Corrective Action Plans

Corrective Action Plan: In response to the current finding of temporary access monitoring, the frequency of reviews for people that have temporary Financial Aid role assignments will be increased from an annual review to quarterly, for a period of two years. Staff training for access control and business owner training has taken place, to increase awareness that roles need timely removal when maintenance tasks are completed. Implementation Date: 1/29/24 Responsible Persons: Karen Krause, Office of Financial Aid Doug Bergere, Office of Information Technology

Corrective Action Plan: The Financial Aid and Scholarships Office at Texas Tech University will collaborate closely with the Provost’s office to create a strategy for more precisely recording the final date of academic engagement for students enrolled in online courses. Implementation Date: January 2024 Responsible Persons: Robert Hamilton and Bobbie Brown

Corrective Action Plan: • The University has already implemented significant process enhancements in this area. • The University immediately reviewed all Financial Aid security access and removed any access not deemed immediately necessary to the employee’s job duties. • The University has developed Financial Aid security classes based on employee positions. This will allow us to more easily monitor what access an employee has and ensure that it is appropriate to their job responsibilities. Implementation Date: September 2023 Responsible Persons: Kyle Phillips and Robert Hamilton

Corrective Action Plan: After research, it was determined that the issue was limited to our co-enrollment program with Austin Community College (ACC Pathways). Procedures have been updated in our Systems Team to include recalculating the COA for all co-enrollment students after census. As a double check, our Program Specialist Team will also review all co-enrollment students to ensure that the COA was recalculated correctly. Implementation Date: September 2023 Responsible Person: Dede Gonzales, Director of Financial Aid and Scholarships

Corrective Action Plan: Through analysis of the exceptions identified in the audit, the University is working to hire a new full-time position to create and monitor its information security program and the University is in the process of publishing an information security webpage that meets all regulation requirements and serves as a conduit for users to locate policy, review the related legal code, report incidents, and request both training and OIT’s assistance in assessment. Leadership has signed a contract with a third-party vendor to identify and implement all required GLBA controls. Implementation Date: June 2024 Responsible Person: Mr. Matthew Steimel, Director of Enterprise Applications

Corrective Action Plan: The University has implemented significant process enhancements in this area. The Office of Student Accounting will share the entire list of all completed R2T4 calculations with the Financial Aid department for a secondary review. The Office of Student Accounting will also develop and implement a new report that compares R2T4 “Revised Award Amounts” to the actual account activity to ensure that Title IV aid adjustments needed as a result of a R2T4 calculation are completed. The policy manual will be revised to include detailed procedures. Management will conduct a second level review to ensure that the University is in compliance with the requirements. Implementation Date: February 2024 Responsible Persons: Mr. Errol Thomas, Executive Director Student Accounting Dr. Nickolaus Cioci, Dean of Student Records Corrective Action Plan: The University has implemented significant process enhancements in this area. The university has filled the vacant position of Senior Accountant responsible for the processing of Title IV credit balances. The Senior Accountant will process refunds daily to ensure compliance with Title IV credit balance timeline regulations. Management will conduct a second level review to ensure that the University is in compliance with the requirements. Implementation Date: Spring 2024 Responsible Person: Mr. Errol Thomas, Executive Director of Student Accounting

Corrective Action Plan: The Office of Student Financial Success has worked with the Office of Information Technology to deliver student loan disbursement information via the student portal. A tab has been created that allows students to receive specific disbursement information related to their student loans. In addition, the disbursement notification process has been established to ensure all students receive a disbursement notification before disbursements are made to student accounts. Our policy now requires, before disbursement, the generation of disbursement notifications made by the Senior Systems Analyst. Implementation Date: January 2024 Responsible Person: Dr. Latisha Addison, Executive Director Student Financial Success Corrective Action Plan: The University has implemented significant process enhancements in this area. The University has updated the charges associated with the university installment plan in the ERP system to be designated as an unallowable charge. This update will ensure that Title IV aid will not pay towards those charges. Management will conduct a second level review to ensure that the University is in compliance with the requirements. Implementation Date: February 2024 Responsible Person: Mr. Errol Thomas, Executive Director of Student Accounting

Corrective Action Plan: The Office of Student Financial Success has worked with the Office of Technology to develop an effective budget rule in the Banner system that accurately calculates books and supplies for students based on hours of enrollment. We have identified and rectified issues with banner that prevented identified students from being recalculated to determine appropriate hours of attendance for books and supplies. The Office of Student Financial Success has developed a new Budget Component report that identifies the correct credit hours from both the student enrollment and financial aid banner modules, which assist with the recalculation process ensuring accurate books and supplies for all students. In addition, we have also increased the number of times we recalculate the budget components at the beginning of each semester. Implementation Date: January 2024 Responsible Person: Dr. Latisha Addison, Executive Director Student Financial Success Corrective Action Plan: The Office of Student Financial Success has created written procedures to include the process for recalculating Federal Pell Grant eligibility after the final student add/drop course deadline. In addition, we have also increased the number of times we recalculate Federal Pell Grant eligibility for students at the beginning of each semester based on add/drop processes. Implementation Date: January 2024 Responsible Person: Dr. Latisha Addison, Executive Director Student Financial Success Corrective Action Plan: The Office of Student Financial Success has added to its written policy a process for determining student loan eligibility manually. The system functions to identify students near aggregate limits based on FAFSA data received. Students who have reached their aggregate loan limits are identified through a newly created loan limit Argos report. Student financial aid counselors review the students on the report and compare them with data pulled from NSLDS to determine any remaining eligibility for each student. The ability to award a student more than they are eligible for is a manual process, and in the case of the student in the finding, it was overridden by a staff member. Policies have been implemented to ensure the accuracy of student eligibility identification by financial aid counselors before awarding a student loan manually. Implementation Date: January 2024 Responsible Person: Dr. Latisha Addison, Executive Director Student Financial Success Corrective Action Plan: The Office of Student Financial Success has ensured staff training as it relates to manual SAP calculations as needed based on student circumstances. The SFS Office has identified that some students who have breaks in enrollment may not be included in yearly SAP run processes. Our policy now states that a student who has not been enrolled for more than a year must have a manual SAP calculation completed before being awarded financial aid to ensure accuracy and compliance. Implementation Date: January 2024 Responsible Person: Dr. Latisha Addison, Executive Director Student Financial Success Corrective Action Plan: During the fall of 2022 and some of the spring of 2023, the Office of Student Financial Success did not have a staff member in place to ensure the accuracy of data being pulled in from the Department of Education. Since then, proper staff has been hired and trained to ensure the accuracy of data files being loaded into the Banner student information system. Implementation Date: January 2024 Responsible Person: Dr. Latisha Addison, Executive Director Student Financial Success

Corrective Action Plan: Through analysis of the exceptions identified in the audit, the University has developed a standard operating procedure to assign employee access based on the principle of least privilege as determined by individual roles. The university is engaged with a third-party vendor to procure and implement an automated role-based access assignment process, to ensure that the University complies with this audit findings requirements. Implementation Date: June 2024 Responsible Person: Mr. Matthew Steimel, Director of Enterprise Applications

Corrective Action Plan: Once the discrepancy was identified in July of 2023, corrections were made for the next satisfactory academic progress review in August of 2023 and going forward. The new procedures put into place in August are as follows: the SAP table used for calculating maximum time frame will be reviewed by the Associate Director and Director over Advising in conjunction with the Registrar’s office to ensure there are no discrepancies in degree program hour requirements. The policy manual has been revised to include procedures. Implementation Date: August 2023 Responsible Person: Delisa Falks, Assistant Vice President

Corrective Action Plan: To address accurate reporting of scheduled breaks in the future, we will update our R2T4 policy and procedure to ensure that weekends are included in the scheduled breaks. Our updated policy and procedure will include information regarding how the break is determined. The Assistant Director of Operations will enter these dates on SOATBRK each aid year with secondary confirmation of accuracy by the Director of Financial Aid. The Office of Financial Aid did not have update access to the Banner form (SFAWDRL) used to process R2T4 calculations which caused inaccurate processing of students in modules. We have now properly configured our student information system so that the R2T4 processing staff have update access to this form in order to correctly report the start and end dates for students enrolled in modules. This will accurately calculate their percentage of attendance. Our current R2T4 procedures include a monitoring control to ensure accurate return of aid after an R2T4 is calculated and return is determined. The current process is reviewed by the same R2T4 processor who calculated the return. We will revise this procedure to have secondary review by the Assistant Director of Operations or in the absence of the Assistant Director, the Director will conduct this secondary review. We will review all students in which an R2T4 was calculated, not only those who had a return processed. This review will be documented in RHACOMM. In addition to the above procedural updates, the Office of Financial Aid is re-calculating R2T4 for the students impacted in this sample. The policy and procedure will be revised to include these updated procedures. Implementation Date: May 2024 Responsible Persons: Amanda Petrosian, Director of Financial Aid Josiah Mendoza, Assistant Director of Operations

Corrective Action Plan: In a typical academic year, we package prior to the new aid year COA being finalized. This means that we roll the prior year's components when initially packaging students. Once the new aid year's COA is finalized, we re-run COA to update these components on all students prior to disbursement each term. This involves updating the budget component screen in our student information system. In 2022-2023, we rolled the 2021-2022 budget components and did not accurately update the components in Banner, which led to lower COA for students enrolled in Fall 2022 and Spring 2023. This was not identified until the Summer of 2023 when entering the weekly summer budget components. The Office of Financial Aid will implement a new aid year checklist specific to the review of Cost of Attendance that has a sign-off for each step of the process. The Executive Director and Director have responsibility in creation of the annual Cost of Attendance. The COA is shared with the Vice President of Enrollment Management prior to any awarding occurs. After the creation of the COA chart, the Director and Assistant Director will ensure accuracy of the chart in comparison to the COA methodology. The Director of Financial Aid will enter these components into Banner with secondary review by the Assistant Director. We will provide screenshots with the checklist that the COA chart matches Banner. When our IT staff runs COA prior to disbursement, we will test a sample of students to ensure budgets match the COA chart and RORALGS. The policy and procedure will be revised to include these updated procedures. The 2024-2025 aid year cycle is an atypical cycle with the delayed release of the FAFSA. We will not receive ISIR records until at least February 2024. We will not package students until after the 2024-2025 COA is finalized. This means that we will not roll the 2023-2024 COA. We will follow our new updated procedures and checklist to ensure accurate calculations and reporting. Implementation Date: March 2024 Responsible Persons: Kathy Wright, Executive Director of Student Financial Assistance Services Amanda Petrosian, Director of Financial Aid Josiah Mendoza, Assistant Director of Operations

Corrective Action Plan: The University has adjusted its practices to verify the academic engagement after resigning through online activity reports for students enrolled in distance education courses. Additional training is being provided to faculty members on the importance of the last day of attendance records. Implementation Date: January 2024 Responsible Person: Amy Wilson, Director of Financial Aid and Scholarships

Corrective Action Plan: The user access has been limited to their specific job function. The university will verify user access was appropriately updated/removed. Access review procedures will be reviewed to ensure access is appropriately assigned in the future. To streamline and assure a consistent outcome regarding the approvals for security patches to be introduced to the production environment, the University will convert these normal changes to standard changes. A standard change is “A pre-authorized change that is low risk, relatively common and follows a procedure or work instruction. (ITIL v4 definition.)” Software patching and updates are standard change candidates. Not applying security patches in a timely manner introduces a greater risk to the University than processing these requests as a normal change. A standard change is pre-authorized and will address how IT is testing and/or validating whether the OS patches were successful in an available test environment prior to deployment to production. Test procedures will be documented as a requirement of the Standard Change Model. IT will document that outcome of the testing and/or validating of the OS patch as a Journal entry on the Standard Change prior to implementation. The Change Advisory Board (CAB) will review these changes/procedures on a regular basis to ensure we are in compliance. Policies, Standards and Procedures will be updated to meet any required changes. Implementation Date: January, 2025 Responsible Persons: Michael Dewey, Chief Technology Officer Amy Wilson, Director of Financial Aid and Scholarships

Corrective Action Plan: Lamar University has already begun making strides to improve processes to ensure Return to Title IV (R2T4) funds are being reviewed and calculated correctly as it relates to return calculations. With turnover in staffing, we have worked to identify training materials available and schedule our FA Specialist Sr. the opportunity to attend the Return to Title IV training offered through NASFAA. Moving forward, any future staff will be required to attend this course to gain a better understanding of the process. We were provided a list of schools with unique modules for support or guidance with our processes. Once these resources and trainings are available, the Standard Operating Procedure manual will be updated to reflect process improvements. IT is working with Student Aid to review reports and streamline the data used to identify students with changes to enrollment. This will allow a quicker turnaround time for processing students’ accounts. A process has been implemented with Student Aid and the Registrar’s office to ensure that all changes to the academic calendar are reported so that adjustments can be made. This will ensure that an accurate calculation of days is being used. In addition, we have begun reviewing our current Course Program of Study process and look to implement a change. This will allow us to freeze a student’s CPOS, which will avoid a student having a change in aid eligible enrollment after the R2T4 adjustments have been made. Implementation Date: August 2024 Responsible Person: Megan Begnaud, Director of Student Aid

Corrective Action Plan: The Student Aid office has worked with IT to automate the communications identified in the audit report. All processes are successfully running with the new system. Student Aid is also reviewing disbursement communications. Based on testing it was identified that students were being notified based on the traditional student schedule, but additional disbursements for online students were being missed. We are actively working to implement disbursement communications for all parts of terms. It was identified that the Nursing Faculty Loan Program (NFLP) was initially set up in the system as a grant, which did not cause the missing promissory note to prevent disbursement. This NFLP has been corrected in the Banner system from grant to loan, which will trigger the systems set in place for disbursement to students receiving the NFLP. Implementation Date: February 2024 Responsible Person: Megan Begnaud, Director of Student Aid

Corrective Action Plan: When the office of Student Aid began work on the Fiscal Operations Report and Application to Participate (FISAP), a discrepancy in the PELL amount was identified. The SAO team requested the FISAP in October 2023, which notated that the PELL amount would need to be submitted by the December 15th deadline. The corrections to PELL were not resolved by the December 15th deadline, so a request for extension was requested on December 15, 2023, and granted on December 20, 2023, with an updated due date of January 3, 2024.  Part II, Section E was completed with the corrected PELL amount on final submission.  FSEOG Expenditures Reporting is being reviewed by Student Aid and Student Business Services to identify the error in reporting discrepancies. Implementation Date: February 2024 Responsible Persons: Megan Begnaud, Director of Student Aid

Corrective Action Plan: A process with the Student Aid office exists for aid clean up that is run after Census Day for each part of term identifying students that had a variation in payouts versus packaged budget. In reviewing the 2022-2023 aid year, it appears that these reports and processes were not being worked due to staff turnover. Working the students identified on this report is part of scheduled processes. Student Aid is working with IT to have these reports automated and scheduled out for delivery to ensure that it is received and worked in a timely manner. Implementation Date: February 2024 Responsible Person: Megan Begnaud, Director of Student Aid

Federal Direct Student Loans and Federal Pell Grant Program – Assistance Listing No. 84.268 and 84.063 Recommendation: We recommend that the University enhance its policies and procedures to ensure required contracts and contract components are provided to the Department of Education when required. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The management team acknowledges this finding. At the time of the audit, management could not ascertain whether the contract with BankMobile was uploaded to the Department of Education Contract portal as there is no repository or database available to schools. This submission was completed in February 2024. Names of the contact persons responsible for corrective action: Agnes Maina Planned completion date for corrective action plan: Completed

Federal Direct Student Loans and Federal Pell Grant Program – Assistance Listing No. 84.268 and 84.063 Recommendation: We recommend that the University enhance its policies and procedures regarding stale-dated check escheatment to ensure that the funds are returned to the appropriate program within 240 days from the date of issue. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The management team acknowledges this finding as it was identified and rectified during an internal audit earlier this year. Effective Fall 2023 a new process is in place that incorporates all Title IV funding into the current stale-dated refund check process. The Bursar and the Student Financial aid office will closely monitor aging checks and reissue or return funds to the Department of Education. Names of the contact persons responsible for corrective action: Stephanie Hanigan and Karinda Decker Planned completion date for corrective action plan: Completed

Federal Direct Student Loans and Federal Pell Grant Program – Assistance Listing No. 84.268 and 84.063 Recommendation: We recommend that the University enhance its policies and procedures regarding enrollment reporting including additional monitoring over the third-party service provider to ensure that reporting is completed accurately and timely. Action taken in response to finding: The Student Records Specialist will increase monitoring of Clearinghouse data. SOU will also reach out to Clearinghouse to identify reports/tools that can assist with accurate and timely reporting. Issues that are identified will be communicated to the Director of Financial Aid and University Registrar for reconciliation. Name(s) of the contact person(s) responsible for corrective action: Karinda Decker and Matt Stillman Planned completion date for corrective action plan: Immediately

Finding 2023-002 – Enrollment Reporting – Significant Deficiency ALN Number: 84.063; 84.268 Federal Award Identification Number: P063P220616; P268K230616 Recommendation: It is recommended that the College have someone independent of the preparer review the NSLDS roster file to check the effective date of change in status is in agreement with the College's records. Action Taken: Academic Records Office personnel were re-trained. Also, a report has been written to be run after the Student Status Confirmation Report (SSCR) procedure is run in the student financial aid system, that flags when a “Last Date of Attendance (LDA)” and NSLDS Withdrawal Date differ. Those cases can be troubleshooted and fixed, the SSCR rerun, and that updated file uploaded.

Finding 2023-001 – Eligibility for Subsidized Direct Loans ALN Number: 84.268 Federal Award Identification Number: P268K230616 Recommendation: It is recommended that the College ensure that all EFC information from the ISIR is entered in to the student aid packaging system before the student aid award is calculated. Action Taken: In review of the student records, the student aid packaging system at the time of aid determination indicated an EFC of $0 and months and weeks in academic year being zero. However, the FASFA was completed and the ISIR EFC amount was known at the time of the packaging and loan issued due to the cost of attendance not calculating correctly at time of packaging. The student aid packaging system parameters ensure that if need amount is $0 the system will stop a subsidized direct loan from being awarded. The weeks and months in academic year information was corrected in their next term and a subsidized loan was not awarded. Error appears related to only their first loan issued. The allowance of subsidized loans was due to user error because the months and weeks enrolled in academic year were showing as zero. The College has re-trained its staff on the sequence of processing and ensure that inputs for months and weeks in academic year are correct. The College also worked with their student information system to ensure the set up for academic year definitions for cost of attendance calculations are set to be automatic for proper calculations. The College made an internal report in order to review all student financial need for the 2022-2023 academic year in February 2024 and determined there were no additional students awarded need based aid in excess of their financial need. The College will continue to use this report every term to review need. For the 2 students that received subsidized loans in error, their loans were refunded in March 2024.

Noncompliance with HCM 1 Monitoring Planned Corrective Action: SDCC currently operates under HCM2 status which requires that the College proves that sufficient compliance has been met prior to the reimbursement of all Title IV funds. As SDCC continues its efforts to move to HCM1 status, processes and procedures have been identified and will be implemented when authorization to operate under HCM1 status is received. Person Responsible for Corrective Action Plan: Kayleigh Reyes, Director of Financial Services Anticipated Date of Completion: Policies and procedures for HCM1 was provided during the audit.

Corrective Action Plan To ensure complete and comprehensive National Student Loan Data System (“NSLDS”) reporting compliance as outlined in 34 CFR 685.309(b)(2) and in 2 CFR Part 200, Appendix XI Compliance Supplement, the College undertook a review of its trainings and procedures. Within that review, areas of inconsistencies were identified relative to status changes and timely reporting. Acknowledging that the current procedures were not adequate, the College has implemented additional trainings and reconciliation procedures, as recommended. Revised trainings to the College employees responsible for processing information for the NSLDS will henceforth include, but not be limited to, an annual review of both the NSLDS Enrollment Reporting Guide and the National Student Clearinghouse Enrollment Overview. Such trainings will emphasize the importance of reporting accuracy and timeliness. The College has also updated reconciliation procedures for enrollment reporting and added the implementation of a secondary review of monthly enrollment submissions by the Director of Title IV Compliance. Timeline for Implementation of Corrective Action Plan Effective immediately. Contact Person Colleen Woods, Director of Title IV Compliance