Corrective Action Plans

The Department has ramped up recruiting efforts by advertising positions on external websites such as indeed. The accounting department has recently increased the wages of existing staff and the starting wages of all positions in an effort to attract and retain qualified staff.

The Department has hired a new audit firm that specializes in the audits of Tribes. Our new audit firm has demonstrated a commitment to allocating the necessary resources to complete our audits in a timely manner.

The College has spent a significant amount of time in FY 2025 evaluating their IT controls and policies, and procedures. New internal controls are expected to be implemented to address these findings.

The finding resulted from a manual error. The University will evaluate the existing review process to ensure it operates with the level of precision necessary to detect such discrepancies. Additionally, targeted training will be provided to staff, where applicable, to reinforce proper review procedures and reduce the risk of future manual errors.

The Financial Aid Office has added system controls that will assure that disbursements that are recorded on PeopleSoft is recorded on COD to assure that the Pell reporting requirements are executed in compliance with Federal statutes. The process consisted of creating automation that and reducing the manual intervention so that the issues preventing the Pell disbursement from being recorded on COD is reduced. We are adding automation for processing: FABATCH, ATB automation, and Citizenship automation.

Student Registration and Financial Services (SRFS) and the office of Student Financial Aid (SFA) will review existing policy/practice around updates to disbursement records. We will make any necessary changes to controls to ensure all disbursements are included for reporting to the COD within the required timeframe.

Student Registration and Financial Services (SRFS) and the office of Student Financial Aid (SFA) will continue collaboration with school partners and the office of the Provost to reinforce university policies and procedures by continuing to provide training to individuals involved in the process of updating student’s enrollment. The office of the University Registration (OUR) and SFA will collaborate to use existing school partner meetings, and internal functional partner meetings to conduct training. OUR generated its first Enrollment Reporting out of the new system (Banner Student) in Summer 2022. We expect to achieve steady state processing, when moving from the main frame to ERP system within five years of go-live. SRFS will review school partner access through audit reports to determine error rates and assess risk. SRFS will review existing policy/practice around student activated drops/withdrawals/Penn Leaves of Absence and make recommendations.

Student Registration and Financial Services (SRFS) and the Office of the University Registrar (OUR) will continue collaboration with school partners and the office of the Provost to reinforce university policies and procedures. Over the course of the last year (as the newly implemented system entered its second year), the university has increased the number and expertise level of employees in the OUR and offered entry level training to key stakeholders. OUR generated its first Enrollment Reporting out of the new system (Banner Student) in Summer 2022. We expect to achieve steady state processing, when moving from the main frame to ERP system within five years of go-live. SRFS will increase the depth of the training sessions by working with school registrars to help bolster their understanding and expertise. The SRFS and OUR will use various monitoring reports and data to identify areas of concern and to inform training offerings.

Pacific Union College transmits enrollment information to NSDLS through the National Student Clearinghouse (NCS), a third-party organization. PUC was faced with an unprecedented series of events related to data reporting to the National Student Clearinghouse between January and May 2024. During the month of February 2024, the College Registrar resigned without notice and the Director of Institutional Research tragically passed away within one ten day period. At that time the Director of College Admissions was asked to serve as the emergency Registrar and emergency IR Director. The above events led to some gaps in reporting to the NSC during the months noted above including some gaps in reporting that had occurred before the Registrar resigned. Communication with the NSC began immediately and during this time a series of reporting deadlines were “forgiven” by the NSC liaisons in support of PUC during a difficult series of one time events. Since the above dates PUC has been consistent and timely with all reporting to the NSC and the college anticipates that current staffing levels and cross training will prevent any such occurrences in the future.

Finding: Allowable Activities & Allowable Costs and Eligibility (Reference Number: 2024-001) Criteria or Specific Requirement: Funds may be expended for foster care maintenance payments on behalf of eligible children, in accordance with the Title IV-E agency’s foster care maintenance payment rate schedule and in accordance with 45 CFR section 1356.21, to individuals serving as foster family homes, to childcare institutions, or public/private child-placement or child-care agencies. In accordance with Code of Colorado Regulations (CCR) section 7.302.2, for each child, Jefferson County Human Services (JCHS) must have an agreement with the provider which details the daily maintenance payments. JCHS agreement to purchase services must be signed by the provider and JCHS. Additionally, in accordance with CCR section 7.301.3, the Family Services Plan shall be reviewed in conference with the caseworker and supervisor every 90 calendar days. Condition: • Two instances out of 40 where there was no signed agreement in place to support revised maintenance payments following a child’s 9th birthday. The correct maintenance amount was paid to the provider in accordance with the State of Colorado rates published in IM-CW–2024-0028 and IM-CW-2023-0021. • One instance out of 40 where the required 90-day review was not completed on time. The review was conducted 15 days late. Cause: The state's Foster Care system did not automatically generate a notice that a new agreement to purchase services was needed based on the child's birthday. Additionally, JCHS lacks an effective control mechanism to proactively identify when a 90-day review is approaching or overdue. Corrective Action Plan: We agree with the finding. The Integrated Case Management System (ICM) is designed to generate an email notification to Collaborative Foster Care Program (CFCP) staff when a child turns 9 or 14 years of age while in foster care. This email notification instructs CFCP staff to generate a new Child Specific Addendum (SS23-B) due to the increase of the child maintenance rate. This email instructs and standard procedure requires CFCP staff to verify the child maintenance rate in Trails after an SS23-B is generated. The IT Systems Support Team responsible for the maintenance of ICM determined that ICM has failed to notify CFCP staff when a child turned 9 or 14 years of age while in foster care: • The IT Systems Support Team responsible for the maintenance of ICM has been asked to ensure that ICM is generating an email notification when a child turns 9 or 14 years of age while in foster care. • While this issue is being addressed in ICM, the CFCP requested a report that included the birthdays for all children in foster care. CFCP staff have generated new Child Specific Addendums (SS23-B) for children that have turned 9 or 14 years old while in foster care. CFCP staff will utilize this report to generate new Child Specific Addendums for future birthdays. • After a new Child Specific Addendum is generated, staff will verify the child maintenance rate in Trails. • The CFCP has determined that it can no longer rely on ICM and has decided to migrate its functionality over to the ancillary system supported by Jefferson County known as the Caseworker Application Timesaver (CAT). With this migration, the email notifications will resume so that CFCP staff are properly notified of the need to generate the new SS23-B and verify the child maintenance rate. • Migration is scheduled to occur on Friday, June 20, 2025. • On Monday, June 23, 2025, the CFCP will meet with the Jefferson County Application Program Analyst to ensure the migration was successful. • Additionally, the CFCP and the Jefferson County Application Program Analyst have scheduled a second meeting for July 9, 2025, to ensure the successful migration from ICM to CAT. • To ensure 90-Day Reviews are completed timely, the Division of Children, Youth, Families, and Adult Protection (CYFAP) will continue to utilize the 90-Day Review compliance feature of CAT. Additionally, CYFAP leadership will emphasize this requirement with supervisors and casework staff and ensure their compliance. Person(s) Responsible for Implementation: Barb Weinstein, Director, Division of Children, Youth, Families and Adult Protection Implementation Date: July 1, 2025

2024-003 – Cash Management (Significant Deficiency) Department of Education, SFA Cluster, Cash Management Criteria: In accordance with 34 CFR 668.164, an institution submits a drawdown request for funds utilizing ED’s electronic grants management system that may not exceed the amount of funds needed to make immediate disbursements to eligible students and parents. The institution must disburse the requested funds as soon as administratively possible, but no later than three business days following receipt of those funds from ED. Any funds not disbursed by the end of the third business day are considered excess cash. Condition: A sample of twenty-six students were tested for timely distribution of federal student aid funds. Aid was distributed more than three business days after funds were received from ED for all students tested. Cause: Lack of controls over cash management. Effect: Excess federal cash retained by the institution. Recommendation: We recommend the University implement appropriate training regarding compliance regulations into the employee onboarding process and thereafter for applicable employees. In addition, we recommend the University implements timely review procedures to ensure that any overdrawn funds are returned within the tolerance period. Action Taken: The University acknowledges the deficiency in the timely disbursement of Title IV funds and has taken immediate corrective action to strengthen cash management controls. Specifically, the Financial Aid Office and the Business Office collaborated to revise internal procedures to ensure that federal funds are disbursed within three business days of receipt from the U.S. Department of Education. Effective 7/16/2025, a new standard operating procedure (SOP) was implemented, which includes: 1) Weekly reconciliation between Campus Anyware and G5 drawdowns to track the timing of funds received and disbursed. 2) Mandatory compliance training on federal cash management regulations for all financial aid and student accounts staff, both during onboarding and annually thereafter. 3) Monthly internal audits to review disbursement timelines and identify exceptions. Additionally, any funds inadvertently held beyond the three-day window are now promptly returned to G5 within the regulatory tolerance period. Responsible Party and contact information: Triniti Lee – Financial Aid Processor, Leetk2@webber.edu, Adhley Neal – Business Office Processor, nealad@webber.edu. Expected Date of Correction: 8/1/2025

2024-005 – Over Award of Federal Pell Grant Program Funds (Significant Deficiency) Department of Education, SFA Cluster, Special Tests and Provisions Criteria: In accordance with 34 CFR 668.32, a student is eligible to receive Title IV, HEA program assistance if the student meets all of the requirements in 34 CFR 668.32 paragraphs (a) through (m). 34 CFR 668.32(a)(1)(i) requires the student to be a regular student enrolled, or accepted for enrollment, in an eligible program at an eligible institution. Condition: Of 26 students tested for eligibility, one student received Title IV, HEA program assistance for a semester that the student was not enrolled in. Cause: Controls are not functioning properly. Effect: Title IV program funds were awarded to a student who was not eligible to receive such funds. Recommendation: We recommend the University review and update its procedures to ensure that Title IV funds are awarded properly. Management Response: The University acknowledges the over-award of Title IV funds due to disbursement for a student who was not enrolled during the term in question. In response, the University has strengthened its internal controls to ensure that federal aid is awarded and disbursed only to students who meet all eligibility criteria as outlined in 34 CFR 668.32. Corrective actions taken include: 1) System Validation Enhancements: The student information system has been updated to include enhanced enrollment validation checks before the release of Title IV funds. Title IV disbursements are now restricted to students with confirmed active enrollment in eligible programs for the applicable term. This is enforced through automated disbursement blocks that are triggered when enrollment data is missing or inconsistent. 2) Pre-Disbursement Review Process: A pre-disbursement verification step has been implemented, requiring financial aid staff to confirm active enrollment statuses before releasing funds. 3) Staff Training: Targeted training has been provided to financial aid staff on Title IV enrollment eligibility requirements. Responsible Party and contact information: Triniti Lee – Financial Aid Processor, Leetk2@webber.edu. Expected Date of Correction: 8/1/2025

2024-004 –Satisfactory Academic Progress Policy (Significant Deficiency) Department of Education, SFA Cluster, Eligibility Criteria: In accordance with 34 CFR 668.34(a), an institution must establish a reasonable satisfactory academic progress policy for determining whether an otherwise eligible student is making satisfactory academic progress in his or her educational program and may receive assistance under Title IV, HEA programs. A student placed on academic probation may receive Title IV, HEA program funds for one payment period. At the end of one payment period on financial aid probation, the student must meet the institution's satisfactory academic progress standards or meet the requirements of the academic plan developed by the institution and the student to qualify for further Title IV, HEA program funds. Condition: Our review of 26 student files disclosed that one student was placed on academic probation after fall 2023 semester and received Pell for spring 2024 semester. The student did not meet satisfactory academic progress standards at the end of spring 2024 semester, however, the student received Pell for summer semester 2024. Cause: Controls are not functioning properly. Effect: Title IV program funds were awarded to a student who was not eligible to receive such funds. Recommendation: We recommend the University review and update its policies to ensure that the University’s Satisfactory Academic Progress policy is enforced. Management Response: The University acknowledges the oversight in the enforcement of its Satisfactory Academic Progress (SAP) policy and has taken corrective action to address the deficiency. Specifically, the Financial Aid Office has conducted a comprehensive review of SAP monitoring procedures to ensure full compliance with federal regulations under 34 CFR 668.34. Corrective steps taken include: 1) Policy Clarification and Staff Training: The SAP policy has been reviewed and clarified to emphasize the requirement that a student failing to meet SAP after one payment period on financial aid probation is no longer eligible for Title IV funds unless they meet the conditions of an approved academic plan. Targeted training was delivered to financial aid counselors and compliance staff to reinforce correct application of SAP policies and documentation protocols. 2) Automated SAP Compliance Flag: An automated flag has been integrated into the student information system to alert staff when a student has reached the end of a probation period. This flag prevents Title IV disbursement until a manual review confirms eligibility based on SAP or academic plan compliance. 3)Ongoing Monitoring and Quality Assurance: At the conclusion of each academic term, the University runs comprehensive SAP reports to identify all students who have either regained eligibility, remained on SAP, or have newly been placed on SAP status. The student information system is configured to automatically flag these students and restrict Title IV disbursements through system-based controls in the auto-packaging process, thereby preventing ineligible aid disbursements and ensuring compliance with federal regulations. Responsible Party and contact information: Pamela Denton - Financial Aid Counselor, dentonpe@webber.edu, Trinity Lee – Financial Aid Processor, Leetk2@webber.edu. Expected Date of Correction: 8/1/2025

Identification: 10.766 United States Department of Agriculture (USDA), Community Facilities Loans and Grants Cluster, Noncompliance Finding/Significant Deficiency, Special Tests and Provisions. Corrective Action Plan: The Medical Center will seek guidance from the bond trustee and USDA related to the insurance provisions in the bond documents for the amount of fidelity bond coverage and retaining an insurance consultant to provide a report. Anticipated completion date: The Medical Center anticipates this to be completed during 2025.

Identification: 10.766 United States Department of Agriculture (USDA), Community Facilities Loans and Grants; Noncompliance Finding; Special Tests and Provisions Corrective Action Plan: The Medical Center will take the necessary steps outlined in the bond indenture and work with the bond trustee in order to improve the financial covenants and come back into compliance. Anticipated completion date: The Medical Center anticipates this to be completed during 2025.

Title IV-E Foster Care Assistance Listing No. 93.658 Recommendation: We recommend LSI design controls to ensure an adequate review process is in place for all drawdown requests. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Preparer of drawdown request will have approval from another finance team member. Name(s) of the contact person(s) responsible for corrective action: Roni Knief Planned completion date for corrective action plan: Complete and ongoing

a. Administrator: V.P. Finance/ CFO ....... Victor Parker 601-857-3961 b. Administrator: V.P. Student Services ...... Jennifer Scott-Gilmore 601-857-3250 The District did not properly calculate the total amount disbursed or to be disbursed which lead to incorrect calculation of funds to be returned to Title IV. Additionally, the District did not provide evidence of date of determination used in calculation. b. Corrective Action Plan: The District is an attendance taking institutional and has reviewed its internal controls on how total days in the semester are calculated correctly and timely disbursements are made. The District understands that it should be using the Last Day of Attendance in the calculation of earned aid and made that modification Spring 2025 in collaboration with the U.S. Department of Education and outlined the calculation variables to align with that calculation change. Management has revised its Policy and Procedures accordingly and will submit to the Hinds Board of Trustees for final approval December of 2025. The correction implementation date was June 2025 to be finalized December 2025.

a. Administrator: V.P. Finance/ CFO ....... Victor Parker 601-857-3961 b. Administrator: V.P. Student Services .... Jennifer Scott-Gilmore 601-857-3250 The District did not report timely and accurate student status information to the National Student Loan Data System (NSLDS). The District did not ensure internal controls were in place to ensure timely and accurate reporting. b. Corrective Action Planned: The Management has implemented additional organizational and internal controls to ensure students' enrollment statuses are reported timely and accurately. In reviewing the causation of the finding, it was determined that it was a personnel error and as of June 2024, there is a new Registrar for Hinds Community College charged with compliance of this requirement. During the AY2024-25, the Registrar worked within the new student information system (SIS) to generate the required student data on a monthly cycle to be submitted to the National Clearinghouse which is then transmitted to NSLDS. This update in internal controls should satisfy future reviews.

a. Administrator: V.P. Finance/ CFO ....... Victor Parker 601-857-3961 b. Administrator: V.P. Student Services ...... Jennifer Scott-Gilmore 601-857-3250 The District using a Servicer to Deliver Title IV Credit Balances to a card did not provide a URL for the contract to the Department of Education in the Cash Management Contracts Database and disclose the contract on the District's website. b. Corrective Action Planned: The Management has reviewed the District process of delivering Title IV credit balances to students. Management will disclose the third-party contractual agreement to its Servicer as well and provide the URL to the Department of Education via the Cash Management Contracts Database. The anticipated completion date is August 2025.

2024-005 TIMELINESS OF FEDERAL REPORTING County personnel responsible for resolution: Timothy Rutkowski, Prosecuting Attorney Ann Schultz, Friend of the Court/Director of Juvenile Services Corrective action plan response: The County will review current procedures and implement new procedures as necessary to ensure all reports are completed, reviewed, and submitted timely. Anticipated completion date: December 31, 2025

The late audit submission was a result of significant leadership and staffing turnover, unresolved audit support items, and missing reconciliations from prior months. The University engaged an external firm to stabilize the finance function and has since appointed an interim Controller. Beginning with FY26, the University will adopt a rolling monthly close schedule, establish an internal audit prep calendar, and define internal deadlines for deliverables to external auditors. These steps will support timely completion of future audits. Target: Audit submission by March 31, 2026 for FY25.

The University concurs with this finding. Due to turnover in critical roles, the FY24 FISAP contained inaccuracies. The University has appointed an interim Controller to oversee the correction of reporting processes. The new process will require that all FISAP data be supported by reconciled financial records and reviewed collaboratively by Financial Aid and Accounting staff. Process updates and internal review checklists will be developed in time for the FY25 submission, with training and testing of the new approach by June 30, 2026.

This finding resulted from a loan disbursement exceeding regulatory limits for one student. The issue was corrected before the audit report was finalized. The University will strengthen its review process prior to disbursement by ensuring additional loan eligibility is validated and documented. The Financial Aid Office will receive targeted training on aggregate loan monitoring. Corrective actions will be fully implemented by January 31, 2026.

The University acknowledges the enrollment status reporting errors noted in the audit. This was due to a lack of coordination between departments responsible for enrollment status updates and NSLDS reporting. Under the direction of the interim Controller, the University will work with Registrar, Office of Records and Registrations to implement a monthly reconciliation process and establish clear ownership of status reporting responsibilities. A tracking log will be introduced to monitor timely and accurate submissions. Completion of corrective actions is expected by March 31, 2026.

As of today’s date, the institution has forwarded the corrections to Financial Aid Services to be made in NSLDS. The institution will verify the corrections have been completed by June 20, 2025. In addition to the corrections the institution has and will continue training to better understand the dates to be reported in NSLDS when there is a student on a Leave of Absence that does not return.