Corrective Action Plans

Finding: 2024-003 Verification Responsible Party: Douglas Cleary, Director of Financial Aid Anticipated Completion Date: October 17, 2024 The auditors identified two issues related to verification of financial aid data supplied on the FAFSA by students. Both findings were from the fall of 2023 and in both cases a secondary review was completed and still was not accurately completed. The Office of Financial Aid developed and implemented a comprehensive Business Process Guide (BPG) on October 17, 2024. The guide is aimed at ensuring that all required fields within the verification process are meticulously reviewed and corrected as needed. This guide serves as a crucial resource for staff involved in the financial aid verification process, outlining best practices and standard procedures to maintain compliance and accuracy. The verification correction process follows a two-step approach: 1. Initial Review and Correction: Staff members are required to conduct a thorough review of the required data fields. This involves checking the required ISIR data fields against other supplemental information to identify any discrepancies or inaccuracies. Once identified, corrections are made to ensure that all data aligns with federal and institutional requirements. 2. Final Confirmation and Awarding: After the necessary corrections are implemented, a secondary review is conducted by the Assistant Director to confirm that the adjustments are accurate. This ensures that students receive the correct financial aid awards based on updated and verified information. To maintain transparency, accountability, and an adequate documentation trail. It is imperative that any comments added to student accounts are detailed and include pertinent information regarding the verification process. This documentation serves as a record of the actions taken and aids in future audits and reviews. The Assistant Director of Financial Aid is a very experienced financial aid professional and holds NASFAA certifications in Verification, R2T4, Student Eligibility, Direct Loans and Professional Judgement. The Assistant Director plays a pivotal role in the verification process, being responsible for updating the BPG to reflect any changes in regulations or best practices. Additionally, the Assistant Director will lead training sessions for staff members to ensure they are well-versed in the verification procedures outlined in the BPG. Ongoing training will be provided as needed to accommodate changes in policies or technologies. By implementing this structured approach to verification corrections, the University aims to enhance the accuracy of financial aid processing and improve the overall student experience.

Finding: 2024-002 Enrollment Reporting Responsible Party: Dr. Karen Jarrell, Director of Office of Student Records and Registrar Completion Date: December 30, 2024 The Deputy Registrar from the Office of Student Records (OSR) is responsible for enrollment reporting to the National Student Loan Data System (NSLDS). The university uses a servicer, National Student Clearinghouse (NSC) to complete the reporting requirement. Enrollment data is scheduled to be transmitted to the NSC every thirty days to ensure timely reporting to the National Student Loan Data System (NSLDS). The University has consistently met this 30-day reporting to NSC. The audit noted four students had incorrect program start dates in NSLDS from April 2022 and August 2022, each off by one day. The University’s Student Information System (SIS) reflects the correct program start dates, indicating a potential issue in the data transmission between NSC and NSLDS. In July 2022, several announcements were made concerning the technical issues with NSLDS which prevented reporting for periods of time, including “NSLDS Professional Access – Documentation of Enrollment Reporting and Post-screening Delays for Audit Purposes” published on August 31, 2022. The audit noted three errors related to timely reporting. The university’s SIS records indicate these records were reported to NSC within the 30-day timeframe. However, these records were not transmitted from NSC to NSLDS timely. The Deputy Registrar is currently collaborating with the NSC Compliance division to determine the cause of these discrepancies and how best to correct the records in NSLDS. A response from NSC is anticipated by October 31, 2024. The audit also noted three students who were less than full-time that were not reported to NSC or NSLDS. The Deputy Registrar is researching the SIS system rules to determine the root cause of these errors so they can be corrected. The Deputy Registrar will ensure the reporting rules will be corrected by November 30, 2024, and will ensure any less than full time students are corrected in NSLDS by December 30, 2024. To enhance the enrollment reporting process, the Deputy Registrar, Registrar, and Director of Financial Aid will meet with NSC staff and IT staff to establish a method for comparing monthly data submitted to NSC with the data in the NSLDS system. This will help identify any discrepancies for immediate correction. This project is expected to be completed by December 30, 2024.

Finding: 2024-001 R2T4 Responsible Party: Douglas Cleary, Director of Financial Aid Anticipated Completion Date: November 30, 2024 With the new Financial Aid leadership, the university has already implemented many new strategies to strengthen the Return of Title IV Funds (R2T4) process. The University created a new position, Financial Aid Business Analyst, whose primary responsibility is to maintain financial aid systems, maintain process documentation and provide staff system training and to oversee the R2T4 process. The Financial Aid Business Analyst has two years of previous experience being responsible for R2T4 calculations, completed the National Association of Student Financial Aid Administrators (NASFAA) R2T4 five-week certification program on October 14, 2024, and is in the process of training a Financial Advisor in performing R2T4 calculations. Other areas that have been identified will improve the R2T4 process are as follows: 1. Earlier Availability of the Academic Calendar: The Financial Aid Office leadership (Director, Assistant Director, Financial Aid Business Analyst) will work with the Office of Student Records (Registrar and Deputy Registrar) to ensure that there is an accurate R2T4/academic calendar. Both offices will work to develop such calendars with a clear description of the dates the University is closed for students, and that calendars can be developed years in advance. This will facilitate accurate determination of begin/end dates, break days and the total number of class days within any term. This will also encourage greater levels of transparency and oversight by both offices. The R2T4/academic calendar will also be shared with the Student Accounts Office, adding additional transparency and understanding. Timeline: The calendar for the Spring semester 2025 and the 2025-2026 academic calendar has already been developed and approved. The 2026-2027 academic calendar has been submitted to faculty for their input and will be completed by November 30, 2024. 2. Daily Percentage Calculator: The Financial Aid Business Analyst developed a daily percentage calculator that, implemented for Fall 2024, when combined with the academic calendar, will enable the accurate input of all term dates to generate precise daily percentage calculations for R2T4 purposes. This is also being expanded to create sub-term daily percentage calculations to eliminate the need for manual completion with each module-type calculation. 3. Post-Withdrawal Disbursements: The Financial Aid Business Analyst worked with Information Technology to ensure required communications related to R2T4 including post withdrawals (PWD) are now an automated process after completion of the calculations. This automation was implemented in August 2024. The PWD findings in this audit were the work by previous leadership within the Financial Aid Office. 4. Collaboration with IT for Updated Reporting: Financial Aid Office leadership (Financial Aid Business Analyst, Director) are collaborating with the IT to develop updated reports that will help accurately identify students who have unofficially withdrawn and require review during the R2T4 process. This initiative aims to create a preventive control that identifies errors and ensure timely calculations. The timeline for completion of the updated report is November 30, 2024. 5. Strengthening Internal Controls: The Director of Financial Aid has identified a Financial Aid Advisor who is currently being trained on R2T4 process, and who will eventually assume the primary responsibility for R2T4 calculations. The Financial Aid Business Analyst will provide secondary reviews to ensure accuracy and consistency. Note: The two PWDs from the Fall 2023 semester highlight a significant oversight by previous financial aid leadership. The inadvertent miscalculation of break days stemmed from confusion about the academic calendar. It appeared to suggest that students were required to attend classes on the weekend proceeding Thanksgiving week, while in reality, classes concluded the prior Friday. As a result, the Fall break should have been calculated as 9 days instead of 7.

Student Financial Assistance Cluster- Assistance Listing No. 84.268 Finding: The College did not have documentation that Direct Loan Reconciliation was performed. Context: During our testing we identified the March 2024 Direct Loan Reconciliation was not timely performed and documented. Cause: Due to staff turnover, direct loan reconciliation for March 2024 was not performed timely. Recommendation: We recommend the College implement a formal review procedure to document that the direct loan reconciliations are performed on a timely basis each month. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: A formal review process was already in place. The issue came from the turnover in the FA department leading to a loss of access. This will be remediated moving forward with more than one FA staff having reporting access and knowledge of reconciliations. Name(s) of the contact person(s) responsible for corrective action: Tina Ballinger Planned completion date for corrective action plan: 11/01/2024

Student Financial Assistance Cluster- Assistance Listing No. 84.063, Finding: The College under-awarded funds for the Pell Grant. Context: During our testing, we identified 2 out of 40 students were awarded and disbursed less Pell funds than should have been awarded based on the 23-24 Pell payment schedule. The Pell payment schedule considers the cost of attendance, the student's Expected Family Contribution and the enrollment status of the student. Cause: Student was initially not disbursed Pell funds due to electronic terms & conditions not being completed. However, when the student completed this requirement in the Spring, Pell was not disbursed for the Fall semester Recommendation: We recommend the College review its current procedures for awarding Title IV funds and implement any changes necessary to ensure federal funds are awarded and disbursed in accordance with federal regulations. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: This is due to a loss of knowledge due to turnover within the FA department. Moving forward, knowledge procedures and knowledge will be disseminated to all FA staff to ensure there are no gaps causing a reoccurring issue. Name(s) of the contact person(s) responsible for corrective action: Tina Ballinger Planned completion date for corrective action plan: 11/01/2024

Student Financial Assistance Cluster- Assistance Listing No. 84.007, 84.038, 84.063, 84.268 Finding: The College did not properly have documentation of exit counseling notification. Context: During our testing of 40 students, we identified 5 students that did not have documentation of exit counseling notification. Cause: The College did not have proper procedures in place to ensure that notification of required exit counseling was sent to applicable students. Recommendation: We recommend the College review reporting processes to ensure all students that require exit counseling receive it in a timely manner Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: This is due to a loss of knowledge due to turnover within the FA department. Moving forward, knowledge about loan exit counseling will be disseminated to all FA staff to ensure there are no gaps causing a reoccurring issue. Name(s) of the contact person(s) responsible for corrective action: Tina Ballinger Planned completion date for corrective action plan: 12/15/2024

Student Financial Assistance Cluster- Assistance Listing No. 84.007, 84.038, 84.063, 84.268 Finding: The College did not properly notify students when loans were credited to student's ledger account. Context: During our testing of 40 students, we identified that there were 5 students that did not receive the required notification of Direct Loan disbursements Cause: Due to staff turnover, loan notifications were missed being sent out to students. Recommendation: We recommend the College evaluate its procedures around disbursements of loans and ensure that notifications of disbursements are sent and contain all the required elements outlined in the FSA handbook. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: This is due to a loss of knowledge due to turnover within the FA department. Moving forward, knowledge about loan notifications will be disseminated to all FA staff to ensure there are no gaps causing a reoccurring issue. Name(s) of the contact person(s) responsible for corrective action: Tina Ballinger Planned completion date for corrective action plan: 12/15/2024

Student Financial Assistance Cluster-Assistance Listing No. 84.007, 84.038, 84.063, 84.268 Finding: The College did not properly report student enrollment changes for students who received federal student aid to the National Student Loan Data System (NSLDS). Context: During our testing of 40 students, we identified 3 students that did not have their Program enrollment reported to NSLDS and 3 students that had Program enrollment effective dates that did not match institutional records. Cause: The College didn't have proper procedures in place to verify students' status in NSLDS matched the institution's records accurately. Recommendation: We recommend the College review current processes for reporting to NSLDS and implement procedures to ensure submissions are reported accurately. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: CSC will put in place procedures that will ensure that submissions are reported accurately. Name(s) of the contact person(s) responsible for corrective action: Tina Ballinger Planned completion date for corrective action plan: 01/01/2025

Student Financial Assistance Cluster- Assistance Listing No. 84.007, 84.033, 84.063, 84.268 Finding: The College used the incorrect withdrawal date when calculating Return to Title IV (R2T4) calculations and did not have formal procedures in place to document review of calculations. Context: During our testing, we identified 2 out of 15 R2T4 calculations used an incorrect withdrawal date in their calculation. Also, during our testing, we identified 13 instances of no documentation of a formal review of R2T4 calculations. Cause: The College was using the date a withdrawal form was processed, rather than the date the withdrawal process began. Recommendation: We recommend that the College review policies and procedures related to R2T4 calculations to ensure calculations are performed accurately. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Staff will review policies and procedures and make adjustments as needed to ensure that the calculations are accurate. Name(s) of the contact person(s) responsible for corrective action: Tina Ballinger Planned completion date for corrective action plan: 11/01/2024

Student Financial Assistance Cluster – Assistance Listing No. 84.268 Recommendation: We recommend the University implement procedures to ensure exit counseling notifications are sent to students who graduated or withdrew. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Financial Aid Office will work with our IS department to rebuild the exit counseling notifications so they are more accurate and notify the correct student population. Name(s) of the contact person(s) responsible for corrective action: Jason Hibbert Planned completion date for corrective action plan: March 21, 2025

Student Financial Assistance Cluster – Assistance Listing No. 84.268, 84.063, 84.007, 84.033, 84.379 Recommendation: We recommend the University evaluate its procedures and policies around reporting disbursements to COD to ensure that student information is reported accurately and timely, and to store evidence of the key control having occurred. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Financial Aid Office will work with our IS department to rebuild the original PELL unreported disbursements. Any unreported disbursements greater than 7 days will be reported to the financial aid director, information systems, and the vice president for finance and administration via email from Fast. This will allow for a review and timely reporting. Name(s) of the contact person(s) responsible for corrective action: Jason Hibbert Planned completion date for corrective action plan: January 6, 2025.

Student Financial Assistance Cluster – Assistance Listing No. 84.268, 84.063, 84.007, 84.033, 84.379 Recommendation: We recommend that the University implement a key control to ensure that enrollment data, changes in status and effective dates within NSLDS match the records of the institution and are reported timely, and to store evidence of the key control having occurred. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Review of Banner job to check for errors in reporting format or potential junk data that could cause a report to be rejected. New drop and withdrawal codes that only pertain to post term withdrawals and will only be used for a post term withdrawal to allow the dates to match, are being discussed. As well as internal discussion about developing key control tracking to show evidence that the controls in place are being followed. Name(s) of the contact person(s) responsible for corrective action: Emily Sharratt Planned completion date for corrective action plan: December 13, 2024

Student Financial Assistance Cluster – Assistance Listing No. 84.268 Recommendation: We recommend that the University review their awarding procedures and implement procedures to ensure direct loans are awarded within student eligibility. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Financial Aid office (FAO) plans to do more expansive training for the Financial Aid Administrators upon hire. FAO is exploring the option of National Association of Student Financial Aid Administrators training certification for a Need Analysis credential. Name(s) of the contact person(s) responsible for corrective action: Jason Hibbert Planned completion date for corrective action plan: February 28, 2025

2024-003: U.S. Department of Education. Assistance Listing Number: 84.007 (Federal Supplemental Educational Opportunity Grants Program), 84.033 (Federal Work Study Program), 84.063 (Federal Pell Grant Program), 84.268 (Federal Direct Student Loans Program). Criteria or specific requirement: The Gramm-Leach-Bliley Act (Public Law 106-102) requires financial institutions to explain their information-sharing practices to their customers and to safeguard sensitive data. (16 CFR 314) The Federal Trade Commission considers Title IV-eligible institutions that participate in Title IV Educational Assistance Programs as “financial institutions” and subject to the Gramm-Leach-Bliley Act (16 CFR 313.3(k)(2)(vi)). The Code of Federal Regulations 2 CFR 200.303 requires the University to establish and maintain effective internal controls over Federal awards. Context: Under an institution’s Program Participation Agreement with the Department of Education and the Gramm-Leach-Bliley Act, schools must protect student financial aid information, with particular attention to information provided to institutions by the Department or otherwise obtained in support of the administration of the federal student financial aid programs. Cause: The University has continued to make progress in updating the University’s written security program to become in compliance with all requirements; however, due to capacity and demands on the information technology individuals, this is still a work in process. Recommendation: We recommend the University work to update the written security program to ensure compliance with all the standards. Views of responsible officials: There is no disagreement with the audit finding.

2024-002: U.S. Department of Education. Assistance Listing Numbers: 84.063 - Federal Pell Grant Program, 84.268 - Federal Direct Student Loans. Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 685.309 requires that enrollment status changes for students be reported to the National Student Loan Data System (NSLDS) within 30 days or within 60 days if the student with the status change will be reported on a scheduled transmission within 60 days of the change in status. Regulations require the status include an accurate effective date. In addition, schools are required to certify enrollment every 60 days, and respond within 15 days of the date that NSLDS sends a Roster file to the school or its third-party servicer. Errors must be corrected within 10 days. Cause: The University’s processes and controls did not ensure that student status changes were properly and timely reported to NSLDS. Effect: The errors were caused by National Student Clearinghouse's communication with NSLDS, as a result of the modernization of NSLDS in 2022. The University was told the errors would be fixed and there was nothing more they needed to do. The errors were not fixed. 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. Views of responsible officials: There is no disagreement with the audit finding.

This was an isolated instance and attributed to the merger of three institution into one institution effective July 1, 2023. The registrar is monitoring the re-enrollment of students that have taken a leave of absences or have not enrolled in VTSU since the merger to identify additional errors and will take appropriate action to correct them as the occur.

VTSU is setting standard procedures for the merged financial aid department, so all personnel are following a standard procedure. In the future, VTSU will not be marking students or using the code for “not verifying” for students who do not enroll. Posting rules are in place that will not allow aid to post to a students account if verification is incomplete.

Westminster University is deeply committed to supporting its students and ensuring compliance with the requirements of the Student Financial Assistance Cluster. We appreciate the feedback provided in the Schedule of Findings and Questioned Costs and have taken action to address the concern raised. Our institution is dedicated to continuous improvement in both our financial aid processes and overall student support services. We have developed an action plan to address the issue identified: FINDING 2024‐001 – Special Tests and Provisions – Enrollment Reporting Significant Deficiency in Internal Control over Compliance Recommendation: The University should implement a policy to ensure address changes for all semesters are reported timely. Response: There is no disagreement with this audit finding. Action Taken in Response to Finding: Based upon the definition provided of Section 34 CFR Section 685.309(b) (2), it is our understanding that we are required to report address changes only on enrolled students through the period where they are marked as either (W) Withdrawn or (G) Graduated status. Our policy is to report students’ most current home address with each enrollment submission a minimum of 14 dates per year (three of which are only for graduated students) which ensures compliance with the 60-day threshold. However, our current practices have not always ensured that the current main home address was the one supplied to the National Student Clearinghouse. We will immediately implement processes to ensure that the main home address is the one sent to the National Student Clearinghouse. We consider this to be remediated. Contact Person(s): Karen Henriquez, Director of Financial Aid

Recommendation: We recommend the Academy reevaluate its procedures and review policies surrounding controls implemented for Title IV Aid. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Since the audit, Summit Academy has determined a new process in which we will ensure controls are being implemented within certain processes. For our R2T4’s, once the Bursar has finished the calculations, the Financial Aid Manager will review for any errors & sign off with her initials once reviewed. For NSLDS, the Financial Aid Manager will work closely with the Registrar’s Department to ensure graduates & withdrawal/terminated students are updated in a timely manner. There will also be a spreadsheet used to keep track of all students changed within NSLDS. Name(s) of the contact person(s) responsible for corrective action: Marc Carrier, CFO Planned completion date for corrective action plan: Fall 2024

Recommendation: We recommend the Academy reevaluate its procedures and review policies surrounding reporting status changes to NSLDS to put a process in place to ensure the student status changes are being reported timely. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Since the audit, Summit Academy has determined a new process in which we certify and make changes to the enrollment data found in NSLDS. Moving forward, the Financial Aid Manager will be assigned tasks within our operating system (Anthology) that will notify her of any students who withdrawal, go on a leave of absence, changed their enrollment intensity or graduate. The Financial Aid Manager will check this daily and update the students NSLDS enrollment data accordingly. The Financial Aid Manager will also keep a spreadsheet detailing the students name and the dates each student was certified. The Financial Aid Manager will also work closely with the Registrar’s Department to ensure the graduation and withdrawal lists are accurate. Name(s) of the contact person(s) responsible for corrective action: Marc Carrier, CFO Planned completion date for corrective action plan: Fall 2024

Student Financial Assistance Cluster – Assistance Listing Number 84.007, 84.063, 84.268 Recommendation: We recommend that the University review its procedures related to updating the Eligibility and Certification Approval Report in a timely fashion. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: University will review which individuals are listed on the ECAR. Upon learning of their departure, the University will update ECAR immediately. Name(s) of the contact person(s) responsible for corrective action: H. Jonas Javier Planned completion date for corrective action plan: November 4, 2024

Student Financial Assistance Cluster – Assistance Listing Number 84.007, 84.063, 84.268 Recommendation: We recommend that the University review its procedures related to outstanding student refund checks to ensure they are being returned to the Department of Education after 240 days. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The University will develop and implement a procedure wherein uncashed checks will be reviewed more closely. Student refunds identified as uncashed as of 60 days will be forwarded to the Bursar’s Office. Bursar’s Office will conduct outreach to refund recipients. If refund remains uncashed after 180 days, Bursar’s Office will return funds to federal agency. Name(s) of the contact person(s) responsible for corrective action: H. Jonas Javier Planned completion date for corrective action plan: November 4, 2024

Student Financial Assistance Cluster – Assistance Listing Number 84.007, 84.063, 84.268 Recommendation: We recommend that the University put a process in place to refund student credit balances that arose from federal funds within 14 days. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The University has in place a systematic procedure wherein reviews of credit balances are conducted promptly after aid is transmitted. The University will ensure that this procedure is followed thoroughly. Name(s) of the contact person(s) responsible for corrective action: H. Jonas Javier Planned completion date for corrective action plan: November 4, 2024

NSU – Agrees with the finding. • Detailed corrective action taken, including what will be done to avoid the identified issues in the future, and when these measures will be in place: To ensure accurate and timely reporting of changes in student enrollment status to the National Student Clearinghouse (NSC), Nevada State University (NSU) will enhance its internal controls by implementing the following measures: o Continue the current bi-weekly enrollment reporting schedule. o Set bi-weekly calendar reminders to ensure timely reporting, supplementing NSC notifications. o Establish end-of-term calendar reminders specifically for reporting graduated statuses promptly. o Work closely with the NSC to identify any students included in submitted enrollment reports whose statuses were not updated within the NSC or National Student Loan Data System (NSLDS), ensuring they are addressed even if they do not appear in the reject file. • How compliance and performance will be measured and documented for future audit, management and performance review: To ensure ongoing compliance and performance in reporting changes in student enrollment status, Nevada State University (NSU) will implement the following measures for tracking and documentation: o NSU will conduct monthly reviews of enrollment status reports to verify the accuracy and timeliness of submissions to the National Student Clearinghouse (NSC). o Detailed logs of all enrollment status submissions and NSC notifications will be maintained, including timestamps and submission confirmations, to serve as an audit trail for internal and external reviews. o Periodic internal audits will be scheduled to assess adherence to the bi-weekly and end-of-term reporting schedule, with results documented for management review. o Key performance indicators (KPIs) will be established, such as the percentage of on-time reports and the accuracy rate of enrollment status updates. These metrics will be reviewed quarterly by management. o Any discrepancies identified during audits will be addressed promptly, and corrective actions will be documented for future reference and performance evaluations. o NSU will compile annual compliance reports summarizing audit results, corrective actions, and performance metrics, which will be available for future audits and management reviews. • Who will be responsible and may be held accountable in the future if repeat or similar observations are noted: The Registrar's Office holds primary responsibility for accurate and timely enrollment status reporting. The Registrar will oversee compliance with internal controls including the bi-weekly and end-of-term reporting schedules. Additional oversight will be conducted by the Provost and Vice President of Academic Affairs. Name of contact person responsible for corrective action plan: Rhett R. Vertrees, Assistant Chief Financial Officer 2601 Enterprise Road, Reno NV 89512-1666 Phone: (775)784-3409, Fax: (775)784-1127 Email: rvertrees@nshe.nevada.edu

CSN – Agrees with the finding. • Detailed corrective action taken, including what will be done to avoid the identified issues in the future, and when these measures will be in place: CSN has contracted with a third-party vendor to help review and process R2T4 accounts within the federally mandated timeframe. CSN is currently in the training phase and expects to have the vendor begin reviewing R2T4 file in the next several weeks. In addition, regular monthly training will be provided to CSN staff and the third-party vendor. Quality control through the review of processed R2T4 files will be performed twice a month. • How compliance and performance will be measured and documented for future audit, management and performance review: In collaboration with the third-party vendor, CSN will run R2T4 queries twice a month to ensure all files are reviewed within the federally mandated timeframe. The vendor will also review internally selected files for accuracy. CSN will also randomly select processed files review to meet compliance requirements. CSN will meet with the vendor on a monthly basis and maintain communication throughout the year to ensure consistency and compliance. • Who will be responsible and may be held accountable in the future if repeat or similar observations are noted: The Assistant Director of Processing in the Office of Financial Aid will be responsible for repeat or similar observations. UNLV – Agrees with the finding. There were two findings at the conclusion of the audit. Corrective action plans as well as measurements of compliance and performance correspond with the following two findings: 1. A return was calculated as $2,270, but should have been $1,975. 2. The second finding was regarding an improper return. UNLV’s calculation was correct at $0, as documented for the audit team. Months after the R2T4 calculation was performed, the student did not return to UNLV. At that time, their Pell Grant was appropriately canceled, but due to a system error, their Pell Grant for the entire year was canceled instead of just for subsequent semesters. Through our internal controls we found this error, but did so beyond the permissible 180-day late disbursement period. The error was unrelated to the R2T4 process and had no bearing on the correctly performed calculation. Since the Pell Grant could not be reinstated, we made the student whole with institutional funds. • Detailed corrective action taken, including what will be done to avoid the identified issues in the future, and when these measures will be in place: 1. Since the late disbursement period had passed, and the student had no balance due, there was no immediate corrective action that could be taken. The calculation error related to a withdrawal date incorrectly reported by a faculty member during spring break. The PeopleSoft system is set up to prevent the entry of such spring break withdrawal dates, and we were unable to replicate the error. The issue has therefore been escalated to our technical team for investigation and for prevention in future years. Even if this proves successful, we will ensure that at least two staff responsible for oversight of the R2T4 function will sign off each spring that no calculations are based on a withdrawal date that occurs during spring break. The signoff will occur within seven days of the end of spring break, so that if any error is identified we may still correct it while remaining within the appropriate R2T4 timelines. 2. The erroneous retroactive cancellation of Pell Grants for unenrolled students is now a known PeopleSoft issue. Beginning in fall 2024, we have established programming that packages Pell Grants on a semester-by-semester basis so that any changes to a current-term grant do not impact a prior-term grant. • How compliance and performance will be measured and documented for future audit, management and performance review: 1. A report exists in PeopleSoft that documents the withdrawal date of each student for whom an R2T4 calculation is performed. This report will be used to collect signoffs by two UNLV staff with R2T4 oversight that no calculations are based on a withdrawal date occurring during spring break, and will serve as the basis for that signoff. 2. Pell recipients' accounts will be reviewed in spring 2025 to ensure our packaging approach was effective in preventing retroactive grant cancellations. The team will review monthly to ensure we stay within the 180-day late disbursement time frame, which will allow us to reinstate Pell Grants retroactively, should our original solution prove ineffective. • Who will be responsible and may be held accountable in the future if repeat or similar observations are noted: If similar errors around spring break R2T4 calculations and/or retroactive Pell Grant cancellations occur in the future, of primary accountability will be the Assistant Director of Processing, the Associate Director of Operations, the Associate Director of Processing and Client Services (currently vacant), the Director, and the Executive Director. UNR – Agrees with the finding. The Financial Aid office recognizes a shortfall in this area due to unexpected changes in staffing. • Detailed corrective action taken, including what will be done to avoid the identified issues in the future, and when these measures will be in place: New R2T4 staff is currently undergoing in-depth calculation training which includes internal trainings, NASFAA workshops, and Federal Student Aid provided trainings. In addition, starting this fall, 100% of R2T4 files are being reviewed by a staff member who was not responsible for the initial calculation. To prevent late returns, our office is calculating returns within 15 days of the withdrawal date and return funds within 30 days of the withdrawal. • How compliance and performance will be measured and documented for future audit, management and performance review: Compliance with the above corrective action will be monitored by the Data Manager, who will be reviewing weekly R2T4 reports completed by R2T4 staff. Reports with return data will be compiled in one centralized location to ensure transparency of current return status, and a physical audit trail documented on the R2T4 coversheet detailing initial calculation date, audit check date, and return to COD date. • Who will be responsible and may be held accountable in the future if repeat or similar observations are noted: The R2T4 staff and the Financial Aid Director will be responsible. Name of contact person responsible for corrective action plan: Rhett R. Vertrees, Assistant Chief Financial Officer 2601 Enterprise Road, Reno NV 89512-1666 Phone: (775)784-3409, Fax: (775)784-1127 Email: rvertrees@nshe.nevada.edu