Corrective Action Plans

Student Status Changes The process of reporting enrollment to the NSLDS has historically been housed within the Student Financial Services department. The compliance issues with enrollment reporting during the prior award year were a result of having only one individual trained in transmitting our monthly file to the National Student Clearinghouse. Over the past few months, staff from our Records Office have been receiving training on preparing enrollment reporting files for transmission to the National Student Clearinghouse. During the current award year, collaborative meetings have been scheduled to have the principal agent from the Records Office and the principal agent from the Student Financial Services department meet to transmit data files to the Clearinghouse. Subsequent meetings are scheduled within 24-48 hours of each file transmission date to ensure error reports posted to the Clearinghouse are resolved in a timely manner. Zach Greenlee Director, Student Financial Services Phone: 314-392-2398 Email: zach.greenlee@mobap.edu

Return of Title IV Funds (R2T4) Due to the specialized skills and knowledge required for processing returning funds through the R2T4 process, Missouri Baptist University will be reassigning the responsibility for reviewing withdrawals within the Student Financial Services department to the Director of Student Financial Services. All withdrawals will be evaluated by the Director and all calculations using the R2T4 calculator available on the Common Origination and Disbursement (COD) system will be performed by the Director. Additional staff within the department will be tasked with verifying accuracy of returns to help provide exposure to the highly technical work of R2T4, thus providing training that will enable broader sharing of the responsibility in the future. An internal report has been created to give a daily summary of students who have withdrawn since the following day. This will complement the existing reporting structure which consists of individual withdrawal paperwork processed by our Records Department. Bi-weekly reports will be given to the Senior Vice President for Business Affairs to monitor compliance. Zach Greenlee Director, Student Financial Services Phone: 314-392-2398 Email: zach.greenlee@mobap.edu

The District should only include actual costs, not budgeted costs, on the expenditure reports filed with the Illinois State Board of Education. The District should also ensure that the expenditure reports filed with the Illinois State Board of Education are reconciled with the general ledger accounts of the District prior to submission. The District will ensure that expenditure reports only include eligible expenditures going forward. The District will take the necessary steps to reconcile the expenditure reports with the general ledger accounts before submitting to the Illinois State Board of Education.

The District should file timely quarterly expenditure reports to stay compliant with federal awards. The District will ensure that expenditure reports are timely filed going forward.

FINDING 2024-001 – Notification of Loan Disbursements Program Name: Federal Direct Student Loan Program ALN and Program Expenditures: 84.268 ($5,702,366) Award Number: P268K242030 Federal Award Year: July 1, 2023 to June 30, 2024 Questioned Costs: N/A Condition Found: The University could not provide documentation that the required loan disbursement notifications were made to the student at the time disbursement for the forty-one students who received Federal Direct Student Loans in our sample. This represented the entire population of students who received Federal Direct Student Loans in our sample. Corrective Action Plan: Management agrees with the auditors’ finding and their recommendation. The Financial Aid Office discovered the error in July 2024 before the audit began. Up to that point, the Financial Aid Office believed the software was automatically sending loan disbursement notification emails. The Financial Aid Office worked with the information technology staff to correct the software error. Loan disbursement notification emails are being sent timely as of August 2024. Anticipated Completion Date: The corrective action was completed in August 2024. Contact Person Shala LaTorraca, Director of Financial Aid 918-335-6260

Student Financial Assistance Cluster – Assistance Listing No. 84.268. Recommendation: We recommend the University evaluate its procedures around disbursements of loans and ensure that notifications of disbursements are sent and contain all of 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: We created a weekly report for all communications. We also reviewed the populations selection. Name(s) of the contact person(s) responsible for corrective action: Randi Croyle, Director of Financial Aid. Planned completion date for corrective action plan: 12/31/24

Student Financial Assistance Cluster – Assistance Listing No. 84.268, 84.063. Recommendation: We recommend the College evaluate its procedures and policies around reporting disbursements to COD to ensure that student information is reported accurately and timely. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: We created a report to track the timing of reporting disbursements to COD. Currently we load the disbursement record to COD once a week. If there is an issue and the file is rejected it creates issues with timeliness. We have a meeting on 10/9/2024 to evaluate how we want to resolve the issue. Name(s) of the contact person(s) responsible for corrective action: Randi Croyle, Danial Carlos, and Brady Nelsen. Planned completion date for corrective action plan: December 2024

Student Financial Assistance Cluster – Assistance Listing No. 84.007. Recommendation: We recommend the University review their FSEOG awarding policy and procedures to ensure FSEOG is awarded to students with the lowest expected family contributions. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Student Financial Aid updated our auto packaging policy. Name(s) of the contact person(s) responsible for corrective action: This was a part of our aid year rollover process and planning. Planned completion date for corrective action plan: April 2024

Student Financial Assistance Cluster – Assistance Listing No. 84.268, 84.063, 84.007,84.033. Recommendation: We recommend that the University work with their third-party servicer and implement procedures to ensure that enrollment data, changes in status and effective dates within NSLDS are reported timely and accurately. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: We are adjusting our corrective action. Last year we tested several out of cycle enrollment adjustments each term to ensure our processes were working. We didn’t find any issues. This year we will be comparing all the students were not reported to the Clearinghouse with the list reported to the Clearinghouse to ensure all students who need to be reported are properly reported. Name(s) of the contact person(s) responsible for corrective action: Randi Croyle, Director of Financial Aid. Planned completion date for corrective action plan: We ran our first comparison on 9/19/2024 and we will be running every month we do the Clearinghouse reporting.

Student Financial Assistance Cluster – Assistance Listing No. 84.268, 84.063, 84.007. Recommendation: CLA recommends the University review the requirement and implement an internal process and control to specifically monitor the outstanding Title IV funded checks throughout the year. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The University agrees with the auditors’ recommendations of corrective action needed to ensure unclaimed Title IV federal funds are resolved within 240 days of disbursement date. The University has reviewed existing processes and identified improvements that will be made to internal procedures to ensure proper compliance is met. Name(s) of the contact person(s) responsible for corrective action: Delora Shoop & Amanda Bauer. Planned completion date for corrective action plan: December 2024

Finding 2024‐002 Federal Agency Name: Direct Program – Department of Education Assistance Listing Number: P063P237884, P268K247884, P033A239207, P007A239207 Program Name: Student Financial Assistance Cluster Finding Summary: The College implemented new software functionality that automated sending notifications to students upon loan disbursement. The notifications of student financial aid disbursements were not sent timely due to the process being ran in simulation mode and this was not immediately identified by the College staff. Students were notified of their financial disbursement when this error was noticed by the College staff during the fiscal year 2024, however it was not within the 30 days outlined above. The College was able to correct the process for the summer 2024 disbursements, in which the 30-day time frame was met. Corrective Action Plan: The Assistant Director of Financial Aid will automatically receive an emailed report of all disbursement notifications that are emailed students each time email notifications are processed. The Assistant Director of Financial Aid will run a communication verification report each week to ensure that all disbursed loans correspond to disbursement emails sent to students. Any missing emails will be sent within the required time frame and meetings will occur with the responsible staff person as needed. The Executive Director Financial Aid reviews this communication verification report each month. Responsible Individuals: Jeneé Snyder, Executive Director Financial Aid Michelle Haviland, Assistant Director Financial Aid Anticipated Completion Date: Change in control process implemented July 1, 2024.

Student Financial Aid Cluster: Federal Pell Grant Program – Assistance Listing 84.038 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: The finding was isolated to less-than-half-time Pell recipients. These recipients will be processed through the auto-packing process and then will undergo a secondary manual review prior to disbursement. Name(s) of the contact person(s) responsible for corrective action: Laura Hughes and John Bender Planned completion date for corrective action plan: Immediate Implementation

Student Financial Aid Cluster: Federal Supplemental Educational Opportunity Grant – Assistance Listing No. 84.007 Federal Work Study Program – Assistance Listing No. 84.033 Federal Perkins Loan Program– Assistance Listing No. 84.038 Federal Pell Grant Program – Assistance Listing No. 84.063 Federal Direct Student Loans – Assistance Listing No. 84.268 Teacher Education Assistance. for College and Higher Education Grants– Assistance Listing No. 84.379 Nursing Student Loans – Assistance Listing No. 93.364 Recommendation: We recommend that the College work with their third-party servicer and implement procedures to ensure that enrollment data, changes in status and effective dates within NSLDS are reported accurately and timely. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Financial Aid Office took over the administration of this process due to personnel changes in the Registrar’s Office this past year. During this time period, we have reduced the incidents from 114 to 13. Enrollment reports will continue to be submitted monthly. The data is reviewed at various intervals of the process by Registrar and Financial Aid staff and the reviews are documented. Corrections and updates are provided and submitted as required. Procedures will be updated to reflect all changes and validations. Additional focus will be on the reports which overlap semesters. Timelines will be reviewed and adjusted as determined necessary Name(s) of the contact person(s) responsible for corrective action: Laura Hughes, Soo Lee Bruce-Smith, Travis Osburn, Kim Tuschhoff and John Bender Planned completion date for corrective action plan: Immediate Implementation

Return of Title IV (R2T4) Calculations Planned Corrective Action: The financial aid office has developed a checklist that the aid administrators will use to determine if aid sources have been posted/disbursed to student accounts prior to completing R2T4 calculations. The Financial Aid Office will maintain the checklist record of this verification for audit purposes and to track compliance. The Senior Financial Aid Counselor will complete the R2T4 calculations and one of our Financial Aid Counselors will monitor the completion of all checklist records as part of a check and balance process. Person Responsible for Corrective Action Plan: Cindi Patterson, Director for Financial Aid Anticipated Date of Completion: 10/01/24

The University agrees with the auditor’s findings and recommendation. The following corrective action will be taken: The University will implement controls to ensure student’s aid is being packaged and awarded on the anticipated enrollment of the student, with correct corresponding EFC. The Office of Student Financial Assistance will collaborate with IT to ensure proper training and review of packaging logic accurately reflects the students’ federal student aid eligibility. Anticipated Completion Date: December 31, 2024 Leah Stewart, Assistant Vice President, Enrollment Management

The University agrees with the auditors' finding and recommendation. The following corrective action will be taken: The University Registrar will adhere to: Provisions of 34 CFR Section 685.309(b) will be followed when reporting to NSLDS. The University will develop and implement controls to ensure students’ classification based on actual allowable credit hours are being properly reported to NSLDS. Unofficial withdrawals will be monitored to ensure timely reporting to NSLDS. The University Registrar will work collaboratively with the Information Technology office to modify the enrollment report to identify students with external credits as well as students who stop attending to allow proper reporting to the NSLDS within the required 30 days. Anticipated Completion Date: December 31, 2024 Leah Stewart, Assistant Vice President, Enrollment Management

Northern Kentucky University agrees with the auditors' finding and recommendations. The following corrective action will be taken: The University will return $22,621 in federal student financial aid to United States Department of Education (USED) which represents the updated R2T4 accounting for the correct academic calendar end dates and breaks periods for the 2023-24 academic year. The University provided the external auditors with the current year academic calendar (end of period, break day, etc) for review and validation. The correct definition and calculation of days (end of enrollment period, break days, etc) will be used with return calculations. There will be a review process that will include validation from the Assistant Vice President, Enrollment Management to verify calculations before finalizing returns. Training will be provided to all relevant staff on the proper calculation methods to ensure compliance and accuracy which will include the review of the Federal Student Handbook - Volume 5 - Withdrawals and the Return of Title IV Funds and other relevant guidance from USED. Anticipated Completion Date: December 31, 2024 Leah Stewart, Assistant Vice President, Enrollment Management

Corrective Action Plan – The University ahs reviewed the requirements outlined in 34 CFR 668.164(e) and (f) and the Department of Education’s required submission. The University will comply with the requirements outline. It should be noted that the information required in the above referenced code was available to the students on the University’s website at all times. Implementation – The University submitted the required information to the Department of Education on September 13, 2024. Responsible Official - Deborah Zimmerman, Controller

Corrective Action Plan – The University has engaged the Chief Information Security Officer, IT Security personnel and the Chief Information Officer to review all elements of the Gramm-Leach Bliley Act requirements to ensure that the University complies with all required elements of the Act. A detailed listing of all elements had been prepared; however, full assessment and implementation of remediation needed was not completed in a timely manner. Fifty five percent (55%) of the identified actions were completed at the time of the audit. Remaining items including a Written Information Security Plan were scheduled to be completed by February, 2025. Implementation – The responsible parties for implementation of the corrective action plan and ongoing compliance include the Chief Information Officer, Karl Horvath. As stated previously, over half of the needed items were completed prior to the audit, the Written Information Security Plan was completed by October 1, 2024 and the remaining items are due to be completed by February 28, 2025.

Corrective Action Plan - Upon reflection of the term end date and subsequently the status change date, the Office of Registrar at the University of Dallas updated the term end date to the last date of educationally related activities more widely known as the last date of the final examinations for each relevant term. Upon consultation with the Office of the Provost at the University of Dallas and the appropriate Deans of the affected Colleges, the program length for the Master’s programs at the University of Dallas will be updated to three (3), for those programs who are at least 30 credit hours in length: which will meet a reasonable progression to such degree. The Office of Registrar at the University of Dallas will update all such programs for the University of Dallas. The Office of Registrar and the Office of Financial Aid explored reporting enrollment directly to the National Student Loan Data System and while such was initially promising, the Office of Financial Aid determined that such activity would be disruptive to the business practices of the University of Dallas given the work needed for the Financial Value Transparency and Gainful Employment reporting in which the National Student Loan Clearinghouse has served as an invaluable partner. This option may still be explored further if additional resources become available. The Office of the Registrar at the University of Dallas will split the graduation file sent to our third-party servicer, NSLC, so that the students from the Satish & Yasmin Gupta College of Business who are on a different calendar may be reported to NSLDS sooner which should assist in reporting those students on an earlier timeframe. The Office of Registrar at the University of Dallas will begin rolling grades the week after Add/Drop on a weekly basis of each term to reduce the timeframe for students who have withdrawn from a course to be reported to NSLDS. The Office of the Registrar at the University of Dallas will update the grading policy in Ellucian Banner to align any changes in grading policy for students who fail to attend course. The Office of Financial Aid will work with the Student Registrar to ensure such reporting is accurate by reviewing the set-up of such data points as Enrollment Effective Date, Enrollment Status, Term Begin Date, Term End Date and Award Completion Date. Implementation - The responsible parties include the Office of Registrar - Paula Brown, Registrar, the Office of Financial Aid, James Hubener, Director of Financial Aid, along with the staff of Information Technology led by Karl Horvath at the University of Dallas. Some updates to the status change dates or term end dates have already been recorded. Updates to the program length for Master’s programs will be made by November 2024. Implementation of internal Office of Registrar functions to assist in reporting for changes in grades and enrollment levels should be in place by November 30, 2024. Any change in the processing of the Graduated file from NSLC should be in place by the anticipated date of implementation of February 28, 2025. Full utilization of all changes by May 15, 2025 at the close of the Spring 2025 term.

Title: Student Financial Assistance Cluster – Assistance Listing No. 84.063 Recommendation: We recommend the College evaluate its procedures and policies around reporting Pell disbursements to COD to ensure that student information is reported accurately and timely. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Our office will create formal procedures for the Pell origination/disbursement process to ensure that our dates within the system and COD are aligned. Additionally, our new financial aid management system (FAMS) has the ability to track discrepant dates between COD and our FAMS and we will regularly use this feature to ensure compliance. Name(s) of the contact person(s) responsible for corrective action: Danielle Hayden Planned completion date for corrective action plan: November 1, 2024

Title: Student Financial Assistance Cluster – Assistance Listing Nos. 84.007, 84.0033, 84.063, 84.268 Recommendation: We recommend the College 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: Last year, we developed additional validation steps to ensure that the status of every student who has completed their program and graduated is accurately reflected at both the National Student Clearinghouse and NSLDS. These validation steps improved the accuracy of reporting for students included in the bulk reporting process. I will conduct a comprehensive review of our current reporting procedures to identify any gaps or inefficiencies. An additional staff member will be trained to report individual students to the National Student Clearinghouse in a timely manner, ensuring that any "one-off" updates are promptly completed. Name(s) of the contact person(s) responsible for corrective action: Theresa Rodriguez Planned completion date for corrective action plan: October 1, 2024

Student Financial Assistance Cluster – Assistance Listing No. Various Recommendation: We recommend the University reevaluate its procedures and review policies surrounding reporting status changes to NSLDS to put a process in place to ensure the 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: Financial aid maintains a log of all Title IV withdrawals, and going forward it will provide access to this log to the Registrar’s Office and will notify the Associate Registrar each time a student is determined to be withdrawn for R2T4 purposes. This will ensure that the Financial Aid Office and the Registrar’s Office are aligned with regard to a student’s Title IV enrollment status. This will be particularly helpful to ensure compliance for students enrolled in modules, where a student could be considered withdrawn for a semester even if their transcript shows that credit was earned for all of their officially attempted credits. This compliance issue was discovered and remediated by Drake prior to the audit as part of our own internal review process. Upon each submission of the graduation data file to the National Student Clearinghouse, the Registrar’s Office will double-check the count of awarded degrees that appear on the submission file and compare it to the number of awarded degrees as reported by Drake’s student information system. Additionally, shortly after each file is submitted to the NSC, the Registrar’s Office will cross-check a sample of JD graduates against both the NSC database and the NSLDS database to ensure that the graduation status for graduates of the JD program is being accepted and processed by the NSC as expected, and that they are in turn properly reported to NSLDS. Name(s) of the contact person(s) responsible for corrective action: Kevin Moenkhaus, Associate Registrar and Brandi Miller, Assistant Director of Financial Aid. Planned completion date for corrective action plan: September 1, 2024.

Student Financial Assistance Cluster – Assistance Listing No. Various Recommendation: We recommend the College review its reporting procedures to ensure the 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: Since uncovering this concern, the College is actively working with our third-party vendor (NSC) and our reporting team to resolve the technical issues that caused the errors. We have corrected the dates in NSLDS for the affected students. We have added an additional audit of data submitted to NSC and in NSLDS to rectify any technical errors within the required timeframe. Name of the contact person responsible for corrective action: Jaz Hofbauer, Registrar Planned completion date for corrective action plan: This process is in place for the 2024-2025 academic year.

Student Financial Assistance Cluster – Assistance Listing No. Various Recommendation: We recommend the College evaluate the transfer students’ status each semester. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The student affected by this deficiency gave erroneous information about attendance at another college in the same year as their intent to begin at Dunwoody. The processor failed to follow protocol to check for a transcript in NSLDS. The student had only used some of their loan eligibility at the previous institution in the fall semester, so we returned $5,250 in direct loan funds for this student. The student correctly retained the remaining $4,250 for the spring semester at Dunwoody. The total over award was not $9,500 but $5,250. Going forward, the financial aid counselors will be vigilant to search out every student in NSLDS before issuing the student any additional funding. There is now a check and balance in place that will catch anything the financial aid counselor might miss. Name of the contact person responsible for corrective action: Margaret Price, Director of Financial Aid Planned completion date for corrective action plan: This process is in place for the 2024-2025 academic year.