Corrective Action Plans

Finding 2024-001 Student Status Changes Condition The College did not notify the National Student Loan Data System (NSLDS) in a timely manner for 6 students with status changes in our sample of 25 students. The sample was not a statistically valid sample. Corrective Action Plan Corrective Action Planned: The College has updated its policies and procedures to ensure notification to the National Student Loan Data System are performed timely. All members of the responsible team continue to undergo formalized training to ensure their knowledge and proficiency regarding all applicable rules and regulations are kept up to date. Name(s) of Contact Person(s) Responsible for Corrective Action: Thomas Camillo, Registrar Kevin Thomas, D.O., Assistant Dean of Institutional Enrollment Management Anticipated Completion Date: 6/30/2025 Policies & Procedure update was completed during FY24 Software training for existing staff continued through the summer of 2024

The College acknowledges the audit finding regarding the lack of documented independent review of Return of Title IV Funds (R2T4) calculations and is committed to addressing this issue. To ensure compliance, the College Financial Aid Director will review the R2T4 calculations completed by the College Financial Aid Advisor each month and will implement a standardized email response to confirm that the R2T4 calculations for the month were reviewed. This email response will be archived as evidence of management review. These corrective actions will be implemented in January 2025 , with the College Chief Financial Officer supervising the monthly review of the R2T4 calculations to ensure they are performed.

SIGNIFICANT DEFICIENCY Finding 2024-001 - 84.268, 84.063, 84.033, 84.007 Student Financial Aid Cluster Federal Agency - U.S. Department of Education Grant Period - Year ended August 31, 2024 2024-001 Recommendation: The College should work to implement a standardized and detailed risk management framework, such as those provided by National Institute of Standards and Technology (NIST). Risk assessment documentation should include detailed information regarding current procedures in place, justifications for scoring, safeguards for each identified risk, and remediation plans. As part of this process, the College should then review the current policies and procedures at least annually to determine if any updates should be made. Corrective Action Plan: The College agrees with the finding and as of March 2025 the College has contracted with an outside third party to perform an formal risk assessment. Once the risk assessment has been performed the College will work on ensuring the appropriate safeguards are in place and remediation plans identified. Additionally policies continue to be reviewed and updated through the governance process at the College. FLCC Responsible Party: Jason Tack, VP of Finance and Administration, jason.tack@flcc.edu, 585-785-1208. Audit finding will be corrected by 8/31/2025.

The staff ember responsible for running the process has started to send notification manually instead of through the Banner System until a resolution to the glitch has been identified Task Activity Expected Start Date Expected End Date Completion Date Manual emails sent January 2025 Ongoing Depends upon resolution from Ellucian

2024-002 Special Tests (Enrollment Reporting) Federal Agency: Student Financial Assistance Cluster - U.S. Department of Education Program Titles and ALN: Federal Pell Grant Program (ALN 84.063) and Federal Direct Student Loans (ALN 84.268) Federal Grant Numbers: E-P063P243920 (7/1/2024 – 6/30/2025), P268K253920 (7/1/2024 – 6/30/2025) Contact Person: Catharine A. Punchello, Vice Provost and University Registrar, 609-984-1180, x3135 Corrective Action: National Student Loan Data System (NSLDS) has resolved the issue causing the Error Code 75 (EC75) errors. Our last large batch of 75 errors was received in response to our Student Status Confirmation Report (SSCR) on July 8, 2024. We received one EC75 on September 13, 2024 and two EC75 on November 8, 2024 and none since then. The University continues to monitor NSLDS’ error reports on our SSCRs to ensure we are aware if they return. The University will continue to submit the SSCR responses to the Clearinghouse and ensure we report individual graduations or enrollment if there are error codes that cannot be resolved timely through the Clearinghouse process. Anticipated Completion Date: Completed

2024-001 Special Tests and Provisions (Verification) Federal Agency: Student Financial Assistance Cluster - U.S. Department of Education Program Titles and Assistance Listing Numbers (ALN): Federal Pell Grant Program (ALN 84.063) and Federal Direct Student Loans (ALN 84.268) Federal Grant Numbers: E-P063P243920 (7/1/2024 – 6/30/2025), P268K253920 (7/1/2024 – 6/30/2025) Contact Person: James Owens, Director of Financial Aid, (609) 633-9658 x 3400 Corrective Action: The University has enhanced its report for required verification documentation to highlight those selected with V4 or V5 status to ensure all proper documentation is requested and provided by the students as required for the verification status. The review will be done on a monthly basis throughout the fiscal year. Anticipated Completion Date: April 2025

Student Financial Assistance Cluster – Assistance Listing No. Various Recommendation: We recommend the University review its reporting procedures to ensure that students’ statuses are accurately and timely reported to the National Student Loan Database System (NSLDS) within the appropriate timeframe as required by regulations. University of Maine at Farmington Condition: During our testing of 40 students, we noted four students at the University of Maine Farmington (UMF) whose campus enrollment effective date did not match their program enrollment effective date. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: After a similar audit finding in 2022, UMF understood that having the error reports from the National Student Clearinghouse (NSC) would correct this problem going forward. It was subsequently discovered that the internal report used in submitting withdrawals to the NSC pulled the Program Enrollment Effective Date from the wrong location, resulting in instances where the reported date did not match the Enrollment Effective Date. UMF is actively working with UMS IT staff to correct this report. In the meantime, these dates have been updated manually on the NSC website for all withdrawn students, including the four identified in this finding. Name(s) of the contact person(s) responsible for corrective action: Lisa Beane, Assistant Registrar for the University of Maine at Farmington. Planned completion date for corrective action plan: April 2025.

Special Test — 84.063 — Federal Pell Grant Program Views of responsible officials and planned corrective actions: District management and the technical college director are responsible for providing supervisory oversight for each Technical College’s Registration Office and Financial Aid Office as it relates to the timely and accurate reporting of NSLDS data. NSLDS data will be reviewed by the Financial Aid Officer monthly and will continue to be updated programmatically every 60 days to ensure compliance with the 60-day reporting requirement. The Financial Aid Officer will continue to complete an internal NSLDS Status Change Form and enter updates into the NSLDS reporting platform within 15 business days. Effective immediately, the Financial Aid Officer will enter a new program enrollment line with the updated enrollment status so that information is reflected in the historical action taken for each student. District management and the technical college director will direct the Financial Aid Officer to print the updated NSLDS Enrollment History, confirming the date that the enrollment status was reported. The NSLDS Enrollment History and the NSLDS Status Change form will be maintained in the student’s Financial Aid folder for future reference.

Department of Health and Human Services Response/Corrective Action Plan The Department of Health and Human Services agrees with the recommendation. HHS has begun the process of recoupment and will work to receive full repayment, to date the balance remaining was $5,000 and a payment plan has been sent up to recoup the remaining amount. The Accounts Payable team will collaborate with OMB to implement additional processes within Peoplesoft to verify payment information in the future. Currently, we are working to add display options in the Mass Voucher Approval screen to allow for tallying of the totals of vouchers in range. This addition will enhance the review step to ensure payments are consistent with Program totals for a secondary check before approval of payments are made. Contact Person: Karol Riedman, Assistant CFO Ann Scott, AP Accounting Manager Anticipated Completion Date: 06/30/2025

AUDIT FINDINGS Finding Reference Number: Finding 2024-002 Description of Finding: Statement of Condition: The Financial Aid Office does not consistently report disbursement dates to COD correctly. Two (2) out of six (6) students tested had been incorrectly reported to COD. Statement of Concurrence or Nonconcurrence: According to 34 CFR 668.164(a), Disbursing Funds, an institution makes a disbursement of Title IV, HEA funds on the date that the institution credits a student’s account at the institution or pays a student or parent directly with funds received from the Secretary; or institutional funds used in advance of receiving Title IV, HEA funds. Corrective Action: To ensure timely and accurate processing of financial aid disbursements, the Office of Accounting and the Office of Financial Aid will implement a Disbursement Memorandum outlining specific procedures. The Office of Accounting must upload disbursement files into PowerCampus on the same day they are received from the Office of Financial Aid. If disbursement files cannot be uploaded due to system issues, staff illness, or other delays, the Office of Accounting must immediately notify the Office of Financial Aid. In such cases, the Office of Financial Aid will update disbursement dates in COD as needed. The Office of Financial Aid already has a process in place to identify and correct mismatches between disbursement dates in PowerFAIDS and COD, and this process will continue as part of ongoing reconciliation efforts. The Office of Accounting will maintain awareness of the importance of same-day uploads and exercise diligence in ensuring compliance with this requirement. This corrective action plan will enhance coordination between offices, reduce discrepancies, and improve compliance with federal reporting requirements. Name of Contact Person: Keri Gilbert Associate Vice President of Financial Aid Analytics and Compliance (573) 876-7106 Projected Completion Date: 3/10/2025

Department of Education Bucknell University respectfully submits the following corrective action plan for the year ended June 30, 2024. Audit period: July 01, 2023 - June 30, 2024 The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. FINDINGS—FEDERAL AWARD PROGRAMS AUDITS Department of Education 2024-001 Federal Pell Grant Program – Assistance Listing No. 84.063 Federal Direct Student Loans – Assistance Listing No. 84.268 Recommendation: We recommend the University review procedures around sending correct information to the NSLDS. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Bucknell continues to review and refine its existing process of reporting student enrollment data to the NSLDS at both the campus level and program level. Name(s) of the contact person(s) responsible for corrective action: Tim Kracker, University Registrar and Erin Wolfe, Director, Financial Aid Planned completion date for corrective action plan: December 31, 2024 If the Department of Education has questions regarding this plan, please call Elizabeth D. Stewart, Associate Vice President, Treasurer & Controller at 570-577-3108.

Finding 2024-004 Federal Agency Name: U.S. Department of Agriculture Program Name: Community Facilities Loans and Grants Cluster Applicable Federal Award Number- Direct Loan and Guaranteed Loan Assistance Listing Number #10.766 Finding Summary: The Medical Center was not in compliance with the terms of the loan agreements related to the reservefunds. Responsible Individuals: Ron Harrington, CFO Corrective Action Plan: The CFO worked with the local bank in Concordia to establish the required reserve account equal to the 10% of the annual debt service requirement on the direct loan and the guaranteed loan for the entire year. The Hospital is now in compliance with the terms of the loan agreements related to the reserve funds as of August 31, 2024. The Hospital has access to the accounts set up at the Bank to run monthly reports and record the interest amounts to the proper GL accounts quarterly as the interest on the accounts set up at the bank accrue interest quarterly. This entry is to ensure the Gl accounts agree with the Bank statements on the Reserve funds. Anticipated Completion Date: August 2024

Planned Corrective Action: The University has streamlined the process of R2T4 to prevent delays in processing. This enhanced process creates a countdown report to prioritize R2T4 calculation when staff resources as strained. Contact person responsible for corrective action: Roberta Smith Anticipated Completion Date: 06/30/26

Planned Corrective Action: The University will reassess internal documentation and procedures that were in place to ensure all required campus-level data and program-level data was being reported to NSLDS via NSC. Contact person responsible for corrective action: Roberta Smith/Sarah Lawson Anticipated Completion Date: 06/30/25

Corrective Action Plan The College is required to notify students who have borrowed Title IV student loans to complete loan exit counseling if they withdraw, take a leave of absence, are enrolled less than half-time or have completed their academic program. The Director, or designee, will evaluate students in the above conditions twice a month and email students about the requirement to complete loan exit counseling. In addition, at the end of the fall, spring and summer terms, the Director will request a list of students who completed programs from the Registrar, identify those with loans and send the notice. Timeline for Implementation of Corrective Action Plan: The corrective action plan was implemented in January 2025.

Finding 2024-001 Personnel Responsible for Corrective Action: Director of Financial Aid, Kerry Hallahan Anticipated Completion Date: May 2024 Corrective Action Plan: The funds for the affected student have been retur

Corrective Action: The “Timely Reporting” issue resulted from a misunderstanding in the Registrar’s Office regarding the requirements of what had to be reported and by when. We have discussed this issue with that office’s personnel and established procedures designed to prevent it from happening in the future. The “Funds Not Returned Timely” reflects continued improvements resulting from policies already established to enhance compliance with attendance reporting and tracking of those reports by the Registrar and Financial Aid Offices. The College will continue to reinforce compliance with the attendance monitoring and reporting policy, as well as refine procedures for active monitoring of those reports by these two offices. In particular, the process of evaluating whether students who are on the two-week absence report in any one class are in fact at risk of falling out of enrollment status overall. Proposed Completion Date: June 30, 2025

Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Condition: We identified one student disbursement at Fort Hays State University that was not reported to the COD within 15 days after originally being rejected by the COD system. Recommendation: We recommend that the University implement procedures to ensure that student disbursements are reported to the COD on a timely basis, particularly those that are originally rejected. Views of responsible officials: There is no disagreement with the audit finding. Action taken in response to finding: The University will evaluate and enhance current procedures to ensure the timely reporting of student disbursements to COD. Name(s) of the contact person(s) responsible for corrective action: Chantelle Arnold Planned completion date for corrective action plan: March 2025

Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Condition: We noted that for two of the students tested, the enrollment statuses reported in NSLDS were still listed as withdrawn (W) despite graduating (G). This included one student from the University of Kansas who graduated in December 2023 and one student at Fort Hays State University who graduated May 2024. In addition, we noted that some of the institutions did not have an observable, auditable internal control over the submission process at the time of testing. Recommendation: We recommend that the institutions implement procedures to ensure that enrollment statuses, particularly those who were initially marked as withdrawn but need to be moved to graduated, are reported correctly and timely. Views of responsible officials: There is no disagreement with the audit finding. Action taken in response to finding: Fort Hays State University: The University will evaluate and enhance current procedures to ensure the accurate and timely reporting of student status changes to NSLDS. University of Kansas (KU): KU has implemented a process to review students who withdrew during the semester then subsequently graduated at the end of that semester. This ensures that their enrollment status, which is accurately updated in the National Student Clearinghouse (NSC), is subsequently reflected in the National Student Loan Data System (NSLDS) in a timely manner. Pittsburg State University: The University will evaluate internal controls around NSLDS status change submission process and work with the IT department to implement an observable control procedure. Kansas State University: The University has reviewed their process and identified a control and will maintain documentation of this control occurring. Emporia State University: The University will evaluate their procedures around NSLDS status change submissions and implement a formalized control procedure to document the review of this process. Name(s) of the contact person(s) responsible for corrective action: Fort Hays State University: Chantelle Arnold, Doug Storer University of Kansas: Casey Wallace, University of Kansas Registrar Pittsburg State University: Melinda Roelfs, Registrar Kansas State University: Kelley Brundage, University Registrar Emporia State University: Sheri Brooks, Registrar Planned completion date for corrective action plan: Fort Hays State University: April 2025 University of Kansas: March 4, 2025. Pittsburg State University: July 2025 Kansas State University: March 10, 2025 Emporia State University: April 2025

Type of Finding: Significant Deficiency in Internal Control over Compliance Condition: We noted that for the following during our testing: • Return of Title IV: When a student withdraws from an institution, the institution must calculate the amount of aid to be returned to the Department of Education (ED). The following institutions did not have an observable, auditable internal control over compliance to ensure the calculations of the amounts to be returned were accurate and timely: o Emporia State University o Kansas State University • Verification: For students selected by the ED, institutions are required to verify certain applicant information. The following institutions did not have an observable, auditable internal control over compliance to ensure the verification process was done in compliance with ED regulations: o Emporia State University Recommendation: The institutions should implement observable, auditable internal controls over the Return of Title IV and Verification processes to 1) be compliant with federal regulations and 2) prevent possible instances of noncompliance, errors, and/or fraud. Views of responsible officials: There is no disagreement with the audit finding. Kansas State University management would like to stress that this was not an identified issue in previous audits and there were no issues identified with the calculation of the amounts to be returned, the return of the funds, or the timing in which Title IV Funds were returned for the items selected for compliance testing. Action taken in response to finding: Kansas State University: The University will take immediate action to implement a business practice that will allow for the documentation of a review process for processing R2T4 calculations and return of federal funds. Specifically, the individual responsible for carrying out the R2T4 process will submit the calculation to an assistant or associate director for review and approval. The reviewer, in turn, will provide their signature if approved. The approval will be associated with the R2T4 supporting documentation within the student’s financial aid file. Emporia State University: The University will evaluate internal controls around Return of Title IV and Verification and implement a formalized process to document the review of these processes, including: 1. Hiring additional staff in the Office of Financial Aid to provide support in the area of Return of Title IV, Verification, and other program administration. a. As of March 5, 2025 a position was posted for an “Assistant Director of Compliance” who will be responsible for the oversight of these specific areas as well as contributing toward quality assurance and policy and procedure development. b. As of March 5, 2025, a position was posted for a Financial Aid Coordinator to support internal processes for the administration of financial aid. 2. Drafting of an internal controls document to identify compliance controls within office policy and procedures. This will specifically include controls for Return of Title IV funds and Verification, as well as other key areas. a. Verification Controls – Ensure accuracy and completeness of verification files by: i. Implementing a comprehensive policy and procedure for verification processing. Include specific steps for completing verification, monitoring/logging completed verification files and corrections, and executing internal audits by a second individual. b. Return of Title IV Funds - Ensure accuracy and completeness of R2T4 files by: i. Implementing a comprehensive policy and procedure for withdrawal/return of funds processing. Include specific steps for identifying withdrawals, completing the return calculation, and executing internal audits by a second individual. Name(s) of the contact person(s) responsible for corrective action: Kansas State University: Tanya McGee, Associate Director within the Office of Student Financial Assistance. Emporia State University: Rebecca Grooters, Director of Financial Aid, Scholarships, Veteran Services Planned completion date for corrective action plan: Kansas State University: Full implementation to begin with R2T4 processes no later than March 15, 2025 Emporia State University: Onboarding new staff is critical to implementing the corrective action plan to ensure adequate staffing for training and oversight as described above. • By March 14, 2025: Approve Internal Controls document for outlining control parameters. Also, begin review of office policy and procedures related to Return of Title IV and Verification for completeness and accuracy. • By April 14, 2025: Have internal policy and procedure document edits completed and begin training new Assistant Director of Compliance on these processes using updated/comprehensive policy and procedure documentation. • By May 1, 2025: Fully implement internal audit protocol for a second reviewer to include monitoring of 1/4 of processed return calculations and verification records.

Type of Finding: Significant Deficiency in Internal Control Over Compliance, Other Matters Condition: We identified that for February 2024, Fort Hays State University (FHSU or the University) did not perform the monthly required Direct Loan reconciliation. Recommendation: We recommend the University implement procedures to ensure reconciliations are properly completed and reviewed each month. Views of responsible officials: There is no disagreement with the audit finding. Action taken in response to finding: After the system issues were identified in February 2024 the University utilized a consultant to resolve these issues and were able to successfully complete reconciliations through the remainder of the year. Workday has since delivered functionality that allows for the SAS reports to import directly into Workday. This delivered functionality will prevent the failure for the February 2024 reconciliation from occurring in the future. Name(s) of the contact person(s) responsible for corrective action: Chantelle Arnold Planned completion date for corrective action plan: August 2024

Type of Finding: Significant Deficiency in Internal Control Over Compliance, Other Matters Condition: We identified two Direct Loan disbursements made by Fort Hays State University (FHSU or the University) in which the University did not make the required notification. Recommendation: We recommend the University implement review procedures to ensure disbursement notifications are properly functioning prior to disbursing Direct Loans. Views of responsible officials: There is no disagreement with the audit finding. Action taken in response to finding: At the time the expiration of the engagement plan was discovered in September 2023, it was immediately resolved and put back into place to continue sending notices. We have implemented new ERP functionality and safeguards in place to ensure these engagement plans don’t expire and stop running without our knowledge and action to extend or update them. Name(s) of the contact person(s) responsible for corrective action: Dane Lonnon Planned completion date for corrective action plan: September 2023 and ongoing

Condition: Of the seven students selected for enrollment reporting testing, the Seminary did not properly update the student enrollment information for one student accurately or in a timely manner. Planned Corrective Action: The Seminary will update our institutional policies and definitions of the various types of enrollment status’s allowed to be reported to NSLDS to conform to the federal regulations. Contact person responsible for corrective action: Ashley Schreiner, Director of Financial Aid Anticipated Completion Date: 2/19/25

Condition: The College did not send out the post-disbursement email notifications to a group of students. Planned Corrective Action: The Financial Aid Office has taken immediate action to ensure that students are sent the appropriate loan disbursement notifications and is planning a longterm automated solution. Southwestern Michigan College does not automatically package loans in a student's initial financial aid offer. This strategy was part of a default management plan developed in 2014. As a result, we manually process loan requests throughout the semester as students notify us that they wish to borrow, and complete the Entrance Counseling and Master Promissory Note requirements on studentaid.gov. We will now run the disbursement notification process each week throughout the entire semester to ensure timely notifications. We are also planning to implement a long-term automated solution. This would be a process in our ERP system and will run automatically using our scheduler software. The process will send an email notification to students as new loans are processed. A record of this notification will be retained in our ERP system. Contact person responsible for corrective action: Lauren Mow, Director of Financial Aid Anticipated Completion Date: Immediate corrective action taken with automation planned for Fall 2025.

Auditor’s Recommendation: We recommend the University strengthen the controls in place to provide assurance that proper review occurs and retain documentation needed for an audit. Views of Responsible Officials and Planned Corrective Action: In regards to the Stipends sample, the University cannot determine the accuracy of the audit without seeing the sample materials with the deficiencies. Our corrective action at this time is as follows: We will evaluate our current process and look for a breakdown in the process. We will then revise the process and policy accordingly. In all cases, ORSP will review for compliance and we will monitor the processes for potential deficiencies throughout FY25. Timeline and Estimated Completion Date: June 30, 2025 Responsible Party: Office of Research and Sponsored Projects and Grant Principal Investigators.