Corrective Action Plans

Recommendation: We recommend that the University implement a formal review process as it relates to withdrawn students to ensure R2T4 calculations are being performed accurately and timely. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: ACU has created 1 additional financial aid advisor position. This position will assist the financial aid team. The Financial aid office will review the withdrawn requests sent to the financial aid inbox on a weekly basis. The withdrawn report will be worked at the end of every week to ensure all withdrawn students have been reviewed to date and all R2T4 calculations have been completed. The Director of Financial Aid will create formal training processes and will conduct training with the financial aid advisors. The Director of Financial Aid will conduct periodic reviews to ensure ongoing compliance with Title IV regulations. Name(s) of the contact person(s) responsible for corrective action: Angel Faast- Director of Financial Aid Planned completion date for corrective action plan: 01/31/2025

Recommendation: We recommend the University review its reporting procedures to ensure that students’ statuses are accurately and timely reported to NSLDS as required by regulations. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The AVP of Institutional Effectiveness will create a secure digital tracking spreadsheet that will contain file submission tracking and error resolution tracking. A digital signature protocol will be implemented that will require a sign off on submission from ADIR and AVP will verify and sign off within 48 hours of submission. A weekly check-in will be conducted on Monday that will review weekly reports, upcoming submissions, error resolution status updates and documentation for meeting outcomes. Tracking deadlines will be implemented for error resolution. ADIR must acknowledge NSC error notifications within 1 business day and error resolution must begin within 2 business days. The first attempt must be completed within 5 business days and secondary error notifications must be addressed within 3 business days. AVP IE will conduct a monthly audit and a quarterly assessment to ensure ongoing compliance with Title IV regulations. Name(s) of the contact person(s) responsible for corrective action: Jeff Phillips-AVP of Institutional Effectiveness Planned completion date for corrective action plan: End of Calendar year 2024

Beginning in Spring 2025, the Financial Aid Office will now run the ARGOs Report (Financial Aid Awards by Student) weekly prior to disbursements to find students who applied late in the academic year and need aid to disburse for the previous semester. The financial aid office will no longer need to rely on the processor to notify them when they are packaging aid.

After consulting with other Texas higher education institutions, we have identified that the initial setup of our NSC reports should have included a set of rules. We have submitted an Actionline request to Ellucian Colleague requesting their assistance. We are doing everything to ensure the Fall 2024 report, and subsequent reports, accurately report enrollment statuses.

Criteria: Special Tests and Provisions - Enrollment Reporting (34 CFR 690.93(b)(2); 34 CFR 682.61 O; 34 CFR 685.309). Institutions are required to report enrollment information. Reporting (34 CFR 690.93(b)(2); 34 CFR 682.610; 34 CFR 685.309). Institutions are required to report enrollment information. Condition: The University did not report 3 student's status changes timely, the University reported the incorrect enrollment effective date for 3 students in the campus level records, the University reported the incorrect enrollment effective date for 4 students in the program level records, and the University recorded the incorrect enrollment status for 2 students in both the campus and program level records. Planned Corrective Actions: - LeTourneau is in the process of implementing a new student information system. As part of the implementation, all processes within the Registrar and Student Financial Services are being reviewed. These deficiencies will be addressed as part of that initiative. Responsible Official: Danielle Jeffress, University Registrar Estimated Completion Date: December 31, 2025

Views of the responsible official and planned corrective actions: Cisco College has updated the process for the NSLDS reporting. The Director of Institutional Effectiveness & Planning will be the reporting official and the Dean of Enrollment Services will be the back-up person for the NSLDS reporting. Both positions have been trained and will ensure that the reporting will continue if there is ever another gap in replacing an open position.

Condition: The University did not return Title IV funds within 45 days of the date of determination of withdrawal for four students. Views of Responsible Officials and Planned Corrective Action: Beginning in the Fall 2024 semester, Student Account Services and University Billing (SASUB) implemented a dedicated R2T4 SharePoint site to enhance the tracking and management of withdrawn students as identified. The site includes dynamic lists that log students requiring a return of Title IV funds as they are identified. Each entry records the student’s date of determination, and the corresponding 45-day return deadline. This centralized platform allows authorized users to easily view pending returns, associated deadlines, and the completion dates for each case. The system improves the accuracy of Title IV fund return tracking, enhances accountability, and fosters greater transparency and communication among university stakeholders. Key personnel and leadership from SASUB and the Office of Scholarships and Financial Aid have access to the SharePoint site and conduct regular reviews to ensure compliance and operational efficiency. Contact person responsible for corrective action: Director of Student Account Services and University Billing Anticipated Completion Date: 8/26/2024

2024-001: Reporting This finding is the result of human error when completing the Fiscal Operations Report and Application to Participate (FISAP). An extra digit was added to the tuition/fees charged, changing the tuition and fees charged from $6,880,369 to $68,880,369. This was missed in the review of the FISAP prior to submission. Corrective Action: The Financial Aid Office took great care in reviewing the 2023-2024 (for 2025-2026) FISAP for accuracy. Additionally, the amount requested for SEOG and FWS is the exact same as requested on the 2022-2023 (for 2024-2025) FISAP, rather than the inflated fair share. The Financial Aid Office will request up to the fair share on the 2024-2025 (for 2026-2027) FISAP. This issue has been successfully addressed. Anticipated Date of Correction: 9/30/2024 Contact Person: Shanna Vargas, Director of Financial Aid

2024-002: Reporting This finding is a result of transferring Primary Data Point Administration from Amy Murphy to Shanna Vargas. Part of this issue reflected SAIG/CPS/COD/NSLDS access from being set up correctly and resulted in many hours of contact and meetings with SAIG professionals to correct. Corrective Action: The Financial Aid Office has worked with SAIG professionals to correct this issue. The Financial Aid Office has developed a schedule and process to complete monthly direct loan reconciliation, as well as ensuring other members have access to complete this should the PDPA’s access not be available. Anticipated Date of Correction: Immediately Contact Person: Shanna Vargas, Director of Financial Aid

2024-005: Enrollment Reporting Unofficially withdrawn students (students who failed to earn credit during the term) are reviewed after the end of the semester, and R2T4 is calculated, where required. However, there was not a process in place for the Registrar to update the Enrollment Reporting as a result of the review process. Corrective Action: As part of the process of reviewing these students and performing the R2T4 calculation, the Financial Aid Office will send a report of unofficially withdrawn students to the Registrar to ensure that enrollment reporting is appropriately updated. Anticipated Date of Correction: Immediately Contact People: Shanna Vargas, Director of Financial Aid, and Kayla Miller, Registrar

2024-004: Return of Title IV Funds This student’s late calculation was due to the failure to review withdrawal reports during the changeover in director responsibilities. All students that fail to earn any credit during the semester are reviewed at the end of each semester. This student was found at that point, and the calculation was completed. Corrective Action: The withdrawal report is reviewed at minimum each week by the Financial Aid Office and R2T4s are calculated timely. This issue has been resolved. Anticipated Date of Correction: Immediately Contact Person: Shanna Vargas, Director of Financial Aid

2024-003: Cash Management This finding is the result of transferring Primary Data Point Administration from Amy Murphy to Shanna Vargas. Corrective Action: The Financial Aid Office has developed a schedule and process to complete monthly direct loan reconciliation, as well as ensuring other members have access to complete this should the PDPA’s access not be available. Anticipated Date of Correction: 8/19/2024 Contact Person: Shanna Vargas, Director of Financial Aid

Need Analysis Planned Corrective Action: Additional training was provided to the appropriate staff to identify and award needbased funds within regulatory guidelines. Person Responsible for Corrective Action Plan: Bryan Taylor, Associate Director of SFS Processing Anticipated Date of Completion: December 15, 2024

Incorrect Return of Title IV Funds Calculations Planned Corrective Action: The Student Financial Services Office will train additional staff on R2T4 procedures and then conduct secondary reviews to validate the correctness of the R2T4 calculations and return amounts. Person Responsible for Corrective Action Plan: Bryan Taylor, Associate Director of SFS Processing Anticipated Date of Completion: July 1, 2025

The disbursement process of such refunds was transferred to a new team within the Finance/Treasury branch. The team size was increased from 2 to 4 members. Members added to this team have relevant previous experience in student accounts. The additional resources as well as their experience and knowledge should ensure that funds are returned in a timely manner that complies with program requirements.

FINDINGS — FEDERAL AWARD PROGRAMS AUDITS DEPARTMENT OF EDUCATION 2024-001 Student Financial Aid – CFDA No. 84.007, 84.268, 84.063, 84.033 Recommendation: 1) We recommend the College reevaluate its procedures and review policies surrounding reporting status changes to NSLDS to ensure the enrollment effective date reported to NSLDS is aligning with the College’s last date of attendance. 2) We recommend the College reevaluate its procedures and review policies surrounding reporting program enrollment effective dates to NSLDS. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Corrective Action Response Regarding Graduation Date Discrepancy 1. Immediate Correction of Records: • Verified and corrected all affected student records to reflect accurate graduation dates. • Graduation dates for graduates from Fall 2023 to Summer 2024 will be updated. This action ensures alignment between the student information system, official transcripts, and graduation rosters. 2. Process and Policy Updates: • Internal policies will be revised to provide clear guidance on assigning and verifying graduation dates. Corrective Action Response Regarding Enrollment Transmission Reporting Timeline Beyond the 60-Day Requirement 1. Policy and Procedure Enhancements: • Updated internal policies to require enrollment data transmission at least every 20 days, well ahead of the 60-day federal requirement to ensure receipt by the National Student Loan Data System (NSLDS) in a timely manner. • Staff will periodically request a transmission audit from the Clearinghouse verifying that the institution’s enrollment data has been forwarded to the National Student Loan Data System (NSLDS). Name of the contact person responsible for corrective action: Dayne Chance, Director of Financial Aid at 908-709-7089 If the Department of Education has questions regarding this plan, please contact the appropriate individual outlined above.

Finding 2024-001 – Special Tests and Provisions – Enrollment Reporting (Noncompliance and Significant Deficiency) Identification of the Federal Program - Student Financial Aid Cluster - Assistance Listing Nos. 84.007, 84.033, 84.038, 84.063, and 84.268 Criteria - Institutions are required to report enrollment information under the Pell grant and the Direct loan program via the National Student Loan Data System (NSLDS). The administration of the Title IV programs depends heavily on the accuracy and timeliness of the enrollment information reported by institutions. Institutions must review, update, and verify student enrollment statuses, program information, and effective dates reported to NSLDS. Institutions are responsible for accurate reporting. According to 34 CFR 685.309(2), the University is required to notify the Department of Education via the NSLDS if a “student has ceased to be enrolled on at least a half-time basis for the period for which the loan was intended”. Changes to status are required to be reported within 30 days of becoming aware of the status change, or with the next schedule transmission of statuses if the scheduled transmission is within 60 days. Condition - A sample of 40 students were selected from the population of all students who received federal student financial aid during the year ended May 31, 2024. We obtained the student records and tested compliance with federal regulations for the specific loans and grants. For 13 out of the 40 students selected for Enrollment Reporting testing, the status change to withdrawn was not reported within the 60 day reporting window after the status change was effective. For 7 out of the 40 students selected for Enrollment Reporting testing, the status change was not reported to NSLDS. Cause - The University’s processes of internal controls for reporting enrollment information and to timely report student status changes to NSLDS were not adequate. Effect - Enrollment reporting to NSLDS did not include accurate information. Identification of Repeat Finding – Repeat finding of prior year finding 2023-001. Student status changes were not reported to NSLDS within the required timeframe. Recommendation - We recommend the University revise its processes for reporting student status changes to NSLDS. The University should implement a process to review, update, and verify student enrollment statuses that appear on the Enrollment Reporting roster files. We also recommend that management implement controls to ensure reported changes are timely and correctly reported to the NSLDS. Views of Responsible Officials - Management agrees with the finding. Out of the 20 exceptions included in this finding, 16 were properly and timely reported by the University to the third-party service provider. The University is currently working with their third-party service provider to identify the root cause of the untimely reporting. Corrective Action Plan for Finding 2024-001 - The University provided additional training and monitoring to the employees involved in this process. Furthermore, the University engaged a former employee on a contractual basis to assist with the reporting process. The contract employee has significant experience in reporting information to the University’s third-party agent, National Student Clearinghouse (NSC), and to the National Student Loan Data System (NSLDS). The University is actively working with the Audit Resources team at NSC to revise our reporting processes and develop a reporting schedule that will more closely align with the University's calendar and eliminate the root cause of the data errors.

Corrective Action Plan Enrollment information was not submitted within the required timeframe by the University. Personnel Responsible for Corrective Action: Dena Norris, Associate Vice Chancellor of Student Financial Services, and Tara Dettmer, Director of Financial Aid – Fiscal Operations Anticipated Completion Date: Corrective action plan will be implemented by June 30, 2025. Views of Responsible Officials and Planned Corrective Action Plan: Metropolitan Community College (MCC) will begin a new monitoring process for enrollment reporting to ensure compliance and timely reporting of all students. Enrollment status changes are reported every month to the National Student Clearinghouse (NSC), MCC will make a random selection of 10-15 students each month to verify data was correctly transmitted to NSC. A secondary check of these students will be done to ensure the data is also transmitted to the National Student Loan Data System (NSLDS). MCC will also ensure error reports and other data issues are resolved in a timely manner to ensure reporting of students is completed within the regulatory timeframe.

Responsible personnel will review calculations as they are completed.

Identifying Number: 2024‐004 – U.S. Department of Education Student Financial Assistance Cluster – Special Tests and Provisions: Enrollment Reporting Finding: The College failed to accurately and timely report student status changes to NSLDS for 10 students out of 11 students tested Contact Person Responsible for Corrective Action Plan: Director of Financial Aid Corrective Action Plan: The Financial Aid Director and the Assistant Registrar have been directed to work together on a bi‐weekly basis to determine the appropriate status of all students who are receiving financial aid. Earlier this semester, the Registrar’s Office was directed to issue a daily report of enrolled students as well as what actions led to the change in total enrolled students if the headcount change, including the students’ names and the action (withdrawal, administrative withdrawal, suspension, etc.) The Financial Aid Director will begin working more closely with the Assistant Registrar to accurately report individual enrollment status to the campus administration and the National Student Clearinghouse. Anticipated Completion Date: January 2025

Identifying Number: 2024‐003 ‐ U.S. Department of Education Student Financial Assistance Cluster – Special Tests and Provisions: Return of Title IV Funds Finding: The College failed to return title IV funds to the student within the 45‐day time frame for 1 student out of 3 students tested. Contact Person Responsible for Corrective Action Plan: Director of Financial Aid Corrective Action Plan: The Vice President of Academic Life (VPAL) has been informing the Director of Financial Aid ofeach student who has withdrawn, been administratively withdrawn, or been suspended from the College so as to be able to accurately calculate the return of Title IV funds in a timely manner. Anticipated Completion Date: Immediately

Finding 2024-001 Condition The auditor tested 15 Title IV returns, and noted that 10 returns were deposited or transferred to the SFA account or EFTs were initiated to ED more than 45 days after the date of determination. Corrective Action Plan Corrective Action Planned: In response to prior audit concerns regarding R2T4 (Return to Title IV) calculations, MATC implemented a comprehensive retraining program for staff on R2T4 regulations and requirements. Additionally, we instituted a secondary review process for all R2T4 calculations, which increased processing times. Since implementing these measures, we believe our staff is now sufficiently trained to accurately process R2T4 calculations without requiring a secondary review. To maintain compliance and quality assurance, the Financial Aid Processing Supervisor will oversee the R2T4 process to ensure all calculations and related returns/disbursements are completed within the 45-day regulatory timeframe. To further ensure accuracy and compliance, the Financial Aid Compliance Officer will conduct periodic audits by selecting a random sample of ten R2T4 calculations. These audits will confirm that the calculations are accurate and that returns/disbursements meet the 45-day processing requirement. We are confident that these measures will address prior concerns and uphold compliance with regulatory standards. Name(s) of Contact Person(s) Responsible for Corrective Action: Joshua Montavon, Wendy Hilvo, and Tina Johann Anticipated Completion Date: June 30, 2024

2024-002: Missing Exit Counseling Documentation - Student Financial Aid Cluster - Assistance Listing #s 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 40 did not have documentation in their file that exit counseling was sent thirty days after the student withdrew. We consider the missing exit counseling to be an instance of non-compliance with the Eligibility Compliance Requirement. Corrective Action Plan We have updated our Loan Procedures to include running an internal report on all loan students on the 1st and 15th of every month, or the next work day following those dates if they land on a day the campus is closed. If a student with loans has withdrawn completely and stopped attending, we will send an exit letter within 7 business days of discovering that the student has ceased attending. Responsible Person for Corrective Action Plan Isamar Taylor - Director of Financial Aid and Jill Wohrley - Financial Aid Reconciliation and Compliance Specialist Implementation Date of Corrective Action Plan 10/16/2024

2024-001: Late Return of Title IV Financial Aid - Student Financial Aid Cluster – Assistance Listing #s 84.007, 84.033, 84.063, 84.268 - Grant Period - Year Ended June 30, 2024 Condition Found During our Return of Title IV Fund testing, we noted that the College did not return Title IV Student Financial Aid for five out of twenty-five students tested until after 45 days when the student ceased attendance. We consider the untimely calculation and Return of Title IV Student Financial Aid to be a Significant Deficiency relating to the Special Tests and Provisions Compliance Requirement. Corrective Action Plan To rectify this issue, we have taken the following corrective actions: Enhanced Monitoring and Reporting: Run our internal tracking report once a week to monitor and ensure timely Return of Title IV (R2T4) calculations. This system will alert financial aid staff when a student withdraws, prompting immediate action to review and process the return within the required 45-day timeframe. Staff Training and Certification: Conducted a comprehensive training session for all financial aid staff to reinforce the importance of timely R2T4 calculations. Training covered procedures for identifying students who have ceased attendance, the calculation process, and deadlines for completing returns. Regular refresher training sessions will be scheduled each term to ensure staff remain informed and compliant with federal guidelines. Audit and Quality Control Checks: Institute periodic quality control checks by the Financial Aid Reconciliation and Compliance Specialist to verify the accuracy and timeliness of R2T4 calculations. Responsible Person for Corrective Action Plan Isamar Taylor - Director of Financial Aid and Jill Wohrley - Financial Aid Reconciliation and Compliance Specialist Implementation Date of Corrective Action Plan 10/16/2024

Condition: During our review of the return of Title IV funds, we noted that students were not being properly identified as withdrawn, either officially or unofficially. This resulted in 4 students noted that never had a calculation performed, but should have, and 4 students that were reported late. Criteria: When a recipient of Title IV funds withdraws from an institution during a payment period or period of enrollment in which the recipient began attendance, the institution must perform a Return of Title IV Funds calculation to determine the amount of Title IV assistance the student earned as of the student’s withdrawal date. Cause: Student Financial Aid personnel did not have a method to properly identify students who are required to have a return of funds calculation. Effect: Funds required to be sent back to the Department of Education are either missed or are late. Perspective: There has been high turnover in the SFA department, including a time where there was not a Director in place. Significant personnel changes were made at the end of the June 30, 2024 year. Reports are being obtained from IT department regularly. Recommendation: We recommend training of Student Financial Aid personnel on the rules and regulations over return of funds. In addition, we recommend that Student Financial Aid personnel work with the IT department to develop a report that can be ran weekly or bi-weekly to identify the students and timely prepare the calculations. Views of Responsible Officials and Planned Corrective Actions: Dodge City Community College staff involved are undergoing training to learn requirements. Processes and procedures have been developed to ensure timely calculations and refunds.