Corrective Action Plans

Identifying Number: Finding No. 2024-007 – Student Credit Balances from Title IV Awards Finding: When Title IV funds are credited to a student account and they exceed the amount of tuition and fees, food and housing, and other authorized charges assessed the student, a credit balance is created. The institution must pay the resulting credit balance directly to the student or parent borrower within 14 days after (1) the first day of class of a payment period if the credit balance occurred on or before that day, or (2) the balance occurred if that was after the first day of class. The College does not have a control in place with physical indication of review over refund process for student credit balances. Corrective Actions Taken or Planned: Responsible Official: Judy Byrd, Controller Anticipated Completion Date: April 1, 2025 View of Responsible Individuals: Once the student refunds are imported to the accounting software, the Refund Export Log report along with the Charge/Credit Import report will be given to Controller/Director of Finance. The AP Coordinator will deliver the student refund checks to Controller/Director of Finance. The Controller/Director of Finance will compare the refund log list against the actual printed checks to verify that all checks have been printed. A signature and date on the refund log report will indicate that the review was completed and that all required refund checks have been printed. Signed report and backup will be stored in the AP files under the title “Student Refunds”.

Identifying Number: Finding No. 2024-006 – Perkins Loan Recordkeeping and Record Retention Finding: The College could not locate promissory notes or MPNs for some of its Perkins loans when requested by the auditors. Corrective Actions Taken or Planned: Responsible Official: Tim Pollak, Director of Finance Anticipated Completion Date: May 1, 2025 View of Responsible Individuals: Accounting will review all Perkins loans fully paid in the last three years along with all remaining open loans. Director of Finance will review report of newly paid-off loans from the ECSI website. Loans satisfied/cancelled/assigned will be transferred from “open” status to “closed status file and verified that all appropriate documents remain with the file.

Identifying Number: Finding No. 2024-005 – Enrollment Reporting – Student Financial Aid Special Test Finding: There is no control in place by the College to review information submitted to the NSLDS for student enrollment status changes. There were instances of noncompliance where students with enrollment status changes were received by the NSLDS outside of the 60-day requirement. Corrective Actions Taken or Planned: Responsible Officials: Traci Holland, Registrar and Nikki Bamonti, Interim Vice President for Enrollment Management Anticipated Completion Date: March 21, 2025 View of Responsible Individuals: The occurrence of late submissions is not typical, and the Registrar’s office submitted regular reports to the National Student Clearinghouse (NSC) monthly, which is within the 60-day requirement. Due to staff turnover in the Registrar and Financial Aid offices, there was no documentation available regarding the necessary steps for Financial Aid to confirm the NSC enrollment data within the NSLDS database. The College is committed to ensuring compliance with federal regulations and has implemented the following corrective actions to prevent future delays in submitting and reviewing enrollment and status changes as follows: • The Registrar’s office will continue to set the submission schedule within the NSC database for all reports in August for the upcoming academic year. They will share the schedule with the Financial Aid Director and will provide updates when/if necessary. • Degree Verify and Graduates Only reports will continue to be submitted after each degree conferral date: January 15, June 5, September 15. • The Registrar’s office will continue to submit enrollment and status change reports to NSC every month. • After submission and error resolution, the Registrar’s office will notify the Financial Aid Director, so the Financial Aid office can conduct the independent review of submissions received by NSLDS from NSC. [See Independent Review below] • In addition, the Financial Aid office will continue to receive automated, overnight email notifications when students withdraw from coursework that changes their status.Independent Review: After each enrollment reporting submission, the Registrar’s office will notify the Financial Aid Director. Upon notification, the Financial Aid Director will conduct an independent review of enrollment data received by the National Student Loan Data System (NSLDS). This review will ensure that enrollment status changes, including graduations, withdrawals, and leaves of absence, are accurately reported and processed in a timely manner. The Financial Aid Director will: • Review the submissions to NSLDS and verify the data for accuracy. • Identify and resolve discrepancies in reported enrollment statuses. • Ensure corrections are reported to the Registrar. • Confirm the accuracy of the submissions and document the review.

Name of contact person: Katie Langan, Interim Vice President for Academic Affairs / Dean of the Faculty Corrective action: With respect to the published program length issues, Marymount Manhattan College (the "College") agrees with this finding and will make appropriate changes to ensure that the National Student Loan Data System ("NSLDS") records for program length are based on years, correcting the earlier issue of basing program length on weeks. With respect to the program begin date supporting documenation issue, the College agrees with this finding and will take appropriate actions to correct this issue. These actions will include reinforcing the importance of maintaining documentation and providing adequate secure storage facilities for paper records. With respect to the program start date issue, the College agrees with this finding and will take appropriate corrective actions. These actions will include the creation of a committee consisting of representatives from Registrar, Advisement, Financial Aid, IT, and Business Office to review where inforemtion is stored in the software and ensure it is properly included in the upload to the National Student Clearinghouse ("NSC"), who in turn transmits the information to NSLDS. With respect to the inaccurate CIP code, the College agrees with this finding and will take corrective actions by implementing a double-check process to verify CIP codes before uploading them to NSC, who in turn transmits the information to NSLDS. Proposed completion date: June 30, 2025

2024-006 FINDING: NONCOMPLIANCE WITH PERKINS LOANS’ RETENTION OF RECORDS Corrective Action Plan: Existing University procedures ensure master promissory notes and other Perkins-related documentation requirements are properly maintained. The University will continue its ongoing process of reviewing Perkins documentation to comply with the requirements. Responsible University Personnel: Linda Theres-Jones, Director of Financial Services/Chief Accountant; Villalyn Baluga, Associate Vice President for Finance. Anticipated completion date: Already implemented.

2024-005 FINDING: FAILURE TO RETAIN ADEQUATE DOCUMENTATION OF INTERNAL DIRECT LOANS RECONCILIATION Corrective Action Plan: The University has revised existing procedures to require the retention of internal reconciliation records on a monthly basis. Responsible University Personnel: Linda Theres-Jones, Director of Financial Services/Chief Accountant; Villalyn Baluga, Associate Vice President for Finance. Anticipated completion date: Already implemented.

2024-004 FINDING: NONCOMPLIANCE WITH NOTIFICATION REQUIREMENTS ON DIRECT PLUS LOANS DISBURSEMENTS Corrective Action Plan: The University has implemented changes to procedures to send proper notification to the parent Direct PLUS borrowers. Responsible University Personnel: John Perry, Executive Director of Financial Aid/ Scholarships and Registration Anticipated completion date: Already implemented.

2024-003 FINDING: NONCOMPLIANCE WITH GRAMM-LEACH-BLILEY ACT Corrective Action Plan: The University has recently completed the development of the written incident response plan during Fiscal Year 2025. Responsible University Personnel: Charles Pustz, Associate Vice President for Information Technology Services and Chief Information Officer; David Weissbohn, Director of Information Security and Compliance. Anticipated completion date: Already implemented.

2024-002 FINDING: ENROLLMENT REPORTING Corrective Action Plan: Following consultation with the National Student Clearinghouse (NSC), guidelines were provided for handling various status change scenarios. These guidelines will enhance the accuracy of enrollment status change reporting, particularly for students with changes occurring before or after the subsequent enrollment file submission. Status changes are now being reported to the NSLDS in a timely and accurate manner, in accordance with the NSC guidelines. The University has also implemented a reporting timeline and review protocols to ensure status changes are reported to the U.S. Department of Education’s National Student Loan Data System (NSLDS) in a timely manner. Additionally, the University will collaborate with its Information Technology Services and representatives from the NSC and NSLDS to verify the accuracy of the file layouts and the data flow of the information provided. Responsible University Personnel: John Perry, Executive Director of Financial Aid/ Scholarships and Registration; Timothy Carroll, Registrar. Anticipated completion date: Partially implemented. The University is collaborating with its Information Technology Services and representatives from the NSC and NSLDS on accurate reporting of the program start date, which is expected to be completed during Fiscal Year 2026.

Compliance Deficiency over Special Tests and Provisions – Enrollment Reporting The University acknowledges that there was 1 out of the 16 students selected that the change in enrollment status was reported by the University more than 60 days after the enrollment status change. Effective with the Student Enrollment Roster received from NSLDS in March, 2024 the business practice has changed with the implementation of the modernized NSLDS Professional Access website. Upon receipt of the Student Enrollment Roster, the file is updated by an updated algorithm using data from the University’s CRM, Jenzabar. The resulting spreadsheet is uploaded to NSLDS for verification and submittal. The accepted records are updated in NSLDS’ database and are removed from the resulting spreadsheet produced by NSLDS. The records that error-out are listed on the resulting spreadsheet. This file is maintained for audit purposes. To ensure accurate enrollment status updates, the records listed on the resulting spreadsheet are updated manually on the NSLDS website. The manual entries are updated in real-time. In addition, the University is updating enrollment status changes manually upon receipt of Action Forms initiated by the student instead of waiting for the next Enrollment Report from NSLDS. This should correct the issue where a change in student status was not captured by NSLDS and reasonably ensure compliance with Federal statutes. The addition of a Director of Financial Aid, December 2024, has further improved this process. Contact Person: Kim Wittler, AVP, Enrollment and Financial Aid Completion

2024-001 Student Financial Assistance Cluster – Federal Assistance Listing No. 84.038 Recommendation: We recommend the University evaluate is procedures and policies around recordkeeping and retention. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Management of the University agrees with the finding. We do have policies and procedures in regard to recordkeeping and retention of Perkins loan documents. Active, Assigned and Retired Perkins loans are maintained in a locked, fireproof container in the Bursar office. The repayment schedules are electronically kept in our borrower files with Heartland ECSI. The cancellation and deferment request for each Perkins loan made are electronically kept in our borrower files with Heartland ECSI. We typically retain original or true and exact copies of Master Promissory Notes (MPN). In some cases, the MPN may have been returned to the student during their entrance counseling. The Perkins loan program expired September 30, 2017. We are currently in the process of Assigning the remaining borrowers to close out our Perkins Loan Program. We are working as quickly and efficiently as possible. Staff availability will determine the completion date for this process. Name(s) of the contact person(s) responsible for corrective action: Diane Purcell, Bursar Senior Accountant, (860) 768-4361 Planned completion date for corrective action plan: June 30, 2025 If the United States Department of Education has questions regarding this plan, please call Elaine Daly, Assistant Vice President for Finance & Controller at 860-768-4652 or Katherine Presutti, Director of Student Financial Aid at 860-768-4300.

To: PKF O’Connor Davies LLP, U.S. Department of Education From: Princeton Theological Seminary Jean Hall, Vice President for Finance & CEO Date: March XX, 2025 Subject: Princeton Theological Seminary - Corrective Action Plan for the Year Ending June 30, 2024 2024-001 Special Tests and Provisions – Enrollment Reporting Federal Assistance Listing Number: 84.268, 84.038, and 84.033 Name of Program or Cluster: Student Financial Aid Cluster Agency: U.S. Department of Education Criteria: Princeton Theological Seminary (the “Seminary”) is required to update students’ statuses on the National Student Loans Data System (“NSLDS”) website if they graduate, withdraw or have an increase/decrease in attendance level during the year within 60 days of the date the Seminary becomes aware of the change in enrollment status. Condition: The Seminary did not submit an accurate status change notification to the NSLDS website for two out of eleven students sampled from a total population of 110 students who graduated, withdrew or had an increase/decrease in attendance level during the year. Cause: Management oversight. Effect: Noncompliance with OMB federal grant compliance requirements. Questioned Costs: None. Repeat Finding: Yes. Recommendation: The Seminary should properly follow its policies and procedures over enrollment reporting to ensure that all status changes are submitted to the NSLDS website accurately and within the required timeframe. Views of Responsible Officials: Princeton Theological Seminary’s management acknowledges these two errors and agrees with the requirement to update students’ enrollment status changes as they occur and in a timely manner. The Seminary’s policy mandates reporting every thirty (30) days, and in these two occurrences, that did not happen. We will review all current student files to ensure compliance. Our Corrective Action Plan to prevent further errors includes implementing a monitoring and verification process of the reporting through the National Student Clearinghouse to the National Student Loan Data System (NSLDS). Further, our Registrar’s office will be required to promptly review and resolve any discrepancies noted in the NSLDS or National Student Clearinghouse error reporting.

Finding No. 2024-001 Enrollment reporting Sponsoring Agency: Department of Education Cluster: Student Financial Assistance Award Names: Pell Grant Program and Federal Direct Student Loans Award Number: Not applicable Assistance Listing Title: Federal Pell Grant Program and Federal Direct Student Loans Assistance Listing Numbers: 84.063 and 84.268 Award Year: 2023-2024 Pass-through entity: Not applicable We acknowledge the finding. Two of the three records were processed prior to the start of the effective leave period. Transmission to the NSC occurs at the start of the term, following add/drop. The third record was processed during the student's study away program, whose enrollment extended further in the academic calendar than Amherst. The end of term processing to NSC had just occurred. Amherst College has a set reporting schedule and controls configured with the NSC for enrollment reporting to NSLDS. Exceptions (in the case of a study away schedule that varies from the College schedule) are highly unusual. Jesse Barba, Director of Institutional Research and Registrar Services, will notify the Office of Financial Aid and Office of Student Affairs when the subsequent term reporting to NSC has occurred. We implemented a new control where any exceptions to leave processing following this date will be sent to NSC as a separate file and will be monitored by Nancy Brownfield, Financial Aid Counselor, to confirm the reporting to NSLDS. Nancy Brownfield will confirm the timely update from NSC to NSLDS or will make the update directly to NSLDS. Contact Person: Gail Holt, Dean of Financial Aid (413) 542-2296

Findings and Questioned Costs for Federal Awards: Finding 2024-001: Student Financial Assistance Cluster – Special Tests and Provisions – Enrollment Reporting Name of Contact Person: Alice Herrick, Director of Fiscal Operations; Ryan French, Director of Financial Aid Management’s Views and Corrective Action Plan Root Causes Analysis: Upon internal review, several key factors contributing to this deficiency were identified: a. Clearinghouse Processing Gaps: Enrollment reporting at the Academy is managed through the National Student Clearinghouse (NSC), which transmits enrollment updates to the National Student Loan Data System (NSLDS). A review of discrepancies highlighted cases where: o Student withdrawals were not consistently updated within the mandated timeframe. o In at least one case, a student was initially listed in NSLDS as “Z – No Record Found” on September 21, 2023, suggesting that NSC added the student to the Academy’s roster. The student withdrew after Fall 2023, but no enrollment update was submitted to NSLDS. b. Quality Control Mechanism: o There is currently no established process to cross-check NSC submission data with NSLDS and Student Information System (SIS) records to confirm that all changes were processed correctly. Corrective Measures: To address this deficiency, the Academy will implement the following corrective actions: a. Enhanced Collaboration & Process Review (Owner: FA/IT/Registrar, Deadline: April 30, 2025): o The Financial Aid Office will collaborate with the Registrar’s Office and IT to conduct a thorough review of the NSC reporting process. o IT will analyze report generation to determine if student records that should be included in NSC updates are being omitted due to system logic or timing of data extraction.b. Quality Control Implementation (Owner: FA/IT, Deadline: May 15, 2025): o A monthly QC report will be developed to identify students with the NSLDS status “Z – No Record Found” and verify that their enrollment data has been appropriately updated in NSLDS. o A secondary review of withdrawals, LOAs, and “no-shows” will be completed to confirm their enrollment status changes were transmitted correctly to NSLDS. c. Manual NSLDS Updates for Withdrawals (Owner: FA, Deadline: Immediate): o As a temporary solution, the Financial Aid Office will manually update student enrollment statuses in NSLDS following an R2T4 calculation. o This manual review will act as a safeguard to catch the majority of unreported status changes while a more automated verification process is developed. Future Process Improvements & Next Steps a. Automated Data Integrity Checks (Owner: IT, Deadline: June 30, 2025): o IT will determine whether a custom “NSLDS Status” flag can be implemented in the Academy’s SIS to help identify students whose records do not agree with NSLDS or the NSC report. b. Ongoing Compliance Monitoring (Owner: FA/IT/Registrar, Deadline: July 30, 2025): o Academy staff from the Registrar’s Office, Financial Aid, and IT will meet to discuss and document NSC reporting best practices – Internal Procedures, Operational Workflow, Compliance and QC Measures. o A bi-annual audit of enrollment reporting timeliness will be conducted to ensure continued compliance. Conclusion: Maine Maritime Academy is committed to ensuring compliance with U.S. Department of Education regulations and providing accurate and appropriate financial aid awards to students. The corrective actions outlined in this plan address the deficiencies identified in the Uniform Guidance audit and aim to prevent similar issues in the future. We appreciate the audit findings and remain dedicated to continuous improvement in our financial aid procedures.

Finding: The change in student status for 1 of students tested was not reported to the National Student Loan Data System (NSLDS) timely when the student withdrew at the end of the spring term. Explanation for Finding: The previous registrar created a corrective action plan 6 days before leaving the college and did not pass the information to the correct parties. The previous position of Assistant Director of Academic Data & Records which was listed as in charge of the actions in the Registrar’s plan was cut from the staffing of that office causing a void of all potential personnel to handle the previous plan. Corrective Actions Taken or Planned: The Registrar will run a report on the 15th of the month to verify any students that have exited the institution from the prior two submission periods (last two months) have valid exit dates in the National Student Loan Clearinghouse. The Assistant Registrar will review the work of the Registrar and verify any discrepancies between Coe’s records and those stored in the National Student Clearinghouse for correction. The Registrar will then ensure timely and accurate submission of student records from the Clearinghouse to NSLDS after all the data has been reviewed. Office of the Registrar additional staffing will be trained on this process to ensure this verification policy will be executed even when there are staffing changes in the future. Persons Responsible and Completion Date: Registrar, Assistant Registrar. The actions outlined above has been added to the Withdrawal & Exit Procedure (NSC-NSLDS) as of 10/23/2024

2024-002 Special Tests (Enrollment Reporting) Federal Agency: Student Financial Assistance Cluster - U.S. Department of Education Program Titles and ALN: Federal Pell Grant Program (ALN 84.063) and Federal Direct Student Loans (ALN 84.268) Federal Grant Numbers: E P063P130272 (7/1/2023 – 6/30/2024), P268K130272 (7/1/2023 – 6/30/2024) Contact Person: Robert Fahy, AVP of University Enrollment Services, 848-932-2603 Corrective Action: Related to the student status change which was reported to NSLDS outside of 60 days, the Rutgers Health and University Registrar will continue to provide training and support to University constituents through regular reporting and monthly check-in meetings to reiterate the importance of timely submissions. Related to the effective dates which did not match between the University record, Campus-Level Record and Program-Level Record, the Rutgers Health and University Registrar will continue work with the central Office of Information Technology, University Enrollment Services and Ellucian teams to refine the enrollment reporting process and will provide training to all involved to ensure accurate reporting. Anticipated Completion Date: The corrective action was in place as of March 1, 2025.

2024-001 Eligibility, Reporting (Financial) and Special Tests (Disbursements to or on Behalf of Students) Federal Agency: Student Financial Assistance Cluster - U.S. Department of Education and U.S. Department of Health and Human Services (DHHS), DHHS Health Resources and Services Administration Program Titles and Assistance Listing Numbers (ALN): Federal Supplemental Educational Opportunity Grants (ALN 84.007), Federal Work-Study Program (ALN 84.033), Federal Perkins Loans (ALN 84.038), Federal Pell Grant Program (ALN 84.063), Federal Direct Student Loans (ALN 84.268), Nurse Faculty Loan Program (ALN 93.264), Health Profession Student Loan Program (ALN 93.342), Loans for Disadvantaged Students (ALN 93.342), Nursing Student Loans (ALN 93.364), Scholarships for Health Professions Students from Disadvantaged Backgrounds (ALN 93.925) Federal Grant Numbers: E P007A132602 (7/1/2023 – 6/30/2024), E P033A132602 (7/1/2023 – 6/30/2024), E P038A132602 (7/1/2023 – 6/30/2024), E P063P130272 (7/1/2023 – 6/30/2024), P268K130272 (7/1/2023 – 6/30/2024), E 01HP28821 02 02, E36HP26092, E36HP25751, E26HP25748, E11HP27284 (7/1/2023 – 6/30/2024), 1T08HP393200100 (7/1/2023 – 6/30/2024), 5 T08HP39320 03 00 (7/1/2023 – 6/30/2024) Contact Person: Ellen Law, AVP OIT Enterprise Application Services, 848-445-5064 Corrective Action: Management has documented and implemented system release management practices for the Oracle Student Financial Planning (OSFP) system. All change requests, updates and approvals for the OSFP system are tracked in a project tracking software. There is a dedicated OSFP administrator, segregating duties within the technical team, with the capability of deploying changes to production. A new access role was also implemented which limits the permissions, with only 4 administrators with the advanced privileges. Finally, a preliminary recertification process occurred in October 2023 and October 2024 without formal procedures which remained in development. Formalized procedures, which includes annual training, will be finalized in fiscal year 2025. Anticipated Completion Date: The corrective action for system release management, change management and system access were implemented as of June 30, 2024. The formalized procedures for recertification were developed by October 31, 2024, and the next recertification will be completed by October 31, 2025.

Finding: 2024-003 – Special Tests and Provisions – Return of Title IV Funds Condition: During the testing of the return of Title IV funds, it was noted that on three (3) of five (5) tested calculation of funds to be returned had no documentation to determine if returns were completed timely as the College did not retain the lists of students associated with drawdowns and/or returns and two (2) of five (5) tested had not been returned as of the date of fieldwork which exceeded the required timeframe to return funds. Recommendation: Policies and procedures should be written to provide internal control over the documentation used to complete the drawdowns, including returns, from Department of Education. We recommend the College establish a communication and record retention process that allows for the notification of students withdrawing and a control in place that allows the financial aid department to know the student financial aid was returned to Department of Education within the required timeframe. Views of responsible officials and planned corrective action: Areas of focus will be to put in place written policies and procedures for the Financial Aid office, including the area of disbursements that includes additional controls and documentation of such. Our objectives will be that all Financial Aid staff will be required to maintain documentation of any drawdowns of funds related to student financial aid. We have put in place a shared OneDrive electronic folder with restricted access to provide confidentiality and provide documentation of the shared communication between offices. Documentation of drawdowns and/or returns will be maintained within this folder. Staff will be trained on using the daily generated reports from Poise to monitor students who have withdrawal on their records so that this can be updated and proper calculations done. All financial aid staff will attend training to stay up to date on regulations and changes. Starting in July 2025 the new J1 system will be integrated with JFA (financial aid system). This will create operational efficiencies and reporting capabilities that are not currently available. Less manual transactions will also provide more accurate student reports. Measurable targets will be achieved by documenting the records within the OneDrive shared electronic folder between the Financial Aid office and the Business Office, who handles the return of funds. Daily changes and/or withdrawal of students will be monitored and funds will be returned as required. This will become of a part of the regular duties of staff.

Finding: 2024-002 – Special Tests and Provisions – Payment to Students Condition: During our testing of the financial aid disbursements, it was noted the College is not maintaining records of what students the drawdowns were for, therefore we were unable to determine if the amounts were posted to the student accounts within the required time frame and subsequently were paying out any credit balances created on student accounts. Recommendation: Policies and procedures should be written to provide internal control over the documentation used to complete the drawdowns from the Department of Education. We recommend the College establish a communication and record retention process that allows for the notification of the student financial aid proceeds and a control in place that allows the financial aid department to know the student financial aid was applied to the student’s account timely. Views of responsible officials and planned corrective action: Areas of Focus will be in the documentation of policies and procedures to provide clear expectations of internal control documentation used to complete the drawdowns from the Department of Education and for a process of record retention. Our objective would be to formalize the policies and procedures in the Financial Aid policy manual. The policies and procedures will have shared access between the Financial Aid office who approves the aid, the Business Office who ultimately pulls down from the Department of Education, and with the Cashier who distributes any refunds. A OneDrive electronic folder has been created with restricted access to provide confidentiality and provide documentation of the shared communication between offices. The POISE system generates a listing of students. The list of students will be created for each draw-down that is initiated and will be placed in the shared folder in OneDrive. Draw-downs will not be initiated without a corresponding student list that shows the student account has been credited with the financial aid award. The documentation will be found in the shared OneDrive electronic folder, which has already been implemented. The transfer (interface) of student records into the financial system is being done weekly and documentation is retained of students for which transactions occur.

Condition: Of the 40 students selected for enrollment reporting testing, the University did not properly update the student enrollment information for 6 students accurately. Planned Corrective Action: To ensure accurate and timely reporting of student withdrawals, the Registrar’s Office and the Office of Student Financial Aid have implemented a new process in compliance with 34 CFR 685.309(b) and 34 CFR 668.22:  The Office of Student Financial Aid will generate a list of students who received all failing grades and whose last date of attendance was reported as prior to the end of the term. The report will be shared with the Registrar’s Office.  The Registrar’s Office will then update the student enrollment status to "Withdrawn" in the National Student Clearinghouse database, using the reported last date of attendance as the effective date.  All updates will be submitted within 30 days of determination or included in the next NSLDS reporting cycle, per federal requirements. Staff have received additional training to ensure accurate enrollment status reporting. Additionally, an internal audit process will be implemented to verify that enrollment records are accurately updated each semester. Contact person responsible for corrective action: Carrie Cumming, Registrar Anticipated Completion Date: July 2025

2024-003 – Michigan Reconnect Expansion Refund Calculation Auditor Description of Condition and Effect. Two students in our testing population of forty students had inaccurate calcuations for their Michigan Reconnect Expansion grants. As a result of this condition, the College had an overpayment of $224. Auditor Recommendation. We recommend that the College implement a review process to ensure that any disbursements are being reviewed for accuracy by an independent second individual prior to any disbursement. Corrective Action. The Office of Financial Aid will have the Financial Aid Federal and State Aid coordinator primarily responsible for state awards perform the original calculation using the state approved method. Once completed, a secondary Financial Aid Federal and State Aid coordinator (who has this program as a backup) will perform the calculations. Any differences in the calculations will be reviewed between the two staff members and clarification needed will be brought to the Director of Financial Aid. Once all calculations are performed and verified, they will be added/updated on the student record. Responsible Person. Lexie Seidel and Emmalee Gilaspie, Financial Aid Federal and State Aid Coordinators. Anticipated Completion Date. Spring 2025.

2024-002 – Untimely Reporting of Student Disbursements Auditor Description of Condition and Effect. One student out of forty tested received disbursements that were not reported to the federal government within the required timeframe. As a result of this condition, the College did not fully comply with the requirements to report disbursements within 15 days of disbursing funds. Auditor Recommendation. We recommend that the College implement policies and procedures, including designating an individual to oversee this reporting requirement, to ensure information is submitted to the Common Origination and Disbursement in a timely manner. Corrective Action. During the upload of records to COD, if a file is rejected, the Financial Aid Federal and State Coordinator will work to clear the reject and upload the record again. The process will continue until the record is uploaded successfully. File uploads are occurring weekly. Responsible Person. Lexie Seidel and Emmalee Gilaspie, Financial Aid Federal and State Aid Coordinators. Anticipated Completion Date. Spring 2025.

Corrective Action Plan Xavier complies with the loan disbursement notification rules. During the audit we learned that, while our system was sending the emails to each student with a loan disbursement, our process for copying each individual email to xufinaid was not functioning. Further, the notification report was being overwritten daily, causing us to lose the audit trail for these notifications. We have implemented two steps to be able to document each individual email. 1. The xufinaid@xavier.edu email address is copied on every disbursement notification and each notification email is delivered into the xufinaid inbox in Outlook. Every Wednesday those emails are moved by financial aid personnel into a folder in Outlook where they remain stored. This weekly review allows personnel to know in a timely manner if there are issues with the email delivery process. 2. A log file which saves a list of the disbursement notification emails is saved on a daily basis. It includes the content of each email.

CORRECTIVE ACTION PLAN U.S. Department Education Hobart and William Smith Colleges respectfully submit the following corrective action plan for the year ended June 30, 2024 Name and address of independent public accounting firm: Bonadio & Co., LLP 171 Sully's Trail Pittsford, NY 14534 Audit period: July 1, 2023 - June 30, 2024 The findings from the 2024 schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. FINDINGS AND QUESTIONED COSTS - MAJOR FEDERAL AWARD PROGRAMS SIGNIFICANT DEFICIENCY 2024-001 Timely Return of Title IV Funds Recommendation: We recommend that the Colleges assess and address staffing levels in the Student Financial Aid Department to ensure adequate resources are available to process Title IV fund returns timely. Additionally, the Colleges should develop policies and procedures to ensure timely processing of returns within the required 45-day period. Corrective Action Plan: Additional staffing has been put in place to ensure that we have enough resources to complete title IV refund processing in a timely fashion. A new assistant director (hired in November 2024) will be monitoring the notifications that students have withdrawn and notify the director when title IV refunds are required. The new assistant director is also currently being trained in title IV refund processing and has experience with title IV refunding prior to being hired. The associate director (hired in July 2024) is also an expert in the return of federal funding through EDCONNECT and perform a supportive role in this process. Lisa Hoskey, Director of Financial Aid, is responsible for implementing this plan and can be reached at Hoskey@hws.edu.

Finding 2024-003 Errors in Reporting for NSLDS Condition: Northern Illinois University (the University) did not properly report enrollment changes for certain students who received federal student aid to the National Student Loan Data System (NSLDS) and the internal controls in place did not identify the errors. Corrective Action Plan: University has taken the following corrective actions that will eliminate all material exceptions: 1) The University will correct the software issue which caused some students with the new withdrawal grade code to not have a withdrawal status calculated correctly at the campus level. 2) The University will provide additional training and guidance to address the misinterpretation of withdrawal status effective date reporting which caused an error at the program level. Individual(s) Responsible for Corrective Action: Registration and Records Staff Anticipated Completion Date: June 30, 2025