Corrective Action Plans

Name of Responsible Individual: Mr. Brian K. Blackburn Corrective Action: As a result of Audit Finding 2023-001 the University had implemented a weekly COD Maintenance Files for Direct Loans and Pell Grants. The 2024-001 Finding is a result of an oversight in the setup of the one student record that caused the information to not be picked up and included in the weekly file. The problem has now been identified and corrected to ensure that such an oversight does not reoccur. Additionally, the University has implemented a new policy in terms of creating and updating student records. Anticipated Completion Date: December 9, 2024

2024-002 – Return of Title IV Calculation. Auditor Description of Condition and Effect. A break of at least five consecutive days was not excluded from the reported enrollment period for the Winter 2024 semester, which resulted in the calculation being incorrect for all students who had returns in the Winter 2024 semester. As a result of this condition, Return of Title IV calculations were incorrect for five students for the Winter 2024 semester, resulting in $66.52 in excess funds returned to the U.S. Department of Education. It is our understanding that on August 14, 2024, the College repaid the five students affected by this calculation error. Auditor Recommendation. We recommend that the College implement a review process to ensure the number of enrollment days used in the Return of Title IV calculations is accurate and that the R2T4 calculation is reviewed by a second individual. Corrective Action. Upon discovery of the Return of Title IV Calculation error, the College went through and made corrections to all student accounts affected. To prevent a similar problem from arising in the future, the College has developed a review process where the Director of Financial Aid will review break day regulations in the FSA handbook and verify that the Ellucian Colleague annual set-up has accurate break days. The Director of Financial Aid will also verify accuracy as calculations are processed for students. Responsible Party. Jean Zimmerman, Director of Financial Aid. Anticipated Completion Date. August 14, 2024.

2024-001 – Timeliness of Status Change Reporting. Auditor Description of Condition and Effect. During our testing of thirteen students with status changes, we noted six instances of late reporting of a student's status changes. Three of these instances were winter term graduates whose status change was reported one day late. The other three of these instances were winter term graduates whose status changes had not been reported as of the date of our audit fieldwork, due to a technical glitch in the College's reporting system. Therefore, the NSLDS system is not updated with the student information timely which could lead to a student's grace period being shortened. Auditor Recommendation. We recommend that the College review its reporting procedures to ensure that students' status changes are accurately and timely reported to NSLDS as required by regulators. Corrective Action. The Director of Financial Aid will review the reporting procedures to ensure that students' status changes are accurately and timely reported to NSLDS. The Director of Financial Aid will check NSLDS to ensure timely reporting. Responsible Party. Jean Zimmerman, Director of Financial Aid, and Amy Young, Registrar. Anticipated Completion Date. First Fall 2024 NSC reporting.

The Registrar's Office has performed a further review of its policies and procedures to continue to ensure timely, accurate, and complete submission of enrollment records. The Registrar’s Office has updated its procedures to include response schedules with internal control mechanisms for monitoring compliance with the seven-day response requirement to the Provost’s Office and processing requests for additional assistance as necessary. The updated response schedule includes a goal to respond to error reports within four days of receipt, with final submission no later than six days following notice of the error report, unless the Provost has been notified that enrollment updates have been suspended by National Student Clearinghouse while files are being processed, in which case the Registrar’s Office will monitor and document the processing status until the suspension has been raised. Any response which will exceed six days requires written notice to the Provost’s Office with a plan to complete the required enrollment updates by 5:00pm ET on the seventh day, and any request for additional assistance or resources necessary to do so. Members of the Registrar’s Office also participated in additional training through National Student Clearinghouse with respect to enrollment reporting and error report codes related to enrollment effective dates. Training related to enrollment reporting will be scheduled at least annually through the Registrar’s Office. Finding 2022-005 of the Final Audit Determination (FAD) found that student enrollment status effective dates required further updates following the initial data corrections which were completed in September 2023. In addition to review of its policies and procedures and training, the Registrar’s Office engaged with its third-party servicer for enrollment reporting to review the data reporting systems and integration, as well as the data and information reported by the servicer to the National Student Loan Data System (NSLDS), during its response to Finding 2022-005. In response to the required action for this finding, the University requested an extension and the extension was granted to complete the required action with the U.S. Department of Education Office of Federal Student Aid (FSA). FSA requested regular status reporting and the University complied with the reporting requirement. The status reporting included updates as to the progress of the review and the University’s methods for reviewing and updating the enrollment reports so that FSA could ensure timely and accurate progress was being achieved throughout the University’s completion of the required action. The University completed the required corrections within the extension timeline of September 30, 2024.

November 18, 2024 Response to Finding 2024-002 Special Tests and Provisions - Enrollment Reporting Significant Deficiency in Internal Control over Compliance Otis College of Art and Design agrees with the finding. Responsible Office and Individual The Executive Director of Financial Aid and The One Stop, Michaela Matsumoto (mmatsumoto@otis.edu) and Registrar Nicole Raef (nraef@otis.edu) are the responsible individuals for implementation of the corrective action plan. Corrective Action Plan Upon review of the finding, Financial Aid administration met with the Registrar's staff to create a new procedure whereby immediate reporting of withdrawals are made directly to NSLDS in addition to the regularly scheduled monthly reports to NSLDS through the National Student Clearinghouse (NSC). This immediate reporting should elimnate any timing issues with the monthly reports through NSC. In addition, a joint effort to streamline the routing of withdrawal forms to the appropriate departments for faster processing is underway. This is reprocessing of the withdrawal forms will be implemented in the next 120 days.

November 18, 2024 Finding 2024-001 Special Tests and Provisions - Return of Title IV: Significant Deficiency in Internal Control over Compliance Otis College of Art and Design agrees with the Return of Title IV calculation finding. This error was noticed by new financial aid staff/administration hired in late spring of 2024 after the prior administration had completed all return of Title IV calculations except for the unofficial withdrawals. The new staff noticed the error and made the adjustment going forward starting with the unofficial withdrawals for spring 2024. This error only affected the days of Spring Break. No other semesters had an error in dates used in the Return of the Title IV calculations. Responsible Office and Individual The Executive Director of Financial Aid and The One Stop, Michaela Matsumoto (mmatsumoto@otis.edu) and Registrar Nicole Raef (nraef@otis.edu) are the responsible individuals for implementation of the corrective action plan. Corrective Action Plan Financial Aid Management met with the Registrar's Office to ensure all future semester set up dates are correct and have been reviewed. This improvement of processes to ensure a double check of the Return of Title IV calendar setup has been implemented for 2025-2026.

Recommendation: We recommend the University review their current policies and procedures around credit balances and ensure the processes in place are sufficient to ensure student credit balances due to federal funds are refunded within 14 days. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Continue reviewing student credit balances on a weekly basis ensuring Title IV refund checks are processed within the 14 calendar days. Additionally, the Finace team will review current procedure and draft a formal policy and procedure for Student Credit Balances. Name(s) of the contact person(s) responsible for corrective action: Michael Werner- VP of Finance Planned completion date for corrective action plan: End of Calendar year 2024

Recommendation: We recommend that the University implement a formal review process as it relates to withdrawn students to ensure R2T4 calculations are being performed accurately and timely. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: ACU has created 1 additional financial aid advisor position. This position will assist the financial aid team. The Financial aid office will review the withdrawn requests sent to the financial aid inbox on a weekly basis. The withdrawn report will be worked at the end of every week to ensure all withdrawn students have been reviewed to date and all R2T4 calculations have been completed. The Director of Financial Aid will create formal training processes and will conduct training with the financial aid advisors. The Director of Financial Aid will conduct periodic reviews to ensure ongoing compliance with Title IV regulations. Name(s) of the contact person(s) responsible for corrective action: Angel Faast- Director of Financial Aid Planned completion date for corrective action plan: 01/31/2025

Recommendation: We recommend the University 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: The AVP of Institutional Effectiveness will create a secure digital tracking spreadsheet that will contain file submission tracking and error resolution tracking. A digital signature protocol will be implemented that will require a sign off on submission from ADIR and AVP will verify and sign off within 48 hours of submission. A weekly check-in will be conducted on Monday that will review weekly reports, upcoming submissions, error resolution status updates and documentation for meeting outcomes. Tracking deadlines will be implemented for error resolution. ADIR must acknowledge NSC error notifications within 1 business day and error resolution must begin within 2 business days. The first attempt must be completed within 5 business days and secondary error notifications must be addressed within 3 business days. AVP IE will conduct a monthly audit and a quarterly assessment to ensure ongoing compliance with Title IV regulations. Name(s) of the contact person(s) responsible for corrective action: Jeff Phillips-AVP of Institutional Effectiveness Planned completion date for corrective action plan: End of Calendar year 2024

Beginning in Spring 2025, the Financial Aid Office will now run the ARGOs Report (Financial Aid Awards by Student) weekly prior to disbursements to find students who applied late in the academic year and need aid to disburse for the previous semester. The financial aid office will no longer need to rely on the processor to notify them when they are packaging aid.

After consulting with other Texas higher education institutions, we have identified that the initial setup of our NSC reports should have included a set of rules. We have submitted an Actionline request to Ellucian Colleague requesting their assistance. We are doing everything to ensure the Fall 2024 report, and subsequent reports, accurately report enrollment statuses.

Criteria: Special Tests and Provisions - Enrollment Reporting (34 CFR 690.93(b)(2); 34 CFR 682.61 O; 34 CFR 685.309). Institutions are required to report enrollment information. Reporting (34 CFR 690.93(b)(2); 34 CFR 682.610; 34 CFR 685.309). Institutions are required to report enrollment information. Condition: The University did not report 3 student's status changes timely, the University reported the incorrect enrollment effective date for 3 students in the campus level records, the University reported the incorrect enrollment effective date for 4 students in the program level records, and the University recorded the incorrect enrollment status for 2 students in both the campus and program level records. Planned Corrective Actions: - LeTourneau is in the process of implementing a new student information system. As part of the implementation, all processes within the Registrar and Student Financial Services are being reviewed. These deficiencies will be addressed as part of that initiative. Responsible Official: Danielle Jeffress, University Registrar Estimated Completion Date: December 31, 2025

Views of the responsible official and planned corrective actions: Cisco College has updated the process for the NSLDS reporting. The Director of Institutional Effectiveness & Planning will be the reporting official and the Dean of Enrollment Services will be the back-up person for the NSLDS reporting. Both positions have been trained and will ensure that the reporting will continue if there is ever another gap in replacing an open position.

Condition: The University did not return Title IV funds within 45 days of the date of determination of withdrawal for four students. Views of Responsible Officials and Planned Corrective Action: Beginning in the Fall 2024 semester, Student Account Services and University Billing (SASUB) implemented a dedicated R2T4 SharePoint site to enhance the tracking and management of withdrawn students as identified. The site includes dynamic lists that log students requiring a return of Title IV funds as they are identified. Each entry records the student’s date of determination, and the corresponding 45-day return deadline. This centralized platform allows authorized users to easily view pending returns, associated deadlines, and the completion dates for each case. The system improves the accuracy of Title IV fund return tracking, enhances accountability, and fosters greater transparency and communication among university stakeholders. Key personnel and leadership from SASUB and the Office of Scholarships and Financial Aid have access to the SharePoint site and conduct regular reviews to ensure compliance and operational efficiency. Contact person responsible for corrective action: Director of Student Account Services and University Billing Anticipated Completion Date: 8/26/2024

2024-001: Reporting This finding is the result of human error when completing the Fiscal Operations Report and Application to Participate (FISAP). An extra digit was added to the tuition/fees charged, changing the tuition and fees charged from $6,880,369 to $68,880,369. This was missed in the review of the FISAP prior to submission. Corrective Action: The Financial Aid Office took great care in reviewing the 2023-2024 (for 2025-2026) FISAP for accuracy. Additionally, the amount requested for SEOG and FWS is the exact same as requested on the 2022-2023 (for 2024-2025) FISAP, rather than the inflated fair share. The Financial Aid Office will request up to the fair share on the 2024-2025 (for 2026-2027) FISAP. This issue has been successfully addressed. Anticipated Date of Correction: 9/30/2024 Contact Person: Shanna Vargas, Director of Financial Aid

2024-002: Reporting This finding is a result of transferring Primary Data Point Administration from Amy Murphy to Shanna Vargas. Part of this issue reflected SAIG/CPS/COD/NSLDS access from being set up correctly and resulted in many hours of contact and meetings with SAIG professionals to correct. Corrective Action: The Financial Aid Office has worked with SAIG professionals to correct this issue. The Financial Aid Office has developed a schedule and process to complete monthly direct loan reconciliation, as well as ensuring other members have access to complete this should the PDPA’s access not be available. Anticipated Date of Correction: Immediately Contact Person: Shanna Vargas, Director of Financial Aid

2024-005: Enrollment Reporting Unofficially withdrawn students (students who failed to earn credit during the term) are reviewed after the end of the semester, and R2T4 is calculated, where required. However, there was not a process in place for the Registrar to update the Enrollment Reporting as a result of the review process. Corrective Action: As part of the process of reviewing these students and performing the R2T4 calculation, the Financial Aid Office will send a report of unofficially withdrawn students to the Registrar to ensure that enrollment reporting is appropriately updated. Anticipated Date of Correction: Immediately Contact People: Shanna Vargas, Director of Financial Aid, and Kayla Miller, Registrar

2024-004: Return of Title IV Funds This student’s late calculation was due to the failure to review withdrawal reports during the changeover in director responsibilities. All students that fail to earn any credit during the semester are reviewed at the end of each semester. This student was found at that point, and the calculation was completed. Corrective Action: The withdrawal report is reviewed at minimum each week by the Financial Aid Office and R2T4s are calculated timely. This issue has been resolved. Anticipated Date of Correction: Immediately Contact Person: Shanna Vargas, Director of Financial Aid

2024-003: Cash Management This finding is the result of transferring Primary Data Point Administration from Amy Murphy to Shanna Vargas. Corrective Action: The Financial Aid Office has developed a schedule and process to complete monthly direct loan reconciliation, as well as ensuring other members have access to complete this should the PDPA’s access not be available. Anticipated Date of Correction: 8/19/2024 Contact Person: Shanna Vargas, Director of Financial Aid

Need Analysis Planned Corrective Action: Additional training was provided to the appropriate staff to identify and award needbased funds within regulatory guidelines. Person Responsible for Corrective Action Plan: Bryan Taylor, Associate Director of SFS Processing Anticipated Date of Completion: December 15, 2024

Incorrect Return of Title IV Funds Calculations Planned Corrective Action: The Student Financial Services Office will train additional staff on R2T4 procedures and then conduct secondary reviews to validate the correctness of the R2T4 calculations and return amounts. Person Responsible for Corrective Action Plan: Bryan Taylor, Associate Director of SFS Processing Anticipated Date of Completion: July 1, 2025

The disbursement process of such refunds was transferred to a new team within the Finance/Treasury branch. The team size was increased from 2 to 4 members. Members added to this team have relevant previous experience in student accounts. The additional resources as well as their experience and knowledge should ensure that funds are returned in a timely manner that complies with program requirements.

FINDINGS — FEDERAL AWARD PROGRAMS AUDITS DEPARTMENT OF EDUCATION 2024-001 Student Financial Aid – CFDA No. 84.007, 84.268, 84.063, 84.033 Recommendation: 1) We recommend the College reevaluate its procedures and review policies surrounding reporting status changes to NSLDS to ensure the enrollment effective date reported to NSLDS is aligning with the College’s last date of attendance. 2) We recommend the College reevaluate its procedures and review policies surrounding reporting program enrollment effective dates to NSLDS. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Corrective Action Response Regarding Graduation Date Discrepancy 1. Immediate Correction of Records: • Verified and corrected all affected student records to reflect accurate graduation dates. • Graduation dates for graduates from Fall 2023 to Summer 2024 will be updated. This action ensures alignment between the student information system, official transcripts, and graduation rosters. 2. Process and Policy Updates: • Internal policies will be revised to provide clear guidance on assigning and verifying graduation dates. Corrective Action Response Regarding Enrollment Transmission Reporting Timeline Beyond the 60-Day Requirement 1. Policy and Procedure Enhancements: • Updated internal policies to require enrollment data transmission at least every 20 days, well ahead of the 60-day federal requirement to ensure receipt by the National Student Loan Data System (NSLDS) in a timely manner. • Staff will periodically request a transmission audit from the Clearinghouse verifying that the institution’s enrollment data has been forwarded to the National Student Loan Data System (NSLDS). Name of the contact person responsible for corrective action: Dayne Chance, Director of Financial Aid at 908-709-7089 If the Department of Education has questions regarding this plan, please contact the appropriate individual outlined above.

Finding 2024-001 – Special Tests and Provisions – Enrollment Reporting (Noncompliance and Significant Deficiency) Identification of the Federal Program - Student Financial Aid Cluster - Assistance Listing Nos. 84.007, 84.033, 84.038, 84.063, and 84.268 Criteria - Institutions are required to report enrollment information under the Pell grant and the Direct loan program via the National Student Loan Data System (NSLDS). The administration of the Title IV programs depends heavily on the accuracy and timeliness of the enrollment information reported by institutions. Institutions must review, update, and verify student enrollment statuses, program information, and effective dates reported to NSLDS. Institutions are responsible for accurate reporting. According to 34 CFR 685.309(2), the University is required to notify the Department of Education via the NSLDS if a “student has ceased to be enrolled on at least a half-time basis for the period for which the loan was intended”. Changes to status are required to be reported within 30 days of becoming aware of the status change, or with the next schedule transmission of statuses if the scheduled transmission is within 60 days. Condition - A sample of 40 students were selected from the population of all students who received federal student financial aid during the year ended May 31, 2024. We obtained the student records and tested compliance with federal regulations for the specific loans and grants. For 13 out of the 40 students selected for Enrollment Reporting testing, the status change to withdrawn was not reported within the 60 day reporting window after the status change was effective. For 7 out of the 40 students selected for Enrollment Reporting testing, the status change was not reported to NSLDS. Cause - The University’s processes of internal controls for reporting enrollment information and to timely report student status changes to NSLDS were not adequate. Effect - Enrollment reporting to NSLDS did not include accurate information. Identification of Repeat Finding – Repeat finding of prior year finding 2023-001. Student status changes were not reported to NSLDS within the required timeframe. Recommendation - We recommend the University revise its processes for reporting student status changes to NSLDS. The University should implement a process to review, update, and verify student enrollment statuses that appear on the Enrollment Reporting roster files. We also recommend that management implement controls to ensure reported changes are timely and correctly reported to the NSLDS. Views of Responsible Officials - Management agrees with the finding. Out of the 20 exceptions included in this finding, 16 were properly and timely reported by the University to the third-party service provider. The University is currently working with their third-party service provider to identify the root cause of the untimely reporting. Corrective Action Plan for Finding 2024-001 - The University provided additional training and monitoring to the employees involved in this process. Furthermore, the University engaged a former employee on a contractual basis to assist with the reporting process. The contract employee has significant experience in reporting information to the University’s third-party agent, National Student Clearinghouse (NSC), and to the National Student Loan Data System (NSLDS). The University is actively working with the Audit Resources team at NSC to revise our reporting processes and develop a reporting schedule that will more closely align with the University's calendar and eliminate the root cause of the data errors.

Corrective Action Plan Enrollment information was not submitted within the required timeframe by the University. Personnel Responsible for Corrective Action: Dena Norris, Associate Vice Chancellor of Student Financial Services, and Tara Dettmer, Director of Financial Aid – Fiscal Operations Anticipated Completion Date: Corrective action plan will be implemented by June 30, 2025. Views of Responsible Officials and Planned Corrective Action Plan: Metropolitan Community College (MCC) will begin a new monitoring process for enrollment reporting to ensure compliance and timely reporting of all students. Enrollment status changes are reported every month to the National Student Clearinghouse (NSC), MCC will make a random selection of 10-15 students each month to verify data was correctly transmitted to NSC. A secondary check of these students will be done to ensure the data is also transmitted to the National Student Loan Data System (NSLDS). MCC will also ensure error reports and other data issues are resolved in a timely manner to ensure reporting of students is completed within the regulatory timeframe.