Corrective Action Plans

Views of Responsible Officials of the Auditee Management agrees with this finding and will take corrective actions. Corrective Action Plan The University is in the process of revising its procedures and documentation for the reconciliation of the Federal Pell Grant in order to meet compliance according to 34 CFR 668.171. The University would like to note that while adequate documentation was not maintained, the reconciliations were being done with a matching ending balance at year end. Anticipated Completion Date: May 31, 2024 Contact Person(s): William Washburn, Interim Director of Financial Aid

Views of Responsible Officials of the Auditee Management agrees with this finding and will take corrective actions. Corrective Action Plan The University is in the process of reviewing and modifying its procedures for calculation Federal Pell Grant awards in order to meet compliance according to 34 CFC 690 80. A nticipated Completion Date: May 31, 2024 Contact Person(s): William Washburn, Interim Director of Financial Aid

Identification: 10.766 United States Department of Agriculture (USDA}, Community Facilities Loans and Grants Cluster, Noncompliance Finding/Significant Deficiency, Special Tests and Provisions. Corrective Action Plan: The Medical Center will seek guidance from the bond trustee and USDA related to the insurance provisions in the bond documents for the amount of fidelity bond coverage and retaining an insurance consultant to provide a report. Anticipated completion date: The Medical Center anticipates this to be completed during 2024.

• VP of IT designates a Manager responsible for overseeing, implementing, and maintaining the institution’s or servicer’s information security program and enforcing the information security program (16 C.F.R. 314.4(a)). • Provides for the information security program to be based on a risk assessment that identifies reasonably foreseeable internal and external risks to the security, confidentiality, and integrity of customer information (as the term customer information applies to the institution or servicer) that could result in the unauthorized disclosure, misuse, alteration, destruction, or other compromise of such information, and assesses the sufficiency of any safeguards in place to control these risks (16 C.F.R. 314.4(b)). • Provides for the design and implementation of safeguards to control the risks the institution or servicer identifies through its risk assessment (16 C.F.R. 314.4(c)). At a minimum, the written information security program must address the implementation of the minimum safeguards identified in 16 C.F.R. 314.4(c)(1) through (8). • Provides for the institution to continuously monitor vulnerabilities, or conduct annual penetration tests and systemic scans and reviews of known vulnerabilities at least every six months. (16 C.F.R. 314.4(d)). • Provides for the implementation of policies and procedures to ensure that personnel are able to enact the information security program (16 C.F.R. 314.4(e)). • Addresses how the institution or servicer will oversee its information system service providers (16 C.F.R. 314.4(f)). • Provides for the evaluation and adjustment of its information security program in light of the results of the required testing and monitoring; any material changes to its operations or business arrangements; the results of the required risk assessments; or any other circumstances that it knows or has reason to know may have a material impact the information security program (16 C.F.R. 314.4(g)). • Address the establishment of a written incident response plan (16 C.F.R. 314.4(h)). • Address the requirement for its Qualified Individual to report regularly and at least annually to The President and Board of Trustees on the institution’s information security program (16 C.F.R. 314.4(i)).

To ensure compliance with the provisions of the Gramm-Leach-Bliley Act (GLBA), specifically the requirement that the District’s written Enterprise Data Governance Standard (EDGS) includes a description of the use of a data inventory that includes how the institution is identifying and managing data, personnel, devices, systems and facilities, management has revised the EDGS to specify that a data inventory for each functional system domain shall take place annually under the direction of the Data Owners and the procedures performed and results shall be adequately documented. Implementation Date: August 2024 Responsible Persons: Phong Banh, District Director of Information Technology Services Patrick Vrba, Controller

Corrective Action Plan For the Fiscal Year Ended August 31, 2023 Finding 2023-002 – Special Tests and Provisions – Enrollment Reporting Name of contact person responsible for corrective action: John Carrescia, jcarresc@wagner.edu; 718-420-4264 Corrective action: The College has been working diligently across multiple departments on campus to make these historical corrections. We have identified the various groupings of students that require correction, and have worked through our historical data to update the program begin date (campus level data) to be the first day of the earliest semester for which each student began attending their respective program. We have submitted the listings to the National Student Clearinghouse for revision. We currently have a process in place and are working collaboratively with our information technology system analysts to implement controls to ensure the correct program begin date is used for all future students entering the College. We are currently in the process of reviewing and updating our program level enrollment data. Proposed Completion Date: August 31, 2024

Name of Responsible Individual: Dylan Nowakowski Assistant Director of Financial Aid Corrective Action: For one of two reconciliations tested we were unable to provide documentation that the reconciliation was done. The reconciliation was done, however, there was a server error in the system that caused Wheeling to lose some files. Two of the reconciliation files are missing due to this. We have a Financial Aid Office policy that has been established to ensure that reconciliations are made once a month. Since the loss of the backup system, the files are both saved and printed to avoid any more loss of files. During this period, we were using a now-defunct backup system. We have now moved to multiple backup systems and a new storage server. Our storage server is now a virtual machine with a high availability setup where we have 2 large drive systems continually being mirrored. The backup system has 2 servers with large drive systems. We continually alternate file backups each day as needed. As the backups finish, they are moved up to the cloud each time. Also, we have in place a 30-day non-overwrite policy on the files backed up to the cloud. Anticipated Completion Date: July 2022

Name of Responsible Individual: Tracy Jenkins, Student Accounts Corrective Action: We recognized that students were not receiving the Right to Cancel notifications in a timely manner. We also understood the need for students to receive this information to make an important educational/fiscal decision. As of September 2023, on a monthly basis, notifications were sent to student University emails and parent’s personal email (Plus Loan recipients) informing them of their Right to Cancel. Anticipated Completion Date: September 2023

Name of Responsible Individual: Shelia Yates-Mattingly, Registrar Corrective Action: In response to Finding 2023-005, Wheeling University will continue the enrollment reporting process that was implemented in October 2023, which was in response to Finding 2022-005. With the stability of staffing in the Registrar’s Office and Financial Aid Office and the level of experience and competence of this staff, enrollment reporting has been completed within the parameters of regulatory guidelines. The Registrar’s Office submits enrollment reports as scheduled and subsequent error resolution reports as appropriate. The Financial Aid Office reviews identified NSLDS errors, corrects and resubmits them timely. Regularly scheduled meetings, including the Registrar’s and Financial Aid Offices, continue as noted in corrective action for Finding 2022-005. These meetings serve as the platform to discuss and address identified enrollment reporting concerns/issues timely, resulting in improved accuracy in enrollment reporting and timeliness in error resolution. Anticipated Completion Date: The current process has been in place since October 2023 and is ongoing.

Name of Responsible Individual: Tyler Hosey, Senior Accountant Corrective Action: The University has formalized and documented financial processes to establish internal controls in order to ensure accurate, timely and consistent reporting. In addition, this has created a reasonable transition plan during employee turnover, as well as ensures proper and timely filings. The corrective action involves drawing down the funds from the G5 federal website and issuing refunds to students that day. There is a checks and balance process built in so multiple staff members are involved with the process. The financial aid department calculates the amount of a federal drawdown and relays that information to the business department. The senior accountant draws down the appropriate amount of federal financial aid. The student accounts billing coordinator applies the aid to the various student accounts in the software. After the aid has been applied, the student account billing coordinator determines if a refund is due to the students. Any students that are entitled to a refund will be cut a refund check that day. The students will then have a window of opportunity of to come pick up the refund checks. Within 2 business period, any students who have not picked up their refund checks will have them mailed to their address on file with the University. This process has been developed to ensure that students receive their refunds in a timely and accurate manner. Anticipated Completion Date: A new process has been in place Since February 2024 and is ongoing.

Name of Responsible Individual: Tracy Jenkins, Student Accounts Corrective Action: Wheeling University worked with ECSI regarding Perkins information. With the Perkins program ending, we realized that we needed to move in the direction of closing out Perkins files/information. The University is currently working with ECSI so that we are able to submit Perkins information/files to the Department of Education. We are gathering information (promissory notes, bankruptcy details, payment information, etc.) to assist ECSI with the process. Anticipated Completion Date: May 2024

Name of Responsible Individual: Dylan Nowakowski, Assistant Director of Financial Aid Corrective Action: In the past, Colleague was not used to calculate return to title IV. Once Colleague was properly set up for Financial Aid, the Associate Director discovered that the calendars did not match the actual publicized academic calendar. Had the calendar been accurate with the correct dates of breaks of 5 days or more, Colleague would not have accepted a withdrawal date during the break. This error within the system should not be counted as a finding. The calendar in Colleague is now correct. All breaks that are five days or more are accurate. At Wheeling, we have a comprehensive R2T4 policy. This policy outlines how to count calendar days in a semester and provides clear instructions on what to do when a student withdraws during a break. Anticipated Completion Date: July 2023

Name of Responsible Individual: Tyler Hosey, Senior Accountant Corrective Action: The University acknowledges FISAP report was filed with incorrect data and not amended in a timely manner. The University has developed a series of internal controls and procedures to ensure that the data provide for the FISAP will be accurate going forward. All balance sheet accounts will be reconciled on a monthly basis and all revenue will be recorded on the ledger in the time period that it is earned. A monthly income statement and balance sheet will be generated to determine how much federal aid revenue has been reported throughout the year. The accounting software has a built-in process that will be run on a regular basis to make sure all entries are properly posted. This will ensure accurate reporting in the future. Anticipated Completion Date: A new process will be implemented so this error does not happen again (June 2024).

Name of Responsible Individual: Dylan Nowakowski, Assistant Director of Financial Aid Corrective Action: There is no documentation available to indicate that a professional judgement was completed at the time of the incident cited. Wheeling did not have access to any documentation such as log notes, documents, or contact records of any kind. The DPT program budgets differ in amount for first- and second-year attendance. It is known that at this time, the first-year budget was not available, and some student budgets were not separated and entered correctly for first- and second-year cost of attendance. A Financial Aid Office policy has been established to ensure that proper documentation and records maintenance is achieved. Staff enter detailed log notes regarding student contact and results of those contacts. A Budget Adjustment form has been created for students to present to the office if they request a cost of attendance and budget increase. These forms are scanned into the individual student file and is easily obtained for future use when and if necessary. Each DPT budget year has been incorporated into a spread sheet format. Any change to a budget item is input into the sheet and the system will auto calculate a new or different budget amount. These new numbers and the updated COA (cost of attendance) are inserted into the colleague system and is a permanent, easily retrievable record. Anticipated Completion Date: July 2023.

In order to address this audit finding, CMN financial aid staff plans to seek continual improvement in the areas relating to Return of Title IV funds calculations. Through both Federal Student Aid and National Association of Financial Aid Administrators (NASFAA), staff will complete trainings to understand calculation and timing of returns. It should also be noted that in the current award year, CMN has moved to a model where attendance taking is not required, so staff is working with faculty and students to ensure timely notification of withdrawal and reviewing final grades at the end of the term in order to ensure all students needing a R2T4 calculation have one performed.

In order to address this audit finding, CMN financial aid staff plans to seek continual improvement in the areas relating to Pell calculations. Through both Federal Student Aid and National Association of Financial Aid Administrators (NASFAA), staff will complete trainings to understand all aspects of calculating awards, as well as staying up to date on regulatory changes through our student information system. In addition to more training in this area, priority will be placed on rechecking and auditing Pell awards so that they are reviewed during the award year. Staff has already begun reviewing fall 2023 Pell awards for accuracy and will continue to review awards as terms move forward.

Special Tests and Provisions: Return of Title IV funds for withdrawn students (Repeat finding 2021-004, 2020-002, 2019-003, 2018-005, 2017-004, 2016-003, 2015-004, 2014-011) 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 Responses CSN agrees with the findings. • 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 started to select additional team members to cross train with seasoned R2T4 team members on the processing of R2T4 files. This will ensure that files are processed in a timely manner and meet compliance requirements. Additionally, training opportunities will be assessed and offered to the team members who are processing R2T4 records on an ongoing basis. Additionally, CSN is currently assessing a potential 3rd party vendor to assist with the processing of R2T4s as needed on an ongoing basis. • How compliance and performance will be measured and documented for future audit, management and performance review. Cross training and workshop opportunities will be provided to ensure knowledge and compliance for the R2T4 team and any staff member assisting with processing of R2T4 records. Queries will be utilized to track R2T4 files to ensure timely processing. • Who will be responsible and may be held accountable in the future if repeat or similar observations are noted. The Assistant Director of Financial Aid will be responsible and may be held accountable.

Internal Control over Compliance (Repeat Finding 2022-001, 2021-003, 2020-001, 2019-002, 2018-003, 2017-002, 2015-002, 2014-008) 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 Responses UNR agrees with the findings • 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; The technical staff can only have the PeopleSoft Administrator (PSA) role in either development or production, but not both. There is an approval process in place to ensure that access is removed from either development or production when a PSA needs to be moved across to the other environment. This process became effective March 1, 2023. There is a quarterly security review of the PeopleSoft Administrator role in PeopleSoft. The first quarterly review was performed in FY16 Q1 and has been performed each quarter since. The reviews are documented and approved. There is a quarterly security review of the PeopleSoft Administrator activities in PeopleSoft. The first quarterly review was performed in FY22 Q4 and has been performed each quarter since. The reviews are documented and approved. There is a quarterly security review of the PeopleSoft Oracle database and user access. The first quarterly review was performed in FY20 Q2 and has been performed each quarter since. The reviews are documented and approved. • How compliance and performance will be measured and documented for future audit, management and performance review. Compliance and performance can be measured by the documented quarterly reviews. • Who will be responsible and may be held accountable in the future if repeat or similar observations are noted. The PeopleSoft Manager will be responsible for ensuring the corrective actions plans are implemented and followed. The Vice President of Information Technology will be accountable for the department’s compliance. UNLV 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; UNLV understands the importance of adequate segregation of duties within the PeopleSoft environments and applications. The PeopleSoft Administrator (PSA) position that is the subject of the finding is responsible for the installation, configuration, upgrades, and troubleshooting of all the application environments. The PeopleSoft Administrators are not programmers/developers, and their access to the production environments is periodically required to perform the needed activities required to provide timely support of the application within the scope of their job duties. UNLV has implemented the following controls to mitigate the risks associated with the elevated access required for the administrators to perform their required support activities. 1. UNLV has removed all persistent assignment of the PeopleSoft Administrator role from all PSAs in all environments. 2. The PeopleSoft Administrator role is temporarily assigned only when elevated actions are required. All assignments are of a limited duration and include a justification detailing the need and actions to be performed. All assignments trigger the follow actions: a. An immediate notification to the Director of Business Continuity & Resiliency and the Interim Senior Associate Vice Provost for Digital Strategy and Transformation. b. Removal is automatic but can be initiated by PSA if work is completed sooner than expected. c. All details around the assignment are captured in a tracking table. d. A review of all assignments and activities is performed monthly. 3. UNLV will continue to review access, activities, and assigned privileges monthly for the PeopleSoft Administrators. 4. UNLV will continue researching and implementing other control methods that may strengthen the segregation of duties or the monitoring capabilities that are available. • How compliance and performance will be measured and documented for future audit, management and performance review. The PeopleSoft Administrator role is no longer persistently assigned to the PSA position. It is only assigned upon request with the knowledge and approval of approving authorities. UNLV performs monthly reviews of the access and activities to determine if the PeopleSoft Administrators' activities align with the necessary support. Additionally, UNLV will continue to research other control methods that will address the segregation of duties while providing appropriate service and support. • Who will be responsible and may be held accountable in the future if repeat or similar observations are noted. The Director of Business Continuity & Resiliency will be responsible for performing the activity reviews and access needs of the PeopleSoft Administrators. The Director will complete the reviews and is also accountable if repeat or similar observations are noted. The Chief Information Security Officer will verify that reviews are conducted on a monthly basis per audit practices. SCS agrees with the findings • 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; In addition to the compensating controls (a) to (d), that have been operating since prior to FY23 the segregation of PeopleSoft Administrators (PSA) is enforced through a “locked account” process. Only two employees have PSA access in both the Production and Development environment. Each employee can only have access to the Production or Development environment at any one time, i.e., the PSA account in the other environment remains locked. A JIRA ticket must be opened for an account to be unlocked. The request is approved by management and the account is unlocked by a member of the IT Security Team. The controls listed below should also mitigate the segregation of duties risk and support a review of “user activities” in the absence of an appropriate user activities audit log function. (a) STAT for PeopleSoft – Code control and internal modification tracking provides visibility over PSA activities that are processed via this tool. These object changes are reviewed and approved by the Director of Information and Application Services. (b) JIRA ‐ Change control management and project tracking software. Change requests and projects related to the PeopleSoft shared instance are tracked and approved. This would include user access modifications and system updates for example. (c) Security e‐mail alerts – The SCS security team are alerted via automated e‐mails when key events are triggered. For example, an elevated role is assigned to a user. (d) User Access Reviews – On an annual basis an independent user access review is performed incorporating SCS/SA privileged users and all shared instance security coordinators. • How compliance and performance will be measured and documented for future audit, management and performance review. The PeopleSoft Administrators will have persistent unlocked access to either the Production or Development environments only. Their corresponding account in the other environment will remain locked. In the event that access is needed to the locked environment, a ticket will be created requesting access which will document the rationale and approvals. In addition, PSA activities are monitored via the change control process through STAT for PeopleSoft. Object changes within the Production environment for example, are approved along with the associated workflows. • Who will be responsible and may be held accountable in the future if repeat or similar observations are noted. The SCS Director of Information and Application Services, and SCS Security Group are responsible for locking/unlocking PSA accounts. The SCS Security Group monitor PeopleSoft e-mail alerts. The IT Audit Manager is performing annual SCS/SA privileged user access reviews.

NCC conducted staff training to reinforce requirements for the return of funds within 240 days for all federal award checks returned uncashed. Effective November 2023, we implemented an automated process to assist with identifying federal funds that need to be returned.

The attendance process has been moved to the Registrar’s Office and registration status codes for unofficial withdrawals have been created in order for the system to find those students when submitting monthly enrollment reporting to clearinghouse, which is then sent to NSLDS.

Contact person(s) responsible for corrective action - Amy Cavelier and Robert Wagstaff, Registrar’s Office Anticipated completion date – Complete Corrective Action The Registrar’s office will ensure proper controls and processes are in place to ensure program-level effective date information is properly and timely submitted to the NSLDS. Timeframe: June through August 2023 Responsible Parties: Amy Cavelier and Robert Wagstaff Registrar management and staff worked with the College’s Student Information Systems and IT departments to verify when and how the conflicting program-level effective dates were entered. It appeared that the data originating from Jenzabar was correct. Discrepancies were created during the NSC error cleaning process, and data including those discrepancies were reported to the NSC and subsequently the NSLDS. Registrar’s Office management and staff worked with the NSLDS to obtain final student data reports which were compared to the monthly student data files originally submitted to the NSC, prior to error correction, to identify the discrepancies and the cause of the data errors. The College transitioned the enrollment reporting responsibility to another member of the Registrar’s Office. This transition included formal training on the Jenzabar student information system, with a particular focus on NSLDS data reporting, as well as the NSC and NSLDS data submission processes.

Management's Views and Corrective Action Plan Finding 2023-002 - Non-Compliance with Financial Need Requirements for Subsidized Direct Loans in Non-Standard Semesters Grantor: U.S. Department of Education Program: Student Financial Assistance Cluster Assistance Listing#: 84.268 Award Titles: Federal Direct Student Loan Program Program Award Years: 7/2022 - 6/2024 Management agrees with the finding and proposes the following corrective action plan: Corrective Action Plan: When a student attends a standard semester (Fall and Winter), PeopleSoft uses the Prorated Estimated Family Contribution (EFC) Methodology to determine the subsidized loan eligibility based on their EFC. When a student attends a non-standard term (Spring), PeopleSoft uses the Automatic Zero EFC Methodology and offers subsidized loans to all students rather than the subsidized loan eligibility based on their EFC. Tammie Fonoimoana, Financial Aid & Scholarships Senior Manager, will work to update the PeopleSoft system to use the Prorated EFC Methodology for calculating subsidized loan eligibility for both standard and non-standard terms. In addition, Tammie Fonoimoana, Financial Aid & Scholarships Senior Manager, who is responsible for packaging and awarding of Financial Aid at Brigham Young University- Hawaii will continue to provide training to the staff who administer Title IV aid to ensure they are aware of the changes in packaging and awarding subsidized loans for the non-standard term (Spring). Also, Tammie Fonoimoana will oversee the implementation of controls wherein the University will implement preventative mechanisms to verify financial aid packages are calculated correctly. Timing: Tammie Fonoimoana, Financial Aid & Scholarships Senior Manager, will be responsible for overseeing that the items as noted in the corrective action plan section above will be implemented by July 1, 2024. Signed and Acknowledged, Tammie Fonoimoana, Senior Manager BYU-Hawaii Financial Aid & Scholarships Tammie.fonoimoana@byuh.edu 808-675-4737

Management's Views and Corrective Action Plan Finding 2023-001 - Non-Compliance with Timely and Accurate Student Enrollment Change Submissions to the National Student Loan Data System (Significant Deficiency) Grantor: U.S. Department of Education Program: Student Financial Assistance Cluster Assistance Listing#: 84.268, 84.063 Award Titles: Federal Direct Student Loan Program, Federal Pell Grant Program A ward Years: 7 /2022 - 6/2024 Management agrees with the finding and proposes the following corrective action plan: Corrective Action Plan: The prior year's corrective action plan was successful in addressing two of three issues identified in previous audits in enrollment reporting. These additional steps will be taken to address the remaining issue noted during the 2023 audit, which resulted in a repeat finding of 2022-001. When a student returns from a leave of absence, PeopleSoft updates the students' program begin date for the student's return date rather than the original program begin date. Daryl Whitford, Registrar, will continue reviewing program begin dates for students returning from a leave of absence to ensure the proper program begin date is reported to NSLDS. In addition, we will review if any PeopleSoft enhancements can be made to provide additional comfort that the program begin elates are accurate in these circumstances. Daryl Whitdord, Registrar, who is responsible for enrollment reporting at Brigham Young University Hawaii will continue to provide training to staff who participate in enrollment reporting to ensure that they are aware of the campus and program enrollment changes to be reported, the details to be reported for each change, and the importance of submitting changes timely. Also, Daryl Whitford, Registrar, will oversee the implementation of a control wherein the University will review program begin dates for students returning from leave of absence to ensure the proper program begin date is reported to NSLDS. Timing: Daryl Whitford, Registrar, will be responsible for overseeing that the items as noted in the corrective action plan section above will be implemented by September 1, 2024. Signed and Acknowledged, Daryl Whitford, Registrar BYU-Hawaii daryl.whitford@byuh.edu 808-675-3730

Action taken in response to finding: will include Institutional Research compiling the data and then sending to Financial Aid/Admissions for review of the enrollment files. The Financial Aid/Admissions department will test a sample of the student enrollment data that it is correct. The Department will maintain evidence of the review and confirm back to Institutional Research the review has been completed. Institutional Research can then submit the enrollment files to the National Student Clearinghouse.

Action taken in response to finding: Adjustments have been made to reflect the full spring break period in our return of funds process. The number of days campus is considered to be closed for spring break has been updated to nine days for Spring 2024. Spring terms in the future will be set up in Colleague with the day following the last day of classes prior to spring break as the first day of spring break and the day prior to the first day of classes after spring break as the last day of spring break. For 2023-2024 and 2024-2025, this equates to a nine-day spring break. All R2T4 calculations for Spring 2024 have been reviewed and recalculated using a nine-day spring break rather than a seven-day spring break. In communicating with Ellucian regarding the processing of R2T4, we discovered a report that we can run in Colleague to identify students that have withdrawn from all courses and will not complete any courses for the semester. This will be used instead of the report made in house, previously utilized for this process. A financial aid staff member will run the report and perform the R2T4 calculations in Colleague. Then the staff member that performed the calculations will run the Return of Funds Detail Report in Colleague, indicate on that report that they performed the calculations, and send the report to the Director of Financial Aid. The Director will review the Return of Funds Detail Report and the calculations. The Director will sign off on the Return of Funds Detail Report approving the calculations. The report will then be saved in the Return of Funds folder in the Financial Aid Files. All Financial Aid staff members will be trained and have the ability to perform R2T4 calculations to ensure that the calculations can be performed regularly prior to each student refund date during the term. All R2T4 calculations for the 2023-2024 school year have been reviewed for accuracy. Calculations performed for the fall 2023 semester have been reviewed by the Director of Financial Aid for accuracy. Due to short staffing in the Financial Aid Office in the spring semester, and remaining staff not being trained on the R2T4 process, calculations for the Spring 2024 semester were performed by the Director of Financial Aid. To ensure the accuracy of the calculations, the calculations were checked using the R2T4 calculation tool in COD (Common Origination Disbursement).