Corrective Action Plans

Incorrect Enrollment Reporting to National Student Loan Data System (NSLDS) Planned Corrective Action: With new automation we have more timely notifications when students have been dropped. The Pillar Financial Aid department has updated policies and procedures to monitor the withdrawal process to inform the Registrar’s office, which will ensure the necessary changes to the NSLDS record are made in a timely manner. Person Responsible for Corrective Action Plan: Christine Schroeder, Assistant VP of Enrollment Services Anticipated Date of Completion: Current action

Inaccurate and Untimely Return of Title IV Funds (R2T4) Planned Corrective Action: The Financial Aid team will continue to work R2T4s as the pertinent information of the drop/withdraw is received from the Academic team. Once notification is received from the Academic department, the Third-Service provider will review and make timely requests for additional documentation to ensure the calculations and returns are completed in a timely manner, based off the requested information needed. Both the Financial Aid and Student Accounts departments will work in conjunction with the Third-Service provider to ensure timely changes reflect on the student’s ledger. Person Responsible for Corrective Action Plan: Christine Schroeder, Assistant VP of Enrollment Services Anticipated Date of Completion: Current action

Compliance Requirement: Special Tests and Provisions Criteria.· In accordance with Code of Federal Regulations (CFR) Title 34, unless the School expects to complete its next roster file within sixty days, the School must notify NSLDS within thirty days, if it discovers a student who received a loan either did not enroll or ceased to be enrolled on at least a half-time basis. The College did not submit studem status changes in accordance with CFR 34. Context: Five of the 25 students tested did not comply. Cause: The College's procedures for reporting all students were not designed appropriately to allow for timely reporting to the NSLDS. Effect: The accuracy of Title fV student loan records depends heavily on the accuracy of the enrollment information reported by schools. If an institution does not review, update and verify student enrollment statuses, effective dates of the enrollment status and the anticipated completion dates, then the Title IV student loan records will be inaccurate. Questioned Costs: There are no questioned costs associated with this finding. Views of Responsible Individuals: Management agrees with this finding. Corrective Action Taken: While this was an unusual situation resulting from a rare occurrence when the academic calendar was altered only three months prior to the start of 2023-2024 academic year, the Registrar and Senior Leadership Team immediately implemented the following action steps to prevent the deficiency from reoccurring: 1) The Assistant Registrar submitted status change corrections to the National Student Clearinghouse/NSLDS on the same day (07/15/2024) we received the information on which student records were impacted by the reporting discrepancy. 2) The Registrar, Assistant Registrar, and Provost (Chief Academic Officer) implemented processes to ensure that all necessary controls are in place to verify that course dates and degree conferral dates are synchronized with academic calendar dates. Dawn M. Scialabba, Registrar Anticipated Completion Date of Corrective Action: July 15, 2024

Name of Responsible Individual: Jason Byrd, University Registrar Corrective Action: Liberty University acknowledges that its FY24 single audit identified one instances where students’ enrollment reporting was not updated in a timely manner in accordance with U.S. Department of Education (ED) requirements. Additionally, Liberty acknowledges that there were numerous instances where Clearinghouse error reports identified students with repeat errors which were not corrected within the required timeframe. Liberty has invested significant effort into ensuring its enrollment reporting process is handled compliantly and within alignment with ED’s best practices. Liberty’s Registrar’s Office created a new Director of Clearinghouse Reporting position, which was filled in May 2024, to specifically address any enrollment reporting deficiencies. This new position is responsible for monitoring Clearinghouse feeds and any associated error reports and works closely with Liberty’s Financial Aid and Information Technology (ADS) offices to ensure enrollment reporting compliance. Liberty has continued the work of developing a more comprehensive quality control (QC) process. The QC process utilizes National Student Loan Data System (NSLDS) reporting and compares it to Banner, Liberty’s system of record, to identify students who may not have been accurately reported for a variety of reasons. This process relies on the NSLDS Enrollment History Report -SCHHS1, which is a very large and somewhat unstable report due to the volume of enrollment reporting that Liberty completes. Because of the complexities of this report, and the many changes that occurred with NSDLS updates to reporting, Liberty had to file numerous inquiries with ED to be able to run a functioning report, including an NSLDS ticket submitted on September 20, 2022, (Case # 220920-000436). The report was first successfully run in January 2024, though it took several months for Liberty to build QC reports internally that could leverage the report results. Liberty seeks to run the report at least once per month, though failures at NSLDS are unfortunately somewhat common and require escalation to ED for resolution. NSLDS – SCHHS1 Report: Once downloaded, this report is uploaded into Liberty’s system and is utilized internally for four additional QC reports which compare the NSLDS output to Banner. It should be noted that the QC reports are primarily useful for identifying common and repeat issues that require further research and are not fine-tuned enough to identify all individual instances of missing or incomplete records. Liberty Internal QC Reporting: Below are multiple screenshots of the four additional QC reports that Liberty has created. The Graduated Dates Prior to Term End report compares graduation dates by term to identify NSLDS graduation dates that appear to not match Banner’s graduation date in SHDGMR. The NSLDS MisMatches report generates an Excel file showing instances where it believes a student’s enrollment in Banner does not appear to match their reported enrollment in NSLDS. The NSLDS No Banner SSN report pulls students who appear in NSLDS’ enrollment file but do not appear to have a corresponding student ID record in Liberty’s system. The NSLDS Record Missing report pulls Liberty University students who appear to be missing a corresponding record in NSLDS. With all of these reports, there may be a legitimate reason for the discrepancy between Liberty’s Banner data and the NSLDS system, which causes the reports to generate a number of false positives, however, the reports have been helpful to identify more common/persistent errors and provides an additional layer of QC to ensure that Liberty’s enrollment files are as accurate as possible. Liberty is also engaging in a review of its Clearinghouse file generation process to ensure that student’s enrollment changes, particularly for program level records, are reported in a timely manner. Accountability Meetings Finally, in addition to running regular QC reports and hiring a dedicated Director of Clearinghouse reporting position, Liberty began holding a series of bi-weekly “Enrollment Reporting Check-In” meetings with key stakeholders from University Compliance, Financial Aid, Registrar, and IT/ADS in February 2024, which are dedicated to discussing current and upcoming enrollment reporting submissions and errors, trends seen with SSCR errors, and brainstorming ways to ensure ongoing compliance. While improvement efforts continue to be underway, Liberty believes these efforts are starting to bear fruit as evidenced by a 98.7% reduction in the number of repeat errors in the 2024 calendar year compared to total reporting period. Moving forward Liberty will continue to hold monthly meetings with key stakeholders to discuss any errors being pulled and ensure best practices are implemented to ensure ongoing accuracy. The University’s Registrar’s Office will also continue to review the QC reports in a timely manner, as well as evaluate the current processes for withdrawal/graduated student files. Liberty will continue to review and implement updates as necessary to maintain enrollment reporting compliance and believes these new processes will allow us to be compliant in subsequent years. Anticipated Completion Date: April 2025

Recommendation: We recommend the Office of Financial Aid utilize their financial aid processing software to implement disbursement notifications which include all information required by (34 CFR Section 668.165(a)(2) to be sent electronically to students once disbursements are posted. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Corrective Action Planned: The Office of Financial Aid and Scholarships drafted a letter using best practices laid out by NAFSAA which includes all information required by 34 CFR Section 668.165. The System Specialist, who is responsible for disbursing aid, has created documentation that has been added to the disbursement process. Once a disbursement is complete, the System Specialist will run the process in PowerFAIDS that will send the Loan Disbursement Notification via email to students who have received loans. This includes students who have received Federal Direct Subsidized, Unsubsidized, Parent PLUS, Grad PLUS, and private loans. This process is updated and is now in place. Name of Contact Responsible for Corrective Action: David J. Sarah, Director of Financial Aid, 765.641.4110 Anticipated Completion Date: August 2024

Recommendation: We recommend an individual in financial aid with the appropriate level of experience periodically review R2T4 calculations and returns to help ensure that internal controls over such a process can operate effectively and achieve compliance. We also recommend the University implement controls to track and remind when returns need to be returned once the withdrawal determination has been made. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Corrective Action Planned: ● Moving forward, for each year, when the academic calendar is released prior to the beginning of the fall semester, The Office of Financial Aid and Scholarships will immediately determine the dates and number of days used for the R2T4 calculations. ● The Senior Financial Aid Counselor within the Office of Financial Aid and Scholarships, who is responsible for preparing the R2T4 calculations, has enrolled for R2T4 training from NASFAA, which takes place starting on September 3, 2024. The Senior Financial Aid Counselor will also complete a PowerFAIDS training on the R2T4 process within the system. ● The Systems Specialist within the Office of Financial Aid and Scholarships will also be trained on the R2T4 process to provide quality control for the senior financial aid counselor and to ensure we are cross-trained within the Office of Financial Aid. With two individuals working to keep each other accountable, we will be able to avoid similar issues in the future. The Systems Specialist will also complete the NASFAA and PowerFAIDS training. ● All R2T4s will be tracked on a shared file starting in the Fall 2024. The Senior Financial Aid Counselor, Systems Specialist, and Director of Financial Aid will have access to the file for review and quality control. ● The Systems Specialist and Director of Financial Aid will be added to the student withdrawal form workflow through Etrieve. This team of three will all receive a notification when a student withdrawal needs to be processed. ● The Director of Financial Aid will check at least weekly on the shared R2T4 file and will monitor the dates and timelines to ensure calculations are completed within the timeframe allowed. Name of Contact Responsible for Corrective Action: David J. Sarah, Director of Financial Aid, 765.641.4110 Anticipated Completion Date: September 2024

Finding: 2024-004 Satisfactory Academic Progress Responsible Party: Douglas Cleary, Director of Financial Aid Anticipated Completion Date: July 31, 2024 The audit noted one student was awarded financial aid despite not meeting Satisfactory Academic Progress (SAP) standards. The issue stemmed from a lapse in the SAP review process at the end of the Fall 2023 term, which was primarily attributed to staff turnover and insufficient training for remaining personnel. When the student did not enroll for the Spring term but later registered for the Summer 2024 session, there were no safeguards in place to prevent the system from awarding financial aid. This oversight highlighted a gap in the current process, emphasizing the need for a more robust mechanism to flag students who are not in compliance with SAP prior to awarding financial aid. In the new organizational structure, the Financial Aid Business Analyst is responsible for executing the SAP process. This individual has approximately 10 years of experience working with SAP processes. During the 2023-2024 academic year the University worked diligently to respond to a Federal Program Review from the U.S. Department of Education, (ED). As a result of the corrective actions being undertaken by the University new procedures in many areas were being drafted and implemented. A new Director of Financial Aid, with over 30 years of experience in financial aid, was hired to improve the overall student service and compliance with the Federal Title IV program. The new director commenced his duties on February 1, 2024. Since that time the University has reorganized the financial aid office by creating an Assistant Director and Financial Aid Business Analyst position who have increased the expertise and overall years of financial aid experience. A leadership team including the Director of Financial Aid, Registrar, Director of Student Accounts, Associate Provost, Provost and Vice President for Finance and Administration was created in January 2024 and meet bi-weekly to discuss Title IV compliance topics, process improvement and customer service. Most of the Financial Aid team’s time in the spring and summer was spent working on the new FAFSA. The team has redirected their efforts in training, standardizing, documenting and improving processes to ensure Title IV compliance and better serve students.

Finding: 2024-003 Verification Responsible Party: Douglas Cleary, Director of Financial Aid Anticipated Completion Date: October 17, 2024 The auditors identified two issues related to verification of financial aid data supplied on the FAFSA by students. Both findings were from the fall of 2023 and in both cases a secondary review was completed and still was not accurately completed. The Office of Financial Aid developed and implemented a comprehensive Business Process Guide (BPG) on October 17, 2024. The guide is aimed at ensuring that all required fields within the verification process are meticulously reviewed and corrected as needed. This guide serves as a crucial resource for staff involved in the financial aid verification process, outlining best practices and standard procedures to maintain compliance and accuracy. The verification correction process follows a two-step approach: 1. Initial Review and Correction: Staff members are required to conduct a thorough review of the required data fields. This involves checking the required ISIR data fields against other supplemental information to identify any discrepancies or inaccuracies. Once identified, corrections are made to ensure that all data aligns with federal and institutional requirements. 2. Final Confirmation and Awarding: After the necessary corrections are implemented, a secondary review is conducted by the Assistant Director to confirm that the adjustments are accurate. This ensures that students receive the correct financial aid awards based on updated and verified information. To maintain transparency, accountability, and an adequate documentation trail. It is imperative that any comments added to student accounts are detailed and include pertinent information regarding the verification process. This documentation serves as a record of the actions taken and aids in future audits and reviews. The Assistant Director of Financial Aid is a very experienced financial aid professional and holds NASFAA certifications in Verification, R2T4, Student Eligibility, Direct Loans and Professional Judgement. The Assistant Director plays a pivotal role in the verification process, being responsible for updating the BPG to reflect any changes in regulations or best practices. Additionally, the Assistant Director will lead training sessions for staff members to ensure they are well-versed in the verification procedures outlined in the BPG. Ongoing training will be provided as needed to accommodate changes in policies or technologies. By implementing this structured approach to verification corrections, the University aims to enhance the accuracy of financial aid processing and improve the overall student experience.

Finding: 2024-002 Enrollment Reporting Responsible Party: Dr. Karen Jarrell, Director of Office of Student Records and Registrar Completion Date: December 30, 2024 The Deputy Registrar from the Office of Student Records (OSR) is responsible for enrollment reporting to the National Student Loan Data System (NSLDS). The university uses a servicer, National Student Clearinghouse (NSC) to complete the reporting requirement. Enrollment data is scheduled to be transmitted to the NSC every thirty days to ensure timely reporting to the National Student Loan Data System (NSLDS). The University has consistently met this 30-day reporting to NSC. The audit noted four students had incorrect program start dates in NSLDS from April 2022 and August 2022, each off by one day. The University’s Student Information System (SIS) reflects the correct program start dates, indicating a potential issue in the data transmission between NSC and NSLDS. In July 2022, several announcements were made concerning the technical issues with NSLDS which prevented reporting for periods of time, including “NSLDS Professional Access – Documentation of Enrollment Reporting and Post-screening Delays for Audit Purposes” published on August 31, 2022. The audit noted three errors related to timely reporting. The university’s SIS records indicate these records were reported to NSC within the 30-day timeframe. However, these records were not transmitted from NSC to NSLDS timely. The Deputy Registrar is currently collaborating with the NSC Compliance division to determine the cause of these discrepancies and how best to correct the records in NSLDS. A response from NSC is anticipated by October 31, 2024. The audit also noted three students who were less than full-time that were not reported to NSC or NSLDS. The Deputy Registrar is researching the SIS system rules to determine the root cause of these errors so they can be corrected. The Deputy Registrar will ensure the reporting rules will be corrected by November 30, 2024, and will ensure any less than full time students are corrected in NSLDS by December 30, 2024. To enhance the enrollment reporting process, the Deputy Registrar, Registrar, and Director of Financial Aid will meet with NSC staff and IT staff to establish a method for comparing monthly data submitted to NSC with the data in the NSLDS system. This will help identify any discrepancies for immediate correction. This project is expected to be completed by December 30, 2024.

Finding: 2024-001 R2T4 Responsible Party: Douglas Cleary, Director of Financial Aid Anticipated Completion Date: November 30, 2024 With the new Financial Aid leadership, the university has already implemented many new strategies to strengthen the Return of Title IV Funds (R2T4) process. The University created a new position, Financial Aid Business Analyst, whose primary responsibility is to maintain financial aid systems, maintain process documentation and provide staff system training and to oversee the R2T4 process. The Financial Aid Business Analyst has two years of previous experience being responsible for R2T4 calculations, completed the National Association of Student Financial Aid Administrators (NASFAA) R2T4 five-week certification program on October 14, 2024, and is in the process of training a Financial Advisor in performing R2T4 calculations. Other areas that have been identified will improve the R2T4 process are as follows: 1. Earlier Availability of the Academic Calendar: The Financial Aid Office leadership (Director, Assistant Director, Financial Aid Business Analyst) will work with the Office of Student Records (Registrar and Deputy Registrar) to ensure that there is an accurate R2T4/academic calendar. Both offices will work to develop such calendars with a clear description of the dates the University is closed for students, and that calendars can be developed years in advance. This will facilitate accurate determination of begin/end dates, break days and the total number of class days within any term. This will also encourage greater levels of transparency and oversight by both offices. The R2T4/academic calendar will also be shared with the Student Accounts Office, adding additional transparency and understanding. Timeline: The calendar for the Spring semester 2025 and the 2025-2026 academic calendar has already been developed and approved. The 2026-2027 academic calendar has been submitted to faculty for their input and will be completed by November 30, 2024. 2. Daily Percentage Calculator: The Financial Aid Business Analyst developed a daily percentage calculator that, implemented for Fall 2024, when combined with the academic calendar, will enable the accurate input of all term dates to generate precise daily percentage calculations for R2T4 purposes. This is also being expanded to create sub-term daily percentage calculations to eliminate the need for manual completion with each module-type calculation. 3. Post-Withdrawal Disbursements: The Financial Aid Business Analyst worked with Information Technology to ensure required communications related to R2T4 including post withdrawals (PWD) are now an automated process after completion of the calculations. This automation was implemented in August 2024. The PWD findings in this audit were the work by previous leadership within the Financial Aid Office. 4. Collaboration with IT for Updated Reporting: Financial Aid Office leadership (Financial Aid Business Analyst, Director) are collaborating with the IT to develop updated reports that will help accurately identify students who have unofficially withdrawn and require review during the R2T4 process. This initiative aims to create a preventive control that identifies errors and ensure timely calculations. The timeline for completion of the updated report is November 30, 2024. 5. Strengthening Internal Controls: The Director of Financial Aid has identified a Financial Aid Advisor who is currently being trained on R2T4 process, and who will eventually assume the primary responsibility for R2T4 calculations. The Financial Aid Business Analyst will provide secondary reviews to ensure accuracy and consistency. Note: The two PWDs from the Fall 2023 semester highlight a significant oversight by previous financial aid leadership. The inadvertent miscalculation of break days stemmed from confusion about the academic calendar. It appeared to suggest that students were required to attend classes on the weekend proceeding Thanksgiving week, while in reality, classes concluded the prior Friday. As a result, the Fall break should have been calculated as 9 days instead of 7.

Student Financial Assistance Cluster- Assistance Listing No. 84.268 Finding: The College did not have documentation that Direct Loan Reconciliation was performed. Context: During our testing we identified the March 2024 Direct Loan Reconciliation was not timely performed and documented. Cause: Due to staff turnover, direct loan reconciliation for March 2024 was not performed timely. Recommendation: We recommend the College implement a formal review procedure to document that the direct loan reconciliations are performed on a timely basis each month. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: A formal review process was already in place. The issue came from the turnover in the FA department leading to a loss of access. This will be remediated moving forward with more than one FA staff having reporting access and knowledge of reconciliations. Name(s) of the contact person(s) responsible for corrective action: Tina Ballinger Planned completion date for corrective action plan: 11/01/2024

Student Financial Assistance Cluster- Assistance Listing No. 84.063, Finding: The College under-awarded funds for the Pell Grant. Context: During our testing, we identified 2 out of 40 students were awarded and disbursed less Pell funds than should have been awarded based on the 23-24 Pell payment schedule. The Pell payment schedule considers the cost of attendance, the student's Expected Family Contribution and the enrollment status of the student. Cause: Student was initially not disbursed Pell funds due to electronic terms & conditions not being completed. However, when the student completed this requirement in the Spring, Pell was not disbursed for the Fall semester Recommendation: We recommend the College review its current procedures for awarding Title IV funds and implement any changes necessary to ensure federal funds are awarded and disbursed in accordance with federal regulations. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: This is due to a loss of knowledge due to turnover within the FA department. Moving forward, knowledge procedures and knowledge will be disseminated to all FA staff to ensure there are no gaps causing a reoccurring issue. Name(s) of the contact person(s) responsible for corrective action: Tina Ballinger Planned completion date for corrective action plan: 11/01/2024

Student Financial Assistance Cluster- Assistance Listing No. 84.007, 84.038, 84.063, 84.268 Finding: The College did not properly have documentation of exit counseling notification. Context: During our testing of 40 students, we identified 5 students that did not have documentation of exit counseling notification. Cause: The College did not have proper procedures in place to ensure that notification of required exit counseling was sent to applicable students. Recommendation: We recommend the College review reporting processes to ensure all students that require exit counseling receive it in a timely manner Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: This is due to a loss of knowledge due to turnover within the FA department. Moving forward, knowledge about loan exit counseling will be disseminated to all FA staff to ensure there are no gaps causing a reoccurring issue. Name(s) of the contact person(s) responsible for corrective action: Tina Ballinger Planned completion date for corrective action plan: 12/15/2024

Student Financial Assistance Cluster- Assistance Listing No. 84.007, 84.038, 84.063, 84.268 Finding: The College did not properly notify students when loans were credited to student's ledger account. Context: During our testing of 40 students, we identified that there were 5 students that did not receive the required notification of Direct Loan disbursements Cause: Due to staff turnover, loan notifications were missed being sent out to students. Recommendation: We recommend the College evaluate its procedures around disbursements of loans and ensure that notifications of disbursements are sent and contain all the required elements outlined in the FSA handbook. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: This is due to a loss of knowledge due to turnover within the FA department. Moving forward, knowledge about loan notifications will be disseminated to all FA staff to ensure there are no gaps causing a reoccurring issue. Name(s) of the contact person(s) responsible for corrective action: Tina Ballinger Planned completion date for corrective action plan: 12/15/2024

Student Financial Assistance Cluster-Assistance Listing No. 84.007, 84.038, 84.063, 84.268 Finding: The College did not properly report student enrollment changes for students who received federal student aid to the National Student Loan Data System (NSLDS). Context: During our testing of 40 students, we identified 3 students that did not have their Program enrollment reported to NSLDS and 3 students that had Program enrollment effective dates that did not match institutional records. Cause: The College didn't have proper procedures in place to verify students' status in NSLDS matched the institution's records accurately. Recommendation: We recommend the College review current processes for reporting to NSLDS and implement procedures to ensure submissions are reported accurately. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: CSC will put in place procedures that will ensure that submissions are reported accurately. Name(s) of the contact person(s) responsible for corrective action: Tina Ballinger Planned completion date for corrective action plan: 01/01/2025

Student Financial Assistance Cluster- Assistance Listing No. 84.007, 84.033, 84.063, 84.268 Finding: The College used the incorrect withdrawal date when calculating Return to Title IV (R2T4) calculations and did not have formal procedures in place to document review of calculations. Context: During our testing, we identified 2 out of 15 R2T4 calculations used an incorrect withdrawal date in their calculation. Also, during our testing, we identified 13 instances of no documentation of a formal review of R2T4 calculations. Cause: The College was using the date a withdrawal form was processed, rather than the date the withdrawal process began. Recommendation: We recommend that the College review policies and procedures related to R2T4 calculations to ensure calculations are performed accurately. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Staff will review policies and procedures and make adjustments as needed to ensure that the calculations are accurate. Name(s) of the contact person(s) responsible for corrective action: Tina Ballinger Planned completion date for corrective action plan: 11/01/2024

Student Financial Assistance Cluster – Assistance Listing No. 84.268 Recommendation: We recommend the University implement procedures to ensure exit counseling notifications are sent to students who graduated or withdrew. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Financial Aid Office will work with our IS department to rebuild the exit counseling notifications so they are more accurate and notify the correct student population. Name(s) of the contact person(s) responsible for corrective action: Jason Hibbert Planned completion date for corrective action plan: March 21, 2025

Student Financial Assistance Cluster – Assistance Listing No. 84.268, 84.063, 84.007, 84.033, 84.379 Recommendation: We recommend the University evaluate its procedures and policies around reporting disbursements to COD to ensure that student information is reported accurately and timely, and to store evidence of the key control having occurred. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Financial Aid Office will work with our IS department to rebuild the original PELL unreported disbursements. Any unreported disbursements greater than 7 days will be reported to the financial aid director, information systems, and the vice president for finance and administration via email from Fast. This will allow for a review and timely reporting. Name(s) of the contact person(s) responsible for corrective action: Jason Hibbert Planned completion date for corrective action plan: January 6, 2025.

Student Financial Assistance Cluster – Assistance Listing No. 84.268, 84.063, 84.007, 84.033, 84.379 Recommendation: We recommend that the University implement a key control to ensure that enrollment data, changes in status and effective dates within NSLDS match the records of the institution and are reported timely, and to store evidence of the key control having occurred. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Review of Banner job to check for errors in reporting format or potential junk data that could cause a report to be rejected. New drop and withdrawal codes that only pertain to post term withdrawals and will only be used for a post term withdrawal to allow the dates to match, are being discussed. As well as internal discussion about developing key control tracking to show evidence that the controls in place are being followed. Name(s) of the contact person(s) responsible for corrective action: Emily Sharratt Planned completion date for corrective action plan: December 13, 2024

Student Financial Assistance Cluster – Assistance Listing No. 84.268 Recommendation: We recommend that the University review their awarding procedures and implement procedures to ensure direct loans are awarded within student eligibility. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Financial Aid office (FAO) plans to do more expansive training for the Financial Aid Administrators upon hire. FAO is exploring the option of National Association of Student Financial Aid Administrators training certification for a Need Analysis credential. Name(s) of the contact person(s) responsible for corrective action: Jason Hibbert Planned completion date for corrective action plan: February 28, 2025

2024-003: U.S. Department of Education. Assistance Listing Number: 84.007 (Federal Supplemental Educational Opportunity Grants Program), 84.033 (Federal Work Study Program), 84.063 (Federal Pell Grant Program), 84.268 (Federal Direct Student Loans Program). Criteria or specific requirement: The Gramm-Leach-Bliley Act (Public Law 106-102) requires financial institutions to explain their information-sharing practices to their customers and to safeguard sensitive data. (16 CFR 314) The Federal Trade Commission considers Title IV-eligible institutions that participate in Title IV Educational Assistance Programs as “financial institutions” and subject to the Gramm-Leach-Bliley Act (16 CFR 313.3(k)(2)(vi)). The Code of Federal Regulations 2 CFR 200.303 requires the University to establish and maintain effective internal controls over Federal awards. Context: Under an institution’s Program Participation Agreement with the Department of Education and the Gramm-Leach-Bliley Act, schools must protect student financial aid information, with particular attention to information provided to institutions by the Department or otherwise obtained in support of the administration of the federal student financial aid programs. Cause: The University has continued to make progress in updating the University’s written security program to become in compliance with all requirements; however, due to capacity and demands on the information technology individuals, this is still a work in process. Recommendation: We recommend the University work to update the written security program to ensure compliance with all the standards. Views of responsible officials: There is no disagreement with the audit finding.

2024-002: U.S. Department of Education. Assistance Listing Numbers: 84.063 - Federal Pell Grant Program, 84.268 - Federal Direct Student Loans. Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 685.309 requires that enrollment status changes for students be reported to the National Student Loan Data System (NSLDS) within 30 days or within 60 days if the student with the status change will be reported on a scheduled transmission within 60 days of the change in status. Regulations require the status include an accurate effective date. In addition, schools are required to certify enrollment every 60 days, and respond within 15 days of the date that NSLDS sends a Roster file to the school or its third-party servicer. Errors must be corrected within 10 days. Cause: The University’s processes and controls did not ensure that student status changes were properly and timely reported to NSLDS. Effect: The errors were caused by National Student Clearinghouse's communication with NSLDS, as a result of the modernization of NSLDS in 2022. The University was told the errors would be fixed and there was nothing more they needed to do. The errors were not fixed. 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. Views of responsible officials: There is no disagreement with the audit finding.

This was an isolated instance and attributed to the merger of three institution into one institution effective July 1, 2023. The registrar is monitoring the re-enrollment of students that have taken a leave of absences or have not enrolled in VTSU since the merger to identify additional errors and will take appropriate action to correct them as the occur.

VTSU is setting standard procedures for the merged financial aid department, so all personnel are following a standard procedure. In the future, VTSU will not be marking students or using the code for “not verifying” for students who do not enroll. Posting rules are in place that will not allow aid to post to a students account if verification is incomplete.

Westminster University is deeply committed to supporting its students and ensuring compliance with the requirements of the Student Financial Assistance Cluster. We appreciate the feedback provided in the Schedule of Findings and Questioned Costs and have taken action to address the concern raised. Our institution is dedicated to continuous improvement in both our financial aid processes and overall student support services. We have developed an action plan to address the issue identified: FINDING 2024‐001 – Special Tests and Provisions – Enrollment Reporting Significant Deficiency in Internal Control over Compliance Recommendation: The University should implement a policy to ensure address changes for all semesters are reported timely. Response: There is no disagreement with this audit finding. Action Taken in Response to Finding: Based upon the definition provided of Section 34 CFR Section 685.309(b) (2), it is our understanding that we are required to report address changes only on enrolled students through the period where they are marked as either (W) Withdrawn or (G) Graduated status. Our policy is to report students’ most current home address with each enrollment submission a minimum of 14 dates per year (three of which are only for graduated students) which ensures compliance with the 60-day threshold. However, our current practices have not always ensured that the current main home address was the one supplied to the National Student Clearinghouse. We will immediately implement processes to ensure that the main home address is the one sent to the National Student Clearinghouse. We consider this to be remediated. Contact Person(s): Karen Henriquez, Director of Financial Aid