Corrective Action Plans

Finding Reference Number: 2024-002 Initial Fiscal Year: 2024 Summary of Finding: 2024-002 Significant Deficiency: Return to Title IV Funds (U.S. Department of Education, William D. Ford Direct Loan Program, ALN #84.268; Federal Pell Grant Program, ALN #84.063) In accordance with 34 CFR 668.22(f), in the calculation of the percentage of payment period and/or period of enrollment completed, the total number of calendar days in a payment and/or enrollment period includes all days within the period, except that institutionally scheduled breaks of at least 5 consecutive calendar days and days in which the student was on an approved leave of absence are excluded from the total number of calendar days in a payment period and/or period of enrollment. During the audit, it was noted that the University used the incorrect number of completed days in the payment period or period of enrollment in calculating the percentage of the Title IV aid earned. The audit included a detailed testing of 5 withdrawal student files, of which this significant deficiency applies to 1, indicating an error rate of 20.0%. This finding is monetary in nature. In the instances noted in testing, the total error identified is $1,992 in over-award. Extrapolation of this monetary error was not necessary as the 5 withdrawal students tested as part of the 2024 audit constitute the entire withdrawal population for the period under audit. The University should ensure that the number of completed days in the payment period or period of enrollment are counted correctly utilizing the guidance provided by the Compliance Supplement and the Student Financial Aid Handbook. Entity’s Corrective Action Plan: Corrective Action Plan Summary: The University has determined that this matter constitutes a unique training situation involving the application of procedures related to the Return of Title IV funds. In particular, the University recognizes the need for enhanced training concerning the accurate counting of days when a student withdraws, provides written notification of their intent to attend a future module within the same term, and subsequently withdraws from that second module. The error in question arose from the miscalculation of days, where the University inadvertently counted all days in the initial module rather than counting only the days leading up to the student's initial withdrawal prior to the final withdrawal from the second module. This oversight was attributed to an individual employee, and the University has proactively implemented comprehensive training and procedural safeguards to prevent similar occurrences in the future. Anticipated Completion Date: August 01, 2024 The corrective action plan has been implemented to resolve the prior year finding, helping to ensure that future dates are accurate. Name and Title of Responsible Person: Rocky Christensen, Director of Financial Aid.

Enrollment Reporting Recommendation: We recommend the College strengthen its review and reporting procedures for enrollment status changes to ensure timely and accurate updates to NSLDS. View of Responsible Officials and Planned Corrective Actions: The College acknowledges the errors in the reporting and is updating its procedures to ensure prompt communication of status changes. Staff will receive training to correctly handle student enrollment updates, and the institution will implement additional checks to avoid future errors.

Disbursements to or on Behalf of Students Recommendation: We recommend the College review its refund procedures and implement controls to ensure refunds are disbursed within the required time frame. View of Responsible Officials and Planned Corrective Actions: The College will review its internal processes for handling refunds and ensure that future refunds are processed within the 14-day window. Training will be provided to the responsible staff to improve compliance with regulations.

Contact person responsible for correction action – Michell Hall, CFO Anticipated completion date – June 30, 2024 Corrective action Sterling College agrees with the auditors finding regarding special reporting. We do not anticipate any issues with future reporting as we now understand the process for the reporting.

Contact person responsible for correction action – Mitzi Suhler, Financial Aid Director Anticipated completion date – June 30, 2024 Corrective action Sterling College agrees with the finding. Per our policy, we review enrollment reporting at the end of each term to ensure that students are getting reported accurately. We are doing everything we can to ensure compliance in this area. We will continue to be diligent about enrollment reporting and make sure we review carefully the dates that are submitted. We are still in the process of implementing our new software that will help with this process.

In order to prevent students from being missed in enrollment reporting, the College has enhanced its process to include a check and balance of the 100% refund report provided by the Registrar's Office on the first day of school against the 75% and 40% refund reports; this review will ensure that all exited students are reported as exited in the approporiate timeframe. The Exit list report has historically had a column where the Registrar records the date when the student information is submitted to NSC (National Student Clearinghouse). We have now added a new field to the Exit list report that Financial Aid will be responsible for entering the date at which confirmation is made that the data is correct in NSLDS. The FA Office will be responsible for checking the NSC and NSLDS to ensure all withdrawn students are reported accurately. Following the 40% refund period, the College's Student Success Committee will review a list of students at risk of exiting, and will confirm that any exits after the 40% refund period have been accurately recorded.

Student Financial Aid Cluster – Assistance Listing No. 84.063 & 84.268 Recommendation: We recommend that the College rebuilds the ‘Primary Program GT eForm’ to include a check that verifies all programs are not designated as Secondary. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Records staff now individually review each form submission to ensure a Primary program is appropriately assigned. In addition, a fix is being implemented to the District’s NSC file submission to verify students who have Primary and Secondary programs appear accurately. A cross-functional team has been established to create an audit report to scale NSC file submissions, as well. Name(s) of the contact person(s) responsible for corrective action: Laurie Grigg, Chief Financial Officer Planned completion date for corrective action plan: June 30, 2025

Student Financial Aid Cluster – Assistance Listing No. 84.063, 84.268, 84.007, 84.033 Recommendation: We recommend that the College verifies all withdrawal dates surrounding scheduled breaks. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The withdrawal date and student payment has been updated to reflect the appropriate calculation. Name(s) of the contact person(s) responsible for corrective action: Laurie Grigg, Chief Financial Officer Planned completion date for corrective action plan: June 30, 2025

JEVS HUMAN SERVICES AND AFFILIATES CORRECTIVE ACTION PLAN YEAR ENDED JUNE 30, 2024 FINDINGS – FEDERAL AWARD PROGRAM AUDITS (CONTINUED) U.S. Department of Education 2024-002 Significant Deficiency in Internal Control over Compliance Student Financial Aid Cluster: 84.007 - Federal Supplemental Educational Opportunity Grants 84.063 – Federal Pell Grant Program 84.268 – Federal Direct Student Loans Condition: During the audit, we noted JEVS Human Service has gaps within their Written Information Security Program and policies when compared to the Safeguards Rule. Recommendation: We recommend management continue to evaluate its written information security plan and establish the required documentation in accordance with GLBA safeguard rules. Explanation of Disagreement with Audit Finding There is no disagreement with the audit finding. Action taken in response to finding: Management will evaluate its written information security plan and establish the required documentation in accordance with GLBA safeguard rules. Planned completion date for corrective action plan: March 31, 2025

JEVS HUMAN SERVICES AND AFFILIATES CORRECTIVE ACTION PLAN YEAR ENDED JUNE 30, 2024 FINDINGS – FEDERAL AWARD PROGRAM AUDITS U.S. Department of Education 2024-001 Significant Deficiency in Internal Control over Compliance Student Financial Aid Cluster: 84.063 – Federal Pell Grant Program 84.268 – Federal Direct Student Loans Condition: Certain students’ enrollment information was not reported accurately or timely to the National Student Loan Data System (NSLDS). Recommendation: We recommend the College to review its procedures for transmitting accurate information to the NSLDS. Furthermore, we suggest that the College establish a process to enhance oversight of the submissions completed by the third-party servicer. Explanation of Disagreement with Audit Finding There is no disagreement with the audit finding. Action taken in response to finding: The College has reviewed and updated policies and procedures on reporting enrollment. A new procedure had been added to the process, requiring a designated employee to check and review on a weekly basis the Student Status Confirmation Report (SSCR) on the National Student Clearinghouse (NSC) SSCR Error Correction Platform. The designated employee will document the review and resolution of items identified on the error report. This ensures that any errors are resolved within ten days of receipt, as required by the Department of Education for all schools receiving and distributing Title IV Aid. Planned completion date for corrective action plan: December 31, 2024

Thomas College will ensure that there are dual controls relating to the programs like the Perkins Loan Program going forward to ensure that both the CFO and the Controller are able to access and make deposits. The CFO position was vacant at the time and the Controller was filling both positions, which led to the oversight. When the new CFO started, they determined that there was no lost interest due to the timing of the cash deposit and going forward they would work in collaboration to ensure this was not missed in the future.

Thomas College has refined internal reporting policies and procedures to confirm that student enrollment is reported accurately and in a timely manner. The College uses the National Student Clearinghouse as a data vendor for reporting to NSLDS. The College agrees the students were incorrectly report to NSLDS. However, the student records were regularly updated with the National Student Clearinghouse, according to policies and procedures, NSC was not then transmitting some student records to NSLDS due to a conflict in data reported by a prior instituition concerning name and mismatched SSN. The College has identified the error within the National Student Clearinghouse (NSC). The following findings and corrective actions have been adopted: 1) Additional one on one training with the NSC has been completed to better understand the cause of the finding. The error that is preventing the release of information to NSLDS has been identified and steps required to resolve the error have been communicated. This training will expand to all Thomas College employees who oversee and process enrollment reporting. 2) Thomas College is closely monitoring the processing details from each submission file sent from the college to NSC to identify students not being sent from NSC to NSLDS. Thomas College is submitting the necessary, required paperwork for verification to the NSC, as needed; to verify the student's identify and information, an example of this documentation is an ISIR recorded provided by SFS. The NSC send an automated email to enrollment reporting staff when changes are made and a follow up email requesting additional information if needed. Once resolved, student are no longer shown on the transmission rejection list and are being sent to NSLDS.

Views of Responsible Officials: The Office of the Registrar had a significant decrease in staff who were experienced in the required reporting during this period. Also, we asked Ellucian staff, who support our Power Campus Student Information System and who were responsible for setting up the report, to review the reporting process and the coding generating the report itself for accuracy. At one point, the staff assigned to us were changed by Ellucian and so the process and report review were not completed in a timely manner. All these factors contributed to delay in reporting and old information being included. With new staffing in place now and having had training from National Student Clearinghouse, as well as working with a new group of Ellucian consultants who have reviewed the process and coding for the report, we are back on track with reporting. We expect that coding changes to the report that are being completed by Ellucian consultants will remove any incorrect data.

Student Financial Assistance Cluster – Assistance Listing No. Various Recommendation: We recommend the University reevaluate its procedures and review policies surrounding reporting status changes to NSLDS to put a process in place to ensure the enrollment effective date reported to NSLDS on the campus and program level is aligning with the University. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The process Union Adventist University follows to ensure that enrollment effective dates as reported to NSLDS are submitted and coordinated through the Records Office. Records submits the list of enrollment effective dates to the National Student Clearinghouse. The Records office will be monitoring for error reports from National Student Clearinghouse that might affect the change of enrollment effective dates. The Records submits monthly reports to the National Student Clearinghouse for any changes that occur during the month. Name(s) of the contact person(s) responsible for corrective action: Tricia Harris, Director of Student Financial Services Planned completion date for corrective action plan: The goal date for this project to be completed is prior to the FY25 audit.

The Director of Students Accounts will review current processes and implement the recommendation to process refunds earlier in the 14-day window. Updated procedures will be documented, and the Student Accounts Office staff will be trained on the new procedures. Responsible Party: Steven Perrotta Vice President for Finance and Administration Phone: (603) 897-8501 Anticipated Completion Date: December 31, 2024

Contact Person Responsible: Kelli Engelhardt – Lead Mackenzie Stick - Support Corrective Actions Planned: 1. Enhanced Monitoring of Subsidized Loan Eligibility o Accelerated Nursing Students’ loan eligibility will be closely monitored, particularly during the first two semesters, to identify and prevent over-awards. o Financial Aid staff will utilize Jenzabar Student Information System reporting tools to track Subsidized Loan usage and eligibility. o Anticipated Completion Date: Ongoing; Semester-based Review, effective Spring 2025 2. Preventive Measures for Timing Issues o Financial Aid staff will actively monitor updates to ISIR records and NSLDS reporting to mitigate timing-related errors. o Steps will be taken to identify students at risk for loan overpayment earlier in the process. o Anticipated Completion Date: February 1, 2025, and then ongoing with emphasis on the first two weeks of every semester. Commitment to Compliance: The University will leverage all available tools to prevent timing-related errors and ensure accurate Subsidized Loan awarding in future years.

Contact Person(s) Responsible: Kelli Engelhardt – Lead Mackenzie Stick - Support Corrective Actions Planned: 1. Evaluate Opportunity for Staffing Enhancements o A working group will be assembled to evaluate the feasibility of adding additional staff to the Financial Aid Department to ensure proper segregation of duties and adherence to federal guidelines. o If additional staffing is not possible due to budget constraints, existing resources within the University will be explored to meet compliance goals. o Anticipated Completion Date: March 30th, 2025 2. Implementation of Internal Control Procedures o Eligibility Determinations: Manual and automated eligibility processes will be reviewed by designated staff and supervised by the Vice President for Enrollment Management on a semester basis to ensure compliance. o Return of Funds Calculations: Dual-review processes for return of funds calculations will be implemented each semester to mitigate errors. o Anticipated Completion Date: February 28, 2025 3. Training and Documentation o Annual training will continue for the Financial Aid team to ensure compliance with the Federal Student Aid Handbook. o Comprehensive documentation and supervisory review checklists will be developed to maintain transparency. o Anticipated Completion Date: Ongoing; Annual Review in July 2025 Commitment to Compliance: The University is committed to rectifying this finding and will ensure future compliance with federal regulations.

Federal Awards Findings And Recommendations 2024-001 Special Tests and Provisions - Enrollment Reporting View of Responsible Officials and Corrective Action Plan The Financial Aid and Admissions and Records departments in collaboration with the district, contracted with an outside consultant to help identify why the enrollment reporting process was not accurately reporting students' enrollment levels. It was identified that a system setting was not set to capture chnage sof enrollment levels within the specific terms. Based on the consultant recommendation, the district agreed to update system settings to accurately report student enrollment level changes throughout the term. These adjustments to the system settings will allow for the accurate and timely reporting of information to the National Student Loan Database System (NSLDS). This ongoing change to system settings is in place beginning with the Fall 2024 term. Additionally, the district has implemented internal controls to include: Developed additional training and Information Technology support structures to maintain data integrity associated with the National Student Clearinghouse (NSC) data submission, Developed pre data submission audit report to check for accuracy prior to the upload of required data to the NSC, and Created an internal work group consisting of financial aid and admissions and records professionals to review information associated with NSC reports prior to the scheduled submission of requested information. Implementation Date September 2024

Finding 2024-001 Return to Title IV Condition While testing R2T4, the University was unable to provide proof of a documented review for 2 of the 25 calculations selected for testing. RESPONSE: Husson University agrees with this finding. The financial aid office had staff turn-over that lead to new staff taking over this function. As part of the training, the staff who performed these calculations were under the impression that no secondary review was required for students who earned 100% of the awarded financial aid based on withdrawal after the 60% point of the payment period. CORRECTIVE ACTION: Husson reviewed all calculations completed after 60% point of the term for 2023-2024 to ensure they were accurate. Moving forward all R2T4 calculations are reviewed by a second individual. A staff training was completed to ensure that the financial aid staff understand that a second review is required for all R2T4 calculations completed to ensure the calculation is accurate regardless of the % of term completed. RESPONSIBLE PARTY: Sherry Watson, Director of Financial Aid COMPLETION DATE: July 2024

Responsible Individual: Joan Romano, Registrar Contact Information: jromano2@berklee.edu, 617-747-2475 Corrective Actions: Management concurs with the recommendations provided. The Registrar’s Office will implement a reconciliation of the Ellucian Colleague Enrollment Information and data provided to NSC (the National Student Clearinghouse). The reconciliations will be reviewed by Ari Kaufman, Associate Registrar, and confirmed by Joan Romano, Registrar before submission to ensure that it’s performed timely and accurately. Notifications or any discrepancies will be sent to NSC immediately informing them of any necessary corrections. Estimated Date of Completion: March 31, 2025 Status of Completion: In Process

Responsible Individual: Kathy Anderson, Associate Vice President, Student Financial Services Contact Information: kanderson8@berklee.edu, 617-747-6595 Management concurs with the recommendations provided. To remediate this issue, there are new personnel assigned to complete the process and ensure there are no gaps. The Director of Financial Aid Operations will ensure that the process is run as scheduled by the Assistant Director of Financial Aid Operations. In addition, there is an overflow schedule with the Operations team, if the primary or secondary Assistant Director assigned to this task will be out of the office on the day the report is run. Berklee has changed the date the notifications are sent to students. Berklee has changed the date the notifications are sent to the students. This ensures that notices are sent on day zero and the following week on day seven. This provides Berklee with a second chance to remediate student records that are not resolved on disbursement date zero. Lastly, we have built in additional controls to this process to include a thorough review of error logs so that any errors are resolved and notification sent within the required timeframe Management concurs with the recommendations provided. . Estimated Date of Completion: March 31, 2025 Status of Completion: In Process

Management agrees with the current year’s finding and recommendations to ensure timeliness of the Return of Title IV funds. Management has determined this to be an isolated incident because the Registrar dropped the student on May 9, 2024, following an investigation into the disparity between the student’s self-reported last date of attendance, March 14, 2024, and the receipt of the form on April 15, 2024. Accordingly, May 9, 2024, became the institution’s determination date due to unknown last date of attendance from the faculty. Furthermore, the University offices were closed at 1pm on April 22, 2024, and closed entirely on April 23, 24, 29, 30. The investigation and University closures took the office outside the 45-day compliance requirement. The University plans to enhance the policy for LOA and Withdrawal forms to have the Last Date of Attendance removed as a student self-reported option. In the future, the determination date will be based on date of receipt of the form and not a student-reported, last date of attendance. We believe this finding will be remediated in fiscal 2025.

Management agrees that the current year’s finding is related to the prior year finding and the recommendations should be to ensure staff are aware of the University’s policies and procedures in order to ensure timely enrollment reporting. A delay in reporting enrollment information to NSLDS was brought on by a lag in reporting to National Student Clearinghouse “NSC” due to corrupted “Graduates Only” files. This lag was exacerbated by the time it took to remedy the output files by the University’s ITS department. Off-cycle “Degree Verify” files were submitted to mitigate the impact and allow for the earliest possible SSCR date. This strategy was not effective in all cases. YU is confident that all students were reported correctly (other than the 4 found through the audit). To correct this mistake in the future, the Registrar will implement a process by which NSLDS Graduation status checks are performed, on a sample basis, based on the Grad Only files sent to NSC. We believe this finding will be remediated in fiscal 2025 by correcting the graduation status of the four NSLDS identified with problems in fiscal 2024. In order to instill confidence in our processes, we will return to NSLDS to review all potentially, impacted graduated students during the outage period and assure that they were reported properly.

R2T4 Finding Federal Agency Name: U.S. Department of Education Program Name: Student Financial Assistance Cluster ALN: 84.268, 84.063 and 84.007 Finding Summary: Errors in return to Title IV calculations: Calculations for five students included various errors. Errors included one late determination of withdrawal date (more than 30 days after the end of the period of enrollment), three returns completed more than 45 days after the withdrawal date, two incorrect percentage of aid earned calculations, and one overpayment to the Department of Education. Responsible Individuals: Tim Sechrist, Director of Financial Aid Corrective Action Plan: We agree with the auditors’ findings and recommendations. Financial Aid Office staff that will deal with withdrawals and returns will complete the FSA Training Webinar Videos for R2T4. These include the R2T4 Essentials and R2T4 Modules webinars available online. We will implement a second review of calculations with an additional staff member added to the process. We will have the Financial Aid Counselor review withdrawals as they are received and complete the preliminary calculation. The Counselor will pass the preliminary calculation to the Director of Financial Aid for review prior to processing the returns. We will work with the Online Learning Office to report and retain academic activity for distance education students. Anticipated Completion Date: December 31, 2024

Recommendation: We recommend the College implement IT policies and create an updated WISP to ensure the College is compliant with the GLBA Safeguards Rule. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: We are working on an updated WISP and plan to have it approved by college administration prior to the end of the academic year. Name(s) of the contact person(s) responsible for corrective action: Greg Riehl Planned completion date for corrective action plan: 6/30/2025