Corrective Action Plans

Management's Response: We concur. View of Responsible Officials and Corrective Action Plan I. Campus IVY will aid with the data collection for the FISAP 2. Campus IVY will run a disbursement repo11 showing how much FA was disbursed prior year and record 3. Campus IVY will run !SIR report to show eligible applicant and record 4. School will run population repo11 out of Populi and record 5. Campus IVY will run a report to show the amount of FSEOG disbursed prior year and record 6. Once all data is collected, a comparison year to year will take place 7. A comparison of student population as well as amount used 8. The result will allow the school to determine the amount of FSEOG is needed for upcoming year. This correction action plan will allow Community Christian College to repo11 FISAP figures properly with suppo11ing documentation.

Management's Response: We concur. View of Responsible Officials and Corrective Action Plan The following is the procedure that the College will be implemented to ensure that student withdnrn al calculations are performed accurately and returned within 30 days: I. The registrar will send a list to financial aid of all students that have dropped by end of day every Thursday of each week. a. The list will include date of determination (DOD) and last date of attendance (LOA) of each student b. DOD will be within 14 days of student LOA 2. Upon receipt of the list financial aid will complete the following for each student: a. Gather student's current ledger card b. Gather student's current Transcript c. Complete a cover sheet which indicated the current loan period of the student. d. Financial aid will send over items to 3rd party processor in order for R2t4 calculation to be completed (Campus IVY) no later than Wednesday of the following week by end of business day. 3. Campus IVY will complete the R2T4 3-5 business days upon receipt and conduct the following: a. If a refund is required- campus IVY will schedule the refund, update student account and send to school. b. School (student accounts) will review the refund, update student account and monies will be placed in the operations account and sent back to GS. c. If a refund is not required based on the R2T4 results, Campus IVY will notate the student account. This corrective action plan will allow Community Christian College to complete the drop process for each student within 30 days from LOA.

Finding No. 2023-003: Failure to Notify Recipients of Federal Direct Loan Disbursement CFDA Numbers: 84.268 Program: Student Financial Assistance Cluster Corrective Action: The University added a monitoring report to identify any communication failures for disbursement notifications. Implementation Date: June 10, 2024 Contact Person: Amanda Fijal

Finding No. 2023-004: Untimely and Inaccurate Reporting of Pell and FDL Data CFDA Numbers: 84.268 Program: Student Financial Assistance Cluster Corrective Action: A control will be added to loan set-up. Additional training was provided to staff monitoring loan reports. Implementation Date: June 10, 2024 Contact Person: Amanda Fijal

Name of Responsible Individual: Nate R. McGill, Associate Director, Center for Career & Professional Success, Ben Carmichael, Associate Director for Compliance, John Hooth, Senior Director of Payroll Corrective Action: Federal Work Study supervisors are required to have training on the appropriate policies and procedures when hiring a Federal Work Study student. They will sign off on a document stating they understand they must follow these procedures and losing the privilege of hiring FWS students can be the result of not following these policies and procedures. One of these policies is that students cannot have time approved prior to working those hours. The student’s hours work may match the pay the student received and was approved for, but it is against policy to approve hours before the student worked. FWS supervisors will sign they understand this. The Federal Work Study coordinator (located in the Center for Career & Professional Services) is responsible for reviewing the hours a student works and ensuring supervisors have approved the correct number of hours and the hours were approved after the student worked those hours. Due to turnover in the department, a full-time FWS coordinator had not been hired and the person responsible for reviewing the hours worked had additional responsibilities outside of monitoring Federal Work Study. A full-time Federal Work Study Coordinator position has been approved and the anticipation is this position will be filled prior to the end of the Fall 2024 semester. The Associate Director for Compliance will include a review of when the supervisor approved the students’ hours as a part of the bi-semester Federal Work Study sample. These reviews are completed to ensure students are paid on-time and accurately, as well as ensure the student is not working-class hours. This plan to include when the supervisor approved the hours should provide another layer of oversight. Anticipated Completion Date: The Center for Career and Professional Services is anticipating hiring a full-time Federal Work Study Coordinator by the end of the Fall 2024 semester. All FWS supervisor training occurs prior to the hire of any Federal Work Study students and the first review of timesheets to ensure accuracy/timeliness in payment, as well as no supervisor approves time prior to the student working.

Name of Responsible Individual: Ben Carmichael, Associate Director for Compliance, Roderick Johnson, Assistant Director for Compliance, Robert Muhammad, Executive Director of Financial Aid and Robin Whitfield, Associate VP for Finance & Bursar Corrective Action: It was discovered in December 2021 that Part III Federal Perkins Loan portion of the FISAP had experienced data conversion issues after the conversion from ACS Loan Servicing to ECSI Corporation as the University’s third-party servicer. There were Perkins Loans disbursed to students not included in the conversion, so the data provided annually by ECSI had accuracy issues. The University had approached ECSI in March 2022 requesting a review of the ACS data provided at conversion and an updated report that can be used to accurately complete the FISAP. Work on the project halted due to invoicing issues between Howard University and ECSI. There are currently no invoicing issues between ECSI and Howard University, so the institution engaged with ECSI in March 2024 to identify the loans that fell off during conversion from ACS and then we will update the prior year FISAP’s as needed. ECSI has informed Howard it could take 6 months or more for the comparison process to be completed and made available to the University for updating of prior year FISAP’s. ECSI has stated to Howard that most institutions do not attempt to reach this parity, as it can be difficult to accomplish. Anticipated Completion Date: December 2024 is the anticipated date by which Howard would expect the comparison process to be completed. Howard has been in contact with ECSI and the comparison process is still ongoing.

Name of Responsible Individual: Konya White, Director of Enrollment Systems Associate Director for Compliance, Ben Carmichael, Associate Director for Compliance, and Roderick Johnson, Assistant Director for Compliance Corrective Action: This student’s Pell disbursement was not reported within 15 days of disbursement due to the COD (Common Origination Disbursement) system rejecting the student’s disbursement. These Pell rejects are worked through the reconciliation process and this exception was not worked in a timely manner, resulting in COD accepting the disbursement past the 15-day deadline. The Howard University employee who was completing reconciliation of Title IV funds, as well as responsible for working through any Pell rejected disbursements is no longer employed at Howard. The Assistant Director for Compliance works in the Office of Financial Aid and responsible for completing reconciliation and working any Pell rejected disbursements. The Associate Director for Compliance in Enrollment Management reviews reconciliations and ensures any rejected disbursements are resolved within the 15-day timeframe. Anticipated Completion Date: This finding was mitigated in May 2023. The responsibility of Title IV reconciliation was performed and worked by two consultants who had experience with Title IV reconciliation. The Assistant Director for Compliance hired in January 2024 has experience with Title IV reconciliation and was trained by the two consultants on Howard procedures for Title IV reconciliation and working rejected disbursements. The responsibility for Title IV reconciliation now lies entirely within the Office of Financial Aid.

Name of Responsible Individual: Ben Carmichael, Associate Director for Compliance, Roderick Johnson, Assistant Director for Compliance, Robert Muhammad, Executive Director of Financial Aid and Brenda Willis, Senior Executive Director of Financial Grants & Contracts Corrective Action: The University will continue to provide additional information and training to personnel outside of the Office of Financial Aid. This information and training – where applicable – will be used to ensure that the University’s policies and procedures are in line with federal regulations and that internal policies and procedures do not supersede or impede federal regulations. Anticipated Completion Date: October 31, 2024. The Senior Executive Director of Financial Grants and Contracts is currently working with the Associate Director for Compliance and the Executive Director of Financial Aid to improve communication between all departments responsible for cash management.

Name of Responsible Individual: Ben Carmichael, Associate Director for Compliance, Konya White, Director of Enrollment Systems and LaTrice Byam, Executive Director of Academic Planning and Curriculum Corrective Action: The Enrollment Reporting process is supervised by the University Registrar and is responsible for providing enrollment reports to Howard University’s third-party servicer, National Student Clearinghouse (“NSC”), who then submits the report to NSLDS student’s enrollment status. The University is committed to ensure sufficient training and support to the Office of the Registrar to keep the institution in compliance. While the expectation is the University will hire an experienced University Registrar and Associate Director Registrar for compliance, continued training opportunities will be made available through National Student Clearinghouse and NASFAA (National Association of Student Financial Aid Administrators). The reported data is for students who are ¾ time during a semester, “3Q,” was discovered through testing of enrollment reporting samples to not be set up correctly in Banner. This has resulted in students who are taking between 9-11 credits being reported as “H” for half-time instead of “3Q” for three-quarter time. The newest University Registrar set up the “3Q” status correctly in Banner in January 2024 and testing of enrollment reporting samples show the 3Q status is accurate. The students in the program and campus-level findings should now be accurately reported as “3Q.” After speaking with the Executive Director of Academic Planning and Curriculum, the CIP codes for the program identified as findings had not been updated when all CIP codes were updated in 2020. She also confirmed the length of the program was incorrectly published on the site for these programs. Howard has moved to Workday Student as the University’s Enterprise Resource Planning system and the accurate CIP codes and program lengths were confirmed. The transition to Workday Student allowed the University to review each program to ensure accuracy when integrating the data from Banner to Workday. The University Registrar was not aware the FSA Audit testing exempt range of 07-19-2022 through 02-28-2024 required students who had an enrollment change during that period to be updated. This audit exemption range was abnormal, and the University hired a new Registrar during this time period, which resulted in there being no knowledge transfer the enrollment changes had not been updated. Graduation files are now being sent monthly to the National Student Clearinghouse to avoid students not being picked up for graduation as they are cleared. Anticipated Completion Date: The correction to the “3Q” status took place in January 2024 and testing has shown this issue to be resolved. Additional testing will occur in the new ERP Workday to ensure incorrect reporting of students who are ¾ time does not occur. Enrollment reporting samples will be pulled approximately 2-3 weeks after the first Fall 2024 enrollment file is sent to National Student Clearinghouse.

2023-008 Student Financial Aid Cluster (a) Federal Supplemental Educational Opportunity Grant (b) Federal Work Study Grant (c) Federal Pell Grant Program (d) Federal Direct Loan Program, Assistance Listing No. (a) 84.007 (b) 84.033 (c) 84.063 (d) 84.268 - Year Ended June 30, 2023 Condition: During our testing of thirty-seven student files, we noted one individual (2.7%) received an excess of $1,969 over the maximum undergraduate level of $23,000 in Federal Direct Subsidized Loans. Corrective Action Plan: During the 2022-23 school year, an employee who retired in May 2023 awarded all returning student institutional aid and federal aid. Upon her retirement, Hannah Masters, Executive Director of Financial Aid and Student Accounts, took over awarding all students (incoming and returning students). Starting in June 2023, Hannah awards all students based on enrollment status from Jenzabar 1 (Cottey's ERP) for returning students and Salesforce for incoming students. Then on census date, the Registrar sends an updated final report of student grade level and attempted credit hours. Hannah then reviews all student accounts manually and confirms the enrollment, grade level, and loan levels for each student. This ensures no student is under or over awarded for the term based on grade level or financial need. Responsible Person for Correction Action Plan: Hannah Masters Implementation Date for Corrective Action Plan: June 2023

2023-007 Student Financial Aid Cluster (a) Federal Supplemental Educational Opportunity Grant (b) Federal Work Study Grant (c) Federal Pell Grant Program (d) Federal Direct Loan Program, Assistance Listing No. (a) 84.007 (b) 84.033 (c) 84.063 (d) 84.268 - Year Ended June 30, 2023 Condition: Throughout the year cash on hand exceeded the immediate disbursement needs for three working days and the excess cash tolerances were not eliminated within seven working days. We consider this condition to be a significant deficiency in internal control over compliance relating to the Cash Management compliance requirement and is not a repeat finding. Corrective Action Plan: During the 2022-23 fiscal year, SEOG and Federal Work Study funds were drawn when funds were authorized, not when funds were expended. The mistake was realized in the Federal Work Study draw and the funds were returned, but the SEOG draw was not refunded. The funds were subsequently awarded. Going forward all Federal Funds will be drawn after they are awarded. Responsible Person for Correction Action Plan: Kevin Smithberger Implementation Date for Corrective Action Plan: August 2024

2023-006 Student Financial Aid Cluster (a) Federal Supplemental Educational Opportunity Grant (b) Federal Work Study Grant (c) Federal Pell Grant Program (d) Federal Direct Loan Program, Assistance Listing No. (a) 84.007 (b) 84.033 (c) 84.063 (d) 84.268 - Year Ended June 30, 2023 Condition: During our testing of thirty-seven student files, we noted two individuals (5%) did not receive the full amount of their Federal Direct Subsidized Loans. We consider this condition to be an instance of non-compliance relating to the Eligibility compliance requirement. Statistical sampling was not used in making sample selections. Corrective Action Plan: During the 2022-23 school year, an employee who retired in May 2023 awarded all returning student institutional aid and federal aid. Upon her retirement, Hannah Masters, Executive Director of Financial Aid and Student Accounts, took over awarding all students (incoming and returning students). Starting in June 2023, Hannah awards all students based on enrollment status from Jenzabar 1 (Cottey's ERP) for returning students and Salesforce for incoming students. Then on census date, the Registrar sends an updated final report of student grade level and attempted credit hours. Hannah then reviews all student accounts manually and confirms the enrollment, grade level, and loan levels for each student. This ensures no student is under or over awarded for the term based on grade level or financial need. With the staffing changes, we are also now reviewing each package every time a FAFSA update is imported. This gives us another round of reviews to ensure students are not over or under awarded based on financial need. Responsible Person for Correction Action Plan: Hannah Masters Implementation Date for Corrective Action Plan: June 2023

2023-005 Student Financial Aid Cluster (a) Federal Supplemental Educational Opportunity Grant (b) Federal Work Study Grant (c) Federal Pell Grant Program (d) Federal Direct Loan Program, Assistance Listing No. (a) 84.007 (b) 84.033 (c) 84.063 (d) 84.268 - Year Ended June 30, 2023 Condition: The College did not timely and accurately complete refund calculations due to excluding one extra day in error for Thanksgiving break, which caused the total days to be off by one day. In review of the calculations the number of days in the break was not calculated correctly, resulting in the incorrect days in 1 out of 4 return of Title IV funds calculations. As a result of the incorrect number of days, the amounts of Title IV returned was incorrectly calculated for 1 out of the population of 4 (25%) withdrawal calculations which resulted in only $32 being under refunded for one student in the sample. We consider this finding to be an instance of non-compliance in relation to Special Tests and Provisions and is not a repeat finding. Statistical sampling was not used in making sample selections. Corrective Action Plan: The Registrar's Office will review the school calendar in Common Origination and Disbursement Web Site before the financial aid office begins processing R2T4's for the school year. Responsible Person for Correction Action Plan: Hannah Masters (Executive Director of Financial Aid and Student Accounts) and Chayna Penney (Registrar) Implementation Date for Corrective Action Plan: 09/10/2024

2023-004 Student Financial Aid Cluster (a) Federal Supplemental Educational Opportunity Grant (b) Federal Work Study Grant (c) Federal Pell Grant Program (d) Federal Direct Loan Program, Assistance Listing No. (a) 84.007 (b) 84.033 (c) 84.063 (d) 84.268 - Year Ended June 30, 2023 Condition: The College did not report actual loan disbursement dates to the Common Origination and Disbursement (COD) system for 5 of the 37 students in the sample (13.5%). We consider this condition to be a significant deficiency in internal control over compliance relating to the Eligibility compliance requirement and is a repeat finding shown in Section IV of this report as prior year finding 2022-003. Statistical sampling was not used in making sample selections. Corrective Action Plan: During the 2022-23 school year, an employee who retired in May 2023 worked in the financial aid office. After retiring, a new position was created that is split between the Business Office and Financial Aid and Student Accounts office. This position now reviews student accounts weekly, and during that review they compare the date of disbursement to the student account and the date of disbursement in COD. Through this process, any mismatched dates are corrected and updated to COD. Due to the audit completion delay, our action plan for the previous audit could not be put into place before the year had already been completed. Below is the previous audit plan to show that it was implemented, however, timing meant implementation happened after the 2022-23 year had ended. The financial aid office is currently hiring for a new position that will oversee student accounts. Once this position is filled, we will implement our updated policy and procedure that requires review and collaboration to monitor COD disbursement date, financial aid software disbursement date and student billing statement disbursement date. This will ensure both financial aid staff and student accounts staff will confirm each date in all areas. Planned completion date for corrective action plan: 06/30/2023 Responsible Person for Correction Action Plan: Hannah Masters Implementation Date for Corrective Action Plan: June 2023

2023-003 Student Financial Aid Cluster (a) Federal Supplemental Educational Opportunity Grant (b) Federal Work Study Grant (c) Federal Pell Grant Program (d) Federal Direct Loan Program, Assistance Listing No. (a) 84.007 (b) 84.033 (c) 84.063 (d) 84.268 - Year Ended June 30, 2023 Condition: During our testing of thirty-seven student files, we noted three individuals (8%) received a subsidized loan in excess of need. We consider this condition to be an instance of non-compliance relating to the Eligibility compliance requirement. Statistical sampling was not used in making sample selections. Corrective Action Plan: During the 2022-23 school year, an employee who retired in May 2023 awarded all returning student institutional aid and federal aid. Hannah Masters, Executive Director of Financial Aid and Student Accounts, took over awarding all students (incoming and returning students). Starting in June 2023, Hannah awards all students based on enrollment status from Jenzabar 1 (Cottey's ERP) for returning students and Salesforce for incoming students. Upon census date, the Registrar sends an updated final report of student grade level and attempted credit hours. Hannah then reviews all student accounts manually and confirms the enrollment, grade level, and loan levels for each student. This ensures no student is under or over awarded for the term based on grade level or financial need. With the staffing changes, we are also now reviewing each package every time a FAFSA update is imported. This gives us another round of reviews to ensure students are not over or under awarded based on financial need. Responsible Person for Correction Action Plan: Hannah Masters Implementation Date for Corrective Action Plan: June 2023

Recommendation: We recommend that the Organization implement procedures to document and maintain the documentation to support the controls over compliance are not only properly designed but are working. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Waldorf has established procedures that instead of a second person simply reviewing the first person’s work, that we sign off and date at the time of review. If we cannot sign off in person, we will send an email for confirmation of the review for later documentation. We had the controls in place but lacked the proper documentation. We believe with implementing these items as our procedure will resolve this finding. Name(s) of the contact person(s) responsible for corrective action: Duane Polsdofer Planned completion date for corrective action plan: Immediately

Recommendation: We recommend that the Organization implement procedures to document and maintain the documentation to support the controls over compliance are not only properly designed but are working. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Waldorf reports enrollment data to NSLDS through National Clearinghouse (CH). Waldorf University just recently signed a contract with Jenzabar to adopt their platforms of JRM (Jenzabar Recruiting Management), J! (Jenzabar’s SIS system) and JFA (Jenzabar Financial Aid). This aid in all functions of the university from recruiting, enrollment, awarding, disbursing, academics, grading, and most all aspects of the university. We will no longer be tied to a homegrown system from our prior owners that was originally created for only a single university. We will have IT’s full support for their web-based software directly from the creators of the system. We believe having all the functions under one software platforms will greatly improve operations enabling the university to meet and exceed all guidelines. We are slated to begin with the JRM and JFA modules io late summer or early fall of 2025, with the full university on J1 by summer 2026. We are very excited to be able to finally resolve this finding. Name(s) of the contact person(s) responsible for corrective action: Duane Polsdofer Planned completion date for corrective action plan: Summer of 2026 (new system)

Recommendation: We recommend the College consider hiring a firm to review their documentation and ensure that there are documented safeguards for identified risks and the required documentation and practices are implemented. We also recommend reviewing the changes in the Gramm-Leach-Bliley Act regulations that were required to be implemented as of June 9, 2023. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Waldorf University has contracted with a third-party for IT safeguards and a CPA firm that will help adhere to the most recent GLBA guidelines. Name(s) of the contact person(s) responsible for corrective action: Daisy Halvorson Planned completion date for corrective action plan: Fall of 2024

The fiscal department staff will compare the SACWIS placement cost report with billing. If any discrepancy occurs the fiscal department staff will confirm with the caseworker of the case for correct number of days. The fiscal department will verify the reimbursement report for accuracy.

United States Department of Education 2023-008 Student Financial Aid Cluster – Assistance Listing No. 84.007, 84.033, 84.063, 84.268 Condition: 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. Auditors’ Recommendation: We recommend the University engage a third party or perform the risk assessment for the two areas required by the Gramm-Leach-Bliley Act that have not been completed and documented and ensure that there are documented safeguards for identified risks. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The University has implemented a new SIS and Financial Aid processing system. The new systems are Jenzebar products and are fully compliant. Name(s) of the contact person(s) responsible for corrective action: Qiana Hall, Associate VP of Enrollment Services Planned completion date for corrective action plan: June 30, 2024

United States Department of Education 2023-006 Student Financial Aid Cluster – Assistance Listing No. 84.007, 84.033, 84.063, 84.268 Condition: Students tested in the Common Origination and Disbursement (COD) reporting were not properly reported based upon University documents, including disbursement dates and applied dates. Auditors’ Recommendation: We recommend that the entity strengthen its internal controls to ensure that all disbursement dates are reported to COD accurately and timely. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The previous SIS was subject to frequent interruptions which prevent timely data exchange with COD. Beginning with the 2024-2025 award year a new financial aid processing system was implemented. The new processing system is a more secure environment and hosted by Jenzabar for added compliance assurance. Name(s) of the contact person(s) responsible for corrective action: Qiana Hall, Associate VP of Enrollment Services Planned completion date for corrective action plan: June 30, 2024

United States Department of Education 2023-005 Student Financial Aid Cluster – Assistance Listing No. 84.007, 84.033, 84.063, 84.268 Condition: The University is not reporting student information to the Clearinghouse. Students tested did not have their enrollment status properly reported to the Clearinghouse. Auditors’ Recommendation: We recommend that the entity strengthen its internal controls to ensure that all enrollment records are reported correctly and within the required time frame. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The university uses HEAG Consultant Group for enrollment reporting to NSLDS. HEAG has been made aware of these findings and corrective actions have been requested. Name(s) of the contact person(s) responsible for corrective action: Qiana Hall, Associate VP of Enrollment Services Planned completion date for corrective action plan: November 30, 2024

United States Department of Education 2023-004 Student Financial Aid Cluster – Assistance Listing No. 84.007, 84.033, 84.063, 84.268 Condition: Student checks related to student refunds of Title IV federal financial aid was outstanding more than 240 days as of June 30, 2023. Auditors’ 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 engaged an external consultant in June 2023, hired a new staff accountant in September 2023 and a CFO in November 2023. The University is implementing financial internal controls policies and processes to improve the financial statements preparation and preparation of the schedule of expenditures and federal awards and ensure compliance with the DOE. This includes procedures related to outstanding student refund checks over 240 days. Name(s) of the contact person(s) responsible for corrective action: E. ZeNai Savage, CPA, CFO and Executive VP of Finance and Administration

United States Department of Education 2023-003 Student Financial Aid Cluster – Assistance Listing No. 84.007, 84.033, 84.063, 84.268 Condition: The University submitted inaccurate data in its annual FISAP report. Auditors’ Recommendation: We recommend the applicable campus revise procedures to ensure that the record retention requirements are met and supporting documentation agrees to the FISAP, including a supervisory review by someone other than the preparer. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Unduplicated Recipients for Ungrad/Dependent with salary range of $1000,000 and over was reported as one but should have been two. Completed FISAP reports are sent to the CFO for additional review prior to submission. Name(s) of the contact person(s) responsible for corrective action: Qiana Hall, Associate VP of Enrollment Services Planned completion date for corrective action plan: June 30, 2024

Finding 2023-001: Inaccurate and Untimely Enrollment Status Reporting Comments on Finding and Recommendation(s): Statement of Concurrence: We concur with the finding of inaccurate and untimely reporting of enrollment status. The issue was due to human error from a previous employee who has been terminated as well as a misunderstanding of the policy. The transition period following the termination further compounded these issues. Actions Taken or Planned: 1. New Hire: We have already hired a new member for Financial Aid position since April 2023. This individual is responsible for ensuring the accuracy and timeliness of enrollment status reporting moving forward. 2. Staff Training: • All relevant personnel, including the newly hired staff, have been scheduled for ongoing training on financial aid compliance and the reporting process. • We will ensure that each employee is proficient in using the reporting systems (e.g., NSLDS, COD) and understands the required timelines for submission. 3. Process Review and Improvement: We are reviewing our existing processes to identify gaps and inefficiencies in the current reporting system. Once identified, these processes will be updated to ensure better data accuracy and timeliness. 4. Ongoing Monitoring and Compliance Audits: We will establish regular internal audits and monitoring protocols to ensure continuous compliance with reporting standards. Completion Date: Ongoing Dong-Hua Yang MD, PhD Title: Administrative Dean