission schedule, the registrar will ensure the end-of-term enrollment file has been processed by the NSC before the Degree Verify file is submitted each term. January 16, 2025 U.S. Department of Education 400 Maryland Ave SW Washington, DC 20212 Estimated Completion Date: November 11, 2024 Responsible Personnel: Michelle Robinson, Registrar If you have any questions or would like any additional information regarding these matters, please let us know and we will be happy to provide. Sincerely, Lisa Custardo, CPA Chief Financial Officer

The audit identified discrepancies between the enrollment information reported to the Clearinghouse and the data reflected in NSLDS, affecting 4 of the 10 student files reviewed by the auditors. The root cause was determined to be a communication breakdown between the Clearinghouse and NSLDS systems, resulting in the transfer of inaccurate data. A corrective action plan has been developed to strengthen internal controls and ensure the accuracy of enrollment reporting. To enhance accuracy, the Registrar and the Director of Financial Assistance will conduct a random review of enrollment reporting data submitted through the National Student Clearinghouse and reflected in NSLDS at regular intervals during each semester and following the confirmation of degrees. This review process will include cross-referencing the last date of attendance and effective withdrawal dates recorded in institutional systems against the corresponding data in the Clearinghouse and NSLDS. Any discrepancies identified during these reviews will be documented, and necessary corrections will be promptly submitted to the Clearinghouse.

Name of Contact Person: Jennifer Herman, Finance Director Corrective Action: 1. The Finance Office will no longer make corrections on employee mileage and meal reimbursement forms submitted by County departments. Finance Office staff will return incorrect forms for departmental personnel to make corrections and resubmit the reimbursement form. Proposed Completion Date: This plan has been implemented since October 1, 2024. 2. The County will update its travel policy and require County department heads to be responsible for the use of approved rates on employee travel reimbursement forms. Proposed Completion Date: January 1, 2025.

Name of Contact Person: Michael Dodson, DSS Business Officer Corrective Action: 1. Alexander County DSS has implemented more detailed Indirect Cost Plan review to ensure that the County Manager signed plan is utilized and not the Final (Draft) version. The Business Officer will further train in the differences between the two documents to ensure the proper one is reviewed and financial data is transferred over to the 1571 mthly cost statements. Proposed Completion Date: Reviewing of the two versions of the Indirect Cost Plans by the DSS Business Officer has been completed as of August 6th, 2024 once the Signed FY23 Indirect Cost plan was obtained. DSS Business Officer will continue a review process every fiscal year once the newly signed plan is received. 2. The DSS Director and Business Office team will review the Official Indirect Cost Plans annually and check the 1571 Statement of Admin. letters mthly to ensure accuracy in the Indirect Cost Plan financial data. Proposed Completion Date: August 6th, 2024

Corrective Action Plan for Finding 2024-001 Name of Contact Person: Michael Dodson, DSS Business Officer Corrective Action: 1. On May 7th and May 17th, job counseling sessions and written warnings were given to the employees who were flagged for not logging out or locking their screens to protect confidential information. In addition, On July 2nd, a staff meeting was completed to review agency policy on PII requirements and expectations and I.T. has changed lock out screen settings to take place after 3 minutes of inactivity on all DSS Computer Systems. Proposed Completion Date: PII Policy Enforcement, Training Reviews, Security Implementations have been completed as of 7/2/24. 2. The DSS Director and Agency Admin. team will randomly check office computers to ensure systems are locked per policy. Proposed Completion Date: July 2, 2024

Finding number: 2024-001 Federal agency: U.S. Department of Education Programs: Student Financial Assistance Cluster AL #: 84.063 and 84.268 Award year: 2024 Corrective Action Plan: The R2T4 calculations were done in a timely manner. These errors were due to human error and is considered isolated incidents. The Financial Aid office has taken great steps over the years and improved the processes for identifying and processing R2T4 calculations in a timely manner. Timeline for Implementation of Corrective Action Plan: The corrective action plan was implemented as of October 2024. Contact Person Scott Jewell, Director of Financial Aid