Corrective Action Plans

Finding: 2024-002: Special Tests and Provisions – Enrollment Reporting: Significant Deficiency in Internal Control Over Compliance Corrective Action Plan: The College acknowledges the delay in transmitting a student's graduation status to the Clearinghouse/NSLDS. This was due to a retroactive graduation date change following a thesis review. We are revising our internal policy to ensure timely submission of enrollment status changes and will implement sample checks after each transmission date. Contact Person Responsible for Corrective Action: Deputy Director of Financial Aid, Eleanor Wu has implemented the corrective action plan. Anticipated Completion Date: Corrective action was completed by October 2024.

Finding: 2024-001: Special Tests and Provisions – Return of Title IV: Significant Deficiency in Internal Control over Compliance Corrective Action Plan: The College acknowledges the oversight in configuring the system for Spring 2024 enrollment breaks and has taken corrective measures to ensure system accuracy. At least two financial aid officers will now verify semester start/end dates and break periods, and the 60% mark will be calculated at the beginning of each semester. Additionally, the COD R2T4 calculator will be used for comparison with internal calculations. Withdrawal and R2T4 policies are also being updsated for the 2024-25 College catalog. Contact Person Responsible for Corrective Action: Deputy Director of Financial Aid, Eleanor Wu has implemented the corrective action plan. Anticipated Completion Date: Corrective action was completed by October 2024.

Memo: Audit Findings 2023-2024 Submitted by: Karson Kent, University Registrar Date: 9/13/2024 Below is a description of and explanation for the 3 findings from the 23-24 audit pertaining to the Registrar’s office. Also included is an explanation of how the findings have been addressed, and the action that has been taking to prevent them from happening in the future. ETBU uses the National Student Clearinghouse for enrollment reporting to the National Student Loan Data System. Case 1 – Student 1 withdrew from the spring term on 1/29/2024, but withdrawal was reported as end of fall 2023. Case 2 – Student 2 withdrew from the spring term on 1/31/2024, but withdrawal was reported as end of fall 2023. Error: The enrollment report was being pulled and sent to the National Student Clearinghouse (NSC) after the census date when roster certifications and withdrawal requests, up to that point, had been processed. Students 1 and 2 both withdrew during the roster certification period, which was before the census date, but after late registration had ended. Their withdrawals were processed in the Registrar’s office before the initial enrollment report was pulled, and since they received W’s for the term, they should have been reported for the term to the NSC. In researching the finding, it was discovered that the system is set up to only include students in the enrollment report who are enrolled as of the date that the first report is pulled. This means that students 1 and 2 were never included in the initial enrollment report for spring 2024, and therefore weren’t captured on any of the subsequent of term reports that notify the NSC of enrollment changes throughout the semester. This made it look like they never attended ETBU in the spring, which is why the NSC showed their withdrawal to be the end of the fall term. Action Taken: Students 1 and 2 enrollments for the spring 2024 term have since been corrected with the NSC. Additionally, since learning how the report is set up, the Registrar has been in discussion with the Director of Financial Aid and Institutional Research, to figure out the best timeline for processing the enrollment report moving forward. It has been determined that the initial enrollment report needs to be submitted as soon as late registration ends, so that everyone who is registered for the term is captured on the report. Once the roster certification period is over, students who have been reported as not attending will be dropped, and any University withdrawal request will be processed. Once those things have been done, the Registrar will submit the first subsequent of term enrollment report to the NSC. This will ensure that any enrollment changes that have happened after registration ended up to census date get reported within the time frame needed by Financial Aid. Case 3 – Student 3 was reported as withdrawn after the fall 2023 term, but actually graduated. Error: Student 3 should have been reported to the NSC as a fall 2023 graduate, but was not included on the graduation report. In investigating it appears student 3’s degree was conferred after the fall graduation report had already been submitted, and the Registrar was not made aware of the discrepancy. Since student 3 was not reported as graduated for fall 2023, and was not enrolled in the spring 2024 term, they were considered withdrawn through the the NSC. Action Taken: Student 3’s status has been changed from withdrawn for the fall 2023 term to graduated, with the NSC. To prevent this from happening in the future, the Graduation Certification Officer has been made aware to notify the Registrar anytime a degree is conferred outside of the normal time frame, so that it can promptly be reported to the NSC. As an added measure moving forward, after degrees have been conferred for a standard term, the Records Assistant will double check all the degrees conferred to help ensure that nobody was missed.

Students in the Pell Grant Verification Status (PGVS) file will be reviewed by a Financial Assistance Advisor for Pell and another Financial Assistance Advisor for Verification to make sure all appropriate flags are set correctly in the system. Once this review is complete, Pell will be re-originated. If students persist in the PGVS file, a help desk ticket will be filled with our Information Technology department to investigate why the record is still showing as not verified. This new review process will provide additional oversight in the verification process.

The College acknowledges that a submission error occurred in Spring 2023, resulting in several students not being included in the routine semester enrollment submissions to the National Student Clearinghouse (NSC). Beginning in Spring 2024, our Institutional Research department initiated a comprehensive process to resubmit corrected enrollment files to the NSC, covering Spring 2023, Summer 2023, and Fall 2023. In collaboration with NSC, we followed their established process to rectify the error, which required reloading each submission one at a time in succession from the original submission with the error. This process caused delays in our subsequent submissions until the corrections were fully completed. To prevent recurrence, we have implemented enhanced checks and controls prior to each submission to review the file and file size to ensure the correct number of students are submitted to NSC. Additionally, all submissions post-Spring 2023 have been reviewed, and we have confirmed that this was an isolated incident.

2024-001 – Special Tests and Provisions - Enrollment Reporting. Auditor Description of Condition and Effect. During our testing we noted that twelve students out of a testing population of twelve did not have the correct program begin date reported to NSLDS. As a result, there is an increased risk that incorrect information will be reported to NSLDS. Auditor Recommendation. We recommend that the Organization enhance its policies and procedures regarding enrollment reporting to ensure that reporting is completed accurately. Corrective Action. The institution concurs with the finding. The errors resulted from a system default date used to complete enrollment reporting that has been updated to reflect each student’s program beginning date accurately. The Registrar and IT office have rectified the issue and will implement a semester-based review of the program begin dates per incoming cohort or student to prevent this issue from occurring again. A review with NSC (National Student Clearinghouse), used to complete enrollment reporting, was completed on the following dates: - May 2024 Graduated Students Report updated/uploaded w/correct program start dates: June 28th, 2024. - Summer 2024 Semester Students Term Report updated/uploaded w/correct program start dates: July 23rd, 2024. -Fall 2024 Semester Students Term Report updated/uploaded w/correct program start dates: August 26th, 2024. Responsible Person. Kristy Kryszczak. Anticipated Completion Date. A new system was implemented on June 28th, 2024, to update the correct program start dates for each student moving forward.

Finding Summary: Upon review of the FISAP it was determined the following field items were inaccurately reported.  Part II Section D Field item #7 – Undergraduate students enrolled reported of 822, should have reported 1,080. Graduate students enrolled reported of 290, should have reported 172.  Part II Section F Field item #35 – Eligible dependent undergraduate aid applicants without 1st prof. degree under taxable and untaxable income of $36,000 - $41,999 reported 17 students, rather, should have been 18 students.  Part II Section F Field item #39 – Eligible dependent undergraduate aid applicants without 1st prof. degree under taxable and untaxable income of $60,000 and over reported 358 students, rather, should have been 361 students.  Part II Section F Field item #39 - Eligible independent undergraduate aid applicants with 1st prof. degree under taxable and untaxable income of $20,000 and over reported 6 students, rather, should have been 0 students. The 6 students should have been reported under eligible dependent undergraduate aid applicants with 1st prof. degree line items, affecting field items #32, 34, 35, 37 and 39. Reports used to prepare the FISAP were incorrect, thus the information reported within the FISAP was inaccurate. The FISAP review process failed to identify the inaccurate information. Responsible Individuals: Lauren Svanda, Director of Financial Aid Corrective Action Plan: The Financial Aid Office and IT determined where the report needed to be generated in order to produce the unduplicated number of students that needs to be reported on the FISAP. The uncertainty of where the report comes from and what needs to be reported has been eliminated. We will continue to work with our IT department to ensure the reports are being run correctly and numbers are being reported accurately on the FISAP Application. The Director of Financial Aid and the Accountant will prepare the FISAP Application, with the VP for Enrollment Management and VP for Finance and Administration reviewing respective sections prepared by the Director of Financial Aid and Accountant. Anticipated Completion Date: September 2024

Finding Summary: One instance was identified in which the student was over-awarded Federal Pell assistance. The Watertown location does not use the auto package tool within Anthology for awarding students; rather, awarding student assistance is a manual process. The incorrect line item was read on the PELL chart resulting in the student being over-awarded Pell assistance in the summer of 2023. Responsible Individuals: Lauren Svanda, Director of Financial Aid Corrective Action Plan: When implementing the FAFSA changes for 2024, the SIS was configured to utilize the Auto Packaging function for the Watertown location which significantly reduces the likelihood of a student being awarded the incorrect amount of PELL. After each student is Auto Packaged, it is reviewed to ensure accuracy of the PELL calculation. Anticipated Completion Date: Resolved – Spring 2024

The technical issues experienced during the computer system migration with the report writer are resolved. This required a complete rewrite of reports due to change in a report writing platform. The Office of Financial Aid will monitor the reports which identify the Return of Title IV student population for accuracy of population and timing of the calculation. Moving forward, in the event there is another reporting system failure, the college will utilize programming to identify the students and grades reported in the ERP system for the semester, allowing the college to determine the appropriate course of action for each student.

Finding Number: 2024-001 Federal Assistance Listing Number: 84.268 Federal Direct Student Loans Year Ended: June 30, 2024 Responsible Individual: Christine Banewicz Director of Student Accounts Management’s Response and Corrective Action Plan: The College agrees with the finding and recommendation. The College ran a report of Direct Loan disbursements made during fiscal year 2024, noting that the required communications had not timely been sent out for 43 Direct Loan disbursements that took place from May 31, 2024 through June 30, 2024. Upon discovery of the change in criteria, management identified the students that had been impacted and sent disbursement notifications to students the next day, on July 31, 2024. Management has implemented in their control process an additional step to compare reports of Direct Loan disbursements between the Student Information and Financial Aid systems to identify any discrepancies going forward. The above procedures have already been implemented.

Untimely Returns of Title IV Funds (R2T4) Planned Corrective Action: Exception found during audit on several student returns of their Title IV aid. This was due to multiple factors. Campus Nexus, our SIS system, reported dates for LDA that did not line up with the drop date indicated by the professors on withdrawal/drop forms. A major shift in management of the Registrar’s office also occurred this year that left gaps in information. Our Student Life department that tracks start activity for a term did not translate data to our department for students with loans since they do not track loan borrowing in their system. During audit allstudents were reviewed, in addition to selections to ensure that LDAs were accurate for any R2T4s. As of the Fall 2024 term we will still run our Campus Nexus reports but will be reviewing all dates against withdrawal/drop forms for LDA listed by the professor. The Registrar’s office has a new staff that we are working closely with to ensure accurate data. We also are working directly with Student Life to review inactivity lists the first and second week of classes and are tracking students with loans. Any student with a loan without activity within the first week of classes, we will be returning funding. If they start activity in the second week and maintain activity prior to being dropped at the third week, we can reinstate their loans at their request. Person Responsible for Corrective Action Plan: Gina K Kelbert, Director of Financial Aid Anticipated Date of Completion: Effective since beginning of Fall term 2024.

Name of Responsible Individual: Courtney Thompson-Ballard, Director of Financial Aid Condition: The University did not accurately verify all required information for 2 students. Corrective Action Plan: The University has reviewed its current verification practices. As a result, the Office of Financial Aid will enhance its policies and procedures to ensure accurate verification outcomes. These enhancements will include additional training for financial aid counselors through both internal and external resources, the implementation of the NASFAA Tax Transcript Decoder documentation, and periodic secondary reviews. Anticipated Completion Date: 12/31/2024

Name of Responsible Individual: Courtney Thompson-Ballard, Director of Financial Aid Condition: For certain students identified through our testing, the University did not submit Federal Pell Grant payment data through the COD website within the required timeframes. Corrective Action Plan: The University has evaluated its current practices to confirm student enrollment dates. As a result, the Office of Financial Aid will enhance its policies and procedures for processing Pell grant originations to ensure that accurate enrollment dates are recorded for reporting purposes. These enhancements will include updates to the university’s Pell processing procedures, conducting a simulation of the origination file prior to the official submission to the Common Origination Database (COD), additional training for staff, and implementing periodic secondary reviews. Anticipated Completion Date: 10/31/2024

Name of Responsible Individual: Alex Putzer, AVP of Business and Finance Condition: The University had one instance during the year that were identified in which Title IV funds drawn were held in excess of the allowable time frame. Corrective Action Plan: This is the first time, to the University’s knowledge, that this error has occurred. We believe it was a one-off employee manual oversight, and not a systemic issue. We believe the general procedures for performing the Title IV drawdowns are in good standing; however, we will add a process where the AVP of Business and Finance regularly reviews the Title IV drawdowns to prevent this in the future. Anticipated Completion Date: 12/31/2024

Name of Responsible Individual: Alex Putzer, AVP of Business and Finance Condition The University did not return credit balances to students within the required timeframe. Corrective Action Plan: The University experienced significant turnover of staff in the Business Office, particularly in Student Accounts, during summer 2024 through fall 2024. The University recognizes that there needs to be better checks and balances in place to ensure all credit balances triggered by federal aid are properly refunded to students within the 14-day required period. Director of Student Accounts will more frequently post financial aid awards on student accounts, once a week at a minimum. The Business Office will monitor all refunds and process them weekly. Additionally, a concerted effort to have the majority of students signed up for eRefund will be made priority. The AVP of Business and Finance will review the status of all credit balances on Student accounts’ on a weekly basis throughout the year to ensure timely reimbursement. Anticipated Completion Date: 11/30/2024

Name of Responsible Individual: Jeni Wyatt, Assistant Provost for Undergraduate Education Condition: The University did not report students' status changes accurately and within the required timeframe. Corrective Action Plan: The University experienced significant turnover of staff in the Registrar’s Office in late fiscal year 2023 through fiscal year 2024. This turnover unfortunately was the catalyst for untimely student status change submissions to the NSLDS. This was identified during the 2023 fiscal year-end audit; however, the situation was not able to be rectified until well into the 2024 fiscal year. The University has hired three new permanent staff and an interim registrar, as we search for a permanent registrar. This group has been working with the clearinghouse personnel to work out errors, and reporting is now being addressed in a timely manner. Anticipated Completion Date: 10/31/2024

Responsible party: Mr. Shawn Mathis, Associate VP and Controller Hendrix College concurs with the audit finding related to the Return of Title IV funds for a portion of a Student’s Pell Loan. The College offers the corrective actions as outlined below. For any further questions or requests for further information, please contact Mr. Shawn Mathis, Associate VP and Controller for the College at 501-450-1474, or email mathis@hendrix. Once a student withdraws from the institution, official notification is sent from the Registrar’s office. Upon notification, the Financial Aid office has a process in place whereby a staff member reviews the student’s account and completes a checklist. If it is determined that the student has federal aid, the student’s record will be forwarded to another staff member to complete the Return of Title IV calculation. In this case, the student did not receive any federal loans other than the Pell and the employee simply checked the wrong box in regard to federal loans. After reviewing the finding with the Office of Business and Finance and the Department of Financial Aid it was agreed that additional documentation would be included in the student’s exit packaging that would be reviewed by the supervisor to serve as additional oversight of the student’s financial aid awards to determine if a Return of Title IV calculations is warranted. In addition to increased documentation within the Financial Aid Office, the business office will review all accounts of withdrawn students to determine if any federal aid was received and if so, will communicate with the Financial Aid office to verify that a Return of Title IV calculation was performed. Estimated completion date: August 2024

Student Financial Assistance – Assistance Listing No. Various Recommendation: We recommend the University review their current policies and procedures around credit balances and ensure the processes in place are sufficient to ensure student credit balances due to federal funds are refunded within 14 days. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Individual(s) responsible for processing refunds will review the current internal procedures for processing refunds and student account credits. They will also review the federal guidelines regarding Title IV funds available on fsapartners.ed.gov. After review, the Manager of student accounts will meet with this staff to ensure understanding of procedures and look for areas of improvement and opportunities for clarity. The Manager will also review current procedures to ensure documents are up-to-date and look for areas that require revision. Manager will review current reporting within the Workday system to ensure proper information is being pulled at time of running reports. Names of the contact persons responsible for corrective action: Sirena Huppert, Manager of Student Accounts Planned completion date for corrective action plan: January 1, 2025

Recommendation: We recommend the College review their policies and procedures surrounding FISAP reporting. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Fiscal Operations Report for 2023-2024 and Application to Participate for 2025-2026 (FISAP) for the Campus-Based programs is the second FISAP the Financial Aid & Scholarships Director has completed. The error on the FISAP was the enrollment number. The Financial Aid & Scholarships Director was first provided with a number from the Office of Institutional Effectiveness that was still being further calculated and checked for accuracy. Currently, in our new student information system, reporting and verifying correct numbers is more time-consuming. The Director later received the accurate number and updated the FISAP. Name(s) of the contact person(s) responsible for corrective action: Andrea Padilla-Rosas Planned completion date for corrective action plan: October 2024

Recommendation: We recommend the College review their current policies and procedures around credit balances and ensure the processes in place are sufficient to ensure student credit balances due to federal funds are refunded within 14 days. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Student refunds are processed within 48 hours according to our standard procedures, which ensures that refunds are processed within 14 days according to the federal requirements. However, in the instance of this finding, it appears that the procedure was not followed due to unusual circumstances. We will add a step to our procedure that requires the supervisor to oversee that the credit balance is refunded within guidelines of 14 days. Name(s) of the contact person(s) responsible for corrective action: Robyn Hansen Planned completion date for corrective action plan: October 18, 2024

Recommendation: We recommend that a process is put in place to ensure that all students selected for verification are being reported to the Common Origination Disbursement (COD) system. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: We have a designated staff member who ensures that all students selected for verification are being reported to the FAFSA Portal. Please note the Department of Education has listed on their FAFSA Portal that 24/25 verification reporting is not currently available, and schools will be notified when it becomes available. At that time, all 24/25 verifications will be reported in the FAFSA Portal. Name(s) of the contact person(s) responsible for corrective action: Andrea Padilla-Rosas Planned completion date for corrective action plan: August 2024

Recommendation: We recommend the College review the R2T4 requirements and implement procedures to ensure the R2T4 calculations are using the correct number of break days and are completed timely and accurately. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: With our new student information system, Anthology Student, there are tasks we can assign to a staff member to alert them that there are R2T4s to process. We think this will be helpful in making sure we accurately calculate R2T4s. Anthology Student also has regulatory controls in the R2T4 calculation process that calculates number of days in the semester and break days. Name(s) of the contact person(s) responsible for corrective action: Andrea Padilla-Rosas Planned completion date for corrective action plan: August 2024

Recommendation: We recommend that a review is implemented which compares enrolled credits to Pell award to ensure all Pell funds are awarded at proper amounts. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: With our new student information system, Anthology Student, there are regulatory controls in place that ensure that the Pell awards are awarded at proper amounts per enrolled credits. All undergraduate students are packaged Standard Academic Year (SAY) beginning with the 2024-2025 academic year. This packaging method will ensure that all Pell eligible students will receive their entire Pell award amount for the year. Name(s) of the contact person(s) responsible for corrective action: Andrea Padilla-Rosas Planned completion date for corrective action plan: August 2024

Recommendation: We recommend that a process is put in place to ensure that all students are notified upon withdrawal they may be required to return federal award funds back to the Department of Education. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: All students are instructed by their academic advisors to speak with the Financial Aid department prior to withdrawing from any or all courses. When the Financial Aid department presents at New Student Orientation, our financial aid presentation includes speaking with Financial Aid before dropping courses as dropping courses could result in students having to pay back some or all their federal financial aid. All students with an R2T4 receive an email from Financial Aid & Scholarships notifying them of the return of federal funds to the Department of Education. The Financial Aid & Scholarships department also emails the Student Accounts department to notify them to return funds to the Department of Education. Name(s) of the contact person(s) responsible for corrective action: Andrea Padilla-Rosas Planned completion date for corrective action plan: August 2024

Recommendation: We recommend that the College should ensure all necessary employees receive proper training, support, and time to follow the College's policies and federal requirements related to monthly reconciliations. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: With the start of the 2024-2025 school year, the Financial Aid and Student Accounts departments are working together to reconcile weekly on Fridays. This has worked well since its inception in August 2024. Name(s) of the contact person(s) responsible for corrective action: Andrea Padilla-Rosas Planned completion date for corrective action plan: August 2024