Corrective Action Plans

The University recognizes the importance of complying with all federal requirements. In this case out of the sample of students one student was reported late to NSLDS. During the processing of a student's academic status, there was a unique situation where the student's record remained active in our system due to the presence of an incomplete grade. In this case, because the incomplete grade delayed the finalization of the student’s academic status, the dismissal was not reported to NSLDS within the typical timeframe. Once the incomplete was resolved and the final status was updated, the necessary information was reported to NSLDS. Measures will be put in place to ensure all changes are processed timely, additional measures are as follows.  Adding the following language to the Graduate catalog, consistent with the Undergraduate catalog: Students with one or more Incomplete grades at the end of the term have an academic standing of On Hold until the Incomplete grade(s) is resolved. When all Incomplete grades are converted to letter grades, the term and cumulative GPA are recalculated and academic standing is set according to the Standards of Academic Progress.  Before any dismissal decision is finalized, the Registrar’s Office verifies that all incomplete grades for the student have been resolved and that final grades are recorded in the system. This verification ensures that no student is dismissed prematurely or inaccurately in the academic records. Implement a workflow process as a double check in the student information system that monitors the status of incomplete grades for students who are dismissed, the system will generate alerts to the Registrar’s office when an incomplete grade is pending resolution in conjunction with dismissal.  Implementing controls to ensure accurate grading in conjunction with dismissals in the Student Information System will enable precise reporting to NSC/NSLDS

Reference # and title: 2024-001 Controls over Cash Management Federal program and specific federal award identification: CFDA Number Award Year FEDERAL GRANTER/ PASS THROUGH GRANTOR/PROGRAM NAME United States Department of Education; passed through Louisiana Department of Education Title IV – SSAE 84.424 2024 Stronger Connections Grant Program 84.424F 2023 Condition found: Good internal controls require that all requests for reimbursement submitted to the Louisiana Department of Education (LDOE) are adequately reviewed and approved either before submission or after submission, but in a timely manner, to ensure amounts reported are complete and accurate. In testing a sample of a requests for reimbursements across all SSAE grants, it was noted that for the Stronger Connections Grant, the request for reimbursement was not reviewed and approved in a timely manner, in which the review and approval did not occur until three months after submission. When testing a sample of claims for reimbursements for the Title IV grants, it was noted that the reimbursements were not reviewed and approved by the supervisor. It was further noted that these reports were not printed until the auditor had requested them and were signed off by someone other than the supervisor as required by the procedures of the School Board. Corrective action planned: The Grants Supervisor has worked to update these procedures for the grants department. To ensure a proper review process is followed, the grants secretary will complete the reimbursement request in the system and the Grants Supervisor will review the request. If correct, the Grants Supervisor will submit the request to LDOE ensuring all request are reviewed before they are submitted. All requests will be printed and signed by the supervisor as the requests are submitted.

There is no disagreement with the audit finding. Corrections to the drawdown process will be made. We have implemented new review and reconciliation procedures to ensure that our federal funds drawdown processes are correctly executed in a timely manner.

There is no disagreement with the finding. The program length will be corrected for all students. In response to the findings from 2023, North Central corrected all program lengths within our Enterprise Resource Planning (ERP) system, Ellucian’s Colleague. Throughout the academic year, the Registrar’s Office and Financial Aid Department conducted thorough quality checks of the source data to ensure accuracy. Despite these efforts, unforeseen errors in enrollment data arose due to a data conversion issue between Colleague and the National Student Clearinghouse, which transmits information to the National Student Loan Data System (NSLDS). To address this, we will maintain our semesterly data confirmation process but will shift the primary focus of our reviews to the output data transmitted to NSLDS, ensuring data integrity at every stage of reporting.

Management's Response: Management concurs with the audit finding above. The Director of Admissions & Records has worked with the Audit Resource team at NSC to work through a process to ensure that unofficial withdrawals are accurately captured from Banner and reported in a timely manner. The NSC specialist helped the college set up an additional "subsequent of term" submission roughly 30 days after the end of the semester but prior to the first upload of the following semester. As a nonattendance taking institution, this timeframe will allow the college a chance to make withdrawal determinations for students who did not officially withdraw but stopped attending at some point in the semester and code them appropriately in Banner. This action has occurred, been tested and implemented as of January 2025.

Untimely Returns of Title IV Funds (R2T4) Planned Corrective Action: Southwestern now has an internal review in place to ensure that all calculations are done within the time allotment for the R2T4. We are also working very closely with the Registrar’s Office to ensure that all withdrawals are submitted to our office timely. Person Responsible for Corrective Action Plan: Brenda Hicks, Associate Vice President of Student Financial Planning and Director of Financial Aid Anticipated Date of Completion: Ongoing, process began in October, 2024.

National Student Loan Database System (NSLDS) Enrollment Reporting Recommendation: We recommend the College reevaluate their procedures and review policies surrounding reporting status changes to NSLDS to ensure timely and accurate reporting. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Registrar will re-evaluate policies, procedures and training materials to ensure timely and accurate reporting. Name(s) of the contact person(s) responsible for corrective action: Michele Peterson Planned completion date for corrective action plan: 03/31/2024

Finding Number: 2024-004 Condition: The College does not have a written cash management policy related to federal awards. Planned Corrective Action: In accordance with 2 CFR 200.302(b)(6), the College will establish a written cash management policy, including written procedures related to federal payments/awards in order to implement the requirements of 200.305. Contact person responsible for corrective action: David Cummins, Vice President for Administrative Services and College Treasurer Anticipated Completion Date: As soon as possible moving forward starting December 18, 2024.

Finding Number: 2024-003 Condition: There was a lack of internal controls in place related to the review of the FISAP that was submitted by the College in September 2023. Planned Corrective Action: The College will establish the proper controls to ensure that the information included in the FISAP is accurate, including implementing an additional level of review of the report. Contact person responsible for corrective action: David Cummins, Vice President for Administrative Services and College Treasurer Anticipated Completion Date: As soon as possible moving forward starting December 18, 2024.

Finding Number: 2024-002 Condition: There was a lack of internal controls in place related to the return of Title IV funds. Planned Corrective Action: The College will implement controls related to returns of Title IV funds, to ensure the related calculations are complete and accurate, and the funds are returned in a timely manner. Contact person responsible for corrective action: David Cummins, Vice President for Administrative Services and College Treasurer Anticipated Completion Date: As soon as possible moving forward starting December 18, 2024.

Processes will be implemented to review, update and verify data captured by NSLDS and ensure such data has been accurately reported in a timely manner.

Incorrect Enrollment Reporting to National Student Loan Data System (NSLDS) Planned Corrective Action: A new Registrar was hired in late May of 2024. A new process was implemented for the Fall semester of 2024 to ensure timely and accurate processing of official and unofficial withdrawals. Outcome: All student withdrawal requests both official and unofficial are processed daily and tracked in a shared workbook. This allows information about each individual withdrawal request to be captured and available for both the Business Office and Financial Aid. Date of Determination, Last Date of Attendance, Processed Date, withdrawal type, withdrawal reason, and credits impacted are all captured in the workbook to aid with R2T4 calculations. This workbook also serves as a document that can be audited in real-time to ensure accuracy of each student’s record. A Standard Operating Procedure was developed and used to train the team members effective on 8/12/2024. Person Responsible for Corrective Action Plan: Tonya Troka, University Registrar & Assistant Provost Anticipated Date of Completion: Completed and implemented for Fall 2024 Semester

Incorrect and Untimely Return of Title IV Funds Calculation (R2T4) Planned Corrective Action: See Below Cleary University identified compliance gaps in its Return of Title IV Funds (R2T4) reporting processes during the 2023-2024 award year. These issues stemmed from a lack of timely enforcement of procedures and misinterpretation of R2T4 regulatory requirements, necessitating immediate corrective action and leadership changes. The Financial Aid Director was dismissed, and an experienced Assistant Vice President (AVP) of Financial Aid was hired to oversee compliance and ensure accurate implementation of federal regulations. Additional Financial Aid Data Specialists were hired to improve system efficiency and accuracy. An R2T4 Task force was established, meeting weekly to review Last Day of Attendance (LDA) data, monitor student drop processes, and ensure timely R2T4 calculations and funds returned. A structured process for R2T4 calculations was put in place, with cross-referencing from the Records Department, maintaining through documentation, and improving tracking and reporting. Cleary University has taken significant steps to address the issues and ensure compliance with R2T4 regulations. The revised process, implemented in July 2024, aims to prevent future delays and findings. Weekly checks and ongoing training will ensure that R2T4 processing is accurate, timely, and fully complaint with federal requirements, with a target processing completion of 20 days. Person Responsible for Corrective Action Plan: JoAnn Ross, Vice President of Financial Aid Anticipated Date of Completion: December 18, 2024

While reviewing the follow up questions along regarding enrollment reporting, a discovery was made that there could have been issues with the query that was used to create the lists to be sent to National Student Clearinghouse. A new version of the query was created mid-July 2023. This query was lacking 3 current student statuses that would have prevented them from picked up transmitted/uploaded to National Student Clearinghouse. The original query was missing a status that was introduced in 2023, which was around summer/spring 2023, which is why the second query was created to pull that new status. Moving forward, we will create a new query for all future reports that use all current statuses.

Individuals Responsible for Corrective Action Plan: Collections Coordinator (Victoria Beeston)- Responsible for initiating contact with the borrower, providing documentation instructions, and reviewing completed forms. Director of Student Accounts (Ti Jolly)- Responsible for ensuring compliance with all applicable regulations and reviewing the re-assignment documentation. ECSI (Angela Johnson)- Responsible for updating financial records and confirming the reassignment of collection rights. Condition: Federal regulation 34 CFR 674.19(e) and 34 CFR 674.31 indicates that the institution is responsible for creating and maintaining the Master Promissory Note to indicated specifications. The university has found that the existing Master Promissory Note (MPN) or equivalent documentation that acknowledges the debt is either incorrect, incomplete, or missing. Management’s Corrective Action Plan: The following steps outline the corrective actions that will be taken to resolve this issue: 1. Contact the Borrower - Life University will initiate contact with the borrower to inform them of the need to update or establish a new MPN or equivalent documentation. This will be done via the following communication channels: • Phone call (if available) • Email notification • Postal mail (if no response is received through other means) 2. Provide Clear Instructions for Documentation - The university will send a formal notice to the borrower detailing the need for a new MPN or equivalent documentation. This will include instructions on how to sign the new agreement, the importance of the MPN, and a clear explanation of the implications for the outstanding loan amount. 3. Reassign Collection Rights - Once the borrower has completed the required documentation, Life University will work with ECSI to reassign the university’s right to collect on the remaining balance. 4. Documentation Review and Verification - After the MPN is completed by the borrower, Life University will review the new MPN for completeness and accuracy. This review will ensure that the terms are correctly documented, that the borrower’s consent is properly obtained, and that the right to collect on the outstanding amount is clearly assigned. 5. Update Financial Records - Life University will update its financial records to reflect the new MPN and the re-assigned collection rights. The university will also ensure that any outstanding amounts and repayment schedules are updated accordingly. 6. Ongoing Communication and Monitoring - The university will maintain communication with the borrower throughout the process, providing reminders if necessary. Verification of Effectiveness: Upon completion of the corrective actions, the university will verify that: • The borrower has submitted the new MPN or equivalent documentation. • The collection rights have been successfully reassigned. • Financial records have been updated accurately. The university will conduct a follow-up review in February 2025 to verify the effectiveness of the corrective action plan and to ensure that no further issues remain. Anticipated Completion Date: January 1st, 2025

Individuals Responsible for Corrective Action Plan: Michelle Nixon- Assistant Director of Financial Aid Systems. Melissa Waters- Senior Director of Student Administration and Compliance Condition: Finding related to disbursement record to Common Origination and Disbursement (COD) system in excess of 15 days This student’s disbursement occurred on 10/2/23 and LU verified that a disbursement record was sent to COD on 10/2/23; however, this student was not included in that record. We are unable to determine why the student was not included in that disbursement record. We send up disbursement records to COD 3 times a week. The student’s disbursement was transmitted to COD on 10/20/23. Management’s Corrective Action Plan: After speaking with a Common Originations and Disbursement (COD system representative, she stated that schools will receive a Warning Edit 055 when record of disbursement has not been received after 30 days. She verified that we did not receive this Warning Edit 055 from COD because we had not exceeded 30 days. The COD rep went on to share that this 15-day regulation used to be a 30-day regulation, but COD has not updated their Warning Edit 055 process to notify schools. It’s only done after 30 days. COD rep did identify a report Michelle will run to identify anyone who is not showing up with a disbursement record prior to the 15 days. The COD report is called the Anticipated Disbursement Queue and will be ran every 14 days to identify any potential issues. Anticipated Completion Date: January 1st, 2025

Individuals Responsible for Corrective Action Plan: Jana Holwik- Chief Academic Officer Elizabeth Geisz- Registrar Melissa Waters- Senior Director of Student Administration and Compliance Condition: Federal regulation 34 CFR 685.309 states that the institution shall accurately report a change in a student’s enrollment status directly to the lender or guarantee agency within 30 days if a student has graduated, withdrawn, or ceased to be enrolled (or failed to enroll) at least half-time and the school does not expect its next Roster File to NSLDS within 60 days. Management’s Corrective Action Plan: The University will report to the National Student Clearing (NSC) House using regularly scheduled enrollment reports every 30 days. Suppose a student’s enrollment status is not captured in the regularly scheduled enrollment reports with the NSC. In that case, the enrollment reporting will be reported directly to the National Student Loan Database Service (NSLDS), such as after the end of the term once grades are processed. The enrollment reporting in which a student receives a failing grade of all “Fs” for a quarter will be adjusted to meet the reporting time frame. Anticipated Completion Date: January 1st, 2025

The audit identified that inaccurate program start dates were recorded due to poor report programming and the absence of clear internal policies governing the program date. The root cause of this issue appears to be poor report programming practices, compounded by a lack of a well-defined internal policy to guide the accurate reporting of program start dates. In response to the finding, the NSC enrollment report has been rewritten with improved programming and internal quality control measures. A more robust process is being implemented to ensure data accuracy moving forward. The new report will be in place for Spring 2025. By addressing both the technical and procedural gaps, Palomar College will enhance the accuracy of program start dates and ensure better alignment with NSC reporting requirements.

As of the Spring 2025 semester all R2T4 calculations performed will then go through a secondary review by either the Assistant Director of Financial Aid or the Director of Financial Aid. This will ensure that R2T4 calculations have the correct Determination dates and that the correct amounts have been returned In COD for both the Institutional and Student portion owed.

The College has implemented additional controls to ensure that the School Calendar Profile in Common Origination & Disbursement (COD) is entered correctly and verified by a second person. Specifically, guidance has been provided to properly calculate the start and end dates for Scheduled Break Days in excess of five days.

2024-003: National Student Loan Data System Condition: The college did not properly report student enrollment changes for students who received federal student aid to NSLDS. Context: During testing of 60 students, 15 students were enrollment changes submitted past 60 days, 6 students had incorrect effective dates on campus enrollment, 5 were not certified at least every 60 days, 6 had program enrollment effective dates that did not match institutional records, 4 had incorrect program enrollment statuses, and 4 had incorrect program begin dates. Cause: The College did not have proper procedures in place to verify students’ status in NSLDS matched the institutions records in a timely manner. View of responsible official: MACC believes some of the current audit finding may be attributed to the SIS system implemented in November 2022; and these finding occurred before we implemented our Corrective Action Plan, which we have faithfully followed every month. As noted below, our CAP is a process in which we review enrollment records reported to NSLDS and update, if needed. Supporting documentation and verification of the work that has been done this past year can be provided, if needed. As a result of the continued commitment to submit correct data from our system to NSLDS every month, this fall MACC paid more than $12,000 to our software vendor (Jenzabar) for enhancements needed to collect, retain and report enrollment data. • Jenzabar created and installed a custom process to update the NSC status start date and NSC program status start date to the Last Date of Attendance. We began running this custom process with the November 2024 NSC enrollment file. • Jenzabar created and installed a custom process to update program begin dates for students returning to the same program to the original program begin date. We have implemented this as a scheduled process beginning December 2024. We are confident future reviews of our NSLDS enrollment reporting records will reflect greater accuracy. MACC would like to note, although the auditors are noting several students with effective date issues and failure to report students timely, we have evidence of student records being exported from our system every month and recorded in the Program Certification Details within NSLDS, but the data is not found in the Program Enrollment Effective Date area of NSLDS. We acknowledge the data must be in both areas of NSLDS, but we believe there is evidence that we submitted our records as required. We are hopeful the new enhancements will correct this issue. As disclosed in our audit response for 2022-2023, the corrective action plan has been slightly altered, but continues: • The Registrar will review data in J1 and submit enrollment records to NSC each month. • The Registrar will also work with the Director of Administrative Computing to ensure program information and other vital data are reported correctly. • After the enrollment file is accepted by NSC, MACC will review correct enrollment information in NSLDS for all students who have withdrawn from all classes and/or have had an R2T4 calculation, for accuracy. o The Registrar, or designee, will review the data in NSC. o The Director of Financial Aid, or designee, will review the data in NSLDS. • Discrepancies will be addressed between the Registrar and Financial Aid Offices immediately; and will utilize the Director of Administrative Computing to assist with configuration changes and data clean-up. • The records will be maintained in a designated Teams folder. Name(s) of the contact person(s) responsible for corrective action: Amy Hager and Amy See (Registrar). Planned completion date for corrective action plan: We expect the plan will be an ongoing effort to ensure compliance.

2024-002: Eligibility Cause: During our testing, we identified that the College’s internal control policies were not effectively designed to ensure funds are disbursed to eligible students. Context: During inquiries with management, the College identified four students that were awarded and disbursed Pell, SEOG, and Direct Loans, who were subsequently determined to be ineligible for the programs. View of the responsible official: MACC does not agree with this finding. MACC has many measures in place to ensure funds are disbursed to eligible students, including verifying identity when enrolling degree seeking students in classes each semester and reviewing high school completion status with a high school transcript, as well as reviewing ISIRs, and other documentation to determine eligibility for federal student aid. While preparing disbursements for fall 2024, the Financial Aid Office identified some odd entries on some ISIRs, which prompted us to review various patterns in admissions documents. MACC believes the students in question may be cases of stolen identities. However, this is only suspicion at this time because when the students in question enrolled in the summer 2024 semester they provided identification, submitted high school transcripts from valid high schools, completed FAFSAs which resulted with valid ISIRs (in one case the student submitted Verification (V4) documentation), submitted loan data sheets and completed entrance counseling via Zoom. The students in question were referred to the Office of Inspector General at the U. S. Department of Education on 10/15/2024; no follow-up has been received from OIG as of 01/15/2025. MACC has also discussed this case with Kathy Feith, Region 7 Branch Chief, of the U. S. Department of Education, Federal Student Aid. During an interview with an auditor from CLA, MACC disclosed the situation described above to the auditor when questioned about any potential fraud cases. MACC firmly believes all internal control policies were followed to ensure funds were disbursed to eligible students. At the time of disbursement, there was no indication these students were not eligible. As noted above, the OIG has not determined that these are in fact ineligible students; therefore, MACC does not believe it should return funds based on suspicion of ineligibility. As a result of these findings, MACC has added new steps to provide an additional layer of protection, including verifying images of state drivers licenses or other forms of identity, and development of guidelines for staff to follow if they have any suspicion of fraud. Name(s) of the contact person(s) responsible for corrective action: Amy Hager Planned completion date for corrective action plan: We expect the plan will be an ongoing effort to ensure compliance.

2024-001: Return of Federal Funds Context: During our testing of 40 student’s R2T4 calculations, we noted 3 with refunds that were not returned within the 45-day requirement. Cause: The college has not implemented precise controls to ensure timely return of funds related to withdrawals. View of the responsible official: MACC is an attendance taking institution and our regular practice requires review of attendance records two to three times per week. When the Financial Aid Office discovers students have withdrawn from classes, we review and calculate an R2T4 when required – usually within 1-5 days from the date it is discovered. This finding of a “late return” is due to a faculty member dropping a student outside of the dates required by our attendance policy. I would like to note that the R2T4 was performed timely and accurately as soon as the drop was identified. Action taken in response to finding: The issue was reported to the President, Vice Presidents, and Deans; as a result, the faculty were addressed and reminded of the importance to comply with the college’s attendance policy. Name(s) of the contact person(s) responsible for corrective action: Amy Hager Planned completion date for corrective action plan: Our Registrar, Deans, and Vice President for Instruction will provide reminders of our policy with our faculty each semester. In the event that a faculty member does not comply with the attendance policy, their Dean will take disciplinary action.

The San Bernardino Community College District acknowledges and understands the recommendations associated with the Special Tests and Provisions – Enrollment Reporting audit finding. The District has examined the elements detailed by the finding and is committed to implementing appropriate controls to prevent future non-compliance. The District will enhance current internal controls, develop and implement new supporting procedures and institute best practices as part of this corrective action. Actions to be taken include: the improved collaboration between District Support Services, the Financial Aid Office, and the Admission and Records Office to ensure accurate enrollment data reporting. District staff shall report to the Financial Aid Office immediately after each submission is completed to the National Clearinghouse. The Financial Aid Office shall utilize NSLDS reports to ensure all records are submitted and modified in a timely manner. Immediate action has taken place to address this deficiency, and collaborative efforts will continue to ensure compliance in this reporting area by the start of the Spring 2025 semester.

View of Responsible Officials and Corrective Action Plan The District agrees with the finding and will implement procedures that will ensure student enrollment information is updated and accurate on the NSLDS Access website.