Corrective Action Plans

Corrective Action Plan: • The University has already implemented significant process enhancements in this area. • Additional checks are now in place to ensure that campus-level and program level reporting is accurate moving forward. • Additional checks have also been put in place to ensure that dual-majors graduation statuses are reporting accurately and in a more timely manner moving forward. Implementation Date: January 2024 Responsible Persons: Kyle Phillips and Bobbie Brown

Corrective Action Plan: The University has updated its disbursement notifications to include the type of loan borrowed and the amount borrowed in the template of the notification. In addition, the University has updated the notifications to go out to student and parent borrowers separately. The process has also been updated so that the notifications are sent out after any change to the student award is made on a nightly basis. Implementation Date: January, 2024 Responsible Person: Robert Hamilton

Corrective Action Plan: • The University has already implemented significant process enhancements in this area. • We have implemented an ad hoc report to identify students with canceled loans and loan fees included in their COA. The report is reviewed bi-weekly and loan fees for canceled loans are removed in a timely manner. Training regarding the timely cancelation of loan fees was provided to staff responsible for the review and adjustment. • We have implemented an ad hoc report to review student’s COA budget and the student’s actual enrollment to identify discrepancies between a student’s actual enrollment charges and student’s COA budget. The report is reviewed following our census after the 20th day of classes and COA budgets are adjusted to align with actual enrollment charges. Training regarding post census review of student’s actual attendance and student’s COA budget was provided to staff responsible for the review and adjustments. • We have implemented an ad hoc report to review student’s tuition and fees budget component and the student’s academic program to identify discrepancies between the student’s tuition and fees budget component and the charges associated with their academic program. The report is reviewed monthly, and a student’s tuition and fees budget components are adjusted to align with the student’s academic program. Training regarding review of a student’s tuition and fees budget component and the student’s academic program was provided to staff responsible for the review and adjustments. Implementation Date: January 2024 Responsible Persons: Christina Montecillo and Robert Hamilton

Corrective Action Plan: Texas Southern University agrees with the information that states the student’s program length was incorrectly reported to NSLDS for 10 of 60 students tested. To further enhance reporting accurate information, the Office of Student Records (formerly the Registrar’s Office) has updated our business practice regarding this matter in the following way. First, the Office of Student Records reached out to the Interim Dean of the Graduate School to provide the correct program length for Graduate Programs at TSU. Second, we gathered information regarding the total number of hours of each program offered and the total number of hours required to be considered a fulltime student at TSU. We then utilized this information to calculate the program length in years. (For example, the eMPA program at TSU is 36 hours and a full-time course load for a graduate student is 9 hours. We then divided the total hours of the program (36 hours) by the full-time load (9). This provided us with how many semesters a full-time student would take to complete the program. To finish the calculation and get the program length, we divided it into 2 to get the number of years required to complete the program. Implementation Date: January 2024 Responsible Person: Dr. Nickolaus Cioci, Dean of Student Records Corrective Action Plan: Texas Southern University also agrees with the information stating 17 of 38 student’s tested enrollment status was not reported to NSLDS in a timely manner. We agree with this information that states 13 of the students tested did not have their graduation effective date accurately reported to NSLDS in a timely manner. To combat this issue, the Office of Student Records has created a new business process to report these students to NSLDS in a timelier manner. First, the graduation coordinator has requested academic units to provide her with information regarding students whose degrees are 100% complete earlier to allow her to confer these degrees quicker. Second, the Office of Student Records has also changed their business practice and informed both the Graduation Coordinator and the Law School Registrar’s representative that all degrees must be conferred no later than 45 days after the semester ends. This will allow other staff time to turn in the graduation report to NSC in a timelier manner and review the rejected records/correct the rejected records before the 60-day deadline to help keep us in compliance. Implementation Date: January 2024 Responsible Person: Dr. Nickolaus Cioci, Dean of Student Records Corrective Action Plan: Texas Southern University also agrees with the information stating 4 students that did not have their withdrawal status or effective date of status change reported in a timely manner to NSLDS. In reviewing these records, it appears accurate attendance was not taken causing Texas Southern University to be out of compliance for reporting practices. To further enhance reporting capabilities, the Office of Student Records has created a new business process to correct this error. First, TSU no longer allows advisors to register students and students must register themselves and sign a financial acknowledgement form. Also, the Office of Student Records has collaborated with the Office of the Provost to effectively communicate with faculty the ramifications of inaccurate attendance reporting. In these communications, the faculty are also provided instructions on how to accurately report attendance using their MyTSU attendance portal. Also, the Office of Student Records worked in conjunction with the Office of Information Technology, to automate the process of dropping students for nonattendance as reported by their faculty. Furthermore, we are continuing to update our business processes, so these students are reported to NSC/NSLDS in a timely manner. Another issue involved students being reported as nonattending but attending the course. TSU’s Office of Student Records and Office of the Provost have also worked in conjunction to fix this issue as well. Several faculty members would not mark attendance causing their whole class to get dropped. We have worked in our process to inform instructors they must mark attendance for students to not create this issue in the future. Implementation Date: January 2024 Responsible Person: Dr. Nickolaus Cioci, Dean of Student Records

Corrective Action Plan: The University, with the National Student Clearinghouse (NSC), has developed an expanded enrollment reporting schedule for reporting graduated students on special “Graduates Only” files after subsequent semester enrollment reporting has begun. Previously, we relied on the DegreeVerify file to report Graduated status. The Graduates Only files, which will include only students with an awarded credential for the semester and are a supplement to the regular Enrollment files sent during the semester, will ensure that Graduated statuses for Doctor of Veterinary Medicine students are reported accurately and in a timely manner. The use of a supplemental Graduates Only enrollment file will also eliminate warning files that currently result from the DegreeVerify reporting process. Should there be an issue with the Graduates Only file, an enrollment reporting warning/error file will be received and processed in a timely manner, as they are during the semester when an Enrollment file generates a warning/error report. The new process will be more consistent, efficient, and complete. The Graduates Only file transmission schedule for the current semester has been updated and procedures for setting the enrollment reporting schedule each year have been updated to include the expanded Graduates Only file transmission schedule. Discussion with the NSC resulted in a clear understanding of how the Graduates Only files should be processed to ensure accurate and complete reporting of Graduated statuses. All staff members responsible for processing of the Graduates Only files have been trained in this procedure, and additional information has been included in written procedures for processing the files. Implementation Date: November 2023 Responsible Person: Venesa Heidick, Registrar

Corrective Action Plan: The Office of the Registrar will develop an action plan to evaluate the internal process changes which must occur considering the following implications: • There will be significant process changes of the reporting parameters that are run for the National Student Clearinghouse jobs in Banner to ensure that the proper branch code is identified for each student; • Further research will be required to identify other areas which will be impacted by this change, including but not limited to IPEDS data submissions, CBM Reporting, SACSCOC notifications, etc.; • Will collaborate with College of Graduate Studies to remove degree plans that are listed as sought and are not actively being pursued by the student. This will ensure that correct degree sequencing is accounted for and reported on correctly each month to the National Student Clearinghouse; • Strengthen internal controls and communication channels to ensure consistent and accurate reporting of student statuses across all levels. Implementing additional validation checks in our reporting systems will ensure the accuracy of program begin dates before submission; • Update our standard operating procedures to indicate review of the National Student Clearinghouse EDI Rejection File to ensure all students are accurately being pulled into NSLDS; • Conduct a comprehensive review of our reporting procedures to identify the specific breakdown in the process that led to the failure to report enrollment status to NSLD; • Implement enhanced internal controls and validation checks to ensure that enrollment statuses are accurately reported to both NSC and NSLDS in a timely manner; and • The policies and procedures will be revised to include these updated procedures. Implementation Date: January 2024 Responsible Person: Erika Graham, University Registrar

Corrective Action Plan: The University has implemented corrections to this calculation when it was brought to the attention by the State Auditor’s Office. Corrective action was immediately taken by reducing the unsubsidized award for those who received the incorrect amount during the 2022-2023 award year. The University also corrected awards for the 2023-2024 year and updated the awarding rules in it’s Banner system. Implementation Date: August 2023 Responsible Person: Amy Wilson, Director of Financial Aid and Scholarships

Corrective Action Plan: The University has formally documented the procedures that have been put in place. The University will address issues with National Student Clearinghouse (NSC) reporting and will attempt to fix each issue before sending to NSC, including Social Security Number, Name, and other miscellaneous issues. The procedures include three DegreeVerify files being sent that report graduates and the University will be adding three more DegreeVerify files to be sent two to three weeks after the end of the semester, part of term and end of mini to pick up remaining graduates for the term. The University will have the Information and Analysis team create a report each term of students that were enrolled in the previous semester but are not enrolled in the current semester so that they can be reported as withdrawn to NSC correctly. Implementation Date: February 2024 Responsible Person: Cheri Lewis, Enrollment Management Analyst

Corrective Action Plan: The University is in the process of assigning the remainder of their active Perkins Loans to the Department of Education. However, the University will provide additional training to staff to ensure that any active loans retired prior to assignment will result in a paid-in-full notification being sent to the borrower and will maintain documentation of such notifications as required. Implementation Date: February 2024 Responsible Persons: Kimberley Wells, Director of Financial Aid & Scholarships John Robert, Associate Director of Financial Aid & Scholarships Beth Tolan, Associate Vice President of Financial Aid & Scholarships

Corrective Action Plan: The University has updated and implemented revised procedures. Effective December 26, 2023, the University has begun notifying the borrower in writing with the appropriate documentation when the Perkins loan has been paid in full. Effective January 1, 2024, the institution has further incorporated reconciliation tasks into its procedures to ensure paid in full notifications have been sent as required to borrowers and will retain electronic copies of the notifications in the University’s records. Implementation Date: January 1, 2024, for improved processes and controls Responsible Persons: Yvette Martinez, Senior Director of Financial Affairs and Controller Diana Gonzalez, Director of Student Financial & Treasury Services

Corrective Action Plan: The University will retroactively mail paid-in-full notices to all students who paid their loans in full during the audit period. We have already mailed notices for loans paid in 2022 & 2023 and expect to complete 2021 by February. Relevant policies and procedures will be revised to ensure future paid accounts are handled accordingly by utilizing a monthly paid-in-full report from ECSI. Management will conduct a second level review to ensure that the University is in compliance with the requirements. Implementation Date: February 2024 Responsible Person: Blanca Garcia, Director of Financial Services

Corrective Action Plan: The University has implemented significant process enhancements in this area. The vendor has revised its services to include the paid-in-full letter process and has sent paid if full letters to all Perkins borrowers who were missed. Management will conduct a second level review to ensure that the University is in compliance with the requirements. Implementation Date: November 2023 Responsible Person: Lisa Davis, Director, Bursar Office

Corrective Action Plan: The University is investigating the procurement of required locked, fireproof file cabinets and is in the process of requesting a formal quote for management approval to purchase. Implementation Date: December 2024 (Tentatively) Responsible Person: Lori Peterson, Executive Director and Controller – Accounting and Financial Management

Corrective Action Plan: The University has implemented a review at the start of each term to ensure internal systems (Peoplesoft) are updated with the appropriate number of break days to ensure the accuracy of break days used in Return of Title IV calculations. The University is implementing an enhanced secondary review process for Return of Title IV determinations to ensure accurate calculations and the timely return of funds. The University will implement a process to ensure evidence of participation exists for students who attend all courses via the online platforms. Implementation Dates: Beginning January 2024 with completion May 2024 Responsible Persons: Kimberley Wells, Director of Financial Aid & Scholarships John Robert, Associate Director of Financial Aid & Scholarships Beth Tolan, Associate Vice President of Financial Aid & Scholarships

Corrective Action Plan: The University information security program and associated safeguards will be reviewed to ensure all elements of the GLBA are addressed and implemented. Any missing requirements will be documented and implemented to ensure full compliance with the GLBA. Implementation Date: June 2024 Responsible Person: Jana Chvatal, Interim AVC/AVP, IT Security & CISO

Corrective Action Plan: (1) The University will develop a process to identify all institutional charges and create a master list that will categorize the charges into allowable and non-allowable charges. The master list will be utilized to determine which institutional charges may be included in the calculation of Return of Title IV. (2) The University will coordinate with the Institute of Global Engagement and Online Functional Support to obtain evidence of academic engagement utilizing the learning management software system for students in online only course and confirm active participation for study-abroad coursework. (3) The University will establish a review process to ensure consistency and accuracy in R2T4 calculations. and conduct regular internal audits of a sample of R2T4 calculations to identify errors or discrepancies. Implementation Date: March 2024 Responsible Person: Frank Gomez, Associate Director, SFA

Corrective Action Plan: The Office of Scholarships and Financial Aid will create a reconciliation process that will identify all FSEOG recipients for a given aid year. This reconciliation process will include a report/query that can be distributed weekly and on demand to identify any discrepancies that will be worked timely. The office will also assign a staff member to conduct R2T4 quality control. The staff member will be responsible for running a query and creating a report categorizing the type of returns (i.e. – standard R2T4, Post Withdrawal, etc.) with an estimated time for completion on a weekly basis. Implementation Date: March 2024 Responsible Person: Frank Gomez, Associate Director, SFA

Corrective Action Plan: The University previously misinterpreted the regulation related to enrollment in programs offered in modules. Training has been conducted on this topic. In addition, the Registrar has been granted SIS access to update scheduled breaks of five or more days. During the calculation process the financial aid counselor completing the R2T4 will ensure that the days calculated are correct or, if not, will update the worksheet with the correct number of days. The University will ensure that R2T4 calculations are completed in a timely manner to ensure that funding is returned for students within the 45-day time frame. Implementation Date: 08/2023 Responsible Persons: Scott Lapinski, Assistant Vice President for Enrollment Management/Director of Financial Aid Joe Sanders Assistant Vice President for Enrollment Management/Registrar

Corrective Action Plan: The University now reviews the Cost of Attendance for students as it gets closer to the start of the semester to ensure that there is a variety of Cost of Attendances instead of just mostly full time Cost of Attendance. This will help ensure that the COA amounts are correct before disbursements are made. The University’s Financial Aid & Scholarships Office will also work with the Registrar’s Office to ensure that all online programs are input into the Cost of Attendance formulas before the start of the academic year to further ensure that Cost of Attendance calculations are correct. Implementation Date: 08/2023 Responsible Persons: Scott Lapinski, Assistant Vice President for Enrollment Management/Director of Financial Aid Joe Sanders Assistant Vice President for Enrollment Management/Registrar

Corrective Action Plan: The University has implemented significant enhancements- in its process to grant user access. In addition, to address the specific exceptions noted by the State Auditor’s Office, access for all staff within the SIS has been restricted from disbursing aid. Access is now only granted to the batch user account. Implementation Date: 11/2023 Responsible Person: Scott Lapinski, Assistant Vice President for Enrollment Management/Director of Financial Aid

Corrective Action Plan: The University has revised the procedures to include additional procedural details. Management will conduct a second level review of the R2T4 new year system set up. Additionally, a quality control review of ten percent of the R2T4 calculations will be performed throughout the year to ensure accuracy and compliance with the R2T4 requirements. Implementation Date: February 2024 Responsible Persons: Alejandra Gonzalez, Senior Associate Director Marcia Osman, Associate Director

Corrective Action Plan: The University has implemented significant process enhancements in this area. The policy manual will be revised to include detailed procedures. The steps involved in testing and reviewing Cost of Attendance components for each population of students during aid year roll-over will be expanded to include secondary review of all COA components to show they are assigning correctly for all variations of COA structures. In addition, management will review to ensure we are following federal requirements. Implementation Date: January 2024 Responsible Person: Frankin Foxworthy, Director of Technology, Office of Financial Aid

Corrective Action Plan: The University has implemented significant process enhancements in this area. The policy manual will be revised to include detailed procedures. Management will conduct a second-level review to ensure the University complies with the requirements. Relief under the CARES Act expired at the end of the payment period, including the date of May 11, 2023, per General-23-46. No further corrective action plan is needed for relief under the CARES Act. To address issues of Title IV funds not being returned within the required time frame and incorrectly calculated amounts of Title IV funds to be returned, Office of Scholarships and Financial Aid (OSFA) has added a step to the process that includes a quality control review of no less than 20 percent of a randomly selected sample of all R2T4 reviews. In addition, OSFA has experienced technical limitations in the current custom-developed, mainframe-based system relying on manual processes for R2T4 calculations. The University is replacing the custom-developed, mainframe-based financial aid management system with a vendor-provided, cloud-based system. This will reduce the reliance on manual calculation of returns with a vendor system to assist with R2T4 calculations. By implementing a more robust quality control process and replacing our current mainframe-based financial aid system with a vendor-provided, cloud-based system, we will significantly enhance our R2T4 process to ensure compliance with Title IV requirements. Implementation Dates: Rolling system implementation from February 2024 through August 2024 Responsible Person: Diane Todd Sprague, Assistant Vice Provost of Scholarships and Financial Aid

Corrective Action Plan: In the event that an employee transitions to another University department but needs to retain access for a period of time to facilitate knowledge transfer or to provide backstop support during the transition period, a date will be set for removing that access by setting an expiration date on the authorization, when feasible. If an automated access expiration date is not available, a calendar meeting will be scheduled for at least 2 people authorized to remove that access to remind them to remove the access. Implementation Date: January 2024 Responsible Person: Diane Todd Sprague, Assistant Vice Provost for Scholarships and Financial Aid Corrective Action Plan: The University is currently in the process of replacing its current custom-developed, mainframe-based financial aid management system with a vendor-provided, cloud-based system. The current issue with the mainframe programming library not being under change control will be resolved with the implementation of the new financial aid management system. Implementation Dates: Rolling implementation starting February 2024 through August 2024 Responsible Person: Graham Chapman, Assistant Vice Provost and Director of Academic Information Systems

Corrective Action Plan: The University has implemented significant process enhancements in this area. The policy manual has been revised to include detailed procedures. The University will build Cost of Attendance and place in PeopleSoft Campus Solutions. Before financial aid is disbursed to students the Office of Financial Aid will rebuilt budgets which includes COA to ensure they match all COA’s for all programs. This process will ensure that students are eligible for the aid awarded and disbursed. OIT has implemented new reports to determine PELL, FSEOG, and Direct Loan eligibility and will be reviewed monthly to ensure accuracy of eligible awards and aggregate limits for all financial aid students. Implementation Date: March 2024 Responsible Persons: Laurie Rosenkrantz, Associate Director Karen Krause, Executive Director Lea Anne Sikora, Associate Director