Corrective Action Plans

Finding Number: 2023-015 Federal Program: 14.218 – U.S. Department of Housing and Urban Development (HUD) – Community Development Block Grant (CDBG) – Entitlement Grants Cluster 93.563 – Title IV-D, U.S. Department of Health and Human Service - Child Support Enforcement (CSE) 10.557, U.S. Department of Agriculture – WIC Special Supplemental Nutrition Program for Women, Infants, and Children Condition Per Auditor: Controls in place were not adequate to ensure compliance with 2 CFR 200 Appendix V submission requirements for the County’s self insurance cost allocation process and annual chargeback plan. Planned Corrective Action: Management communicated with the cognizant agency which confirmed in November 2021, OMB issued guidance relating to CARES Act funding and its effect on indirect cost. Part of this guidance stated that “CARES Act funding should not be included toward the threshold amount for indirect cost submission required in 2 C.F.R. part 200, Appendix VII, paragraph D.1.b”. Therefore, County governments that met the $100 million threshold as a result of CARES Act funding are not required to submit their Central Service Cost Allocation Plan for approval. The CARES Act funding would have increased the County’s funding in excess of $100 million, which should not have been a part of the determination for the original finding. However, since CSLFRF funds were also received increasing the County’s funding in excess of $100 million the annual chargeback plans were submitted to the cognizant agency and U.S. Treasury in 2023 for implementation in FY 24 and will continue to submit subsequent plans to federal cognizant agency, as required by 2 CFR 200 Appendix V. Anticipated Completion Date: 9/30/24 Responsible Contact Person: Shauntika Bullard and Michael Bridges

2023-008 – Eligibility – Material Weakness in Internal Controls over Compliance and Material Noncompliance Student Financial Assistance Cluster U.S Department of Education Federal Assistance Listing Number: 84.063, 84.268, 84.007, 84.033, 84.379 Federal Program Name: Federal Pell Grant Program, Federal Direct Student Loans, Federal Supplemental Educational Opportunity Grants, Federal Work-Study Program Finding Summary: The College did not have adequate controls in place to ensure the appropriate and reasonable amounts were included in each eligible cost of attendance category for its students, that awards were properly calculated, refunds were disbursed timely and student records were accurate. The auditors were not able to conclude that the College is in compliance with eligibility requirements in the OMB compliance supplement. Repeat finding: No Responsible Individuals: Michael N. Espinoza, Vice President of Student Services Views of responsible officials and planned corrective actions: The college entered into a third-party contract to manage financial aid packaging and awarding. Calculation and reporting completed by prior Financial Director submitted national average as the college calculations instead of college service area specific calculations. The college worked with the third-party provider to ensure policies and processes adopted in July 2023 to ensure cost of attendance (COA) reporting and calculations are complete and accurate going forward. Corrective Action: The College will review their policies, procedures and controls to ensure that annually a cost of attendance schedule is approved, and that the approved schedule is used in packaging student financial aid. Rationale for adjustments made to the budgeted cost of attendance for individual students should be documented and support maintained. The College will review all processes and procedures related to eligibility to ensure controls are well documented and to properly adhere to requirements for eligibility of Title IV aid. Anticipated Completion Date: to be completed by June 30, 2024

2023-007 – Reporting – Material Weakness in Internal Controls Student Financial Assistance Cluster U.S Department of Education Federal Assistance Listing Number: 84.063, 84.268 Federal Program Name: Federal Pell Grant Program, Federal Direct Student Loans Finding Summary: The College did not have adequate and/or functioning controls in place to ensure the reporting of disbursements to students on COD was submitted in a timely way and that the dates and amounts agreed. The administration of the Title IV programs depends heavily on the accuracy and timeliness of the disbursement information reported by institutions. The College is not in compliance with the federal COD reporting requirements described in the OMB Compliance Supplement and required by the Department of Education. Repeat finding: Yes, 2022-004 Responsible Individuals: Michael N. Espinoza, Vice President of Student Services Corrective Action: The college will conduct ongoing training to develop reporting and process steps to prevent reporting errors and improve accuracy in reporting in identifying student’s assistance needs. The College has entered into an agreement with a third-party financial aid provider to service and administer financial aid awards, COD reporting and reconciliation.  The College will implement a process to review, update, and verify student disbursements are reported to COD accurately and timely.  Prevention to include creation of reports for awards pending and detailed disbursement and reconciliations schedules, and system back-end processes. 108  Implemented a tracking log starting in July 2023 between Financial Aid and the Business Office to ensure distribution in compliance with Common Origination and Disbursement (COD). Anticipated Completion Date: to be completed by June 30, 2024

2023-006 – Gramm-Leach-Bliley Act – Student Information Security – Material Weakness in Internal Controls over Compliance and Material Noncompliance Student Financial Assistance Cluster U.S Department of Education Federal Assistance Listing Number: 84.063, 84.268, 84.007, 84.033, 84.379 Federal Program Name: Federal Pell Grant Program, Federal Direct Student Loans, Federal Supplemental Educational Opportunity Grants, Federal Work-Study Program 107 Finding Summary: Staffing shortages have contributed to the delay in the implementation of this standard. The absence of a well-designed and documented policy addressing the standards set forth under the act could put the security, confidentiality, and integrity of student information at risk. Responsible Individuals: Andrew Burke, Chief Information Officer Corrective actions Plan: The college released a Request for Proposal (RFP) to contract with outside information technology services to guide the development and implement a comprehensive information security program and address staffing gaps. Outside Chief Information Officer, information security, and technical partnership completed and contracted effective April 2024. Outside service will guide the college in the review and implementation of procedures and policies necessary for the required controls to be completed through the following phase:  Assessment and gap analysis of current infrastructure and cybersecurity measures.  Develop necessary policies and procedures based on NIST guidelines and GLBA requirements.  Detect and respond to ongoing training and incident response planning. Anticipated Completion Date: to be completed by June 30, 2024

2023-005 – Special Tests and Provisions – Return of Title IV Funds (R2T4) – Material Weakness in Internal Controls over Compliance and Material Noncompliance Student Financial Assistance Cluster Department of Education Finding Summary: This occurred because of lack of controls and processes in place to ensure supporting documentation is maintained for student’s withdrawal dates, and a lack of understanding of compliance requirements. This resulted in a failure to properly identify students requiring calculation for return of funds to the federal government, or eligibility for post withdrawal disbursement. As a result, the auditors were unable to determine if the College is remitting unearned funds to the federal government, or offering eligible students post withdrawal disbursements if available to them. Responsible Individuals: Michael N. Espinoza, Vice President of Student Services Corrective Action Plan: The college entered into a third-party contract to manage financial aid packaging and awarding. Integration and processes for the R2T4 calculation with the third-party processer was not completed correctly. New integrations, policies, and processes to be adopted in fiscal year 2023-24.  Develop and implement ongoing tracking and reporting for all financial aid reporting.  Financial Aid and Student Accounts work to regularly review and action student account files.  Continue to work with third-party service to review and promptly return Title IV funding in compliance with federal rulings. Anticipated Completion Date: to be completed by June 30, 2024

over Compliance and Material Noncompliance Student Financial Assistance Cluster Department of Education Federal Assistance Listing Number: 84.063, 84.268 Federal Program Name: Federal Pell Grant Program, Federal Direct Student Loans Finding Summary: The College did not have controls in place to ensure the reporting of enrollment information under the Pell grant and Direct loan programs via NSLDS was completed. Due to the way the College’s software pulls the roster information, the Clearing House is unable to send the data to NSLDS. While the College has been working with the software vendor to correct this issue, the reporting process for NSLDS stopped in the prior award year and has not resumed. Management did not implement other processes or procedures to deal with the issues encountered with the software to fulfill their responsibility to ensure accurate and timely reporting and submission of student status during the year. The College is not in compliance with the federal enrollment reporting requirements described in the OMB Compliance Supplement and required by the Department of Education. Repeat finding – Yes, 2022-003 Responsible Individuals: Mary Martin, Registrar Michael N. Espinoza, Vice President of Student Services Corrective Action Plan: Enrollment reporting is the responsibility of the Columbia Gorge Community College (CGCC) Registrar. Reporting of enrollment information in a timely manner for the year ended June 30, 2023, was impacted by the implementation of a new Student Information System (SIS) in May 2021. The SIS included significant changes to student recording procedures and a new enrollment reporting process. In response to the Enrollment Reporting Finding for the year ended June 30, 2023, the Registrar continues working to mitigate any issues negatively impacting enrollment reporting by:  working with the Vice President of Student Services and Director of Financial Aid to establish internal checks and balances to ensure reporting is being done in a timely manner.  working with SIS system support staff and internal IT staff to promptly address technical issues and/or other issues impacting enrollment reporting. 106  working with National Student Clearinghouse representative to ensure reporting schedule meets required timeframes.  consistent review of enrollment files prior to submission to ensure correct student enrollment statuses and program information are being reported.  prompt resolution of reporting errors.  identifying and training of additional staff on enrollment reporting. Anticipated Completion Date: to be completed by June 30, 2024

Enrollment Reporting Cluster: Student Financial Assistance Federal Awarding Agency: Department of Education (ED) Award Name: Federal Pell Grant Program, Federal Direct Student Loans Award Number: Not applicable Award Year: 2022-2023 Assistance Listing Title: Federal Pell Grant Program, Federal Direct Student Loans Assistance Listing Number: 84.063 and 84.268 Pass-through entities: Not applicable Facts of Finding: The University uses National Student Clearinghouse (NSC) to help report enrollment status changes to National Student Loan Data System (NSLDS). For students that had a gap in enrollment and were no longer with the University, the NSC system recognized these students as “withdrawn” regardless of whether they were reported as “withdrawn” or “graduated.” The University confirmed these students were properly reported to NSC as “graduated”; however, when the reporting from NSC to NSLDS occurred, it was based on the information recognized by NSC, and as such these students were reported as “withdrawn.” Acceptance of Finding: We agree with the above finding and will implement the corrective plan of action as described below: Corrective Plan of Action: After submission of enrollment information to the NSLDS, the University has not historically verified that the NSLDS has updated students’ enrollment status accurately. The University will formalize a process and establish procedures to regularly identify students whose enrollment status is improperly reported to NSLDS, particularly those reported as “withdrawn” instead of “graduated.” To the extent there are discrepancies between the University’s records and these students’ enrollment status in NSLDS, the University will correct the enrollment status of such students in NSLDS accordingly. This process and related procedures will be established and implemented by the close of the current fiscal year, July 31, 2024.

I will ensure the Financial Aid Office works closely with the Accounts Payables department to monitor that all Title IV refund checks have been cashed after 30 days of issuance of the refund. If a check has not been cashed a new check will be reissued immediately. If, after 30 days of the reissuance, the check has not been cashed then the funds will be returned to the Department of Education within the mandated 45-day period.

We recently completed the transition and onboarding of departmental staff which would allow the University to fully enact its plan to ensure both the financial aid and the Registrar's office will perform prompt review of processing University withdrawals. The Registrar's office will develop process and procedures documentation as an internal control measuring tool to ensure that Administrative Withdrawals (AW) and Withdrawals for lack of attendance (WA) that affect student emollment are identified immediately. Staff in the Financial Aid and the Registrar's office will actively take part in training workshops and webinars provided by the Depatiment of Education and NASF AA for continuing education to stay abreast of new developments and best practices in the industry.

Finding 2023-002 - U.S. Department of Education (USD), Title IV Student Financial Aid Programs (material weakness): We observed the following conditions in connection with our testing of the various U.S. Department of Education, Title IV, Student Financial Assistance Programs: (a) The College did not reconcile the following programs between the Office of Financial Aid and the Business Office. Per 34 CFR 685.300(b)(5). i. Federal Pell Grant Program ii. Federal Direct Student Loans iii. Federal SEOG (b) The Office of Financial Aid submitted unreconciled expenditures within the Fiscal Operations Report and Application to Participate (FISAP) for the programs below: i. Federal Pell Grant Program ii. Federal Work Study (FWS) Program (c) One (1) out of 6 students tested for withdrawals and the return of Title IV funds did not have their Title IV program funds returned within the 45-day requirement. HEA, Section 484B & 34 CFR 668.22. (d) One (1) out of 60 students had a credit balance on their account created by Title IV program funds longer than 14 days. 34 CFR 668.164(h)(1). (e) One (1) out of 60 students tested did not make satisfactory academic progress (SAP) for the academic year. The College did not provide supporting documentation for successful appeals and allowed the students to receive Title IV funding. 34 CFR 668.34. Questioned cost for this finding is: $6,198. (f) Five (5) out of 60 students tested did not have high school/GED to prove eligibility for the program they were enrolled within the College. HEA Section 484(d) and 34 CFR 668.32. Questioned cost for this finding is $41,443. (g) Four (4) out of 60 students tested were accepted as transfer students but did not have official (transfer) transcripts to prove eligibility for the program they were enrolled within the College. HEA Section 484(d) and 34 CFR 668.32. Questioned cost for this finding is $40,383. The College should implement corrective actions to ensure that the above findings are resolved and do not recur in future periods. Moreover, internal controls over compliance with federal program regulations should be revisited to ensure adequate supervisory controls, quality assurance reviews of processes, and policies and procedures are being updated and adhered to for compliance purposes. Corrective Actions – Philander Smith College concurs with this finding, and the following action has been taken. Philander Smith College improved the efficiency of reconciling between the Financial Aid Office and COD by standardizing procedures. Staff-wide calendar events have been set to standardize routine processing of reconciliation data. Direct Loan SAS files are imported into the COD "DL SAS Disb On Demand Reader" tool and converted to Microsoft Excel files. Pell SAS/ Reconciliation files are imported into the COD "Pell Recon Reader" tool and converted to Microsoft Excel files. The SAS files and financial aid management system (FAMS) files are imported into Microsoft Access tables and Microsoft Access queries are run to determine discrepancies between SAS file data and FAMS data. This standardization provides an efficient procedure for staff members to follow. Staff have been cross trained to reduce processing delays. This system, incorporating efficient technology, calendar reminders, and cross training has improved the efficiency of reconciliation activities. Financial Aid staff coordinate with Business Office staff for notification after the Financial Aid to COD reconciliation is complete. Financial Aid staff are updating the policies for SAP supporting documentation submission that require students to submit documents via the student financial aid portal where documents will be securely stored and backed up within the College servers. Financial Aid staff are updating processes among Financial Aid, the Registrar's Office, and Academic Affairs to strengthen timely identification of both official and unofficial withdrawals for timely Return to Title IV Funds processing. Finally, during the pandemic, the College experienced some difficulties obtaining official high school transcripts due to school closings. The College is continuing to work to review files to ensure this is fully addressed.

Description: Special Tests & provisions – Return of Title IV Funds Corrective action: The University’s finance office has reviewed the finding presented by FORVIS and agrees with their evaluation that the R2T4 calculation. As the University has closed and there are no additional R2T4 calculations to be made, this problem has self‐corrected. Person Responsible for Implementation: Kenneth M. Macur, VP for Business and Finance Status: Fully corrected

Federal Award Findings and Questions Costs Corrective Action Plan Year Ended August 31, 2023 Finding No. 2023-001: Inaccurate Enrollment Reporting CFDA Numbers: Various Program: Student Financial Assistance Cluster Corrective Action: Students will be required to request special permission to re-enroll, thus ensuring that their graduation is reported before any additional enrollment or withdrawal. Additionally, a thorough assessment of the management review process will be performed to identify areas that will help ensure the accurate submission of data to the NSLDS. We anticipate revised processes in the Spring of 2024. Contact Person: Jaci Casazza Expected Implementation: April 30, 2024

Going forward, all students who withdrawal from the College will be forwarded to the financial aid team to review whether a student is still eligible for the full funding of the specific semester in question or whether funding needs to be returned based on the withdrawal date. If it is deemed that funds need to be returned, the Bursar will provide the financial aid team with a copy of the student charges for that period and the Registrar will provide proof of the withdrawal date and the financial aid team will determine the amount of funding that needs to be returned. Financial Aid will then complete the return through the student's account and notify the Controller and VP of Finance and Administration to process the return to G5.

When SAP is run in the spring, students will be notified of their academic standing. Students who are suspended will have an opportunity to appeal their suspension. If the appeal of suspension is approved, students will meet with their academic advisor to be placed on an academic plan. The academic plan must be signed by both the student and advisor. The academic plan must be submitted to the Office of Financial Aid via the teams. A financial aid hold will be placed on the student's account until the signed academic plan is received. Once received, the Office of Financial Aid will remove the hold so the student can be awarded.

Currently, the College marks students withdrawn on the date the withdrawal is officially processed in the system, indicating their last data of attendance. The withdrawal policy will be updated to indicate that the withdraw date to be reported for all students withdrawing at either the program or campus level should be processed as the "last date of attendance". In the case of the 5-year program (4+1 internally), we currently do not officially "enroll" a student into the master's program until their bachelor's degree is conferred. The official admit date will be updated to reflect the term a student enters the master's program officially, which will begin after the conferral of their bachelor's degree. Our policy and processes for the 4+1 program will be updated to reflect this change.

The Student Financial Aid department will address the circumstances of the finding by working with the institution’s primary contact at the National Student Clearinghouse before Fall 2024. They will review and establish a scheduled transmission of reporting to meet the standards of The Department of Education Title IV programs. The Financial Aid Director and Registrar will work closely together to revise the unofficial withdrawal process before Fall 2024. The new process should ensure unofficial withdrawals are reported promptly, with accurate data, and within the roster file, based on the 50% midpoint of the semester instead of the last date of attendance. Testing will be conducted randomly during Fall 2024 to ensure the accuracy of the new process and the information reported in each roster file.

Management's Response: Upon discovery of the errors, the University reviewed the population of withdrawn students where the dates for one module were used versus the payment period. The University performed the additional or revised Title IV calculations and returned additional funds. The $3,060 reported as questioned costs identified by the auditors has also been returned.

Individuals Responsible for Corrective Action Plan Daniel Hall (Interim Vice President for Finance and Administration) Libby Shull, CPA (Controller) April Baur (Director of Student Financial Aid) Kevin Crider (Chief Information Officer) Vicky Wilson (Registrar) Finding 2023-006 For 3 of 24 students selected for testing, the College was unable to locate Perkins master promissory note. Corrective Action Plan: The College maintains all Perkins promissory notes in alphabetical order, in a dedicated filing cabinet, in a fireproof vault. This finding relates to promissory notes that were signed in 1987, 2006, and 2016, and the College is not aware of what may have caused these promissory notes to be misplaced. No further action is planned by Management as the Perkins Loan Program expired on September 30, 2017 and no additional Perkins Loan disbursements were made by the College since the Program’s expiration.

Individuals Responsible for Corrective Action Plan Daniel Hall (Interim Vice President for Finance and Administration) Libby Shull, CPA (Controller) April Baur (Director of Student Financial Aid) Kevin Crider (Chief Information Officer) Vicky Wilson (Registrar) Finding 2023-003 For 4 of 40 students tested, the College did not send the required loan disbursement notification to the parent borrower for PLUS loans. Corrective Action Plan: For the 2023-2024 academic year, a PLUS Loan Form was created and sent to the parent borrower to confirm the amount requesting. As of March 6, 2023, notifications are created to notify parents with PLUS loans of disbursement and their rights.

Individuals Responsible for Corrective Action Plan: Daniel Hall (Interim Vice President for Finance and Administration) Libby Shull, CPA (Controller) April Baur (Director of Student Financial Aid) Kevin Crider (Chief Information Officer) Vicky Wilson (Registrar) Finding 2023-002 For 2 of 2 mid-year transfer students tested, the school did not actively add these students to the NSLDS transfer monitoring list. Corrective Action Plan: While the college experienced significant turnover in its staffing in fiscal years 2021 and 2022, the college has historically reviewed the NSLDS history of transfer students to ensure they were not enrolled or receiving a disbursement for the current term at another institution. Any student that showed a pending disbursement on COD would be notified to inform their previous college and request the pending disbursement be removed. Starting in the fall 2023, the transfer monitoring tool was utilized along with reviewing NSLDS history.

Individuals Responsible for Corrective Action Plan Daniel Hall (Interim Vice President for Finance and Administration) Libby Shull, CPA (Controller) April Baur (Director of Student Financial Aid) Kevin Crider (Chief Information Officer) Vicky Wilson (Registrar) Finding 2023-007 For 3 of 25 students selected for testing, the College did not report accurate program level data to the NSLDS. For 4 of 29 students selected for testing, the College did not timely report campus level data to NSLDS. For 4 out of 29 students, the College did not report students’ enrollment statuses accurately. Corrective Action Plan: The college will be more cognizant of reporting accurate student information to the National Student Clearinghouse in a timelier fashion. The Registrar’s Office and Information Technology Office will review the reporting procedures to determine if changes are necessary in the parameters selecting the appropriate student information that is sent to the National Student Clearinghouse and retrieved by the NSLDS.

Individuals Responsible for Corrective Action Plan Daniel Hall (Interim Vice President for Finance and Administration) Libby Shull, CPA (Controller) April Baur (Director of Student Financial Aid) Kevin Crider (Chief Information Officer) Vicky Wilson (Registrar) Finding 2023-005 For 1 of 2 students selected for testing, the College did not return the correct amount to the ED in the required timeframe. Corrective Action Plan: This finding is in regards to a R2T4 return that was not returned within the 45 days. The Assistant Director of Financial Aid successfully took and passed the R2T4 course offered by the National Association for Student Financial Aid Administrators (NASFAA) in November 2023 and we have implemented the process to return funds in a timely manner.

Individuals Responsible for Corrective Action Plan Daniel Hall (Interim Vice President for Finance and Administration) Libby Shull, CPA (Controller) April Baur (Director of Student Financial Aid) Kevin Crider (Chief Information Officer) Vicky Wilson (Registrar) Finding 2023-004 In accordance with the Gramm-Leach-Bliley Act requirements, the College did not maintain a written information security program that addresses the minimum elements set forth in 16 CFR 314.4. Corrective Action Plan: The college made good progress in 2022-2023 with its compliance and security planning by completing a Risk Assessment and an Incident Response Plan. The findings from those assessments are the foundation for developing an Information Security Plan.

We observed the following conditions in connection with our testing of the various U.S. Department of Education, Title IV, Student Financial Assistance Programs: a. Two (2) out of 21 students did not complete exit counseling requirements upon graduating or dropping below half-time status. 34 CFR 685.304(b)(1) b. One (1) out of 21 students was awarded Federal Direct Loans at less than half-time status. 34 CFR 685.200 (a)(1)(i). Attributable questioned cost: $3,000 c. Documentation to support the Center’s reconciliation of the Federal Direct Loan program between Common Origination and Disbursement (COD) and the Office of Financial aid was not available. 34 CFR 685.300(b)(5) d. Documentation to support the Center’s reconciliation of the Federal Work-Study program was not available. 34 CFR Part 668 Subpart L e. One (1) out of 21 students did not have timely or accurate enrollment reporting to the National Student Loan Data System (NSLDS). 34 CFR685.309(b) f. Documentation to conduct Federal Work-Study compliance testing was not provided. 34 CFR Part 675 g. Documentation to support testing for withdrawals and the return of Title IV funds compliance was not provided. HEA Section 484B & 34 CFR 668.22 h. Documentation to support credit balance (student refund) testing was not provided. 34 CFR 668.164(h)(1) i. Two (2) out of 21 students were paid Federal Direct Loans and did not make satisfactory academic progress (SAP) for the academic year. Additionally, the school did not provide updated documents supporting successful appeals. 34 CFR 668.34. Attributable questioned cost: $30,730 j. One (1) out of 21 students did not have an undergraduate transcript to prove eligibility for the program they were enrolled within the institution. HEA Section 484(d) and 34 CFR 668.32. Attributable questioned cost: $20,500. Auditor's Recommendation – The Center should implement corrective actions to ensure that the above findings are resolved and do not recur in future periods. Moreover, internal controls over compliance with federal program regulations should be revisited to ensure adequate supervisory controls, quality assurance reviews of compliance steps, technical training of staff, and adequate procedures are being followed for compliance purposes. View of Responsible Officials – Management agrees.

The University agrees with this finding. The University submits its enrollment status changes through the National Student Clearinghouse system to ensure proper recording in NSLDS. The University will strengthen its controls to ensure that the Registrar Office validates the completeness and accuracy in the NSLDS system by reconciling the data per the NSLDS system to what is recorded in the University’s system for both branch locations; the main campus (003714-00) and HU Online (003714-81). Additionally, the Registrar’s Office will strengthen its monitoring controls over the transmission for both branch locations to ensure the data transmission is complete and accurate.