Corrective Action Plans

Planned Corrective Action: UW-Madison’s Office of Student Financial Aid (OSFA) and Registrar’s Office (RO) reviewed the enrollment reporting recommendations cited in Finding 2024-708 and corrected error reports as appropriate. UW-Madison will review procedures to report all changes in student enrollment accurately, completely, and in a timely manner for all instances that require reporting. OSFA and RO will review and update internal procedures to ensure that the date that a student is unofficially withdrawn is communicated and reported consistently between the National Student Loan Data System (NSLDS) and the National Student Clearinghouse (NSC) as appropriate. Prior to the LAB’s review, UW-Madison discovered and corrected issues relating to program enrollment status in NSC and NSLDS. As of November 2024, updates were made for all retroactive instances using appropriate conferral dates and accurate “G - Graduated” statuses. The long-term solution includes the creation of a “Graduates Only Enrollment” file which includes all students who have been reported as enrolled, not withdrawn in a given term and who have earned their degree in each of UW-Madison’s three degree conferral dates. This enrollment file will trigger an enrollment status update that occurs outside of the automatic NSC process. UW-Madison has updated procedures and now uses the NSC extract process to comply with the NSLDS and NSC reporting procedures for program-level enrollment status effective dates. For the beginning of the Fall 2025 term, UW-Madison will update procedures and extract logic from the student information system to ensure accuracy in the reporting of program begin dates. In the meantime, the RO team has reviewed, tested, and updated the process to ensure previously inaccurate program begin dates are corrected. Anticipated Completion Date: September 30, 2025 Person responsible for corrective action: Beth Warner Registrar Office – Division of Enrollment Mangement beth.warner@wisc.edu

Interim corrective actions: These cases involved situations where students dropped courses before withdrawing (officially or unofficially) from all courses. UW-River Falls did not have a system in place to review course participation for courses which students dropped prior to withdrawal, although it has procedures in place to review course participation for enrolled courses at the time of withdrawal and when students are assigned failing grades. For Fall Semester 2024: Existing procedures: 1. Official withdrawals: Students officially withdrawing from the University must complete an electronic form which collects instructor verification of course participation. The Financial Aid office receives this form once it has been processed by the Registrar’s office. Students reported as not having participated in courses have their financial aid adjusted prior to calculating a return to Title IV funds. 2. Unofficial withdrawals: Instructors assigning failing grades to students must report student’s course participation or non-participation and, if available, a last date of course participation. Following the grading deadline, a report listing all students who never participated in classes is run and students found to have failed courses due to non-participation have their financial aid adjusted prior to calculating a return to Title IV funds. Additional procedure instituted: 3. Learning management system review: Students who withdraw (officially or unofficially) and who dropped courses prior to withdrawing had their dropped courses reviewed in the Learning Management System (LMS). Students who submitted assignments as recorded in the system were determined to have begun participation in the course. Students who submitted no assignments were determined to not have participated in the course and financial aid was adjusted prior to calculating a return to Title IV funds. For Spring Semester 2025: Existing procedures: 1. Procedures 1,2, and 3 from Fall Semester 2024 continue to be employed for Spring semester 2025. Additional procedures: 2. Expanding the LMS review to Pell grant students with dropped courses: Students with disbursed Pell Grants who drop courses after the Pell grant census date now have these courses reviewed to determine if the student began attendance before dropping the course, using the same procedure as #3 above.Instructor course participation verification: After the 3rd week of classes for Spring 2025, UWRiver Fall requested that instructors report students who had not begun participation in their courses. This report is currently being reviewed and students with Pell grants will be evaluated to determine if an adjustment to the student’s enrollment intensity is needed to ensure that the disbursed Pell grant is accurate. Student who have begun participation in no enrolled courses will be reviewed for possible return of all Title IV funds. Future additional corrective actions: 1. UW-River Falls will pursue making course participation verification by instructors during the first month of the semester an administrative policy and develop formal procedures for surveying instructors and reporting students found to not have begun participation in a course or courses to the Financial Aid office for adjustments to their disbursed Title IV aid. 2. UW-River Falls will pursue adding an instructor course participation step to the course drop form currently in use by the Registrar’s office. Anticipated Completion Date: Interim actions were implemented in September 2024 and February 2025. Permanent action expected by Spring 2026. Person(s) responsible for corrective action: Cindy Holbrook, Executive Director of Enrollment Management Cindy.Holbrook@uwrf.edu 715-425-3500 Robert Bode, Director of Financial Aid and Military/Veterans Resource Center Robert.Bode@uwrf.edu 715-425-3141 Kelly Browning, University Registrar Kelly.Browning@uwrf.edu 715-425-3342 Responsible Unit Division of Enrollment Mangagement

Planned Corrective Action: Financial Aid will continue to reconcile Direct Loans and the Federal Pell Grant programs with the Department of Education through the Common Origination and Disbursement system. The loan coordinator and Pell Grant manager will confirm SIS amounts reconcile with WISER monthly, at minimum. If there are any discrepancies, the Controller will be contacted to assist with internal reconciliation of funds. Anticipated Completion Date: Will begin corrective action Spring 2025 Person responsible for corrective action: Alison Casady, Director of Financial Aid; casadya@uwosh.edu In conjunction with Direct Loan coordinator: Ashley Hass; hassa@uwosh.edu Pell Grant program manager: Elizabeth Bloedow; bloedowe@uwosh.edu Controller: Mai Lee; Financial Services; leemai@uwosh.edu

Finding 2024-001 Special Tests and Provisions - Enrollment Reporting Compliance and Internal Control Contact person(s) responsible for corrective action – Dennis Madigan, VP of Administration and Finance Anticipated completion date – Completed in July 2024 Corrective Action Federal Student Aid processing has moved to Bay Path University effective 7/1/24. Responsible Party: Dennis Madigan, VP Administration and Finance

Return of Title IV (R2T4) Calculations Federal Supplemental Educational Opportunity Grants; Federal Work Study Program; Federal Pell Grant Program; Federal Direct Student Loans – Assistance Listing No. 84.007; 84.033; 84.063; 84.268 Recommendation: We recommend that the University review the R2T4 requirements and implement procedures to ensure that scheduled breaks and correct withdrawal dates are properly factored into the calculations. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to the finding: Felician University has evaluated and updated our procedures in overseeing R2T4 requirements and will implement procedures to ensure that scheduled breaks and correct withdrawal dates are properly factored into the calculations. Appropriate staff have been notified, and management will monitor this issue regularly during the year to ensure compliance. Name(s) of the contact person(s) responsible for corrective action: Kathy Prieto, Director of Financial Aid Planned completion date for corrective action plan: April 1st, 2025.

Title IV Credit Refunds Federal Supplemental Educational Opportunity Grants; Federal Work Study Program; Federal Pell Grant Program; Federal Direct Student Loans – Assistance Listing No. 84.007, 84.033, 84.063, 84.268 Recommendation: We recommend the University evaluate its procedures and review policies in overseeing student credit balances to ensure credit balances are returned within the required 14-day timeframe. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to the finding: Felician University has evaluated and updated our procedures in overseeing student credit balances to ensure credit balances are returned within the required 14-day timeframe and notified the appropriate staff. Management will monitor this regularly during the year to ensure compliance. Names(s) of the contact person(s) responsible for corrective action: Mariela Henriquez, Director of Student Accounts Planned completion date for corrective action plan: April 1st, 2025.

Common Origination and Disbursement (COD) Reporting Federal Pell Grant Program; Federal Direct Student Loans – Assistance Listing No. 84.063, 84.268 Recommendation: We recommend the University evaluate its procedures and policies around reporting to the 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 the finding: Felician University has evaluated its procedures and policies around reporting to the COD to ensure that student information is reported accurately and timely. Appropriate staff have been notified, and management will regularly monitor this issue during the year to ensure compliance. Name(s) of the contact person(s) responsible for corrective action: Kath Prieto, Director of Financial Aid Planned completion date for corrective action plan: April 1st, 2025.

Federal Pell Grant Program; Federal Direct Student Loans – Assistance Listing No. 84.063, 84.268 Recommendation: We recommend the University evaluate its procedures and review regulations set by the Department of Education around NSLDS to ensure the University understands the definitions for each enrollment information that gets reported. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to the finding: Felician University has evaluated and updated our procedures in overseeing submission to NSLDS and notified the appropriate staff. Management will monitor this issue regularly during the year to ensure compliance. Name(s) of the contact person(s) responsible for corrective action: Erminda Velez, Director of Registration and Records Planned completion date for corrective action plan: April 1st, 2025.

The College will be looking at making some business process changes to review files submitted to NSC (National Student Clearing House) and NSLDS (National Student Loan Data Service) on a monthly basis and perform monthly reconciliation between responsible offices to ensure students are accurately reported to ED/NSLDS. This new implementation will allow the College/Office to better verify each student’s enrollment status, status changes and related effective date visibility of reporting issues in the future. Timeline for Implementation of Corrective Action Plan Implemented Fall 2024 Contact Person: Alaina Marcotte, Director Financial Aid

To ensure that there are no further instances of late return of title IV funds due to withdrawals, the financial aid office has updated their process. As a quality assurance measure, every withdrawal processed by the Registrar’s office will be sent to three individuals in the FA office- Director, Associate Director, and Withdrawal Coordinator. After the final withdrawal report from the Registrar’s office has been processed each semester, all students will be reviewed individually by Director, Associate Director, and Coordinator. The manual review process will ensure that all reported students have been appropriately reviewed and processed within the required timeframe. This updated process will eliminate the human error associated with the finding. Timeline for Implementation of Corrective Action Plan Implemented Fall 2024

2024-002 Notification of Disbursements (Significant Deficiency) Criteria: Institutions are required to report enrollment information under the Pell grant and the Direct loan programs via the NSLDS. The administration of the Title IV programs depends heavily on the accuracy and timeliness of the enrollment information reported by institutions. Institutions must review, update, and certify student enrollment statuses, program information, and effective dates that appear on the Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS Professional Access website in accordance with 34 CFR 690.83(b)(2) and 34 CFR 685.309. Condition: Eleven of the seventeen students selected for withdraw testing for the 2023-2024 academic year required an update to NSLDS enrollment status. The enrollment status for four students was not updated in a timely manner. Enrollment status updates failed to be reported within 60 days of the date of determination after the students were no longer enrolled on at least a half-time basis. Action Taken: As part of completing the institution’s conversion to a new student information system (Colleague), the Registrar’s Office has set up the enrollment management module, which streamlines enrollment and graduation reporting to the National Student Clearinghouse. The University has set an annual schedule of submissions with the National Student Clearinghouse, according to federal guidelines and has been following it accordingly. Responsible Party: Julie R. Allen, Registrar Point of Contact: Julie R. Allen, Registrar allen.jr@lynchburg.edu (434) 544-8223 Expected date of correction: January 1, 2025

2024-001 Notification of Disbursements (Significant Deficiency) Criteria: Prior to making a disbursement, the school must notify students of the amount and type of Title IV funds they are expected to receive, and how and when those disbursements will be made (often referred to as an award letter or college financing plan) (34 CFR 668.165(a)(1)). Condition: One out of twenty-five undergraduate students selected for disbursement testing for the 2023-2024 academic year was not documented as having been notified prior to the disbursement of Title IV funds. Notification failed to occur after the student's enrollment status changed from half-time to three-fourths time enrollment, making them eligible for additional Pell Grant awards. Action Taken: The University will request assistance from the software provider and consultants to develop a notification process for when a student’s enrollment status changes from half-time to three-fourths time enrollment. Responsible Party: Emily Williamson, Financial Aid Director Point of contact: Emily Williamson, Financial Aid Director Williamson_e@lynchburg.edu (434) 993-8253 Expected date of correction: June 1, 2025

U.S. Department of Education 2024-001 Student Financial Aid Cluster – Assistance Listing No. 84.063 & 84.268 Recommendation: We recommend that the University be utilizing the most current version of software for reporting, and the University reviews withdrawals monthly to ensure that the students are reported correctly to NSC and subsequently to NSLDS. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The University has submitted and reviewed a batch update for the two individuals currently labeled with incorrect statuses and/or effective dates. Name(s) of the contact person(s) responsible for corrective action: Nicole Biddle, Senior Director of Finance Planned completion date for corrective action plan: June 30, 2025

Finding#2024-001: 40 files were sampled, and 18 files were found to have late reporting. We agree with the findings and have put forward an action plan to ensure this is not a repeat finding in the future. 17 out of 18 students that were part of the findings were reported within the 60 days, however, the program and campus level were not matching in NSLDS. Per the NSLDS Enrollment Reporting Guide, both the campus level enrollment reporting and program-level enrollment reporting should be updated every 60 days. To ensure both program and campus-level enrollments are updated within 60 days, our Registrar will be working closely with the National Student Clearinghouse. We are reviewing each report generated by our system to ensure that the main data elements are found in the report which include: - Student current SSN - OPEID - CIP Code - CIP Year - Credential level - Published Program Length Measurement - Published Program Length - Weeks in Title IV Academic Year - Program Begin Date - Program and Campus Enrollment Status - Special Program Indicator - Program and Campus Enrollment Effective Date - Certification Date In addition, we are carefully reviewing the reports and changing the timing of reporting. One of the 18 students that was part of the findings withdrew and was not reported timely. The university will monitor closely with NSC the timing of files and reporting. Finding #2024-001 Action: Implementation of new control: Registrar to review system generated reports to match NSLDS reporting guides and monitor closely the timing of when files are processed and reported to NSLDS. Name of contact person responsible for corrective action plan: Marilyn Payan, University Registrar Anticipated Completion Date: Currently being implemented, to be completed before 12/31/2024.

Finding number: 2024-002 Federal agency: U.S. Department of Education Programs: Student Financial Assistance Cluster Assistance Listing #: 84.268 Award year: 2024 Corrective Action Plan: The Financial Aid Office has a robust policy and procedure for calculating the Return of Title IV (R2T4) Funds. In this particular case, the Financial Aid Counselor who completed the R2T4 calculation inadvertently transposed numbers when adjusting the subsidized student loan that needed to be returned to the U.S. Department of Education. While human error can never be fully eliminated, we take proactive measures in an attempt to avoid mistakes, such as testing the R2T4 process within Banner, our Student Information System (SIS), updating policies and procedures as needed, and providing ongoing staff training. In light of this error, an internal audit will be conducted to review all R2T4 calculations completed to date for the 2024-2025 academic year. Furthermore, staff will be provided additional training on the R2T4 process, reinforcing the importance of attention to detail. The staff member who made the error has been spoken to, and the necessary correction has been made to the student’s account. Timeline for Implementation of Corrective Action Plan: The corrective action plan will be implemented by April 2025. Contact Person Despina Lambropoulos, Director of Financial Aid

Finding number: 2024-001 Federal agency: U.S. Department of Education Programs: Student Financial Assistance Cluster Assistance Listing #: 84.007, 84.063, 84.268 Award year: 2024 Corrective Action Plan: In the Fall of 2023, the Registrar of 25 years retired, and the Assistant Registrar was promoted to replace her. During the transition, the new Registrar got behind in submitting Enrollment Reports for Spring 2024. The result of the first report being behind schedule caused a backlog of Enrollment and Error reports which resulted in a delay for the enrollment reports to be sent to NSLDS. The Registrar has made it a priority to submit enrollment reports and error reports in a timely manner (within 24-48 hours) so that they can be submitted to NSLDS within the 60-day timeframe. Timeline for Implementation of Corrective Action Plan: Corrective action plan began immediately when the next semester began. The action plan appears to be successful as there was no backlog of Enrollment/Error reports for Summer 2024, Fall 2024, and into Spring 2025 semester. Contact Person: Registrar – Shawna Lind

Boston Public Schools has revised its’ eligibility record keeping process to ensure that records are accurate and complete. This adjustment to record keeping practice has been instituted beginning with the FY25 grant application cycle. Anticipated Completion Date: June 30, 2025 Responsible Contact Person: Colin Musto, Assistant City Auditor, Grants Monitoring Unit colin.musto@boston.gov

Purpose: To document Santa Clara University’s Corrective Action Plan relating to finding 2024-001 in its June 30, 2024 Single Audit Report. Finding #2024-002: Criteria The institution shall require each applicant whose application is selected by the Department of Education to verify the information required for the Verification Tracking Group to which the applicant is assigned. If verification reveals that the student information does not match, the institution must submit corrections to the FAFSA. Corrections and updates can be submitted by the student on the web or by the institution using the FSA Access to Central Processing System Online or the Electronic Data Exchange. Statement of Condition During testwork, KPMG selected 40 students that were selected for verification. Of the 40 students selected for verification test work, one student’s information required for the appropriate Verification Tracking Group was not completed and 6 students had inconsistencies for which corrections were not submitted. Corrective Action Planned The University agrees with this assessment and is implementing a new process to ensure verifications will now have a second approver who will ensure verifications are completed correctly. Additionally, we also have added additional training to ensure that appropriate second and third checks are implemented. Name of contact Person responsible for corrective action plan Sandra Hayes, Assistant Vice President for Enrollment Management Anticipated completion date The above measures have already been implemented.

Purpose: To document Santa Clara University’s Corrective Action Plan relating to finding 2024-001 in its June 30, 2024 Single Audit Report. Finding #2024-001: Criteria Institutions must report disbursement data to Common Origination and Disbursement (COD) system within 15 calendar days after the institution makes a disbursement or becomes aware of the need to make an adjustment to previously reported student disbursement data or expected student disbursement data. Institutions may do this by reporting once every 15 calendar days, bi-weekly or weekly, or may set up their own system to ensure that disbursements are reported in a timely manner. Statement of Condition During testwork, KPMG selected 40 students that had Pell Grant or Direct Loan disbursements where the University was required to report student disbursement date to Common Origination and Disbursement (COD) system within 15 calendar days after the institution makes a disbursement or becomes award of the need to make an adjustment to previously reported student disbursement data or expected student disbursement data. KPMG identified 5 of the 40 students were not reported to COD in a timely manner. Corrective Action Planned The University agrees with this assessment and is implementing a new process to ensure Direct Loan and Pell Grant disbursements will now be reviewed after each disbursement (Monday, Wednesday, and Friday) and are reported within the Department of Education's requirements. Additionally, we will ensure that the COD Workday outbound and inbound integrations are monitored daily. Name of contact Person responsible for corrective action plan Sandra Hayes, Assistant Vice President for Enrollment Management Anticipated completion date The above measures have already been implemented.

Corrective Action Plan: To prevent conflicts between student work schedules and class schedules, the Financial Aid Office will verify, at the beginning of each term, that Federal Work-Study (“FWS”) student work schedules do not conflict with their academic schedules. As part of this verification process, department managers hiring FWS students will submit both the student's work schedule and class schedule to the Financial Aid Office. A report has been developed to compare FWS student work hours with their class schedules during each pay period. Any instances of students working during scheduled class time will be communicated to both the student and their supervisor for correction, if the hours were reported in error. If the hours are accurate, the department must provide documentation of a class schedule change, cancellation, or the fund and organization codes to be charged, crediting the FWS funds accordingly. Timeline for Implementation of Corrective Action Plan: This policy will be implemented immediately and applied retroactively to July 1, 2024. Contact Person Todd Wonders, Associate Director of Financial Aid Curt Foster, Comptroller

Corrective Action Plan: The Pell Reconciliation process is currently conducted monthly. A file is generated by the Financial Aid Office and transmitted to the Common Origination and Disbursement (“COD”) system via EdConnect software. Upon receipt of the COD response file, any discrepancies are addressed, and corrected data is resubmitted to COD. In a recent instance, the timing of a student's adjusted award relative to the monthly reconciliation file resulted in a disbursement outside of federal guidelines. While this discrepancy was identified during a subsequent internal audit, the Financial Aid Office acknowledges the need for process improvement. To ensure timely disbursements and prevent future occurrences, the Pell Reconciliation process will be revised to occur multiple times per month. This revised policy has been reviewed and approved by the relevant Financial Aid staff. Timeline for Implementation of Corrective Action Plan: The corrective action plan was implemented as of October 2024. Contact Person Todd Wonders, Associate Director of Financial Aid Curt Foster, Comptroller

Corrective Action Plan: Despite previous corrective actions addressing NSLDS reporting findings, an audit has revealed additional discrepancies in reporting between HCC and the National Student Clearinghouse (“NSC”). Our current database generates a file for submission to the NSC, intended to report all graduates. Upon review of the data transmission process, it has been determined that students enrolled in simultaneous degree programs require specific evaluation of their graduate status due to the NSC's unique parameters for these programs. Consequently, manual updates to NSLDS will be necessary for cases that fall outside the NSC's automated reporting guidelines. To address this systematically, a working group will be established to review and revise campus policies and procedures. This group will collaborate with the IT Enterprise Operations team to develop refined reporting mechanisms that accurately identify and address students in simultaneous degree programs, ensuring timely and accurate NSLDS reporting. Timeline for Implementation of Corrective Action Plan: The corrective action plan was implemented as of October 2024. Contact Person Todd Wonders, Associate Director of Financial Aid Allison Wrobel, Registrar Curt Foster, Comptroller

Corrective Action Plan:. The Student Financial Services Office will work with the Registrar and use reports delivered by Institutional Effectiveness to monitor and determine withdrawals on a regular basis. Additional reports at the end of each semester have been created to assist with identifying students who fail to complete at least half-time attendance. Policy and procedures have been updated to insure proper Exit Counseling notifications. Timeline for Implementation of Corrective Action Plan: Immediately Contact Person: Karrie M. Trautman

Finding 2024-001 Name of Responsible Individual: Cinnamon Bradley, Associate Dean of Student Affairs Corrective Action: We concur. We will review our procedures to ensure proper recording of these changes by NSLDS based on our submission to the National Student Clearinghouse. We will also implement an automated monitoring notification system that will alert us within the established timeframe of status changes to ensure accuracy in both third-party systems. Change in our submission process to the National Student Clearinghouse from 30 days to occur weekly to ensure timely reporting to NSLDS. All student records contained in the NSLDS for the Academic Term will be reviewed every month and the student roster will be reviewed weekly for accuracy in both third-party systems. We will complete the corrective action no later than March 31, 2025. Anticipated Completion Date: March 31, 2025

Finding 2024-001: Return of Title IV Funds For one out of three students tested (33%) who withdrew from the Institute, the Institute could not provide evidence that Institute reviewed the return of Title IV funds calculation. Further, the calculation that was originally performed failed to identify $480 of aid to be disbursed as post-withdrawal. Corrective Action Plan The Director of Financial Aid, Registrar and Student Affairs have instituted a communications protocol for all student withdrawals that include the notification of all required institutional constituents. In addition, as a control practice the Director of Financial Aid reviews a daily enrollment change report to ensure all withdrawals are processed on a timely basis. Contact Person Monique Foster Director of Financial Aid mfoster@erikson.edu Anticipated Completion Date October 2024