Corrective Action Plans

National Student Loan Data System (NSLDS) Enrollment Reporting Recommendation: We recommend that the University review their policies and procedures to ensure accurate reporting and responding to enrollment rosters to NSLDS. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Reason for finding: The previous corrective action plan failed to fully address this finding. Action taken in response to finding: Not Applicable- No corrective action will be made, Hodges University closed on August 25th, 2024. Name(s) of the contact person(s) responsible for corrective action: Not Applicable Planned completion date for corrective action plan: Not Applicable

Finding 2024-002: Student Financial Assistance Cluster - Refunds of Title IV Funds - Special Tests & Provisions Criteria: In accordance with 34 CFR 668.221, when a recipient of Title IV grant or loan assistance withdraws from an institution during a payment period or period of enrollment in which the recipient began attendance, the institution must determine the amount of Title IV aid earned by the student as of the student's withdrawal date. If the total amount of Title IV assistance earned by the student is less than the amount that was disbursed to the student or on his or her behalf as of the date of the institution's determination that the student withdrew, the difference must be returned to the Title IV program within 45 days of the date of withdrawal. Condition: We examined 12 students who had withdrawn from the institution during a payment period or period of enrollment in which the recipient began attendance to ensure that the calculation and return of Title IV funds was done in accordance with 34 CFR 668.221. We noted that for one student who officially withdrew as of July 1, 2024, the calculation related to the return of Title IV funds was not done until October 7, 2024 and the return of funds did not occur until October 16, 2024. Controls in place were not operating effectively to ensure calculations and return of Title IV funds were done in the required time frame as outlined in 34 CFR 668.221. Cause: The College's process to identify students whose withdrawal requires a calculation of the return of Title IV funds is a manual process. The College does not have a process in place to verify that all students are identified and that all calculations and return of funds were done timely. Effect: The College had 1 student whose calculation and return of Title IV funds was not completed within the required timeframe and potentially could have additional students whose calculation and return of Title IV funds was also not completed in a timely manner. Repeat Finding: This is not a repeat finding. Questioned costs: Unknown Recommendation: We recommend that the College follow procedures in place to ensure all students who have withdrawn and require a calculation and potential return of Title IV funds are identified timely so that return of Title IV funds may be completed as required. View of Responsible Officials and Planned Corrective Action: Management agrees, see separate Corrective Action Plan Responsible Official: Executive Director of Finance and Financial Aid Corrective Action Plan: To ensure compliance with federal regulations regarding the Return to Title IV (R2T4) process, the College will implement the following steps to review students who begin attendance during a payment period or enrollment period, withdraw from the institution, and determine if the amount of Title IV aid earned by the student is less than the amount disbursed to the student or on their behalf as of the withdrawal date. Any excess Title IV aid will be returned to the appropriate program within 45 days of the withdrawal. The following procedures will be enacted: 1. Review of Withdrawal Reports: The Assistant Director of Financial Aid will regularly review the daily registration changes report to identify students who have withdrawn from the term. 2. Assessment of Title IV Aid: For each student identified as withdrawn, the Assistant Director of Financial Aid will verify whether Title IV aid was disbursed. If Title IV aid was received, the R2T4 calculation will be completed to determine the amount of aid earned. 3. Return of Unearned Title IV Funds: If the calculation indicates that the amount of Title IV aid disbursed exceeds the amount earned, the Assistant Director of Financial Aid will ensure that the appropriate funds are returned to the Title IV program through the Common Origination and Disbursement (COD) system, PowerFAIDS, and Jenzabar within 30 days of the student's withdrawal. 4. Notification and Coordination of Fund Return: If the College is required to return Title IV funds, the Assistant Director of Financial Aid will notify the Executive Director of Finance and Financial Aid, as well as the Chief Financial Officer, to ensure that funds are returned to the G5 system in a timely manner. 5. Daily Report Verification: The Assistant Director of Financial Aid will sign and date the daily registration changes report to confirm that it has been reviewed, the appropriate R2T4 calculation has been completed, and any necessary funds have been returned to the Title IV program. By implementing these steps, the College will ensure that it remains in full compliance with Title IV regulations, effectively manages financial aid disbursements, and returns unearned funds in a timely manner.

Finding 2024-001: Student Financial Assistance Cluster-Student Eligibility Criteria: In accordance with 34 CFR 668.165 (a), before an institution disburses title IV program funds for any award year, the institution must notify a student of the amount of funds that the student or his or her parent can expect to receive under each title IV program and how and when those funds will be disbursed. Additionally, when Direct Loans are being credit to a student's account, the institution must notify the student, or parent in writing of the date and amount of disbursement as well as the timing and process by which a parent may cancel the loan. The notification process is often completed by either an award letter or college financing plan. Controls were not in place to ensure that college financing plans were emailed to all required students and/or parents. Condition: The college notifies students of Title IV funding by emailing a college financing plan to the student and/or parent. The college's manual process to identify students who should be notified of the Title IV funding did not identify three students out of forty tested that should have received a college financing plan. Cause: The college process to notify students and/or parents, involves a manual process to idently those who should receive a college financing plan. College financing plans are distributed by email to the student/ and or parent. The college does not have a system in place to verify that everyone who received Title IV funding received a College Financing Plan. Effect: The college did not provide notification via a College Financing Plan of Title IV funding to three of its students as required and potentially could have additional student that did not receive proper notification. Repeat Finding: This is not a repeat finding Recommendation: We recommend that the college implement procedures to ensure all students receive notification of Title IV funding as required under 34 CFR 668.165 (a). Questioned Cost: None View of Responsible Officials and Planned Corrective Action Plan: Responsible Party: Executive Director of Finance and Financial Aid Corrective Action Plan: To ensure that alt students and their parents are adequately informed of the funds they can expect to receive under each Title IV program, as well as the timing and process for disbursement, the college will implement the following actions: 1. College Financing Plan Notification: The college will incorporate the College Financing Plan notification into the packaging checklist, ensuring that it is completed when a student's financial aid package is finalized. 2. Updated College Financing Plan: A new College Financing Plan will be provided to students whenever there is an addition or adjustment to their awards. 3. Loan Disbursement Notification: Loan notification letters will be sent to students each time a Direct Loan is disbursed to their account, informing them of their right to cancel the loan if desired. 4. Quarterly Review: The Assistant Director of Financial Aid will conduct a quarterly review to ensure compliance with these procedures and verify that all necessary notifications are being issued as required.

Southwestern Law School provides the following corrective action plan for the finding Moss Adams, LLP identified during the Southwestern's federal awards audit for the year ending June 30, 2024. Southwestern acknowledges the finding and recommendation from Moss Adams. Finding 2024-001 - Special Tests and Provisions - Enrollment Reporting: Significant Deficiency in Internal Control over Compliance. Responsible Offices and Individuals: Improving procedures around enrollment reporting is the joint responsibility of the Registrar's Office and the Information Office. Eileen Zwiers, Registrar, and Sean Murphy, Chief Information Officer, are responsible for implementing the corrective action plan. Corrective Action Plan: Southwestern has prepared and implemented a new Enrollment Reporting Policy to ensure Title IV compliance when reporting changes in student enrollment status to the National Student Loan Data System. The policy outlines Southwestern's procedures for timely, accurate and complete through the National Student Clearinghouse. Additionally, the Financial Aid Office will conduct monthly audits of reported submissions directly from the National Student Loan Data System portal to ensure accuracy. The Financial Aid Office documents and securely stores these verified submissions to support the federal audit, in compliance with federal retention and data management policies. Anticipated Completion Date: Southwestern took immediate action to improve the policies and procedures around enrollment reporting. The remediation was appropriately completed September 2024. Sincerely, Eileen Zwiers Registrar Sean Murphy Chief Information Officer

It is our understanding that the issue is occurring for many instituations and appears to be due to changes in processes at the National Clearinghouse. We will monitor steps taken and updates made to maintain awareness of any resolution to the issue made at the Clearinghouse. We will also develop an internal process to review student status effective dates as reflected in NSLDS and make updates as needed.

Finding 2024-003 A plan has been developed to take corrective action regarding finding 2024-003 in our audit for the year ended June 30, 2024. Condition: Return of Title IV funds calculations were incorrectly performed during the year. Cause: The Financial Aid department does not have adequate processes and controls around return of funds to ensure calculations are accurate and return of funds are timely. Effect: Refund calculations completed were not correct and funds were not remitted to the Department of Education properly. Corrective Action Plan (CAP) and Anticipated Completion Date: This is the result of dates being entered into multiple departmental screens and a mismatch occurred. With the recent reorganization of the Registrar and Student Financial Services now combined with Admissions into a new Enrollment Management unit, greater coordination and control is gained and will improve reporting. The Registrar and Director of Student Financial Aid will oversee these changes under the direction of the Executive Director for Enrollment Management. This will be completed asap during Fiscal Year 2025 but no later than June 30, 2025. Responsible Party for Implementing CAP: Executive Director for Enrollment Management

Finding 2024-002 A plan has been developed to take corrective action regarding finding 2024-002 in our audit for the year ended June 30, 2024. Condition: Out of 25 students tested, there were 16 students with Pell and Direct Loan attributes incorrectly reported to COD. Cause: The Financial Aid department does not have adequate processes and controls around return of funds to ensure reporting to COD is accurate. Effect: COD reporting was not properly completed for Direct Loan and Pell Grant recipients. Corrective Action Plan (CAP) and Anticipated Completion Date: The Colleague system uses the dates that are entered into parameter screens when the academic year is set up. Those dates from the setup screen are used in setting up the information per student to be sent to COD. It is likely that these preliminary dates were updated as they became more fixed. This would result in differences in individual record dates based on timing of data entry. With the gathering of offices under the Enrollment Management umbrella this fiscal year, greater coordination and control is gained and will control entry and maintenance of system dates. The Registrar will also look at creating a centralized change log for term dates for reference between the two staff areas. The Registrar and Director of Student Financial Aid will oversee these changes under the direction of the Executive Director of Enrollment Management. This will be completed asap during Fiscal Year 2025 but no later than June 30, 2025. Responsible Party for Implementing CAP: Executive Director of Enrollment Management

Finding 2024-001 A plan has been developed to take corrective action regarding finding 2024-001 in our audit for theyear ended June 30, 2024. Condition: Out of 40 students tested, there were 39 students with enrollment status changes during the year that were not communicated to the National Student Loan Data System (NSLDS) or were incorrectly reported. Cause: The Registrar’s Office and the Enrollment Services Technical Coordinator do not have adequate processes and controls around enrollment reporting to ensure reporting is accurate and timely. Effect: NSLDS was not properly notified of student enrollment status changes of Direct Loan and Pell Grant recipients. Corrective Action Plan (CAP) and Anticipated Completion Date: The Registrar's Office reports student enrollment status to the National Student Clearinghouse according to the predetermined reporting schedule. As of this fiscal year, the financial aid and registrar offices have been placed under a new Enrollment Management umbrella that will allow and require careful coordination of term, enrollment, and financial aid issues. The Registrar's Office has created and made available a procedural guide for running and submitting reports to make sure program length and other data submitted is accurate and timely. The Registrar will oversee these changes under the direction of the Executive Director of Enrollment Management. This will be completed asap during Fiscal Year 2025 but no later than June 30, 2025. Responsible Party for Implementing CAP: Executive Director of Enrollment Management

Finding No. 2024-004 Delay in Direct Loan Adjustment After Enrollment Cancellation Condition Found During our eligibility test, we identified a situation in which a student's enrollment was canceled after Pell and Direct Loan funds had already been credited to the student's account. Even though the Pell Grant adjustment and return to COD were completed promptly, the adjustment for the Direct Loan was only made after the auditor discovered that the loan had not been properly adjusted and returned to the Department of Education. Corrective Action Plan We will thoroughly explore system capabilities, and a targeted training session in the Ellucian software will be developed and scheduled to directly address the identified deficiency. All Student Financial Aid Officers will be required to complete this mandatory training. Additionally, comprehensive internal monitoring exercises will be conducted for all R2T4 events to ensure full compliance and process integrity. Name(s) of the Contact Person(s) Responsible for Corrective Action Doris Quero, Senior Financial Aid director Carmen Rivera Laboy, Title IV Compliance Coordinator Eliezer Rodriguez, Ellucian Specialist Anticipated Completion Date Will be completed on or before December 15, 2024.

Finding No. 2024-003 Late R2T4 reimbursement to ED Condition Found In testing compliance with the return of Title IV funds requirement, we noted three (3) cases, or eight percent (8%), of the sample selected, in which the University failed to return the total corresponding refund within 45 days from the date the University determined that the student withdrew, dropped-out, or failed to attend to the University. Corrective Action Plan The institution will enhance the total withdrawal process by assigning a dedicated financial aid officer to each campus, responsible for overseeing all funds. This officer will be solely accountable for determining whether a withdrawal is official or unofficial, executing the Return of Title IV (R2T4) process, and coordinating with the fiscal department to ensure timely completion of refunds. As a further safeguard, the Title IV Compliance Coordinator will rigorously monitor the effectiveness of this corrective action plan and ensure ongoing compliance. Name(s) of the Contact Person(s) Responsible for Corrective Action Doris Quero, Senior Financial Aid Director Carmen Rivera Laboy, Title IV Compliance Coordinator Anticipated Completion Date Will be completed on or before January 15, 2025.

Finding No. 2024-002 Late Refund Issuance Condition Found During our evaluation of compliance with these requirements, we noted one (1) instance, or six percent (6%) of the sample selected, in which the University failed to return the corresponding refund within 14 days’ time frame from the date the University determined that the student had a Federal Student Aid (FSA) credit balance. Forty-one (41) days passed between the date the University identified an FSA credit balance for the student and the actual refund to the student. Corrective Action Plan We will aggressively pursue systems automation alternatives to streamline operations and enforce interdepartmental collaboration to ensure strict compliance with deadlines. Additionally, we will deliver targeted cash management training, with a strong focus on rigorously reviewing and optimizing refund processing procedures. Name(s) of the Contact Person(s) Responsible for Corrective Action Héctor L. Peña, Director of Finance Ramón L. Menéndez, CFO Dr. Antonio Llorens, CIO Anticipated Completion Date Will be completed on or before January 15, 2025.

Finding No. 2024-001 Excess of Cash Condition Found In nine (9) of fifty-three (53) return drawdowns from the San Juan Campus, returns were not properly returned on G-5, creating excess cash for more than the required period of ten (10) days (3 business days plus an additional seven calendar days). In addition, refunds were not returned on G-5 in a timely manner during the required period of thirty (30) days. Corrective Action Plan The institution will appoint a dedicated G-5 administrator in Puerto Rico, independent of the Miami office, to ensure compliance. This role will be complemented by the active pursuit and implementation of advanced system functionalities designed to enhance the identification of student cases and automate and streamline processes. This comprehensive initiative will not only fortify existing procedures but will also significantly enhance operational efficiency and accountability, with an immediate escalation protocol requiring that any delays or processing issues be reported to management for prompt resolution. Name(s) of the Contact Person(s) Responsible for Corrective Action Héctor L. Peña, Director of Finance Ramón L. Menéndez, CFO Dr. Antonio Llorens, CIO Anticipated Completion Date Will be completed on or before December 15, 2024

Finding 2024-001: Unpaid Credit Balance – As the funds were used to pay prior academic year tuition, it is recommended the Institution increase controls over credit balances. Comments on Finding and Recommendation(s): HJC concurs with the finding. Student had requested funds be used to pay prior year balance, but we should not have exceeded the $200 maximum allowed by regulation. Actions Taken or Planned: FA staff has reviewed the regulatory restrictions on prior-year payments to ensure that, even at a student's request, we do not exceed the $200 maximum allowed. Excess funds retained have been returned to the student.

Finding 2024-004: Unpaid Refund – It is recommended the Institution refund the $2,071 to the Department of Education and increase controls over paying refunds. Comments on Finding and Recommendation(s): HJC has refunded the funds to the Department of Education as recommended by the audit team. This was the first active quarter in the new SIS and there was an attendance processing error. The student only logged in one time but was not withdrawn. When found, the funds were returned to the Department of Education. Actions Taken or Planned: As soon as the issue was discovered, HJC began looking at options, and entered into an agreement with CourseKey for the accurate daily import of academic and attendance information into the Campus Cafe SIS system. Daily academic information exports to GF AS are being done to ensure they have the most accurate information available for processing Title IV aid.

Finding 2024-003: Incorrect Refund Calculation – It is recommended the Institution refund $50 to the Department of Education and increase controls over refund calculations. Comments on Finding and Recommendation(s): HJC concurs with the finding of the audit team. Actions Taken or Planned: The $50 will be returned to the Department of Education. The refund was calculated correctly but posted incorrectly. HJC will be responsible for processing R2T4 calculations for aid packaged prior to the engagement of GFAS, and GFAS will process HJC R2T4 refunds required going forward.

Finding 2024-002: Inaccurate Reporting of Disbursement Dates to the Common Origination and Disbursement (COD) System – It is recommended the Institution correct the disbursement dates in COD and tighten controls over reporting disbursements dates. Comments on Finding and Recommendation(s): HJC concurs with the finding. The transition to a new SIS system created import and export issues affecting disbursement date posting. Actions Taken or Planned: HJC has entered into an agreement with Global Financial Aid Services (GF AS) to process Title IV financial aid beginning with new 2024-25 aid packaged in the Fall 2024 quarter. Global processing the aid with HJC backing up and reviewing will ensure accurate date reporting to COD. The dates in question have been updated at COD.

Finding 2024-005: Untimely Enrollment Status Reporting – It is recommended the Institution increase controls over enrollment reporting. Comments on Finding and Recommendation(s): After the transition to Campus Cafe had begun, it was determined that they did not have the capability of importing NSLDS enrollment reporting reports as our previous system had, so FA staff has been updating enrollment information manually. Actions Taken or Planned: HJC has initiated discussions with the Clearinghouse for NSLDS reporting purposes. As a recent ECAR is required to complete the contract, we are currently waiting on an updated EApp to be processed to complete the process.

Recommendation: We recommend that at each NSLDS upload date, management review the NSLDS enrollment reporting upload to ensure student withdrawals during the period are appropriately reported in a timely manner. Corrective Action: The Clarendon College Registrar’s Office will establish a review process to ensure that all classes in which a student fully withdrawing from the institution was enrolled are dropped promptly, and that the student's enrollment status matches the status reported to NSLDS.

Finding 2024-003 Significant Deficiency over Activities Allowed and Unallowed and Allowable Costs/Cost Principle; Foster Care -Title IV-E (Foster Care), Assistance Listing Number 93.658, U.S. Department of Health and Human Services, passed through the N.C Department of Health and Human Services (NCDHHS), Division of Social Services. Medicaid Cluster (Medicaid), Assistance Listing Number 93.778, U.S. Department of Health and Human Services, passed through the N.C Department of Health and Human Services (NCDHHS), Division of Medical Assistance. Supplemental Nutrition Assistance Program (SNAP) Cluster, Assistance Listing Number 10.561, 10.561-COVID, U.S. Department of Agriculture, passed through the N.C Department of Health and Human Services (NCDHHS), Division of Social Services. Recommendation: We recommend that the County implements a review control over weekly timesheets to ensure the timesheets include all program time coded on the day sheets. Corrective Action Plan: The county will conduct training on day sheet and time sheet processes. The county will complete random monthly reviews of day sheets and timesheets. For those staff identified by the random monthly review with discrepancies, supervisors will provide refresher training on day sheet and timesheet procedures. Additional targeted reviews will be completed monthly until the deficiencies are corrected. Proposed Completion Date: 1/31/2025 for initial department training 2/28/2025 initiate random monthly reviews of day sheets and timesheets 7/31/2025 for additional reviews as needed for identified staff and refresher trainings Name of Contact Person: Yolanda Mcinnis, Economic Services Division Director and Sheila Donaldson Child Welfare Division Director

Finding 2024‐001 Federal Agency Name: Department of Education Assistance Listing Number: 84.268, 84.063, 84.007, 84.033 Program Name: Student Financial Assistance Cluster – Special Tests and Provisions – Return to Title IV Finding Summary: During our review of the Return of Title IV funds, there were five instances out of nineteen in which the Title IV funds to be returned was calculated incorrectly. Corrective Action Plan: The Office of Financial Aid will review and adjust the process for calculation and review of all Return to Title IV calculations. This process will be documented and reviewed periodically to ensure adherence. Responsible Individual(s): Director of Financial Aid] Anticipated Completion Date: January 2025

The institution implemented adequate oversight to ensure the dates and the student information match NSLDS. While the institution already had a process in place to ensure National Student Clearinghouse received error-free information, the Director of Financial Aid has now started to go a step further and manually review a sample of records on the NSLDS to confirm accuracy.

Condition: The College did not accurately report the effective date of a students' status changes to the NSLDS or the correct status change to the NSLDS. Planned Corrective Action: Before pulling the enrolled student list for submission to the National Student Clearinghouse (NSC), the Director of Financial Aid will run a debugging process created by the Financial Aid and Information Technology teams to identify any inaccuracies in student enrollment status to be easily identified and corrected. Implementing this debugging process in advance of finalizing the NSC Student Enrollment Report file will ensure all data submitted to NSC is accurate. Contact person responsible for corrective action: Mathew Catanese, Director of Financial Aid Anticipated Completion Date: June 30, 2025

Federal Agency Name: U.S. Department of Education Program Name: Student Financial Assistance Cluster Federal Financial Assistance Listing #84.007, 84.033, 84.063, 84.268 Compliance Requirement: Reporting – COD Reporting Significant Deficiency in Internal Control Finding Summary: During our testing of compliance for COD Reporting, it was noted that there was no documented control over the Student Account Statement (SAS) reconciliation that is performed after loans have been submitted to COD and disbursed. Responsible Individuals: Randy Mashek, Director of Financial Aid Corrective Action Plan: The Financial Aid office will retain documentation of the control over the SAS reconciliation process. Anticipated Completion Date: November 1, 2024.

Finding 2024-001 Federal Agency Name: U.S. Department of Education Program Name: Student Financial Assistance Cluster Federal Financial Assistance Listing #84.007, 84.033, 84.063, 84.268 Compliance Requirement: Special Tests and Provisions – Enrollment Reporting Significant Deficiency in Internal Control Finding Summary: During testing of compliance for Enrollment Reporting, there was 1 instance out of 60 where the College did not report a student’s change in enrollment status accurately or within the required time frame of 60 days from the effective date of the student’s change in enrollment status. In addition, evidence of the review of this submission was not retained. Responsible Individuals: Karla Winter, Registrar Corrective Action Plan: The Registrar’s office will review clearing house batch errors reports and any students that go from enrolled in a course to auditing a course. In addition, the Registrar’s office will conduct and retain evidence of quality sampling once a semester. Anticipated Completion Date: November 1, 2024.

Finding 2024-001 - Special Tests and Provisions – Gramm-Leach-Bliley Act Responsible Individuals – Director of Computer Services and Vice President for Finance & Risk Management. Finding Summary: During testing of Gramm-Leach-Bliley Act and inquiry with management, it was determined that the University does not have certain elements of the required written information security program in place. Corrective Action Planned: Dordt will continue to work with an external organization familiar with the policy requirements of the Gramm-Leach-Bliley Act to make sure the remaining elements have been incorporated into the written policies. Anticipated Completion Date: June 30, 2025.