Corrective Action Plans

Auditor Description of Condition and Effect. When funds were returned through COD for one student, they were mistakenly applied to the Fall 2022 semester instead of being applied to the Spring semester, the semester in which the aid was earned. As a result of this condition, the College corrected their mistake by removing the refund from the Fall 2022 semester and applying it to the Spring semester on June 12, 2023. Due to the Covid Forbearance ruling, the unsubsidized loan did not accrue interest which made the correction more straight forward. Auditor Recommendation. We recommend that the College implement procedures to ensure that the return to Title IV calculation and distribution is being reviewed by a second individual. Corrective Action. The College has performed the necessary steps to correct the error and will develop a process to ensure that a second individual is reviewing the work performed. Responsible Person. Maryann Decaire, Director of Financial Aid. Anticipated Completion Date. June 30, 2024.

Finding Number 2023-004 – Student Financial Assistance (SFA) Cluster – Various ALN Numbers – Enrollment Reporting Management’s Response The UPR concurs with this finding. In the previous three years, cases have been reported in which the change in the student's status was never reported, the change in status was incorrectly reported, or the change in status was reported after 60 days. For FY2023, the auditors only pointed out that the UPR reported the change in the student's status over 60 days. This is evidence that the measures implemented before are achieving their objective. The UPR has implemented provisions to prevent the change in status from ever being reported or the incorrect status from being reported. However, we still must comply 100% to ensure that changes in student status are reported on time. For this, the UPR will issue written instructions and will have meetings with the Deans of Academic Affairs of the eleven (11) campuses to ensure they guide their staff to understand the importance of complying with the academic calendars and the implications of not doing so; including: (a) the importance of submitting grades on time (b) the importance of Bachelor or Master’s degrees being conferred on time. For the four cases of UPR-Bayamon campus, the registrar has evidence that they were reported to the National Student Clearinghouse (NSC) on June 30, 2023. UPR-Bayamon campus will contact the NSC to determine why these cases were reported on August 30, 2023, and will implement the necessary actions to prevent this from happening again. Responsible Person/Office: Executive Vice President for Academic Affairs and Research. Timeline: June 2024, so we will notice their effect during fiscal year 2024-2025.

Finding Number 2023-003 – Student Financial Aid Cluster – Various ALN Numbers-Return of Title IV Funds (R2T4) Management’s Response The UPR concurs with this finding. UPR-Río Piedras campus did not return the funds to the federal government within 45 days from the official date of the student's total withdrawal because there was a delay on the part of the Registrar's Office in submitting the report of students who requested withdrawal to the Fiscal Office. From now on, RRP will follow the following procedures: 1. The Registrar’s Office will process immediately the requests for withdrawal submitted by students. The Technology Division will produce a report about such students. 2. The Technology Division will send the report to the Financial Aid Office and the Fiscal Office. 3. The Financial Aid Office will identify which students in the report received PELL or Direct Loan payments. 4. The Fiscal Office will prepare the R2T4 and will determine the amount to be returned to the federal government, if any. 5. The Finance Office will return the overpayments to the federal government on the G5 platform. 6. The Finance Office will establish a weekly protocol to notify and monitor the offices involved in this process (Registrar, Financial Aid, and Fiscal offices) through institutional mail. Also, UPR-Río Piedras will coordinate a meeting with the offices involved in this process to evaluate the situation and identify possible improvements to make it more effective. Responsible Person or Office: Registrar, Fiscal, and Financial Aid Offices at UPR-Río Piedras. Timeline: 2023-2024, so we will notice their effect starting in April 2024.

At the beginning of each semester, the Registrar will run a No Show report and share the report with the Financial Aid Office to show which students did not return for the current semester.

We’ve updated processes to include documentation of risks associated with protecting customer data. Risk assessment documents and methodologies will be reviewed and updated in consultation with the Vice-President of Administration & Finance and the Director of Technology Services.

The information that we listed initially only included the Work Study portion. However, the number of students was correct. Going forward, we will ensure that both portions are listed correctly on the FISAP.

Although we checked and double checked the information as shown in COD under the R2T4 section, there still appears to be an issue with regards to COD correctly showing Vacation time in COD. Going forward, we are actually printing out the R2T4's to ensure that the correct number of days are listed on the R2T4 sheet and maintaining hard copies in addition to saving online.

Our Correction Plan will be to check monthly that loan disbursements correctly match with COD. While progress was definitely made from the prior year, it is important that every student disbursement is correctly shown by the Business Office.

The largest issue regarding student working when they are in class is communication. Faculty are supposed to alert the work office when they are cancelling class. However, they are only alerting the Provost about cancelling classes and they are keeping a calendar of cancelled classes. We will continue to remind faculty that they must let the Work Office know directly when they cancel class. All managers have been informed that their workers cannot work during a class period unless the professor has emailed the work office. We are looking at new payroll vendors who may be able develop a system for student schedules and the payroll system to help integrate data so that we can access class schedules within the Payroll system and blackout periods where they cannot work.

Finding Number 2023-002 – Enrollment Reporting, Significant Deficiency in Internal Control over Compliance. Contact Person(s): Shanell Tilo, Financial Aid Officer Dr. Emilia Le’i, Dean of Student Services Dr. Letupu Moananu, Vice President of Academics, Community, and Student Affairs Explanation and specific reasons for disagreement with the audit finding or that corrective action is not required (if applicable): No disagreement. Corrective actions taken/planned: The Financial Aid Coordinator (control #1, with FA Officer as alternate) has been assigned to transmit the bi-monthly Enrollment Report roster. The control #1 reviews the roster and performs data entry, status updates, and submission by the 15th of the reporting month. On the 1st of every nonreporting month, control #1 will review and report any enrollment status changes before the 15th. Financial Aid Manager (control #2) will review the status updates on NSLDS before and after every submission. Identified errors will be documented and returned to control #1 for correction and resubmission. The policy will ensure all student changes in status are identified, updated, and submitted timely and accurately. ASCC FAO participates in Federal Student Aid (FSA) training and conferences regarding NSLDS updates, changes, and functionality. FAO also subscribes to the Weekly Knowledge Center Updates from FSA Partner Connect. ASCC is a member of the National Association of Student Financial Aid Administrators (NASFAA). All of these resources provide access and education in the process of enrollment reporting and compliance, as well as the responsibilities and consequences of inaccurate reporting. Graduates: Students who graduate will be updated into NSLDS within one week after graduation. Official / Unofficial Withdrawal: All Withdrawals must then be reported to NSLDS within 45 days. On the 1st of every nonreporting month, control #1 will review and report any enrollment status changes before the 15th. Financial Aid Manager (control #2) will review the status updates on NSLDS before and after every submission. Identified errors will be documented and returned to control #1 for correction and resubmission. The policy will ensure all student changes in status are identified, updated, and submitted timely and accurately. ASCC FAO participates in Federal Student Aid (FSA) training and conferences regarding NSLDS updates, changes, and functionality. FAO also subscribes to the Weekly Knowledge Center Updates from FSA Partner Connect. ASCC is a member of the National Association of Student Financial Aid Administrators (NASFAA). All of these resources provide access and education in the process of enrollment reporting and compliance, as well as the responsibilities and consequences of inaccurate reporting. Graduates: Students who graduate will be updated into NSLDS within one week after graduation. Official / Unofficial Withdrawal: All Withdrawals must then be reported to NSLDS within 45 days.

Cluster name: Student Financial Assistance Cluster Assistance Listings numbers and names: 84.007 Federal Supplemental Educational Opportunity Grants 84.033 Federal Work-Study Program 84.063 Federal Pell Grant Program 84.268 Federal Direct Student Loans Luisa Ott Anticipated completion date: June 30, 2024 The District agrees with the finding. After reviewing the student in the finding, the District reprocessed the Return of Title IV calculation. The one student record was updated and resulted in an amount of $8 to be returned to the student by offsetting their current balance with the District. The District will fund the reimbursement with institutional funds. During the fiscal year ending June 30, 2023, the District has created supporting automated processes to identify potential Return to Title IV accounts. The District has started the implementation project of using the student information system to automatically calculate student Return to Title IV calculations. The District will continue to strengthen procedures surrounding Return to Title IV compliance requirements.

FINDING 2023-001 Finding Subject: Student Financial Assistance Cluster - Special Tests and Provisions - Enrollment Reporting Summary of Finding: Although the University had policies and procedures in place over Enrollment Reporting, a process to ensure that system defects did not impact reporting requirements was not implemented. As such, for students who had a reduction or increase in enrollment status during the Spring 2023 term, errors in reporting campus level and program level data went undetected. Students with a status of withdrawn or with no changes during the period were accurately reported. It was recommended that the University's management establish a system of internal controls that includes a review of Banner job processes to verify source data is correctly populated so as to ensure that all data elements required to be submitted to NSLDS are accurate. Contact Person Responsible for Corrective Action: Angel Nelson, Associate Registrar Contact Phone Number and Email Address: (812) 465-1626; angel.nelson@usi.edu Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: While the University of Southern Indiana had internal controls in place to verify the accuracy of our enrollment reporting data, these controls were not effective in discovering system errors. In order to correct this deficiency, the following corrective actions have been implemented: 1. The system defect within our student information system has been corrected by our vendor. 2. All student records affected by the system defect have been corrected in the National Student Loan Clearinghouse database. 3. Beginning in January 2024, the University increased the number of records selected for review from the enrollment file, making sure to review some students who had a reduction or increase in enrollment status, as well as some who had withdrawn. 4. Associate Registrar has subscribed to the e-community for our software vendor to monitor for future system errors. Anticipated Completion Date: The system defect was corrected with the installation of a system patch that was installed on June 4, 2023. All other steps in the corrective action plan have been completed as of January 26, 2024.

Finding No. 2023–002 – Enrollment Reporting Name of Contact Person: Dr. Kendra Ortiz, Registrar Corrective Action Plan UCB recognizes its obligation to report enrollment data to the National Student Loan Data System (NSLDS) at least every 60 days. The Registrar's Office reports enrollment data to NSLDS on a monthly basis. To ensure that the University comply with the 60-day requirement, we have established an additional notification procedure. The Financial Aid Office will forward report of all Title IV student recipients classified as withdrawn to the Registrar's Office, this process consists of a reconciliation of the data. The Registrar's office will report the enrollment change of this cases to NSLDS within 60 days required. Anticipated completion date: Immediately.

Finding No. 2023–001 – Disbursement to or on behalf students Title IV, HEA credit balances Name of Contact Person: Dr. Ismael A. Velez de la Rosa Corrective Action Plan The University affirms its understanding of its obligation to submit disbursement according to the 34 CFR 668.164(h)(2)(i) A title IV, a HEA credit balance must be paid directly to the student or parent as soon as possible, but no later than fourteen (14) days after the balance occurred, if the credit balance occurred after the first day of class of a payment period. Due to an error in the system, within institutional officials in charge of managing this process, one disbursement was not submitted on a timely basis. UCB will reinforce their policies and procedures to satisfy all applicable requirements specified in 668.164 (h) and due a doble verification of the process to make sure every student no later than fourteen (14) days after the balance occurred. As of the date of the auditors’ report, the University request all of the institution’s officials to work in the school premises and the communication between officials has been improve, making easier the tracking of the disbursements on a timely basis to students. Anticipated completion date: Immediately.

Student Financial Aid Cluster – Assistance Listing No. 84.063 & 84.268 Recommendation: We recommend that the College design and implement controls to ensure reporting to NSLDS are designed to capture all enrolled students and programs offered by the District. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The District worked with NSC to resolve the errors surrounding mismatched CIP codes, resulting in the enrollment report being finalized in late 2022. The College will work with their Records Department to explore accommodations surrounding future term requirements. Name(s) of the contact person(s) responsible for corrective action: Laurie Grigg, Chief Financial Officer Planned completion date for corrective action plan: June 30, 2024

Planned Corrective Action: The Seminary has taken action on many security standards outlined in the Gramm-Leach-Bliley Act. However, the Seminary has not created a written comprehensive information security plan. The Seminary will develop this plan, that will incorporate many of the items that we have already put in place. However, we realize with out a written plan that we are no incompliance with the Act. The Seminary will put the plan in writing. Person Responsible for Corrective Action Plan: Melissa Trayhan – Manager of Information Technology Anticipated Completion Date June 2024

FISAP Reporting Recommendation: We recommend the College evaluate its procedures for reviewing the FISAP and implement changes to validate the information on the FISAP. Views of Responsible Officials and Planned Corrective Actions: This number comes directly from an eligible aid applicant’s report. The College has implemented additional oversight procedures for the control to double check figures in future FISAP filings prior to submission. Anticipated Completion Date: September 30, 2023

Pell and SEOG Awarding Errors Recommendation: We recommend the College evaluate its procedures for reviewing financial assistance and implement changes to validate the awarding of financial assistance. Views of Responsible Officials and Planned Corrective Actions: When the Department of Education changes Pell Grant eligibility parameters, there is a process that is run to update Pella Grant eligibility in the Datatel processing system. However, when new eligibility parameters increase the number of eligible students due to increasing the estimated family contribution (EFC) eligibility cut-off, there is a separate process that must be run to catch these newly eligible students. This was the scenario in 2022-2023. Six students that were not originally eligible for Pell Grant became eligible. Similar circumstances also occurred in 23-24 and the process was run ensuring all eligible students are being awarded. The additional process has been added to the financial aid calendar to ensure this will not happen in the future. Anticipated Completion Date: September 30, 2023

Return of Title IV Funds (R2T4) Calculation Errors Recommendation: We recommend the College evaluate its procedures for reviewing R2T4 calculations and implement changes to validate the inputs to the calculation. Views of Responsible Officials and Planned Corrective Actions: The finding is due to Central College incorrectly inputting the number of break days in the school calendar profile in the R2T4 section of the common origination and disbursement website. When doing annual set-up, the financial aid office will now be confirming correct dates with Central’s controller. The school calendar profiles have already been issued to Forge Financial & Management Consulting for the 23-24 academic year. Anticipated Completion Date: September 30, 2023

DCF has updated the eligibility determination procedure document and referenced checklists to ensure that there are additional reviews of the manual data entry and its processing in the data system (SSMIS). There is a process in place by which any cases where manual data entry causes erroneous IV-E draws, the Department will make changes in the data system and return IV-E funds erroneously claimed within one quarter of the mistake being identified. Scheduled Completion Date of Corrective Action Plan: January 1, 2024 Contact for Corrective Action Plan: Gillie Hopkins, DCF-FSD Permanency Planning Program Manager gillie.hopkins@vermont.gov Barbara Joyal, DCF-FSD System of Care Unit Director barbara.joyal@vermont.gov Beth Sausville, DCF-FSD System of Care Unit Director beth.sausville@vermont.gov Ed Dwinell, DCF Business Office, Financial Director ed.dwinell@vermont.gov Peter Moino, AHS Director of Internal Audit peter.moino@vermont.gov

Contact person responsible for corrective action: University Registrar Corrective action: Sacred Heart University implemented a comprehensive corrective action plan in collaboration with the following key stakeholders: Sacred Heart University’s enterprise resource provider (ERP), Ellucian; the Registrar’s Office; and Sacred Heart University’s Department of Information Technology (IT). Sacred Heart University acknowledges the erroneous reporting of graduation effective dates for two students, wherein the effective start date of their first graduate course mistakenly overrode their previously reported correct graduation date. The University took decisive action to address the inaccuracies identified within a summer 2023 enrollment submission to National Student Clearinghouse for Branch 80 and Branch 81. Sacred Heart University conducted a thorough investigation with Ellucian Support to identify the source of these errors. The investigation resulted in a determination by Ellucian Support that the reporting error was caused by a software bug within its software platform, Ellucian Colleague. Ellucian developed a patch, released in October 2023, to rectify the issue. Implementation of this patch by the Sacred Heart University Information Technology department is scheduled for March 2024. Proposed completion date: March 31, 2024

Corrective Action Plan: Management agrees with the recommendation. Regarding the repeat condition of the total number of undergraduate and graduate students, it was partially corrected as the presentation of 1,219 was correct for undergraduate and the total number of enrolled undergraduate and graduate was 1,818, however the supporting data was not. The Financial Aid Office and the Business Service Office have documented the process and data source to obtain accurate data for reporting purposes. This will be corrected moving forward and reflected in the revised reporting of FISAP on December 15, 2023. Regarding the repeat condition of the tuition and fees reporting, the Business Service Office has documented the reconciling process and data source to ensure accurate reporting. The corrected undergraduate and graduate student’s tuition and fees should be $69,898,134. This will be corrected moving forward and reflected in the revised reporting of FISAP on December 15, 2023.

The College identified what took place during contact with the Clearinghouse. Student records have been updated and procedures have been implemented to ensure accuracy of enrollment reporting in addition to implementing review procedures between college records and NSLDS enrollment reports.

Condition: The University did not have documented controls in place, reviewing that the comprehensive information security program was in compliance with the Safeguards Rule and was prepared and in place by June 9, 2023 Corrective Action Planned:The University will reevaluate procedures to ensure that all reports required under Uniform Guidance are reviewed, approved, documented, and retained in a timely manner. Name(s) of Contact Person(s) Responsible for Corrective Action: Richard Thomas, Senior Director of IT Informational Technology, and Paul Matson, CFO & VP of Finance

Friday, March 15, 2024 Harrisburg Area Community College respectfully submits the following corrective action plan for the year ended June 30, 2023. The findings from the June 30, 2023 audit report dated March 15, 2024 schedule of findings and questioned cost are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. Agency: (Federal Agency per Finding) U.S. Department of Education Audit Period: July 1, 2022 – June 30, 2023 Name and Address of independent public accounting firm: Smith Elliott Kearns & Company, LLC, Certified Public Accountants & Consultants 804 Wayne Avenue Chambersburg, Pennsylvania Finding Type: (per Finding) Student Financial Aid Cluster: Material Weakness in internal Controls over Compliance and NonCompliance Internal Control Type: (please choose the type per the finding) o Material Weakness(es) o Significant Deficiencies Audit Finding No.: 2023-001 Federal Program: (per Finding) Student Financial Aid Cluster: Compliance Requirement: (per Finding) Reporting Audit Finding Title/Statement of Condition: (copy from audit findings documentation) Institutions are required to report enrollment information under the Pell grant and the Direct loan programs via the National Student Loan Data System (NSLDS). Two student’s enrollment changes were not properly reported to NSLDS and this was not initially addressed by the College. Seven student’s enrollment changes were not timely reported. These students were enrolled during the Spring 2023 semester and the changes were not reported to NSLDS until September 2023, beyond the 60-day reporting requirement. Auditor Recommendation: (copy from audit findings documentation) We recommend that the College ensure all error reports are reviewed and followed up on timely to ensure students information is being properly reported to NSLDS. Additionally, we recommend the college review its policies and procedures and training processes to ensure reporting is happening in a timely manner. Specific steps to be taken to correct the situation [including a timetable for performance of the CAP] or reason why corrective action is not necessary (including disagreement with the finding). 1) The College will correct the enrollment discrepancies that were reported/uncovered in the audit process. 2) The College will review its existing reporting process for enrollment to the National Clearinghouse. 3) The College will regularly cross reference National Clearinghouse reporting to ensure accurate transfer into NSLDS. 4) The College will address any issues with NSLDS reporting carryover/transfer with NSLDS staff support. Anticipated Completion Date: Corrections to the students’ enrollment errors will be addressed by March 31, 2024. Name(s) and Title(s) of contact person(s) responsible for correction action: Tim Barshinger, Assistant Vice-president of Student Enrollment Services