Corrective Action Plans

The disbursement process of such refunds was transferred to a new team within the Finance/Treasury branch. The team size was increased from 2 to 4 members. Members added to this team have relevant previous experience in student accounts. The additional resources as well as their experience and knowledge should ensure that funds are returned in a timely manner that complies with program requirements.

FINDINGS — FEDERAL AWARD PROGRAMS AUDITS DEPARTMENT OF EDUCATION 2024-001 Student Financial Aid – CFDA No. 84.007, 84.268, 84.063, 84.033 Recommendation: 1) We recommend the College reevaluate its procedures and review policies surrounding reporting status changes to NSLDS to ensure the enrollment effective date reported to NSLDS is aligning with the College’s last date of attendance. 2) We recommend the College reevaluate its procedures and review policies surrounding reporting program enrollment effective dates to NSLDS. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Corrective Action Response Regarding Graduation Date Discrepancy 1. Immediate Correction of Records: • Verified and corrected all affected student records to reflect accurate graduation dates. • Graduation dates for graduates from Fall 2023 to Summer 2024 will be updated. This action ensures alignment between the student information system, official transcripts, and graduation rosters. 2. Process and Policy Updates: • Internal policies will be revised to provide clear guidance on assigning and verifying graduation dates. Corrective Action Response Regarding Enrollment Transmission Reporting Timeline Beyond the 60-Day Requirement 1. Policy and Procedure Enhancements: • Updated internal policies to require enrollment data transmission at least every 20 days, well ahead of the 60-day federal requirement to ensure receipt by the National Student Loan Data System (NSLDS) in a timely manner. • Staff will periodically request a transmission audit from the Clearinghouse verifying that the institution’s enrollment data has been forwarded to the National Student Loan Data System (NSLDS). Name of the contact person responsible for corrective action: Dayne Chance, Director of Financial Aid at 908-709-7089 If the Department of Education has questions regarding this plan, please contact the appropriate individual outlined above.

Finding 2024-001 – Special Tests and Provisions – Enrollment Reporting (Noncompliance and Significant Deficiency) Identification of the Federal Program - Student Financial Aid Cluster - Assistance Listing Nos. 84.007, 84.033, 84.038, 84.063, and 84.268 Criteria - Institutions are required to report enrollment information under the Pell grant and the Direct loan program via the National Student Loan Data System (NSLDS). The administration of the Title IV programs depends heavily on the accuracy and timeliness of the enrollment information reported by institutions. Institutions must review, update, and verify student enrollment statuses, program information, and effective dates reported to NSLDS. Institutions are responsible for accurate reporting. According to 34 CFR 685.309(2), the University is required to notify the Department of Education via the NSLDS if a “student has ceased to be enrolled on at least a half-time basis for the period for which the loan was intended”. Changes to status are required to be reported within 30 days of becoming aware of the status change, or with the next schedule transmission of statuses if the scheduled transmission is within 60 days. Condition - A sample of 40 students were selected from the population of all students who received federal student financial aid during the year ended May 31, 2024. We obtained the student records and tested compliance with federal regulations for the specific loans and grants. For 13 out of the 40 students selected for Enrollment Reporting testing, the status change to withdrawn was not reported within the 60 day reporting window after the status change was effective. For 7 out of the 40 students selected for Enrollment Reporting testing, the status change was not reported to NSLDS. Cause - The University’s processes of internal controls for reporting enrollment information and to timely report student status changes to NSLDS were not adequate. Effect - Enrollment reporting to NSLDS did not include accurate information. Identification of Repeat Finding – Repeat finding of prior year finding 2023-001. Student status changes were not reported to NSLDS within the required timeframe. Recommendation - We recommend the University revise its processes for reporting student status changes to NSLDS. The University should implement a process to review, update, and verify student enrollment statuses that appear on the Enrollment Reporting roster files. We also recommend that management implement controls to ensure reported changes are timely and correctly reported to the NSLDS. Views of Responsible Officials - Management agrees with the finding. Out of the 20 exceptions included in this finding, 16 were properly and timely reported by the University to the third-party service provider. The University is currently working with their third-party service provider to identify the root cause of the untimely reporting. Corrective Action Plan for Finding 2024-001 - The University provided additional training and monitoring to the employees involved in this process. Furthermore, the University engaged a former employee on a contractual basis to assist with the reporting process. The contract employee has significant experience in reporting information to the University’s third-party agent, National Student Clearinghouse (NSC), and to the National Student Loan Data System (NSLDS). The University is actively working with the Audit Resources team at NSC to revise our reporting processes and develop a reporting schedule that will more closely align with the University's calendar and eliminate the root cause of the data errors.

Corrective Action Plan Enrollment information was not submitted within the required timeframe by the University. Personnel Responsible for Corrective Action: Dena Norris, Associate Vice Chancellor of Student Financial Services, and Tara Dettmer, Director of Financial Aid – Fiscal Operations Anticipated Completion Date: Corrective action plan will be implemented by June 30, 2025. Views of Responsible Officials and Planned Corrective Action Plan: Metropolitan Community College (MCC) will begin a new monitoring process for enrollment reporting to ensure compliance and timely reporting of all students. Enrollment status changes are reported every month to the National Student Clearinghouse (NSC), MCC will make a random selection of 10-15 students each month to verify data was correctly transmitted to NSC. A secondary check of these students will be done to ensure the data is also transmitted to the National Student Loan Data System (NSLDS). MCC will also ensure error reports and other data issues are resolved in a timely manner to ensure reporting of students is completed within the regulatory timeframe.

Responsible personnel will review calculations as they are completed.

Identifying Number: 2024‐004 – U.S. Department of Education Student Financial Assistance Cluster – Special Tests and Provisions: Enrollment Reporting Finding: The College failed to accurately and timely report student status changes to NSLDS for 10 students out of 11 students tested Contact Person Responsible for Corrective Action Plan: Director of Financial Aid Corrective Action Plan: The Financial Aid Director and the Assistant Registrar have been directed to work together on a bi‐weekly basis to determine the appropriate status of all students who are receiving financial aid. Earlier this semester, the Registrar’s Office was directed to issue a daily report of enrolled students as well as what actions led to the change in total enrolled students if the headcount change, including the students’ names and the action (withdrawal, administrative withdrawal, suspension, etc.) The Financial Aid Director will begin working more closely with the Assistant Registrar to accurately report individual enrollment status to the campus administration and the National Student Clearinghouse. Anticipated Completion Date: January 2025

Identifying Number: 2024‐003 ‐ U.S. Department of Education Student Financial Assistance Cluster – Special Tests and Provisions: Return of Title IV Funds Finding: The College failed to return title IV funds to the student within the 45‐day time frame for 1 student out of 3 students tested. Contact Person Responsible for Corrective Action Plan: Director of Financial Aid Corrective Action Plan: The Vice President of Academic Life (VPAL) has been informing the Director of Financial Aid ofeach student who has withdrawn, been administratively withdrawn, or been suspended from the College so as to be able to accurately calculate the return of Title IV funds in a timely manner. Anticipated Completion Date: Immediately

Finding 2024-001 Condition The auditor tested 15 Title IV returns, and noted that 10 returns were deposited or transferred to the SFA account or EFTs were initiated to ED more than 45 days after the date of determination. Corrective Action Plan Corrective Action Planned: In response to prior audit concerns regarding R2T4 (Return to Title IV) calculations, MATC implemented a comprehensive retraining program for staff on R2T4 regulations and requirements. Additionally, we instituted a secondary review process for all R2T4 calculations, which increased processing times. Since implementing these measures, we believe our staff is now sufficiently trained to accurately process R2T4 calculations without requiring a secondary review. To maintain compliance and quality assurance, the Financial Aid Processing Supervisor will oversee the R2T4 process to ensure all calculations and related returns/disbursements are completed within the 45-day regulatory timeframe. To further ensure accuracy and compliance, the Financial Aid Compliance Officer will conduct periodic audits by selecting a random sample of ten R2T4 calculations. These audits will confirm that the calculations are accurate and that returns/disbursements meet the 45-day processing requirement. We are confident that these measures will address prior concerns and uphold compliance with regulatory standards. Name(s) of Contact Person(s) Responsible for Corrective Action: Joshua Montavon, Wendy Hilvo, and Tina Johann Anticipated Completion Date: June 30, 2024

2024-002: Missing Exit Counseling Documentation - 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 student file testing, we noted two students out of 40 did not have documentation in their file that exit counseling was sent thirty days after the student withdrew. We consider the missing exit counseling to be an instance of non-compliance with the Eligibility Compliance Requirement. Corrective Action Plan We have updated our Loan Procedures to include running an internal report on all loan students on the 1st and 15th of every month, or the next work day following those dates if they land on a day the campus is closed. If a student with loans has withdrawn completely and stopped attending, we will send an exit letter within 7 business days of discovering that the student has ceased attending. Responsible Person for Corrective Action Plan Isamar Taylor - Director of Financial Aid and Jill Wohrley - Financial Aid Reconciliation and Compliance Specialist Implementation Date of Corrective Action Plan 10/16/2024

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 return Title IV Student Financial Aid for five 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 a Significant Deficiency relating to the Special Tests and Provisions Compliance Requirement. Corrective Action Plan To rectify this issue, we have taken the following corrective actions: Enhanced Monitoring and Reporting: Run our internal tracking report once a week to monitor and ensure timely Return of Title IV (R2T4) calculations. This system will alert financial aid staff when a student withdraws, prompting immediate action to review and process the return within the required 45-day timeframe. Staff Training and Certification: Conducted a comprehensive training session for all financial aid staff to reinforce the importance of timely R2T4 calculations. Training covered procedures for identifying students who have ceased attendance, the calculation process, and deadlines for completing returns. Regular refresher training sessions will be scheduled each term to ensure staff remain informed and compliant with federal guidelines. Audit and Quality Control Checks: Institute periodic quality control checks by the Financial Aid Reconciliation and Compliance Specialist to verify the accuracy and timeliness of R2T4 calculations. Responsible Person for Corrective Action Plan Isamar Taylor - Director of Financial Aid and Jill Wohrley - Financial Aid Reconciliation and Compliance Specialist Implementation Date of Corrective Action Plan 10/16/2024

Condition: During our review of the return of Title IV funds, we noted that students were not being properly identified as withdrawn, either officially or unofficially. This resulted in 4 students noted that never had a calculation performed, but should have, and 4 students that were reported late. Criteria: When a recipient of Title IV funds withdraws from an institution during a payment period or period of enrollment in which the recipient began attendance, the institution must perform a Return of Title IV Funds calculation to determine the amount of Title IV assistance the student earned as of the student’s withdrawal date. Cause: Student Financial Aid personnel did not have a method to properly identify students who are required to have a return of funds calculation. Effect: Funds required to be sent back to the Department of Education are either missed or are late. Perspective: There has been high turnover in the SFA department, including a time where there was not a Director in place. Significant personnel changes were made at the end of the June 30, 2024 year. Reports are being obtained from IT department regularly. Recommendation: We recommend training of Student Financial Aid personnel on the rules and regulations over return of funds. In addition, we recommend that Student Financial Aid personnel work with the IT department to develop a report that can be ran weekly or bi-weekly to identify the students and timely prepare the calculations. Views of Responsible Officials and Planned Corrective Actions: Dodge City Community College staff involved are undergoing training to learn requirements. Processes and procedures have been developed to ensure timely calculations and refunds.

Condition: There were no monthly Title IV reconciliations performed. Criteria: Per SFA requirements, the College is required to reconcile the COD data files with the College’s financial records. Cause: Turnover in the staff and Director positions of the College. The new employees were not aware of this requirement. Effect: Noncompliance with SFA requirements. Perspective: Significant personnel changes were made at the end of the June 30, 2024 year. There were also new written standard operating policies and procedures implemented. Auditor sighted new policies and new spreadsheets. We also noted that monthly reconciliations have begun and are occurring monthly. Recommendation: We recommend that the direct loans are reconciled at least monthly between the COD and the College’s general ledger. Views of Responsible Officials and Planned Corrective Actions: Dodge City Community College staff involved have received training and been made aware of requirements. Monthly reconciliations will be performed immediately.

Condition: We examined a sample of Title IV aid recipients to verify that information reported on the Enrollment Reporting roster file sent to the National Student Loan Data System (NSLDS) matched the student's academic files and found instances where students received Title IV aid during a semester but the status of withdrawn or graduate were not reported correctly or timely on the NSLDS Enrollment Reporting roster files sent during that semester. Criteria: Per the NSLDS Enrollment Reporting Guide, a school should report all students that NSLDS includes in its request to the school on a roster file. This includes timely and accurate reporting of the status of the student of withdrawn or graduate. Cause: The status of the students were not timely and accurately reported to NSLDS. Effect: Students could potentially not be placed in grace or repayment status when they should be. Perspective: Condition is still present in part. All withdrawn students tested were reported accurately and timely. There were still some graduates that were not reported until first of term submission rather than when the Graduates only report was submitted. There has been high turnover in the SFA department, including a time where there was not a Director in place. The new Director came on at the end of the June 30, 2024 year and is working to correct the reporting. Recommendation: We recommend that personnel in charge of enrollment reporting be diligent in reviewing the roster file to ensure that all appropriate students are shown and attendance changes are reported in a timely and accurate manner. We also recommend contacting the Clearinghouse to ensure the correct reports are being used by the Clearinghouse and possibly changing the deadline for submission of the Graduates only report as it currently has a very quick turnaround and not all grades are known or submitted by the current deadline. Views of Responsible Officials and Planned Corrective Actions: Dodge City Community College staff involved in enrollment reporting to the NSLDS have reviewed the NSLDS Reporting Manual to better understand and accurately report the student's enrollment status. There has been high turnover in the SFA department, including a time where there was not a Director in place. The new Director came on in the in June 2024. The College is still working on fully implementing new procedures and catching up submissions.

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: 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 KCC Office of Financial Aid has reviewed and updated the Return of Title IV process to ensure compliance standards are consistently met. A weekly report has been set up to detect unprocessed R2T4 awards and transmittal will occur on a weekly basis to support the timely return of Title IV funds. Responsible Person for Corrective Action Plan: Kendra Souligne, Director of Financial Aid & Student Engagement Implementation Date of Corrective Action Plan: June 12, 2024

We acknowledge the finding 2024-001 regarding the untimely reporting to the NSLDS and understand the importance of adhering to the prescribed reporting timelines to ensure that student loan and grant information is accurate and up-to-date. We take this matter seriously and are committed to rectifying the situation as quickly as possible. Root Cause: The root cause of the late reporting to NSLDS was primarily attributed to employee turnover within the department responsible for data reporting. Specifically, the loss of key personnel during the reporting period led to a temporary breakdown in the continuity of reporting processes. This turnover resulted in insufficient staffing which caused delays in the submission of required reports to the National Student Clearinghouse and, thus, NSLDS. Corrective Actions: • We are in the process of reviewing and streamlining the reporting process to increase efficiency and reduce the likelihood of delays. • Additionally, we are reviewing backup procedures to ensure that in the event of further turnover, there is a well-documented and easily transferable knowledge base for the remaining staff. Conclusion: We take the findings of the audit seriously and are committed to improving our processes and addressing the root causes of late reporting. The corrective actions outlined above are designed to prevent recurrence of this issue, ensure compliance with NSLDS reporting deadlines, and improve overall reporting accuracy and timeliness. Linda Fleischman, Registrar, 704-406-4263

Student Financial Assistance Cluster – Assistance Listing No. Variou Recommendation: We recommend the University review its reporting procedures to ensure that students’ statuses are accurately 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: We will update our procedures to make sure we are reporting accurate graduate dates and enrollment effective dates in a timely manner. We have already begun reviewing this and are finding that the incidents found appear to be isolated. Therefore we are updating procedure to include additional quality control checks to ensure that anomalies are found and resolved within the required timeframe. Name(s) of the contact person(s) responsible for corrective action: Hannah Blahnik Planned completion date for corrective action plan: May 2025

Management's Response: We concur. View of Responsible Officials and Corrective Action Plan Based on the review and assessment of findings, Lemoore College will update its established policies and procedures to include a report to track all steps of the Return to Title IV process and the date each step is completed for each student. The report will be reviewed periodically and compared with monthly reconciliation reports to ensure all steps have been completed within the required timeframes. This will ensure that each step of the return of Title IV process is completed within regulatory timelines.

To address this issue and ensure compliance moving forward, the following steps will be implemented: a. Establishing Strong Internal Controls o Develop and document clear policies and procedures related to the area of concern. o Designate a compliance checklist for National Student Clearinghouse to ensure all steps are followed. o Conduct regular internal reviews to identify and correct potential discrepancies. b. Training and Awareness o Provide comprehensive training sessions for all relevant personnel on reports for the National Student Clearinghouse. o Maintain attendance records and training materials to document the completion of training. c. Monitoring and Accountability o Assign a dedicated staff member to oversee the adherence to new procedures. Jackie De Los Santos will upload the data on the 15th of every month. Angela Salmeron will then update the data on the Clearinghouse site by the 28th of every month. Angel Gladue will double check the work of Angela Salmeron by the 1st of every month. o Utilize software or tracking tools to monitor compliance and flag potential issues. o Develop a system for employees to report concerns or questions about compliance processes. Person Responsible: Angel Gladue will oversee the implementation and execution of the corrective action plan. This individual will also ensure that all training sessions are completed and properly documented and will serve as the point of contact for internal reviews and audits. Timing for Implementation: The corrective action plan will be implemented immediately, with a target completion date of February 15, 2025. All fiscal records 2023, 2024, plus fiscal 2025 will be reviewed, corrected, and uploaded by this date to ensure compliance prior to the next audit. Follow-Up: Progress will be monitored on a monthly basis to ensure timely implementation. Adjustments will be made as needed to address any unforeseen challenges during the corrective action process.

Finding 2024-002: In order to ensure proper compliance with reporting student enrollment statuses to the National Student Loan Data System, the CFO and Controller will familiarize themselves with federal reporting deadlines and inform other parties on campus who will need to report student enrollment changes on a timely basis. Furthermore, the CFO and Controller will review the sample of enrollment status changes the auditors reviewed for the fiscal year 2024 audit, and immediately develop procedures to strengthen internal controls surrounding the reporting of enrollment status changes.

Finding 2024-001: In order to ensure proper compliance with the Federal Perkins Loan Program, the CFO and Controller will review the sample of 25 promissory notes the auditors reviewed for the fiscal year 2024 audit, and immediately develop procedures to strengthen internal controls surrounding the retention of documents. Although the College was unable to locate the promissory note in question, the College did have a physical file which contained information about the student and the Perkins Loan which was issued over 30 years ago, including correspondence with debt collection agencies and a remaining balance as of June 20, 2024. Effective September 30, 2017, the Perkins Loan Program was terminated and no new loans have been issued since that time.

Name of Responsible Individual: Mary Mercer, Director of Student Financial Services Corrective Action: We recently discovered an issue with our Title IV funds refunding report which impacted this student. The report viewing eligible Title IV recipients has been corrected. Anticipated Completion Date: December 12, 2024

Name of Responsible Individual: Kasi Turner, Registrar Corrective Action: Methodist University will enroll in the National Student Clearinghouse G from DV Process, which will eliminate the need to transmit a Graduates Only file. The student enrollment record will be updated to a graduated (G) status based on the transmission of the Degree Verify file only (see process workflow graphic below). Additionally, we will review the G status records generated from the Degree Verify file to ensure that the status was accurately applied to each student's enrollment record. Any status not applied will be updated manually by an office team member. Our goal for enrollment in this program is 12/13/2024 in order to pilot for the fall 2024 degree conferral date. Lastly, we will update our end-of-term processing documents to remove the NSC Graduates Only file transmission and add the updated enrollment status review component once the Degree Verify file has been transmitted and processed by the NSC. Anticipated Completion Date: January 31, 2025

Name of Responsible Individual: Bonnie Adamson, Director of Financial Aid Corrective Action: The student that was not reported within 15 calendar days was before we had a process in place to prevent this issue from happening. As a result of this finding, Financial Aid and Accounting are reconciling weekly to mitigate this issue. Anticipated Completion Date: This process was put into place for the Fall 2024 semester.

Lack of Documentation of Exit Counseling Planned Corrective Action: Current SIS is set to trigger the Exit Counseling to all students that are coded anything other than E (Enrolled). The Registrar updates all student files with any enrollment changes triggering the email to go to the student. The FA Director will run a report in the middle of each term to pick up any students that may have been missed by the Registrar. Person Responsible for Corrective Action Plan: Stephanie Castillo, Director of Financial Aid Anticipated Date of Completion: Fall 2024

Return of Title IV (R2T4) Calculations Planned Corrective Action: Calander was set using prior year information it was not until notification in April 2024 from the DOE Audit Resolution Group that the error was made known to Financial Aid Director. Prior year R2T4 was handled by 3rd party vendor. The calendar for 2023-2024 was updated immediately and all calculations were processed and adjustments made. The ABU director has now taken NASFAA R2T4 Specialist training and is in charge of updating and maintaining the calendar. Person Responsible for Corrective Action Plan: Stephanie Castillo, Director of Financial Aid Anticipated Date of Completion: Fall 2024