Corrective Action Plans

Management concurs with the findings regarding the delay and insufficient graduation reporting to NSLDS. The University Registrar is aware of the 6-day delinquency in reporting for summer term due to the timing of the degree awards for the May graduates on the East Falls campus. Degree audits will be checked to ensure are awarded in a timely manner. We also will work with NSC to ensure all enrollment reporting schedules are updated in accordance with the academic calendar of the appropriate branch, limiting any issue with the 60-day certification date during our Summer term, as all other terms have been reported correctly. This will happen every semester on a 4–6week basis, in tandem with enrollment report submissions. This will resolve the 60-day certification issue. Academic Services makes every effort to report clean enrollments accurately and on time. However, we continue to find inconsistencies with the NSC transmissions to NSLDS and are aware of the need for additional oversight of the NSC process as well as the development of a process to audit NSC transmissions to NSLDS. This will also aid in the elimination of reporting errors between NSC and NSLDS, as in the case of the three graduation records. The Office of Academic Services is working to identify resources to address the above action plans. Spring 2024 update: The University Registrar has gained access directly to the NSLDS enrollment files. The University Registrar will audit enrollment files twice monthly to be certain that any errored NSLDS enrollment records created at the time of NSLDS roster submission, are corrected to negate the 65-day outstanding record (NSLDS ERROR 22). The University Registrars will continue to work with NSLDS and National Student Clearinghouse to locate cause of errored NSLDS roster records.

Finding 2023-001 - U.S. Department of Education (USDE), Title IV Student Financial Aid Programs (Deficiency): We observed the following condition in connection with our testing of the various USDE, Title IV, Student Financial Assistance Programs. a) One (1) out of 15 files tested were missing official transcripts. The total questioned costs $9,415. 34 CFR 668.32 Auditor’s Recommendation – The College should implement corrective actions to ensure the above finding is resolved and will not recur in future periods. Corrective Action – Management will implement procedures to ensure that the above finding is resolved and will not recur in future periods. The files of Title IV student financial assistance recipients will be reviewed to ensure that they are properly completed and maintained, inclusive of official transcripts.

Criteria: Institutions are required to report enrollment information under the Pell Grant and Direct Loan programs via the National Student Loan Data System (NSLDS) (Pell, 34 CFR 690.83(b)(2); Direct Loan, 34 CFR 685.309). The administration of the Title IV programs must review, update, and verify student enrollment statuses, program information, and effective dates that appear on the Enrollment Reporting Roster file. The Department of Education lists several certification methods for enrollment reporting, including certifying directly through the NSLDS website, certifying through the NSLDS’s batch enrollment reporting process, or through certification of rosters provided to the National Student Clearinghouse (NSC). Per 2 CFR 200.303, a non-federal entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statues, regulations, and terms and conditions of the federal award. Corrective Action Taken or Planned: Management, more importantly the Financial Aid Director, Erin Hanlon will review its processes and internal controls to ensure that all enroll,ent information and status changes are reported completely, accurately, and in a timely manner, effective immediately. Additionally a review of the submitted enrollment data to the NSLDS be performed to ensure current student status information and status is properly reflected. Enrollment reporting corrections will be corrected by April 30, 2024. The following outlines of steps to be taken will be implemented immediately: 1. Ensure that multiple people are trained to report to NSC. a. This would mean at least once a semester having multiple peoples (at least two) involved in not only the reporting b. Also, others should be trained and aware of the follow-up correction process. 2. Reporting to NSC on a more frequent basis (twice a month). a. Right now, we report once a month at the end of each month. b. As long as students are reported within 60 days, they are within reported guidelines, so this has typically been ok. c. Reporting twice a month ensures any changes in enrollment are caught early. 3. Working with other departments (registrars/admissions/etc.) to find the common errors in the reporting and find ways to make sure these errors do not occur. a. Meeting at least once a semester to review where the most common/most errors occurred. b. Formulate processes to make sure these errors don't slow down reporting times.

Finding: As described in 34 CFR 668.171, the U.S. Department of Education (ED) requires institutions of higher education to report the occurance of specific events, known as triggering events, to them within ten days of the event. The notification of the vote by the Massachusetts Board of Registration in Nursing (BORN) to withdraw the approval of the College's Associate Degree Nursing Program is a triggering event that should have been reported to the ED within ten days of occurance of the event. ED requirements for reporting triggering events. The triggering event occurred on June 20, 2023 and communication was not made to the ED until August 2023. Corrective Action Plan. The College has implemented procedures to ensure triggering events are identified and reported to the ED in a timely mannger. The Financial Aid Director: Erin Hanlon or VP of Administration and Finance: William McDonald is responsible for communicating triggering events once identified.

Views of Responding Officials: The Department agrees with the finding and will implement corrective action, however, notes the following: The referrals to the Child Support Enforcement Agency (“CSEA”) are done through an interface between the HAWI eligibility and CSEA’s KEIKI systems. When a recipient is determined noncompliant by CSEA, the information is sent via the interface from KEIKI to HAWI in the form of a system-generated alert. This process worked well when application processing and maintenance of recipient cases were done in a case management method (e.g., each eligibility worker assigned to process applications and/or maintain a caseload of active cases). Using this method, eligibility workers managed their caseloads and checked for incoming alerts for cases assigned to them; these alerts included the CSEA noncompliant alerts coming from the KEIKI system. Workers were able to take appropriate and timely action in response to the alerts received. However, necessary changes were made to how applications and active cases are managed. The division stopped the case management method and converted to “task-oriented” processing statewide. Workers are no longer assigned to caseloads but are assigned to “tasks” such as processing applications, incoming documents/verifications, reported changes, six month review and annual recertifications, etc. A case is not reviewed and worked in HAWI until a worker is prompted to do so, e.g., six-month review, annual recertification or a change was reported by the household. It is until such action occurs when an eligibility worker, who picks up the task, will check for alerts for the case. Aside from that, recipient cases will not be reviewed during their certification period. So how the “alerts” were developed in HAWI no longer works for the way we currently process applications and maintain recipient cases. We are unable to modify the HAWI system because we are currently developing a new eligibility system that will replace HAWI. The new eligibility system is scheduled to go into production in late 2024. Corrective Action Taken or Planned: As an interim solution until the new eligibility system rolls out into production, a shared folder is being created where CSEA will place the monthly reports of non cooperating TANF cases so designated TANF staff members, who are granted access to the shared folder, will be able to retrieve the reports. TANFPO will review the identified TANF cases. Individual lists will be forwarded to the Section Administrators to instruct the affected Processing Centers to take appropriate action (i.e., TANF case closure due to noncompliance with CSEA). Expected Completion Date: July 1, 2024 Responding Officials: Catherine Scardino, Temporary Assistance for Needy Families Program Administrator

Views of Responding Officials: The Department agrees with the finding and will implement corrective action; however, notes the following: Adoption Assistance is an incentive program with payment beginning prior to the finalization of an adoption. The adoption decree is not required for payment as the Adoption Assistance Agreement must be entered into prior to the finalization of an adoption. Corrective Action Taken or Planned: 1. Child Welfare Service (“CWS”) staff will be informed of the audit findings, the importance of diligent compliance of policies and procedures, records maintenance and this corrective action plan. 2. Unit staff (Licensing, CWS, and FPPEU) who manage cases identified with errors in this audit will be retrained, ensuring familiarity with grant requirements and related policies and procedures. • Staff will be given coaching/supervisory support to correctly complete documentation. 3. Case specific audit findings and corrective action taken will be noted in each record where there was a finding. • Research/review and document why licensing approval was granted to a household with an individual who was convicted of spousal abuse. i. If review determines that Adoption Assistance Agreement (“AAA”) was inappropriately authorized, provide family with an adverse action notice discontinuing the AAA and explaining the appeals process. • Investigate whether supporting documentation regarding whether the State determined that the child cannot or should not be returned to the home of his or her parents can be located and added to the record. • Secure a copy of the missing adoption decree, although adoption assistance is an incentive program with payment beginning prior to the finalization of an adoption. • Document the qualifying need for Difficulty of Care (“DOC”) determination for the records, showing how DOC was calculated. • Document how income eligibility was verified. • Secure missing modified adoption agreements. • Locate missing clearances or re run them if not located. Note: Not all clearances are secured prior to placement; FBI clearances come later and are NOT required prior to placement in a “provisionally licensed” home. 4. The identified errors and the related corrective action steps proposed above will be reviewed by CWS Administrators, staff supervisors, and the Management Information Compliance Unit (“MICU”) within 90 days to ensure missing documentation has been secured and/or properly noted in record. 5. MICU staff will audit records with findings to ensure errors have been documented and corrected. • MICU will work with Branch Administrators, Social Services Assistants (“SSA”), and program personnel to ensure file updates with completion of missing information. 6. As CWS implements this corrective action plan and monitors the results, the action steps proposed in 1 – 5 may be modified, based on input from CWS Administrators or exploration groups with line staff who complete this documentation. Expected Completion Date: May 31, 2024 and on going Responding Officials: Kisha C. Raby, Social Services Division, Child Welfare Services Program Development Office, Administrator, and Tonia Mahi, Social Services Division, Child Welfare Services Program Development Office, Assistant Branch Administrator

Views of Responding Officials: The Department agrees with the finding and will implement corrective action. Corrective Action Taken or Planned: 1. Child Welfare Service (“CWS”) staff will be informed of the audit findings, the importance of diligent compliance of policies and procedures, records maintenance and this corrective action plan. 2. Unit staff (Licensing, CWS, and FPPEU) who manage cases identified with errors in this audit will be retrained, ensuring familiarity with grant requirements and related policies and procedures. • Staff will be given coaching/supervisory support to correctly complete documentation. 3. Case specific audit findings and corrective action taken will be noted in each record where there was a finding. • Locate Police Protective Custody form, Voluntary Foster Custody Agreement, or other documentation which clarifies whether the child was removed as part of a voluntary placement agreement or judicial determination. • Locate missing clearances or re-run them if not located, placing note in record about audit re run. Note: Not all clearances are secured prior to placement; FBI clearances come later and are not required prior to placement in a “provisionally licensed” home. • Document the qualifying need for Difficulty of Care (“DOC”) determination for the records, showing how DOC was calculated. • Review resource caregiver licensing status and locate missing license or reissue license. • Investigate the case where the Judicial Determination was missing and therefore did not support the removal of the child was contrary to the welfare of the child, if the Department made reasonable efforts to prevent removal and finalize the permanency plan, and if the determination was within 60 days from removal. i. Locate court order documenting “contrary to welfare” language, verifying timelines, place in record and document findings. • Locate missing Imua Kakou minutes or secure additional documentation validating monthly meeting requirement was met. 4. The identified errors and the related corrective action steps proposed above will be reviewed by CWS Administrators, staff supervisors, and the Management Information Compliance Unit (“MICU”) within 90 days to ensure missing documentation has been secured and/or properly noted in record. 5. MICU staff will audit records with findings to ensure errors have been documented and corrected. • MICU will work with Branch Administrators, Social Services Assistants (“SSA”) and program personnel to ensure file updates with completion of missing information. 6. As CWS implements this corrective action plan and monitors the results, the action steps proposed in 1 – 5 may be modified, based on input from CWS Administrators or exploration groups with line staff who complete this documentation. Expected Completion Date: May 31, 2024 and on-going Responding Officials: Kisha C. Raby, Social Services Division, Child Welfare Services Program Development Office, Administrator

The system is being reviewed to ensure flags are set not only from the Central Process System (CPS) on the ISIR as an alert, but to implement secondary measures in PowerFaids to flag the student’s electronic file record as part of the communication process that the counseling unit must review. Staff will be counseled and additional training is being provided to ensure all staff are knowledgeable and conscientious of policy, review and the calculation process when determining yearly and aggregate loan limits. The University will be implementing Transfer Monitoring which has been discussed as preparation of bringing up a new system.

To address and eliminate the prior audit finding related to Return of Title IV Funds, Academic Affairs and Records and Registration have been working closely with, and to train and educate Deans and Faculty on the Federal Regulations and Guidelines. Internal controls focused on monitoring, documenting, electronically reporting, follow-up reviewing and reporting of students’ last date of attendance and academic related activity have been implemented. The Registrar Office will work with the comparable offices at the consortia universities to implement reporting requirements for timely notification and documentation of withdrawals and/or no-shows to avoid repeat findings. Controls are being tightened between Academic Affairs, the Office of Records and Registration and the Office of Financial Aid & Scholarships.

Corrective Action Plan: Due to limitation on the FISAP, once the number of borrowers and loan balances are entered they cannot be changes, as a result there were minor differences, approximately 5 students and less than $10,000, that had been carried forward for several years. The Department of Education program officer, as well as the University’s loan servicer ECSI, have communicated that some of the numbers may differ due to payments or cancellations made after the loans were recorded. The Department of Education has accepted the information as final. The University has completed the Perkins Loan program liquidation process. The re-assignment of eligible loans to the Department of Education has been completed. Those not eligible for re-assignment have been deemed uncollectible and written-off. Once the University’s audit has been submitted we anticipated receiving the final close out letter from the Department of Education, which will officially close the Perkins Loan program at the University. Anticipated Completion Date: February 28, 2024

Corrective Action Plan: The University experienced significant staffing changes in the TRIO programs. The changes in staffing lead to a loss of institutional knowledge, and interrupted policy and process enforcement. In many instance the documentation wasn’t available due to the transition of key individuals. During the period of staff transition for the McNair program, original communication showing previous approval from the Program Officer was not accessible. While the Department of Education provided correspondence granting McNair projects permission to reallocate travel funding to increase stipends for participants, given the limitations on travel capabilities due to the COVID-19 pandemic, which was subsequently confirmed by the Program Officer, we encountered difficulty locating explicit documentation approving the specific stipend increase amount. Continuous monitoring of program records will be implemented to ensure compliance with federal, Institutional and program requirements. The programs will review existing program operating procedures manuals to identify needed updates to current policies and procedures to align with federal, Institutional and program requirements. The program stall will also engage in professional development opportunities to improve grant management. Anticipated Completion Date: July 31, 2024

Finding No. 2023-007 Department(s): New York City Administration for Children’s Services Program(s): Assistance Listing Number 93.658, Foster Care – Title IV - E Corrective Action(s): • ACS will review all outstanding non-finalized Redetermination packages and re-request outstanding Court Orders. • Moving forward, if the hard copy Court Order has not been received by ACS within 90 days of the Permanency Hearing, ACS will request a court transcript of the Permanency Hearing. • ACS will finalize IV-E Redetermination packages if a Reasonable Effort determination finding has not been conferred within four months of the request for court action. • ACS will work with the Office of Court Administration to address challenges in timely completion of hearings and receipt of Court Orders. Anticipated Completion Date: September 2024 Person(s) Responsible for Implementation: Andrew Martin, Executive Director, Central Eligibility Office (212)-341-2816

NSLDS Enrollment Reporting Student Financial Assistance Cluster – Assistance Listing No. 84.063, 84.033, 84.268 Recommendation: We recommend the University review its reporting procedures to ensure that enrollment and program information is accurately reported to NSLDS as required by regulations. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: A complete internal review of the audit findings was undertaken. We discovered an inconsistency in our SIS that has been corrected to align with best practices state in the “NSLDS Enrollment Reporting Guide November 2022”. We have also engaged with the National Student Clearinghouse (NSC) Audit Resource Center to ensure timely reporting to NSLDS. SCU has also created a “Monitoring of Reporting Compliance Program” that will compare various reports available in NSLDS to data that was submitted to NSC. We have also increased our reporting frequency to ensure the latest data is being sent. Name(s) of the contact person(s) responsible for corrective action: Robert Boggs, EdD, University Registrar Planned completion date for corrective action plan: The internal monitoring program will be in place by 3/1/2024

Title: Student Financial Assistance Cluster – Assistance Listing Nos. 84.038, 84.268, 84.033, 84.007, 84.063 Recommendation: We recommend that the College review the updated GLBA requirements and ensure their WISP includes all required elements. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The College will review the updated GLBA requirements to ensure Bethany is compliant with all the WISP required elements. Name of the contact person responsible for corrective action: John Sehloff, Director of Information Technology Planned completion date for corrective action plan: June 30, 2024

Title: Student Financial Assistance Cluster – Assistance Listing Nos. 84.038, 84.033, 84.007 Recommendation: We recommend the College implements a formalized yearly reconciliation of Federal Work Study, Perkins, and Supplemental Education Opportunity Grants. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: FWS: Jeff Younge, Director of Financial Aid, directs Business Office on when to pull funds. Reconciliation between financial aid system and payroll system is done annually, prior to end of fiscal year by Director of Financial Aid. Piece we will add is for Director of Financial Aid to verify amounts requested to be pulled actually got pulled by Business Office. This has not been a problem, but additional step will serve as an extra safeguard so that all stays in balance. Perkins: No new Perkins loans are being made. Annual FISAP serves as reconciliation for this program. SEOG: Jeff Younge, Director of Financial Aid, directs Business Office on when to pull funds at time of disbursement. Piece we will add is for Director of Financial Aid to verify amounts requested to be pulled actually got pulled by Business Office. This has not been a problem, but additional step will serve as an extra safeguard so that all stays in balance. Name of the contact person responsible for corrective action: Jeff Younge, Director of Financial Aid Planned completion date for corrective action plan: 3/26/2024

Title: Student Financial Assistance Cluster – Assistance Listing Nos. 84.038, 84.268, 84.033, 84.007, 84.063 Recommendation: We recommend the College implements policies to review all student award packages at the start of the academic year to ensure no over awards exist. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Financial Aid Office looks for over award situations throughout the academic year, as changes to Cost of Attendance and financial aid (Scholarships/Grants, Loans, and Work- Study earnings) can change throughout the year. That said, Financial Aid Staff (Jeff Younge and/or Sally Sorensen) will review every student for potential over awards during the 1st two weeks of fall semester (beginning August 20, 2024), to catch any over awards that may have been created between the time of packaging, and beginning of the academic year. Name of the contact person responsible for corrective action: Jeff Younge, Director of Financial Aid Planned completion date for corrective action plan: 3/26/2024

Title: Student Financial Assistance Cluster – Assistance Listing Nos. 84.038, 84.268, 84.033, 84.007, 84.063 Recommendation: We recommend the College review its reporting procedures to ensure that students’ statuses are accurately and timely reported to NSLDS as required by regulations. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Issue: Taylor Theiste began official withdrawal process on 1/31/23. This date was used in Return of Title IV calculations, and entered into PowerFAIDS system. Student was asked to unenroll from the courses by the Registrar, which she did, but not until 2 days later. Resolution: Jeff Younge (Director of Financial Aid) met with Sergio Salgado (Registrar) and Lisa Shubert (Manager of Administrative Computing and Institutional Reporting) on 11/29/23. Going forward, when student indicates intent to withdraw, Registrar will unenroll the student from courses using the withdrawal date used for Title IV purposes. This will ensure that the correct date is reported to Clearinghouse, and then to NSLDS. Issue: Ben Draper began official withdrawal process on 1/20/23. Since this was the 10th day of class, he was not included in the Census Report that was run at the end of the day (although correct date was used for Return of Title IV calculations, and transcript shows Ws). Consequently, he was treated for reporting purposes as if he did not return for spring semester, and withdrawal date sent to Clearinghouse, and then on to NSLDS, reverted to last day of the previous fall semester, which was 12/15/22. Resolution: On December 20, 2023, meeting was held in Luther Hall that included the following: (Stacey Dawley, Jeff Lemke, Jason Lowrey, Ted Manthe, Daniel Mundahl, Sergio Salgado, Lisa Shubert, Renee Tatge, Estelle Vlieger, Jeff Younge) Proposal was made (and accepted by this group, and later the President) that stated the following: 1. Add/Drop period is day 1-5 of fall and spring semester. During this time, classes can be added, and dropped courses disappear from student schedule/transcript, as if student did not begin the class. Courses withdrawn from after 5th day result in a grade on the transcript (W, WP/WF, or F, depending on the timing of the withdrawal). This is the current policy, not a proposed change. 2. Change wording of refund policy, so that instead of Week 1, Week 2, Week 3...it is worded as Day 1-5, Day 6-10, Day 11-15... (This solves the issue of 1st week being only 4 days in the fall, but 5 days in the spring, and the day after Labor Day being the 10th day of class, but 3rd week of the semester). 3. Change Census report figures from being (10th day) to (end of 5th day). That does not mean census report is available on the 5th day, but just that the information is “locked” as of that day for reporting purposes. Name of the contact person responsible for corrective action: Jeff Younge, Director of Financial Aid Planned completion date for corrective action plan: 3/26/2024

Student Financial Aid Cluster – Assistance Listing No. 84.007, 84.033, 84.038, 84.063, 84.268, 84.379 Recommendation: The College should develop and implement an approved written information security program and verify there is a risk management section that describes how the College is identifying, assessing and communicating risks. In addition, there should be a description on the evaluation of safeguard sufficiency in mitigating risks. The information security program should also include the following: • IT Security Policy • Acceptable Use Policy • Incident Response Policy • Data Classification Policies • Vendor Management Policy • Patch Management Policy • Data Disposal Policy • Risk Assessment Policy • Logical Access and User Access Review Policies • Evidence of Review by CIO/CISO and responsibility of program Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The college will develop and implement an information security program to verify our risk management efforts. This plan will identify how we are identifying, assessing and communicating risks. Name(s) of the contact person(s) responsible for corrective action: Jossie Johnson - Director of Financial Aid and Scott Seidman – Director of IT Planned completion date for corrective action plan: September 30, 2024

Student Financial Aid Cluster – Assistance Listing No. 84.007, 84.063, 84.268, 84.379 Recommendation: We recommend the College evaluate its procedures and policies around reporting to the COD to ensure that student information is reported timely. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The college will evaluate our procedures and review regulations to ensure the appropriate enrollment information is reported, timely. In the summer of 2023, the financial aid office implemented weekly COD mismatch updates and real time R2T4 adjustments. In doing so, we are ensuring that COD has the most accurate information and adjustments are reported in a timely manner. Name(s) of the contact person(s) responsible for corrective action: Jossie Johnson – Director of Financial Aid and Michael Reig – Registrar. Planned completion date for corrective action plan: June 30, 2024

Student Financial Aid Cluster – Assistance Listing No. 84.063, 84.268 Recommendation: We recommend the College evaluate its procedures and review regulations set by the Department of Education around NSLDS to ensure the College 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 finding: The college will evaluate our procedures and review regulations to ensure the appropriate enrollment information is reported, timely. Name(s) of the contact person(s) responsible for corrective action: Jossie Johnson – Director of Financial Aid and Michael Reig – Registrar. Planned completion date for corrective action plan: June 30, 2024

Student Financial Aid Cluster – Assistance Listing No. 84.007, 84.063, 84.268, 84.379 Recommendation: We recommend reviewing the report that is run to identify withdrawn students to understand why these students were not included, as well as implement a compensating control to ensure future students are not missed. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Financial Aid Office fully understands federal requirements surrounding the completion of R2T4s and strive to remain up to date with R2T4 best practice. We are fully committed to identifying the root cause, implementing corrective actions, and improving the system to prevent similar issues in the future. Name(s) of the contact person(s) responsible for corrective action: Jossie Johnson – Director of Financial Aid and Michael Reig – Registrar. Planned completion date for corrective action plan: April 30, 2024

Student Financial Aid Cluster – Assistance Listing No. 84.268 Recommendation: We recommend the College review its policies and procedures around sending exit counseling information to students to ensure students are receiving proper counseling. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Action taken in response to finding: We have conducted a thorough review of our exit counseling procedures and have identified areas of opportunity. Our team is committed to making the necessary corrections to ensure compliance with regulatory requirements. Our goal is to enhance our exit counseling program to better support students in understanding their rights and responsibilities regarding their federal student loans. We will execute this plan by including exit notices in our biweekly notifications, emailing students once an R2T4 is completed and notifying students that are less than halftime students the day after add/ period of each semester. For graduating students, we will host an event leading up to graduation where students can learn about the repayment process and an opportunity for students to complete their exit counseling. . Name(s) of the contact person(s) responsible for corrective action: Jossie Johnson – Director of Financial Aid Planned completion date for corrective action plan: April 30, 2024

Student Financial Aid Cluster – Assistance Listing No. 84.063, 84.268 Recommendation: We recommend the College evaluate its procedures and policies around reporting to the COD to ensure that student information is reported timely. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Financial Aid policies and procedures will be reviewed and amended as necessary. In conjunction with the Registrar’s Office all student changes and information will be reported and reconciled timely. Name(s) of the contact person(s) responsible for corrective action: Jossie Johnson – Director of Financial Aid Planned completion date for corrective action plan: September 30, 2024

Student Financial Aid Cluster – Assistance Listing No. 84.007, 84.033, 84.063, 84.268, 84.379 Recommendation: We recommend the College review its policies and procedures related to Title IV outstanding checks to ensure they are being returned to the Department of Education after 240 days. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The office of Financial Aid and Accounting will review outstanding checks on a monthly basis. In addition, any checks related to financial aid returns or refunds will be sent to the Department of Education within the required time frame. Name(s) of the contact person(s) responsible for corrective action: Larz Jeter – Controller and Jossie Johnson – Financial Aid Director Planned completion date for corrective action plan: September 30, 2024.

Federal Direct Loans Reconciliations Planned Corrective Action: The University’s Financial Aid Office will review the reconciliations to ensure that the Direct Loan Program is reconciled. We will also refer the ED announcement DL-22-07 to maintain consistent and accurate reconciliations. Person Responsible for Corrective Action Plan: Nicholas Capodice, Director of Financial Aid Anticipated Date of Completion: April 30, 2024