Corrective Action Plans

Recommendation: We recommend the Academy reevaluate its procedures and review policies surrounding controls implemented for Title IV Aid. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Since the audit, Summit Academy has determined a new process in which we will ensure controls are being implemented within certain processes. For our R2T4’s, once the Bursar has finished the calculations, the Financial Aid Manager will review for any errors & sign off with her initials once reviewed. For NSLDS, the Financial Aid Manager will work closely with the Registrar’s Department to ensure graduates & withdrawal/terminated students are updated in a timely manner. There will also be a spreadsheet used to keep track of all students changed within NSLDS. Name(s) of the contact person(s) responsible for corrective action: Marc Carrier, CFO Planned completion date for corrective action plan: Fall 2024

Recommendation: We recommend the Academy reevaluate its procedures and review policies surrounding reporting status changes to NSLDS to put a process in place to ensure the student status changes are being reported timely. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Since the audit, Summit Academy has determined a new process in which we certify and make changes to the enrollment data found in NSLDS. Moving forward, the Financial Aid Manager will be assigned tasks within our operating system (Anthology) that will notify her of any students who withdrawal, go on a leave of absence, changed their enrollment intensity or graduate. The Financial Aid Manager will check this daily and update the students NSLDS enrollment data accordingly. The Financial Aid Manager will also keep a spreadsheet detailing the students name and the dates each student was certified. The Financial Aid Manager will also work closely with the Registrar’s Department to ensure the graduation and withdrawal lists are accurate. Name(s) of the contact person(s) responsible for corrective action: Marc Carrier, CFO Planned completion date for corrective action plan: Fall 2024

Student Financial Assistance Cluster – Assistance Listing Number 84.007, 84.063, 84.268 Recommendation: We recommend that the University review its procedures related to updating the Eligibility and Certification Approval Report in a timely fashion. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: University will review which individuals are listed on the ECAR. Upon learning of their departure, the University will update ECAR immediately. Name(s) of the contact person(s) responsible for corrective action: H. Jonas Javier Planned completion date for corrective action plan: November 4, 2024

Student Financial Assistance Cluster – Assistance Listing Number 84.007, 84.063, 84.268 Recommendation: We recommend that the University review its procedures related to outstanding student refund checks to ensure they are being returned to the Department of Education after 240 days. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The University will develop and implement a procedure wherein uncashed checks will be reviewed more closely. Student refunds identified as uncashed as of 60 days will be forwarded to the Bursar’s Office. Bursar’s Office will conduct outreach to refund recipients. If refund remains uncashed after 180 days, Bursar’s Office will return funds to federal agency. Name(s) of the contact person(s) responsible for corrective action: H. Jonas Javier Planned completion date for corrective action plan: November 4, 2024

Student Financial Assistance Cluster – Assistance Listing Number 84.007, 84.063, 84.268 Recommendation: We recommend that the University put a process in place to refund student credit balances that arose from federal funds within 14 days. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The University has in place a systematic procedure wherein reviews of credit balances are conducted promptly after aid is transmitted. The University will ensure that this procedure is followed thoroughly. Name(s) of the contact person(s) responsible for corrective action: H. Jonas Javier Planned completion date for corrective action plan: November 4, 2024

NSU – Agrees with the finding. • Detailed corrective action taken, including what will be done to avoid the identified issues in the future, and when these measures will be in place: To ensure accurate and timely reporting of changes in student enrollment status to the National Student Clearinghouse (NSC), Nevada State University (NSU) will enhance its internal controls by implementing the following measures: o Continue the current bi-weekly enrollment reporting schedule. o Set bi-weekly calendar reminders to ensure timely reporting, supplementing NSC notifications. o Establish end-of-term calendar reminders specifically for reporting graduated statuses promptly. o Work closely with the NSC to identify any students included in submitted enrollment reports whose statuses were not updated within the NSC or National Student Loan Data System (NSLDS), ensuring they are addressed even if they do not appear in the reject file. • How compliance and performance will be measured and documented for future audit, management and performance review: To ensure ongoing compliance and performance in reporting changes in student enrollment status, Nevada State University (NSU) will implement the following measures for tracking and documentation: o NSU will conduct monthly reviews of enrollment status reports to verify the accuracy and timeliness of submissions to the National Student Clearinghouse (NSC). o Detailed logs of all enrollment status submissions and NSC notifications will be maintained, including timestamps and submission confirmations, to serve as an audit trail for internal and external reviews. o Periodic internal audits will be scheduled to assess adherence to the bi-weekly and end-of-term reporting schedule, with results documented for management review. o Key performance indicators (KPIs) will be established, such as the percentage of on-time reports and the accuracy rate of enrollment status updates. These metrics will be reviewed quarterly by management. o Any discrepancies identified during audits will be addressed promptly, and corrective actions will be documented for future reference and performance evaluations. o NSU will compile annual compliance reports summarizing audit results, corrective actions, and performance metrics, which will be available for future audits and management reviews. • Who will be responsible and may be held accountable in the future if repeat or similar observations are noted: The Registrar's Office holds primary responsibility for accurate and timely enrollment status reporting. The Registrar will oversee compliance with internal controls including the bi-weekly and end-of-term reporting schedules. Additional oversight will be conducted by the Provost and Vice President of Academic Affairs. Name of contact person responsible for corrective action plan: Rhett R. Vertrees, Assistant Chief Financial Officer 2601 Enterprise Road, Reno NV 89512-1666 Phone: (775)784-3409, Fax: (775)784-1127 Email: rvertrees@nshe.nevada.edu

CSN – Agrees with the finding. • Detailed corrective action taken, including what will be done to avoid the identified issues in the future, and when these measures will be in place: CSN has contracted with a third-party vendor to help review and process R2T4 accounts within the federally mandated timeframe. CSN is currently in the training phase and expects to have the vendor begin reviewing R2T4 file in the next several weeks. In addition, regular monthly training will be provided to CSN staff and the third-party vendor. Quality control through the review of processed R2T4 files will be performed twice a month. • How compliance and performance will be measured and documented for future audit, management and performance review: In collaboration with the third-party vendor, CSN will run R2T4 queries twice a month to ensure all files are reviewed within the federally mandated timeframe. The vendor will also review internally selected files for accuracy. CSN will also randomly select processed files review to meet compliance requirements. CSN will meet with the vendor on a monthly basis and maintain communication throughout the year to ensure consistency and compliance. • Who will be responsible and may be held accountable in the future if repeat or similar observations are noted: The Assistant Director of Processing in the Office of Financial Aid will be responsible for repeat or similar observations. UNLV – Agrees with the finding. There were two findings at the conclusion of the audit. Corrective action plans as well as measurements of compliance and performance correspond with the following two findings: 1. A return was calculated as $2,270, but should have been $1,975. 2. The second finding was regarding an improper return. UNLV’s calculation was correct at $0, as documented for the audit team. Months after the R2T4 calculation was performed, the student did not return to UNLV. At that time, their Pell Grant was appropriately canceled, but due to a system error, their Pell Grant for the entire year was canceled instead of just for subsequent semesters. Through our internal controls we found this error, but did so beyond the permissible 180-day late disbursement period. The error was unrelated to the R2T4 process and had no bearing on the correctly performed calculation. Since the Pell Grant could not be reinstated, we made the student whole with institutional funds. • Detailed corrective action taken, including what will be done to avoid the identified issues in the future, and when these measures will be in place: 1. Since the late disbursement period had passed, and the student had no balance due, there was no immediate corrective action that could be taken. The calculation error related to a withdrawal date incorrectly reported by a faculty member during spring break. The PeopleSoft system is set up to prevent the entry of such spring break withdrawal dates, and we were unable to replicate the error. The issue has therefore been escalated to our technical team for investigation and for prevention in future years. Even if this proves successful, we will ensure that at least two staff responsible for oversight of the R2T4 function will sign off each spring that no calculations are based on a withdrawal date that occurs during spring break. The signoff will occur within seven days of the end of spring break, so that if any error is identified we may still correct it while remaining within the appropriate R2T4 timelines. 2. The erroneous retroactive cancellation of Pell Grants for unenrolled students is now a known PeopleSoft issue. Beginning in fall 2024, we have established programming that packages Pell Grants on a semester-by-semester basis so that any changes to a current-term grant do not impact a prior-term grant. • How compliance and performance will be measured and documented for future audit, management and performance review: 1. A report exists in PeopleSoft that documents the withdrawal date of each student for whom an R2T4 calculation is performed. This report will be used to collect signoffs by two UNLV staff with R2T4 oversight that no calculations are based on a withdrawal date occurring during spring break, and will serve as the basis for that signoff. 2. Pell recipients' accounts will be reviewed in spring 2025 to ensure our packaging approach was effective in preventing retroactive grant cancellations. The team will review monthly to ensure we stay within the 180-day late disbursement time frame, which will allow us to reinstate Pell Grants retroactively, should our original solution prove ineffective. • Who will be responsible and may be held accountable in the future if repeat or similar observations are noted: If similar errors around spring break R2T4 calculations and/or retroactive Pell Grant cancellations occur in the future, of primary accountability will be the Assistant Director of Processing, the Associate Director of Operations, the Associate Director of Processing and Client Services (currently vacant), the Director, and the Executive Director. UNR – Agrees with the finding. The Financial Aid office recognizes a shortfall in this area due to unexpected changes in staffing. • Detailed corrective action taken, including what will be done to avoid the identified issues in the future, and when these measures will be in place: New R2T4 staff is currently undergoing in-depth calculation training which includes internal trainings, NASFAA workshops, and Federal Student Aid provided trainings. In addition, starting this fall, 100% of R2T4 files are being reviewed by a staff member who was not responsible for the initial calculation. To prevent late returns, our office is calculating returns within 15 days of the withdrawal date and return funds within 30 days of the withdrawal. • How compliance and performance will be measured and documented for future audit, management and performance review: Compliance with the above corrective action will be monitored by the Data Manager, who will be reviewing weekly R2T4 reports completed by R2T4 staff. Reports with return data will be compiled in one centralized location to ensure transparency of current return status, and a physical audit trail documented on the R2T4 coversheet detailing initial calculation date, audit check date, and return to COD date. • Who will be responsible and may be held accountable in the future if repeat or similar observations are noted: The R2T4 staff and the Financial Aid Director will be responsible. Name of contact person responsible for corrective action plan: Rhett R. Vertrees, Assistant Chief Financial Officer 2601 Enterprise Road, Reno NV 89512-1666 Phone: (775)784-3409, Fax: (775)784-1127 Email: rvertrees@nshe.nevada.edu

UNR – Agrees with the finding. • Detailed corrective action taken, including what will be done to avoid the identified issues in the future, and when these measures will be in place: The Financial Aid Office and the Cashiers Office have implemented procedures to ensure that refund holds are reviewed twice a week (Tuesdays, Thursdays). Automatic reports have been implemented to check for students with credit balances who have holds on their accounts. Assigned FA advisors review the reports and work with the Cashiers Office to resolve any hold issues to ensure that the student receives their refund promptly but no later than 14 days after funds are disbursed to the student account. • How compliance and performance will be measured and documented for future audit, management and performance review: The Data Manager is running weekly quality assurance reports to check that the FA advisors are reviewing theirs list and that there are no students on the lists that need attention. • Who will be responsible and may be held accountable in the future if repeat or similar observations are noted: The assigned financial advisors who review refund holds and the Financial Aid Director will be responsible. Name of contact person responsible for corrective action plan: Rhett R. Vertrees, Assistant Chief Financial Officer 2601 Enterprise Road, Reno NV 89512-1666 Phone: (775)784-3409, Fax: (775)784-1127 Email: rvertrees@nshe.nevada.edu

National Student Loan Data System (NSLDS) Enrollment Reporting Award Period: July 1, 2023 to June 30, 2024 Type of Finding: Significant Deficiency in Internal Control over Compliance Recommendation: We recommend the College review its reporting procedures to ensure that students’ statuses are accurately and timely reported to NSLDS as required by regulations. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Financial Aid Office will further collaborate and expand procedures with the Registrar office to continue to ensure that we meet the Code of Federal Regulations, 34 CFR 685.309 that requires enrollment status changes to be reported to NSLDS within 30 days or 60 days if scheduled enrollment transmission will be sent within 60 days. Specifically, adjusting procedure to ensure that all 0.0 GPA students due to F grade are reported. Name(s) of the contact person(s) responsible for corrective action: Alyssa Gillette Planned completion date for corrective action plan: November 30, 2024

Finding: The University’s R2T4 calculation was improper for one student, as the student had not signed a promissory note for the direct loans and the direct loans should have not been included in the calculation. Corrective Actions Taken or Planned: The Director of Financial Aid reviews and processes the R2T4 calculations. The Director will reassess R2T4 calculations and verify that only aid with signed promissory notes are being included in R2T4 calculations. Internal policies and procedures have been updated to ensure accurate calculations. Person Responsible: Teresa Brahm, TBrahm@dbq.edu Anticipated completion date: 09/25/2024

Finding: The University did not timely or accurately report enrollment changes to the National Student Loan Data System (NSLDS). Corrective Actions Taken or Planned: The Registrar’s Office submits a monthly report to the National Student Clearinghouse (NSC). To ensure withdraw dates during the academic year are being reported on a timely basis Financial Aid Office will manually check and enter dates of withdrawn students to NSC and National Student Loan Data Systems (NSLDS). Students who have withdrawn at the end of the spring semester will be manually entered and monitored closely by the Registrar’s Office who will adjust reporting schedule to ensure timely reporting of withdrawn dates Financial Aid Office and Registrar’s Office have been continually working together to ensure timely and accurate reporting of withdrawal dates. Person Responsible: Teresa Brahm, TBrahm@dbq.edu Anticipated completion date: 09/25/2024

Management agrees with the finding and the recommendations made by the auditor. Over the next thirty days Management will analyze the enrollment reporting control environment including (but not limited to) how enrollment status effective dates, for students who withdrawal after the completion of the semester, are identified and accounted for by Management. Within forty-five days, Management will implement enhanced enrollment reporting processes to ensure accurate and timely enrollment statuses are reported to NSLDS in compliance with federal regulations.

The College agrees that Enrollment Reporting should be submitted in a timely manner. The College has been actively working with the new SIS to ensure the ability to produce the reports and has currently submitted reports through the Fall 2023 term. The College anticipates completion of reports through the Fall 2024 term by the end of December, resulting in compliance with this requirement.

Student Financial Assistance Cluster– 84.038 – Federal Perkins Loans Recommendation: We recommend that the University implement a procedure with the third-party servicer to ensure that its Title IV compliance report is completed in a timely manner so that the University can perform the necessary due diligence. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: For 22-23, the third-party servicer provided the compliance report in March 2024. For 23-24, the third-party servicer states the report should be available by the end of December 2024. Name(s) of the contact person(s) responsible for corrective action: Michael Dorner Planned completion date for corrective action plan: Already in place

Student Financial Assistance Cluster– Assistance Listing No. Various Recommendation: We recommend the University review its 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: An internal tracker has been created for the entire team to report why a credit balance is not released to the student; and to monitor what steps are still needed to take to clear and release the credit balance. This will allow staff and the Financial Aid Director to quickly assist when staff is unexpectedly out of the office and connect with the necessary departments. Name(s) of the contact person(s) responsible for corrective action: Amanda McCaughan Planned completion date for a corrective action plan: Put into place November 2024

Student Financial Assistance Cluster– Assistance Listing No. Various Recommendation: We recommend that the University implement a review process as it relates to R2T4. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: A report was created in response to 2022-001 that pulls all students to verify no R2T4 are missed, it was put into place and pulled at the end of the semester. This did catch the 5 students, however, instead of running at the end of the semester, it now runs every 30 days to make sure students are processed within 45 days. Name(s) of the contact person(s) responsible for corrective action: Amanda McCaughan Planned completion date for a corrective action plan: The new process started in August 2024

Student Financial Assistance Cluster– Assistance Listing No. Various Recommendation: We recommend that the University implement a review process as it relates to R2T4. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: A report was created in response to 2022-001 that pulls all students to verify no R2T4 are missed, it was put into place and pulled at the end of the semester. This did catch the 5 students, however, instead of running at the end of the semester, it now runs every 30 days to make sure students are processed within 45 days. Name(s) of the contact person(s) responsible for corrective action: Amanda McCaughan Planned completion date for a corrective action plan: The new process started in August 2024

Student Financial Assistance Cluster– Assistance Listing No. Various Recommendation: We recommend the University review its reporting procedures to ensure the 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. Registrar's Office did note that while nine students were flagged within the audit review, the final report does include an additional 18 students who were not brought to the attention of the Registrar’s Office during the audit. Action taken in response to finding: The Registrar's Office worked with the National Student Clearinghouse to identify new errors with CIP code rejects. We have now updated the curriculum in our SIS to eliminate the error and review the reject report for this specific error. The Registrar's Office will modify the report schedule with the National Student Clearinghouse to every three weeks to assist NSLDS with more time to update their website to align with compliance timelines. The National Student Clearinghouse records show the submission timeline. Name(s) of the contact person(s) responsible for corrective action: Lynn Lundquist Planned completion date for a corrective action plan: The new process started in August 2024

Inaccurate Packaging of Federal Direct Loans (FDL) Planned Corrective Action: Shorter University will provide additional training to Financial Aid Staff regarding the importance of reviewing students financial aid offers after manual adjustments are made. The training will include practice scenarios. In addition to training staff, Shorter University's Director of Information Technology is creating a quality control report that will identify students who may be eligible for a subsidized Stafford loan but have not received one. The report will be monitored by the Assistant Director of Financial Aid Systems who will review the students' financial aid. The quality control report will ensure the proper subsidized and unsubsidized Stafford loan allocation. A manual adjustment error was made to a student's financial aid offer, after financial aid was accepted resulting in an under awarding of a Stafford loan. A $3,500 unsubsidized loan to subsidized loan swap will be completed to hold the student harm less and correct the manual adjustment error. Person Responsible for Corrective Action Plan: Colleen Lassiter Anticipated Date of Completion: Training will be completed November 8, 2024 and Quality Control Report will be completed by December 15, 2024.

Individual Responsible for Corrective Action: Sarah Christoffersen, Director of Financial Aid Corrective Action: Corrective action steps have been taken to ensure that excess cash balances are eliminated in a timely manner. The corrective action focuses on the campus-based awards, as there was only one instance of non-compliance for the FSEOG, and adds an additional step between financial aid and the finance office to verify the amount of funds disbursed to students before initiating a drawdown of funds. Anticipated Completion Date: 11/1/2024

Individual Responsible for Corrective Action: Sarah Christoffersen, Director of Financial Aid Corrective Action: An incorrect satisfactory academic progress tracking status was assigned to a single student, which resulted in the one student receiving federal aid for the spring semester when they should have been marked as ineligible. The spring disbursement was corrected promptly when uncovered and funds have been returned to ED. An enhanced system is now in place to more clearly track the satisfactory academic progress of students who take a leave of absence from the university and return without demonstrating satisfactory academic progress at a different school. Anticipated Completion Date: 11/1/2024

Individual Responsible for Corrective Action: Sarah Christoffersen, Director of Financial Aid Corrective Action: This finding cumulated into three different types of issues, summarized below, and corrective action has been taken for each of the three. In addition to addressing the three issues, training has been provided to the financial aid staff for the verification process as a whole and a report is being run several times a month to identify possible data entry errors of the verification process. 3 of the 8 students had a discrepancy in their documentation that does not result in a change to their federal aid eligibility. This has been addressed by implementing an electronic signature of the verification worksheet through DocuSign. 3 of the 8 students submitted documentation for a professional judgement that was approved, however the professional judgement flag was not properly selected. This has been addressed by reviewing the professional judgement steps taken by the financial aid team and providing training to those who submit professional judgement changes in the FAFSA Partner Portal. 2 of the 8 students had incomplete documentation saved to the student file. This has been addressed by implementing an additional step in the verification process to require a second review of verification documents by two separate staff members. Anticipated Completion Date: 11/1/2024

Individual Responsible for Corrective Action: Sarah Christoffersen, Director of Financial Aid Corrective Action: All instances of this finding occurred during the fall 2023 semester while we were still in the implementation process for joining the National Student Clearinghouse. Since completing implementation, there have been no further instances. Anticipated Completion Date: Completed

Corrective action plan – Management concurs with this finding. This exception was due to Professional and Continuing Education (PCE) not being part of the withdrawal information workflow. PCE has created an e-form which will be completed by them and submitted to the Office of Financial Aid anytime a student withdrawals or takes a leave of absence. Management believes these enhancements will be sufficient to prevent future errors. Completion date: August 2024 Persons responsible: Kellie Nehring, Director of Financial Aid and Diana Hannasch-Haag, Director of Retention – Online Degree Programs

Views of Responsible Officials and Planned Corrective Actions – The National Student Clearinghouse (NSC) Graduation Status submission calendar will be updated to reflect the necessary reporting timeline and appropriate parties within the Office of the Registrar, Student Financial Services, and Office of Institutional Effectiveness will be held responsible for specific deadlines each month. The report will be completed after verification of graduation requirements and credentialing or other status changes are completed in Colleague by the Registrar's Office. Ellucian Colleague processes will be fully utilized for NSC file generation. The Registrar and Associate Registrar complete different steps in the credentialing process, but will review the student records together to ensure accuracy and timely completion. Submission of graduation status to NSC will occur after each academic term (fall and spring semester, January and summer sessions) and submission of other status changes will occur monthly and follow-ups will occur within four business days.