Corrective Action Plans

Finding No. 2024-001 Excess of Cash Condition Found In nine (9) of fifty-three (53) return drawdowns from the San Juan Campus, returns were not properly returned on G-5, creating excess cash for more than the required period of ten (10) days (3 business days plus an additional seven calendar days). In addition, refunds were not returned on G-5 in a timely manner during the required period of thirty (30) days. Corrective Action Plan The institution will appoint a dedicated G-5 administrator in Puerto Rico, independent of the Miami office, to ensure compliance. This role will be complemented by the active pursuit and implementation of advanced system functionalities designed to enhance the identification of student cases and automate and streamline processes. This comprehensive initiative will not only fortify existing procedures but will also significantly enhance operational efficiency and accountability, with an immediate escalation protocol requiring that any delays or processing issues be reported to management for prompt resolution. Name(s) of the Contact Person(s) Responsible for Corrective Action Héctor L. Peña, Director of Finance Ramón L. Menéndez, CFO Dr. Antonio Llorens, CIO Anticipated Completion Date Will be completed on or before December 15, 2024

Finding 2024-001: Unpaid Credit Balance – As the funds were used to pay prior academic year tuition, it is recommended the Institution increase controls over credit balances. Comments on Finding and Recommendation(s): HJC concurs with the finding. Student had requested funds be used to pay prior year balance, but we should not have exceeded the $200 maximum allowed by regulation. Actions Taken or Planned: FA staff has reviewed the regulatory restrictions on prior-year payments to ensure that, even at a student's request, we do not exceed the $200 maximum allowed. Excess funds retained have been returned to the student.

Finding 2024-004: Unpaid Refund – It is recommended the Institution refund the $2,071 to the Department of Education and increase controls over paying refunds. Comments on Finding and Recommendation(s): HJC has refunded the funds to the Department of Education as recommended by the audit team. This was the first active quarter in the new SIS and there was an attendance processing error. The student only logged in one time but was not withdrawn. When found, the funds were returned to the Department of Education. Actions Taken or Planned: As soon as the issue was discovered, HJC began looking at options, and entered into an agreement with CourseKey for the accurate daily import of academic and attendance information into the Campus Cafe SIS system. Daily academic information exports to GF AS are being done to ensure they have the most accurate information available for processing Title IV aid.

Finding 2024-003: Incorrect Refund Calculation – It is recommended the Institution refund $50 to the Department of Education and increase controls over refund calculations. Comments on Finding and Recommendation(s): HJC concurs with the finding of the audit team. Actions Taken or Planned: The $50 will be returned to the Department of Education. The refund was calculated correctly but posted incorrectly. HJC will be responsible for processing R2T4 calculations for aid packaged prior to the engagement of GFAS, and GFAS will process HJC R2T4 refunds required going forward.

Finding 2024-002: Inaccurate Reporting of Disbursement Dates to the Common Origination and Disbursement (COD) System – It is recommended the Institution correct the disbursement dates in COD and tighten controls over reporting disbursements dates. Comments on Finding and Recommendation(s): HJC concurs with the finding. The transition to a new SIS system created import and export issues affecting disbursement date posting. Actions Taken or Planned: HJC has entered into an agreement with Global Financial Aid Services (GF AS) to process Title IV financial aid beginning with new 2024-25 aid packaged in the Fall 2024 quarter. Global processing the aid with HJC backing up and reviewing will ensure accurate date reporting to COD. The dates in question have been updated at COD.

Finding 2024-005: Untimely Enrollment Status Reporting – It is recommended the Institution increase controls over enrollment reporting. Comments on Finding and Recommendation(s): After the transition to Campus Cafe had begun, it was determined that they did not have the capability of importing NSLDS enrollment reporting reports as our previous system had, so FA staff has been updating enrollment information manually. Actions Taken or Planned: HJC has initiated discussions with the Clearinghouse for NSLDS reporting purposes. As a recent ECAR is required to complete the contract, we are currently waiting on an updated EApp to be processed to complete the process.

Recommendation: We recommend that at each NSLDS upload date, management review the NSLDS enrollment reporting upload to ensure student withdrawals during the period are appropriately reported in a timely manner. Corrective Action: The Clarendon College Registrar’s Office will establish a review process to ensure that all classes in which a student fully withdrawing from the institution was enrolled are dropped promptly, and that the student's enrollment status matches the status reported to NSLDS.

Finding 2024-003 Significant Deficiency over Activities Allowed and Unallowed and Allowable Costs/Cost Principle; Foster Care -Title IV-E (Foster Care), Assistance Listing Number 93.658, U.S. Department of Health and Human Services, passed through the N.C Department of Health and Human Services (NCDHHS), Division of Social Services. Medicaid Cluster (Medicaid), Assistance Listing Number 93.778, U.S. Department of Health and Human Services, passed through the N.C Department of Health and Human Services (NCDHHS), Division of Medical Assistance. Supplemental Nutrition Assistance Program (SNAP) Cluster, Assistance Listing Number 10.561, 10.561-COVID, U.S. Department of Agriculture, passed through the N.C Department of Health and Human Services (NCDHHS), Division of Social Services. Recommendation: We recommend that the County implements a review control over weekly timesheets to ensure the timesheets include all program time coded on the day sheets. Corrective Action Plan: The county will conduct training on day sheet and time sheet processes. The county will complete random monthly reviews of day sheets and timesheets. For those staff identified by the random monthly review with discrepancies, supervisors will provide refresher training on day sheet and timesheet procedures. Additional targeted reviews will be completed monthly until the deficiencies are corrected. Proposed Completion Date: 1/31/2025 for initial department training 2/28/2025 initiate random monthly reviews of day sheets and timesheets 7/31/2025 for additional reviews as needed for identified staff and refresher trainings Name of Contact Person: Yolanda Mcinnis, Economic Services Division Director and Sheila Donaldson Child Welfare Division Director

Finding 2024‐001 Federal Agency Name: Department of Education Assistance Listing Number: 84.268, 84.063, 84.007, 84.033 Program Name: Student Financial Assistance Cluster – Special Tests and Provisions – Return to Title IV Finding Summary: During our review of the Return of Title IV funds, there were five instances out of nineteen in which the Title IV funds to be returned was calculated incorrectly. Corrective Action Plan: The Office of Financial Aid will review and adjust the process for calculation and review of all Return to Title IV calculations. This process will be documented and reviewed periodically to ensure adherence. Responsible Individual(s): Director of Financial Aid] Anticipated Completion Date: January 2025

The institution implemented adequate oversight to ensure the dates and the student information match NSLDS. While the institution already had a process in place to ensure National Student Clearinghouse received error-free information, the Director of Financial Aid has now started to go a step further and manually review a sample of records on the NSLDS to confirm accuracy.

Condition: The College did not accurately report the effective date of a students' status changes to the NSLDS or the correct status change to the NSLDS. Planned Corrective Action: Before pulling the enrolled student list for submission to the National Student Clearinghouse (NSC), the Director of Financial Aid will run a debugging process created by the Financial Aid and Information Technology teams to identify any inaccuracies in student enrollment status to be easily identified and corrected. Implementing this debugging process in advance of finalizing the NSC Student Enrollment Report file will ensure all data submitted to NSC is accurate. Contact person responsible for corrective action: Mathew Catanese, Director of Financial Aid Anticipated Completion Date: June 30, 2025

Federal Agency Name: U.S. Department of Education Program Name: Student Financial Assistance Cluster Federal Financial Assistance Listing #84.007, 84.033, 84.063, 84.268 Compliance Requirement: Reporting – COD Reporting Significant Deficiency in Internal Control Finding Summary: During our testing of compliance for COD Reporting, it was noted that there was no documented control over the Student Account Statement (SAS) reconciliation that is performed after loans have been submitted to COD and disbursed. Responsible Individuals: Randy Mashek, Director of Financial Aid Corrective Action Plan: The Financial Aid office will retain documentation of the control over the SAS reconciliation process. Anticipated Completion Date: November 1, 2024.

Finding 2024-001 Federal Agency Name: U.S. Department of Education Program Name: Student Financial Assistance Cluster Federal Financial Assistance Listing #84.007, 84.033, 84.063, 84.268 Compliance Requirement: Special Tests and Provisions – Enrollment Reporting Significant Deficiency in Internal Control Finding Summary: During testing of compliance for Enrollment Reporting, there was 1 instance out of 60 where the College did not report a student’s change in enrollment status accurately or within the required time frame of 60 days from the effective date of the student’s change in enrollment status. In addition, evidence of the review of this submission was not retained. Responsible Individuals: Karla Winter, Registrar Corrective Action Plan: The Registrar’s office will review clearing house batch errors reports and any students that go from enrolled in a course to auditing a course. In addition, the Registrar’s office will conduct and retain evidence of quality sampling once a semester. Anticipated Completion Date: November 1, 2024.

Finding 2024-001 - Special Tests and Provisions – Gramm-Leach-Bliley Act Responsible Individuals – Director of Computer Services and Vice President for Finance & Risk Management. Finding Summary: During testing of Gramm-Leach-Bliley Act and inquiry with management, it was determined that the University does not have certain elements of the required written information security program in place. Corrective Action Planned: Dordt will continue to work with an external organization familiar with the policy requirements of the Gramm-Leach-Bliley Act to make sure the remaining elements have been incorporated into the written policies. Anticipated Completion Date: June 30, 2025.

2024-002: Missing Exit Counseling Documentation - Student Financial Aid Cluster Assistance Listing Number 84.007, 84.033, 84.063, 84.268, Grant Period - Year Ended June 30, 2024 Condition Found During our student file testing, we noted four 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 a Significant Deficiency with the Eligibility Compliance Requirement. This is a repeat finding, see Prior Year Audit Findings 2023-002. Corrective Action Plan LLCC has developed a new reporting method to capture students needing exit counseling. Responsible Person for Corrective Action Plan Alison Mills-Director of Financial Aid Implementation Date of Corrective Action Plan FY25

2024-001 Incorrect Pell Disbursement Amount - Student Financial Aid Cluster Assistance Listing Number 84.007, 84.033, 84.063, 84.268, Grant Period - Year Ended June 30, 2024 Condition Found During our student file testing we noted one student out of forty had was not disbursed the correct Pell Grant award. Based on the student’s enrollment status and need, the College over awarded the student by $925. We consider this to be an instance of noncompliance relating to the Eligibility Compliance Requirement. Corrective Action Plan This is a manual process and aid is initially reviewed during the awarding process. LLCC is working to create a report to double check aid that has been cancelled for students during an ineligible term. Responsible Person for Corrective Action Plan Alison Mills-Director of Financial Aid Implementation Date of Corrective Action Plan FY25

2024-003 Student Financial Assistance Cluster– Assistance Listing No. 84.063, 84.007, 84.033, 84.268 Recommendation: We recommend that the College review policies and procedures related to R2T4 calculations to ensure calculations are performed correctly and timely. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Registrar will use original contact date from students regarding withdrawal instead of the final approval date. Name(s) of the contact person(s) responsible for corrective action: Ashley Mayfield, Director of Admission & Enrollment; David Fisher, Financial Aid Director Planned completion date for corrective action plan: 09/30/24

2024-002 Student Financial Assistance Cluster– Assistance Listing No. 84.063, 84.007, 84.033, 84.268 Recommendation We recommend that the College implement procedures to ensure that enrollment data, changes in status and effective dates within NSLDS match the records of the institution and are reported timely. And we recommend that the College implement formal review procedures to document the review process. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Registrar will prepare the files for the clearing house based on the scheduled receipt of the enrollment roster from NSLDS. Before sending the report to the clearing house the report will be reviewed for accuracy of withdrawal or change in status dates. Name(s) of the contact person(s) responsible for corrective action: Ashley Mayfield, Director of Admission & Enrollment; David Fisher, Financial Aid Director Planned completion date for corrective action plan: 01/01/2025

Incorrect Enrollment Reporting to National Student Loan Data System (NSLDS) Planned Corrective Action: With new automation we have more timely notifications when students have been dropped. The Pillar Financial Aid department has updated policies and procedures to monitor the withdrawal process to inform the Registrar’s office, which will ensure the necessary changes to the NSLDS record are made in a timely manner. Person Responsible for Corrective Action Plan: Christine Schroeder, Assistant VP of Enrollment Services Anticipated Date of Completion: Current action

Inaccurate and Untimely Return of Title IV Funds (R2T4) Planned Corrective Action: The Financial Aid team will continue to work R2T4s as the pertinent information of the drop/withdraw is received from the Academic team. Once notification is received from the Academic department, the Third-Service provider will review and make timely requests for additional documentation to ensure the calculations and returns are completed in a timely manner, based off the requested information needed. Both the Financial Aid and Student Accounts departments will work in conjunction with the Third-Service provider to ensure timely changes reflect on the student’s ledger. Person Responsible for Corrective Action Plan: Christine Schroeder, Assistant VP of Enrollment Services Anticipated Date of Completion: Current action

Compliance Requirement: Special Tests and Provisions Criteria.· In accordance with Code of Federal Regulations (CFR) Title 34, unless the School expects to complete its next roster file within sixty days, the School must notify NSLDS within thirty days, if it discovers a student who received a loan either did not enroll or ceased to be enrolled on at least a half-time basis. The College did not submit studem status changes in accordance with CFR 34. Context: Five of the 25 students tested did not comply. Cause: The College's procedures for reporting all students were not designed appropriately to allow for timely reporting to the NSLDS. Effect: The accuracy of Title fV student loan records depends heavily on the accuracy of the enrollment information reported by schools. If an institution does not review, update and verify student enrollment statuses, effective dates of the enrollment status and the anticipated completion dates, then the Title IV student loan records will be inaccurate. Questioned Costs: There are no questioned costs associated with this finding. Views of Responsible Individuals: Management agrees with this finding. Corrective Action Taken: While this was an unusual situation resulting from a rare occurrence when the academic calendar was altered only three months prior to the start of 2023-2024 academic year, the Registrar and Senior Leadership Team immediately implemented the following action steps to prevent the deficiency from reoccurring: 1) The Assistant Registrar submitted status change corrections to the National Student Clearinghouse/NSLDS on the same day (07/15/2024) we received the information on which student records were impacted by the reporting discrepancy. 2) The Registrar, Assistant Registrar, and Provost (Chief Academic Officer) implemented processes to ensure that all necessary controls are in place to verify that course dates and degree conferral dates are synchronized with academic calendar dates. Dawn M. Scialabba, Registrar Anticipated Completion Date of Corrective Action: July 15, 2024

Name of Responsible Individual: Jason Byrd, University Registrar Corrective Action: Liberty University acknowledges that its FY24 single audit identified one instances where students’ enrollment reporting was not updated in a timely manner in accordance with U.S. Department of Education (ED) requirements. Additionally, Liberty acknowledges that there were numerous instances where Clearinghouse error reports identified students with repeat errors which were not corrected within the required timeframe. Liberty has invested significant effort into ensuring its enrollment reporting process is handled compliantly and within alignment with ED’s best practices. Liberty’s Registrar’s Office created a new Director of Clearinghouse Reporting position, which was filled in May 2024, to specifically address any enrollment reporting deficiencies. This new position is responsible for monitoring Clearinghouse feeds and any associated error reports and works closely with Liberty’s Financial Aid and Information Technology (ADS) offices to ensure enrollment reporting compliance. Liberty has continued the work of developing a more comprehensive quality control (QC) process. The QC process utilizes National Student Loan Data System (NSLDS) reporting and compares it to Banner, Liberty’s system of record, to identify students who may not have been accurately reported for a variety of reasons. This process relies on the NSLDS Enrollment History Report -SCHHS1, which is a very large and somewhat unstable report due to the volume of enrollment reporting that Liberty completes. Because of the complexities of this report, and the many changes that occurred with NSDLS updates to reporting, Liberty had to file numerous inquiries with ED to be able to run a functioning report, including an NSLDS ticket submitted on September 20, 2022, (Case # 220920-000436). The report was first successfully run in January 2024, though it took several months for Liberty to build QC reports internally that could leverage the report results. Liberty seeks to run the report at least once per month, though failures at NSLDS are unfortunately somewhat common and require escalation to ED for resolution. NSLDS – SCHHS1 Report: Once downloaded, this report is uploaded into Liberty’s system and is utilized internally for four additional QC reports which compare the NSLDS output to Banner. It should be noted that the QC reports are primarily useful for identifying common and repeat issues that require further research and are not fine-tuned enough to identify all individual instances of missing or incomplete records. Liberty Internal QC Reporting: Below are multiple screenshots of the four additional QC reports that Liberty has created. The Graduated Dates Prior to Term End report compares graduation dates by term to identify NSLDS graduation dates that appear to not match Banner’s graduation date in SHDGMR. The NSLDS MisMatches report generates an Excel file showing instances where it believes a student’s enrollment in Banner does not appear to match their reported enrollment in NSLDS. The NSLDS No Banner SSN report pulls students who appear in NSLDS’ enrollment file but do not appear to have a corresponding student ID record in Liberty’s system. The NSLDS Record Missing report pulls Liberty University students who appear to be missing a corresponding record in NSLDS. With all of these reports, there may be a legitimate reason for the discrepancy between Liberty’s Banner data and the NSLDS system, which causes the reports to generate a number of false positives, however, the reports have been helpful to identify more common/persistent errors and provides an additional layer of QC to ensure that Liberty’s enrollment files are as accurate as possible. Liberty is also engaging in a review of its Clearinghouse file generation process to ensure that student’s enrollment changes, particularly for program level records, are reported in a timely manner. Accountability Meetings Finally, in addition to running regular QC reports and hiring a dedicated Director of Clearinghouse reporting position, Liberty began holding a series of bi-weekly “Enrollment Reporting Check-In” meetings with key stakeholders from University Compliance, Financial Aid, Registrar, and IT/ADS in February 2024, which are dedicated to discussing current and upcoming enrollment reporting submissions and errors, trends seen with SSCR errors, and brainstorming ways to ensure ongoing compliance. While improvement efforts continue to be underway, Liberty believes these efforts are starting to bear fruit as evidenced by a 98.7% reduction in the number of repeat errors in the 2024 calendar year compared to total reporting period. Moving forward Liberty will continue to hold monthly meetings with key stakeholders to discuss any errors being pulled and ensure best practices are implemented to ensure ongoing accuracy. The University’s Registrar’s Office will also continue to review the QC reports in a timely manner, as well as evaluate the current processes for withdrawal/graduated student files. Liberty will continue to review and implement updates as necessary to maintain enrollment reporting compliance and believes these new processes will allow us to be compliant in subsequent years. Anticipated Completion Date: April 2025

Recommendation: We recommend the Office of Financial Aid utilize their financial aid processing software to implement disbursement notifications which include all information required by (34 CFR Section 668.165(a)(2) to be sent electronically to students once disbursements are posted. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Corrective Action Planned: The Office of Financial Aid and Scholarships drafted a letter using best practices laid out by NAFSAA which includes all information required by 34 CFR Section 668.165. The System Specialist, who is responsible for disbursing aid, has created documentation that has been added to the disbursement process. Once a disbursement is complete, the System Specialist will run the process in PowerFAIDS that will send the Loan Disbursement Notification via email to students who have received loans. This includes students who have received Federal Direct Subsidized, Unsubsidized, Parent PLUS, Grad PLUS, and private loans. This process is updated and is now in place. Name of Contact Responsible for Corrective Action: David J. Sarah, Director of Financial Aid, 765.641.4110 Anticipated Completion Date: August 2024

Recommendation: We recommend an individual in financial aid with the appropriate level of experience periodically review R2T4 calculations and returns to help ensure that internal controls over such a process can operate effectively and achieve compliance. We also recommend the University implement controls to track and remind when returns need to be returned once the withdrawal determination has been made. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Corrective Action Planned: ● Moving forward, for each year, when the academic calendar is released prior to the beginning of the fall semester, The Office of Financial Aid and Scholarships will immediately determine the dates and number of days used for the R2T4 calculations. ● The Senior Financial Aid Counselor within the Office of Financial Aid and Scholarships, who is responsible for preparing the R2T4 calculations, has enrolled for R2T4 training from NASFAA, which takes place starting on September 3, 2024. The Senior Financial Aid Counselor will also complete a PowerFAIDS training on the R2T4 process within the system. ● The Systems Specialist within the Office of Financial Aid and Scholarships will also be trained on the R2T4 process to provide quality control for the senior financial aid counselor and to ensure we are cross-trained within the Office of Financial Aid. With two individuals working to keep each other accountable, we will be able to avoid similar issues in the future. The Systems Specialist will also complete the NASFAA and PowerFAIDS training. ● All R2T4s will be tracked on a shared file starting in the Fall 2024. The Senior Financial Aid Counselor, Systems Specialist, and Director of Financial Aid will have access to the file for review and quality control. ● The Systems Specialist and Director of Financial Aid will be added to the student withdrawal form workflow through Etrieve. This team of three will all receive a notification when a student withdrawal needs to be processed. ● The Director of Financial Aid will check at least weekly on the shared R2T4 file and will monitor the dates and timelines to ensure calculations are completed within the timeframe allowed. Name of Contact Responsible for Corrective Action: David J. Sarah, Director of Financial Aid, 765.641.4110 Anticipated Completion Date: September 2024

Finding: 2024-004 Satisfactory Academic Progress Responsible Party: Douglas Cleary, Director of Financial Aid Anticipated Completion Date: July 31, 2024 The audit noted one student was awarded financial aid despite not meeting Satisfactory Academic Progress (SAP) standards. The issue stemmed from a lapse in the SAP review process at the end of the Fall 2023 term, which was primarily attributed to staff turnover and insufficient training for remaining personnel. When the student did not enroll for the Spring term but later registered for the Summer 2024 session, there were no safeguards in place to prevent the system from awarding financial aid. This oversight highlighted a gap in the current process, emphasizing the need for a more robust mechanism to flag students who are not in compliance with SAP prior to awarding financial aid. In the new organizational structure, the Financial Aid Business Analyst is responsible for executing the SAP process. This individual has approximately 10 years of experience working with SAP processes. During the 2023-2024 academic year the University worked diligently to respond to a Federal Program Review from the U.S. Department of Education, (ED). As a result of the corrective actions being undertaken by the University new procedures in many areas were being drafted and implemented. A new Director of Financial Aid, with over 30 years of experience in financial aid, was hired to improve the overall student service and compliance with the Federal Title IV program. The new director commenced his duties on February 1, 2024. Since that time the University has reorganized the financial aid office by creating an Assistant Director and Financial Aid Business Analyst position who have increased the expertise and overall years of financial aid experience. A leadership team including the Director of Financial Aid, Registrar, Director of Student Accounts, Associate Provost, Provost and Vice President for Finance and Administration was created in January 2024 and meet bi-weekly to discuss Title IV compliance topics, process improvement and customer service. Most of the Financial Aid team’s time in the spring and summer was spent working on the new FAFSA. The team has redirected their efforts in training, standardizing, documenting and improving processes to ensure Title IV compliance and better serve students.