Corrective Action Plans

Need Analysis Planned Corrective Action: To ensure compliance with Needs Analysis regulations for the limitations of keeping aid within the Cost of Attendance (COA) both during R2T4 calculations and in overall packaging, Point Loma will use system-specific configuration our new Workday Student Financial Aid software: • Disbursement Eligibility criteria that flags “Exceeds COA”, preventing disbursement • Automatic calculations of the COA based on the number of weeks in which the student is enrolled. (Our previous software required all manual review and adjustments to COA when a student was only enrolled in a single module.) Any changes to the number of weeks or to enrollment as a whole, will result in a Need Packaging Reaction, prompting staff to re-run Cost of Attendance calculations and Need Packaging as needed. Furthermore, Point Loma will review and revise procedures for mandatory recalculations of COA, and train staff on these procedures. Person Responsible for Corrective Action Plan: Daniel Reed, Director of Financial Aid Jamie Asche, Director of SFS Business Analysis and Compliance Joanna Castro, Associate Director of Financial Aid, GPS Anticipated Date of Completion: December 31,2024

Return of Title IV (R2T4) Calculations Planned Corrective Action: To ensure compliance with R2T4 regulations for modules and the consideration of days, Point Loma will review and revise procedures for completion and clarity, and train staff on these procedures. Person Responsible for Corrective Action Plan: Daniel Reed, Director of Financial Aid Jamie Asche, Director of SFS Business Analysis and Compliance Joanna Castro, Associate Director of Financial Aid, GPS Anticipated Date of Completion: December 31,2024

October 22, 2024 RE: Finding 2024-001 Student Financial Aid Cluster Enrollment Reporting - Clearinghouse for National Student Loan Data (NSLDS) enrollment reporting for the Fall 2023 and Spring 2024 semesters. Student Affair’s response and corrective action plan. Purpose of Student Reporting Student enrollment reporting is critical, as it is sent to the National Student Clearinghouse, which then provides this data to the National Student Loan Data System (NSLDS). This information is used to determine students' enrollment status, which is essential for the administration of financial aid, particularly for calculating grace periods and repayment timelines for student loans. Corrective Actions and Process Changes Once we identified the reporting issue, we re-ran the reports using the previous method, prior to the saved list implementation, to compare the results. We thoroughly reviewed the enrollment numbers for both semesters to ensure all students were correctly reported. In addition, we contacted the National Student Clearinghouse to make the necessary corrections. To ensure this issue is fully resolved moving forward, we have implemented a more rigorous internal process, including thorough testing and random sampling. We now compare reported enrollment data against actual student enrollment for each semester, allowing us to verify that all students are accurately reported. These enhanced measures will safeguard against similar oversights in the future. Challenges with Clearinghouse Resolution While we completed our internal corrections, we experienced significant delays in finalizing the data updates due to customer service challenges on the National Student Clearinghouse’s side. After escalating the issue, we were able to receive assistance from a representative on October 23rd, which we believe will resolve the discrepancies. Expected completion date: 10/31/24 Partys Responsible: Dr. Jason Johnson, Vice President for Student Affairs - Amanda Williams- Mize, Assistant Vice President for Enrollment Services, Registrar Contact Information: jason.k.johnson@occc.edu 405-682-1611 ext. 7784 amanda.williams-mize@occc.edu, 405-682-7537

2024-001: Late Return of Title IV Financial Aid - Student Financial Aid Cluster – Assistance Listing #s 84.007, 84.033, 84.063, 84.268 - Grant Period - Year Ended June 30, 2024 Condition Found During our Return of Title IV Fund testing, we noted that the College did not calculate or return Title IV Student Financial Aid for two out of twenty-five students tested until after 45 days when the student ceased attendance. We consider the untimely calculation and Return of Title IV Student Financial Aid to be an instance of noncompliance relating to the Special Tests and Provisions Compliance Requirement. Corrective Action Plan The weekly R2T4 report that identifies student withdrawals will be reviewed on a weekly basis. During these reviews we will focus on the timely calculation and disbursement of earned Title IV aid. Responsible Person for Corrective Action Plan Ana Mirnic, Financial Aid Program Manager Leana Davis, Executive Director of Financial Aid Implementation Date of Corrective Action Plan October 1, 2024

It is our understanding that the issue is occurring for many institutions and appears to be due to changes in processes at the National Clearinghouse. We will monitor steps taken and updates made from professional organizations such as NASFAA to maintain awareness of any resolution to the issue made at the Clearinghouse. We will also develop an internal process to review student status effective dates as reflected in NSLDS and make updates as needed.

Finding 2024-002 Reporting-According to 34 CFR 690.83, Dear Colleague Letter Gen 13-13, and Federal Register Volume 84, Number 212, November 1, 2019 an institution must submit Pell and Direct Loan Origination and Disbursement (COD) in imely and accurate manner Condition-Cost of attendance per the College's system did not agree with the reported cost of attendance reported per COD records. Corrective Action Plan-A periodic check will be done to ensure Banner and the COD system have the same COA. If systems do not match Financial Aid Director will work with COD and Ellucian to resolve the issue Responsible contact-Lynette Viskozki, Financial Aid Director Anticipated Completion-December 1, 2024

Finding 2024-001 Special Tests and Provisions-Return of Title IV (34 CFR 668.22(a)(1) through (a)(5) Condition-The College's internal controls did not ensure the calculation of amounts to be returned to the U.S. Department of Education were correct Corrective Action-All withdrawals that result in less than a 60% attended ratio, R2T4 calculations will be calculated by the Financial Aid Director and reviewed by thte Assistant Director. Both will attest to the accuracy by placing their initials on the calculation worksheet. Responsible contact-Lynette Viskozki, Financial Aid Director and Quintina Miles, Assistant Financial Aid Director Anticipated Date of Completion-November 15, 2024

2024-002 Initial Fiscal Year End, 2024 Summary of Finding- During the audit, it was noted that the University's Gramm-Leach-Bliley Act Policy did not fully address all of the requirements as described by 16 CFR 314.4. In addition, the application of the comprehensive information security program was not effectively administered by the University during the 2024 year. An updated policy was put into place in February 2024, which addressed several of the deficiencies noted in the existing policy, but not all. Name and Title of Responsible Contact Person(s)- Sara Shepherd, Vice President for Finance Corrective Action Plan Summary-The university recently reviewed the Gramm-Leach-Bliley Act Policy and has put in place controls and practices to effectively monitor antl administer the policy. In April 2024, we hired an IT company to help with various campus needs, including data compliance procedures and security measures. The company has been reviewing our current policies and making recommendations to implement appropriate safeguards to keep the university up to date and compliant. We have already installed multi-factor authentication features for our software systems, and there are more updates to come. In July 2024, we received a notice of compliance from the Federal Student Aid regarding our corrective action procedures for the Gramm-Leach-Bliley Act. Anticipated Completion Date- July 1, 2025

2024-005 Initial Fiscal Year End, 2024 Summary of Finding- During the audit, it was noted that the University returned funds in an incorrect sequence during the Return to Title IV Funds process upon student withdrawal. Name and Title of Responsible Contact Person(s)- Sara Shepherd, Vice President for Finance and Nicole Umphlett, Financial Aid Administrator Corrective Action Plan Summary-The University's Vice President of Finance and Financial Aid Administrator recently attended a week-long workshop and received training to complete the R2T4 calculation via COD. The training was received after the infringements and a plan has been adapted to utilize COD for future R2T 4 calculations and sequence. The school calendar has been updated in COD for correct future calculations and sequence. Anticipated Completion Date- July 1, 2025

2024-004 Initial Fiscal Year End, 2024 Summary of Finding- During the audit, it was noted that the University used the incorrect sum of aid disbursed or disbursable to the student when applying the percentage earned in calculating the return to Title IV Funds upon student withdrawal. Name and Title of Responsible Contact Person(s)- Sara Shepherd, Vice President for Finance and Nicole Umphlett, Financial Aid Administrator Corrective Action Plan Summary-The University has enhanced the process of completing return to Title IV calculations by incorporating additional training and workshops provided by the Department of Education. The financial aid office has continued with the implementation of the calendar that displays the attendance days from the first day of school to the last day of school, referring to the school's master calendar. The financial aid office added an extra verification step of written notification from the Registrar's office of beginning and end days for each semester. The return calculations were one day off due to the misinterpretation of the semester's ending date. Anticipated Completion Date- July 1, 2025

2024-003 Initial Fiscal Year End, 2024 Summary of Finding- During the audit, it was noted that the University used the incorrect number of total days in the payment period or period of enrollment in calculating the percentage of payment period and/or period of enrollment completed. Name and'Title of Responsible Contact Person(s)- Sara Shepherd, Vice President for Finance and Nicole Umphlett, Financial Aid Administrator Corrective Action Plan Summary-The University improved the process for completing return to Title IV calculations by adding in additional training and workshops offered through the Department of Education. The financial aid office continued with the calendar process showing days of attendance from the first day of school to the last using the school's master calendar as a reference. This will be used also as a double check of days when calculating returns. The dates used in the return calculations were off a day due to misreading the ending date of semester. The Financial Aid Administrator verified the beginning and last day of each semester with the Registrar's office in writing. Anticipated Completion Date- July 1, 2025

Audit examination revealed that some students' records were not updated correctly in the National Student Loan Data System (NSLDS). Specifically, these records were either incomplete or inaccurate in reflecting student enrollment statuses. After reviewing the issue, the primary reasons identified is a known error code within the NSLDS system, referred to error code 75. Students are flagged with a status error, Z (No Record Found). We know more students have this error flag than were selected for audit. We have determined batches of records that need updated. Steps Already Taken to Correct Issue • Action was taken with Student Clearinghouse (NSC), July 23, 2024, our Registrar reached out for assistance to resolve. Guidance was the specific error codes, such as NSLDS Error Code 75, flagged, consult the NSLDS and NSC for guidance on correcting these errors (NSLDS SSCR Error Code 75). • Financial Aid Director reached out to NSLDS, August 7, 2024 for resolution. Guidance was given as follows: "CSR advised that the resolution for Error code 75 is to make sure they aren't trying to report program level enrollment data in the batch when they have already report X or Z. CSR advised they should be reporting N for the program indicator. CSR advised they can report this in a batch to resolve all the issues. CSR advised if they continue to have issue then they can call us back so we can do further research". • Manual corrections have been implemented in NSLDS for all 7 students selected for audit with error codes, NSLDS now to reflects an accurate status for these students. Next Steps to Correct Issue • Resubmit the corrected enrollment data to NSLDS, if batch submission is possible. lnclude cross-verification with internal records to ensure accurate reporting. * lf batch correction is not possible or successful, manual corrections to records will be executed until all records are resolved. • Review and verification of student records for the affected students to ensure accurate enrollment data is reflected. Correct the discrepancies in the NSLDS system manually. Preventative Actions: * Provide additional training to the staff for reporting to ensure the requirements for accurate and timely updates of student enrollment data. • Conduct monthly internal audits to verify that student enrollment statuses are correctly updated in NSLDS. Review of random student records in NSLDS to confirm that updates are made in compliance with federal guidelines.

Student Financial Assistance Cluster – Federal Assistance Listing Numbers 84.007, 84.033, 84.038, 84.063, 84.268 Recommendation: We recommend the College evaluate its policies and procedures to ensure there is a process in place to ensure timely refund of Title IV credit balances. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Student Accounts Office has revised the procedures surrounding all student balances. Balances will be evaluated once a week and a refund will be issued in the next check run. Previously, the Office was conducting this evaluation for the first few weeks of the semester or when a special case occurred. In addition, an error in the report excluded certain balances. The Office has now revised the report to include all students. Name(s) of the contact person(s) responsible for corrective action: Carrie DiEnna Planned completion date for corrective action plan: August 1, 2024

We observed the following condition in connection with our testing of the various U.S. Department of Education, Title IV, Student Financial Assistance Programs: • Per 34 CFR 668.34, one (1) student out of 15 tested for satisfactory academic progress requirements (SAP) received Title IV, HEA program funds in the amount of $6,342 and was not meeting the requirements specified by the University. The University subsequently returned the funds. The University should implement corrective actions to ensure that the above findings are resolved and do not recur in future periods. Corrective Action – The University agrees with the finding. To address, the University’s registrar’s office will flag students in the student information system and place a registration hold on their account if they are not currently meeting Satisfactory Academic Progress (SAP) requirements. The financial aid office will check for all holds, any former SAP corrective actions and ensure that all students, including those re-entering the University following an absence, are meeting SAP requirements.

Eligibility Federal Program Title: Student Financial Assistance Cluster Assistance Listing No. 84.063 Type of Finding: Significant Deficiency in Internal Control over Compliance Other Matters Recommendation: We recommend the University 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: The University has reviewed its current procedures for awarding Title IV funds and modified edit reports to find Pell-eligible students who had previously been inactivated or not yet awarded for an aid period to be reviewed and awarded accordingly. Name(s) of the contact person(s) responsible for corrective action: James Martin, Director of Financial Aid and Jody Finnegan, Associate Director of Financial Aid Planned completion date for corrective action plan: 09/18/2024

Special Tests & Provisions Federal Program Title: Student Financial Assistance Cluster Assistance Listing No. 84.033, 84.268, 84.063, 84.007 Type of Finding: Significant Deficiency in Internal Control over Compliance Other Matters Recommendation: We recommend that the University implement procedures to ensure that enrollment data, changes in status and effective dates within NSLDS match the records of the institution and are reported timely. And we recommend that the College implement formal review procedures to document the review process. Explanation of disagreement with audit finding: There is no disagreement with the audit findings. Action taken in response to finding: The Office of the Registrar is following the best practices for reporting official withdrawals. We are recording the actual withdrawal date initiated online by the student. We do not have a problem in recording unofficial withdrawals taken from Moodle (as determined by Financial Aid) as long as there is a consensus from Enrollment Management on changing the practice used. I suggest the Financial Aid, Registrar, and Enrollment Management get together to determine the best course of action. Name(s) of the contact person(s) responsible for corrective action: Hala Abou Arraj, Registrar Planned completion date for corrective action plan: 09/01/2024

Finding 2024-002: Disbursements to or on Behalf of Students – Credit Balances Corrective Action Plan: We concur with the auditor’s finding. This was a unique situation as the refund in question related to interterm for which there are no charges. The student completed interterm but did not return for spring. Refunds are a very manual process and the late refund in question was an oversight. There have been multiple changes made since the fiscal year under review. We will no longer be offering an interterm session which presented unique challenges around student accounts and financial aid. We have implemented an updated accounting software which will simplify the process of reviewing accounts for refunds. We have a new staff person in student accounts and have reviewed all processes related to the issuance of refunds. We are reviewing accounts and issuing refunds on a weekly basis. We believe these changes will reduce the likelihood of a late refund. Contact Person Responsible for Corrective Action: Carol Summervill, VP for Finance Anticipated Completion Date: Corrective Action was completed as of the date of this report.

Finding 2024-001: Perkin’s Loan Recordkeeping and Record Retention Corrective Action Plan: We concur with the auditor’s finding. As we were unable to assign the loan, we reimbursed the Perkins fund for the full amount of the outstanding loan, interest and fees. The loan is fully paid off. Contact Person Responsible for Corrective Action: Carol Summervill, VP for Finance Anticipated Completion Date: Corrective action was completed October 9, 2024.

Pittsburgh Institute of Mortuary Science Student Financial Aid Audit Corrective Action Plan This corrective action plan is in response to the institute's single audit report for the year ended June 30, 2024, prepared by McClintock & Associates, P.C. Finding 2024-001: Pell Grant Award Recommendation: The Institution should adjust the 2023-2024 Pell awards according to the amounts listed in Summary. Corrective Action: The Institute has returned the Pell awards in the amounts listed in the Summary. The Institute wrote off the dollar amounts so as not to penalize the students identified. The Institute has also reviewed all students who received a Pell award du1ing the current Fiscal Year and recalculated and returned funds appropriately. The Institute again wrote off these dollar amounts. The Institute now has a clear understanding as to how and when the Pell awards should be recalculated. Since this item directly applies to our online student population only, the Institute has rewritten and implemented a specific "Pell Recalculation for Online Students" portion into the already robust Withdrawal procedure. Additionally, the Institute has initiated a weekly meeting to review all students who changed statuses during the prior week. Any online, Pell-eligible students will be recalculated during the meeting and funds will be returned within 7 days of the meeting when deemed necessary. Persons Responsible for Corrective Action: Financial Aid Advisor, Senior Financial Aid Administrator, and Registrar/Director of Administrative & Student Services. Anticipated Completion Date for Corrective Action: The Corrective Action was immediately implemented in response to the auditors' recommendation.

Student Financial Assistance Program Cluster - Department of Education Federal Financial Assistance Listing #84.063 Federal Pell Grant Program P063P222212, P063P232212 Federal Financial Assistance Listing #84.038 Federal Perkins Loans Federal Financial Assistance Listing #84.007 Federal Supplemental Educational Opportunity Grants P007A223837, P007A233837 Reporting Significant Deficiency in Internal Control over Compliance Finding Summary: The amount reported for Cash on Hand as of 6/30/2023, line-item Part II Section A Field Item 1.1, did not agree to supporting documentation Responsible Individuals: Michael Van Surksum, Vice President for Business and Finance Corrective Action Plan: Management will review their current process to ensure that line items reported are accurate. Anticipated Completion Date: June 30, 2025.

Student Financial Assistance Program Cluster - Department of Education Federal Financial Assistance Listing #84.063 Federal Pell Grant Program P063P222212,P063P232212 Eligibility Significant Deficiency in Internal Control over Compliance Finding Summary: One student was not awarded Pell assistance during the summer term as the student's FAFSA was not completed at the time the financial aid office was determining award eligibility. The student later completed the FAFSA within the award year and became eligible for a retroactive disbursement of Pell assistance; however, the financial aid office did not provide the student a retroactive disbursement of Pell. Responsible Individuals: Karrie Morgan, Director of Financial Aid Corrective Action Plan: Management will review procedures and control processes over monitoring retroactive disbursements. Anticipated Completion Date: October 31, 2024.

The issues identified in the previous audit were identified part way through fiscal year 2023. Corrective actions identified in the prior audit and listed below are in place going forward. To address these issues, SBU employees have taken the following corrective measures: 1. We reworked the reporting process for withdrawals. All withdrawals now go to the Associate Provost regardless of campus or program. They are then processed by the Registrar's Office and placed in a shared drive. Once there, they are reviewed weekly by the Financial Aid Office, and R2T4s are completed in a timely manner. If there are any withdrawals outside of the normal process timeframe they are escalated and the Registrar and Executive Director of Financial Aid are notified. 2. R2T4 requests are completed by one Financial Aid staff member and verified and processed by another to ensure accuracy and reliability. 3. We have implemented an administrative withdrawal process to give campus and program directors the ability and authority to withdraw students who are no longer in attendance to limit the number of all Fs at the end of the semester.

Due to turnover in the Controller position, the calculations for the FISAP cash balances was not retained in a shared drive for future reference and audit review. This practice is against University policy and resulted in the inability of current staff to produce the documentation for audit review. To address these issues, SBU employees have taken the following corrective measures: 1. The current Controller will adhere to University policy and save documentation in a shared drive for future review and reference.

Marshall B. Ketchum University Corrective Action Plan For the Fiscal Year Ended June 30, 2024 U.S. Department of Education – Student Financial Assistance Cluster Federal Awards Finding Item 2024-001 – Special Tests and Provisions – Return of Title IV Funds – Significant Deficiency In Internal Controls Over Compliance Conditions – A sample of seven students out of a population of 21 were identified by the University as having received some federal assistance and withdrew from the University during the year under audit. The auditors found two calculations of the return of Title IV funds contained errors related to the total number of days in the term because consideration for the exclusion of certain days from the winter scheduled break were not properly implemented. This calculation error caused two of the seven samples to have the wrong total of aid earned because those two students had withdrawn before the 60% completion threshold. In this same sample universe, two students had incorrect calculations of values to be returned because the institutional charges were not included in the R2T4 calculation. In both cases, the students began a term while the school evaluated their academic performance form the previous term. The students were dismissed from their respective programs based on academic performance, but the school refunded full tuition and fees as the students were not given adequate opportunity to attend the terms for which they withdrew. As such, the school had considered the full tuition refund as a $0 institutional charge on the R2T4 calculation which caused calculation errors for what was earned in the term. These two errors caused an understatement of $24,127 unsubsidized loan that would be required to be returned by the school. Corrective Action Plan: In response to the findings regarding Return of Title IV funds Marshall B. Ketchum University is taking the following corrective actions. The Financial Aid Office has revised the Return of Title IV Aid policy to now include the following statement: When calculating the amount the school must return, the tuition and fee charges that were applicable at the time of withdrawal are used for purposes of calculation the Return of Title IV funds. Any subsequent tuition and fee refunds credited back to the students account after the withdrawal date will not be taken into consideration for purposes of calculating the Return of Title IV funds. The revised R2T4 policy above will be updated in the university catalog as well. When Financial Aid is processing the configuration and system setup for the upcoming academic year, we will take into account any additional days in which there are no scheduled classes that are not included in the university defined scheduled breaks. For example, if the scheduled Winter Recess break as defined by the University Registrar for the 2024-2025 academic year is 12/23/24-1/5/25, we will also include 12/21/24 & 12/22/24 as part of the scheduled break for Return of Title IV purposes, as there will be no scheduled classes on those days. This will increase the scheduled break for R2T4 purposes from 14 to 16 days and will be excluded from the R2T4 calculation. The scheduled R2T4 breaks for the 2024-2025 academic year have already been reviewed and confirmed for compliance purposes per FSA R2T4 regulations. The Director of Financial Aid has reviewed the Title IV federal regulations on Return of Title IV funding and acknowledges the issues and is prepared to be compliant going forward. In addition, Financial Aid Staff will be properly trained and will continue to be trained as needed. Sincerely, Kyle Pryor, Director of Financial Aid, (714) 449-7448 Projected Completion Date: October 15, 2024

The following is the Student Financial Aid Corrective Action Plan for the single Audit Finding for FY24. Criteria or Specific Requirement: – Special Tests and Provisions – Return of Title IV Funding (R2T4), 34 CFR Section 668.22 Finding Summary: The calculation and process for Return to Title IV (R2T4) calculations were not processed correctly for a student with a Federal Pell Grant. Officials Responsible for Ensuring Corrective Action: Stacey Harris, Director, Student Financial Aid Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding and has implemented procedures to ensure Return to Title IV (R2T4) calculations are correct and the return of Title IV funds are accurate. To ensure precise Return to Title IV (R2T4) calculations for all students receiving Federal Pell Grant disbursements, each student's file will include an independent manual calculation which will be compared to the PeopleSoft system’s automated calculation. Written policies and procedures have been updated, with changes implemented as of August 31, 2024.