Corrective Action Plans

Views of Responsible Officials and Planned Corrective Actions: The University agrees with this recommendation and will ensure that staff with reporting compliance responsibilities are appropriately trained during periods of transition.

Auditor Description of Condition and Effect. A break of at least five consecutive days was not excluded from the reported enrollment period for the Fall 2022 semester, which resulted in the calculation being incorrect for all students who had returns in the Fall 2022 semester. As a result of this condition, Return of Title IV calculations were incorrect for 60 students for the Fall 2022 semester, resulting in $10,459 less funds returned to the U.S. Department of Education. It is our understanding that on July 24, 2023, the College repaid the 60 students affected by this calculation error. Auditor Recommendation. We recommend that the College implement a review process to ensure the number of enrollment days used in the Return of Title IV calculations is accurate and that the R2T4 calculation is reviewed by a second individual. Corrective Action. Upon discovery of the Return of Title IV Calculation error, the College went through and made corrections to all student accounts affected. To prevent a similar problem arising in the future, the College has developed a review process that will require an additional sign‐off for the total days to be used in the calculation. Responsible Person. Ruth Carlson, Director of Financial Aid. Anticipated Completion Date. July 24, 2023.

Finding 2023-001: Special Test and Provisions: Enrollment Reporting Context/Condition: Of the 37 students selected for enrollment reporting testing, 5 students within the sample were reported to NSLDS outside the maximum 60-day window. Recommendation: The auditor recommended that the College review and update internal controls to ensure student enrollment status in the National Student Loan Data System (NSLDS) is updated in a timely manner to ensure compliance with Federal Requirements. Persons Responsible for Corrective Action: Tammy Gibson, Registrar Planned Corrective Action: Additional dates will be added to the National Student Clearinghouse submission schedule to capture December graduates. In addition, Registrar's Office staff will be instructed to update individual student records, as needed, to account for changes outside of the submission schedule to avoid reporting outside of the maximum 60-day window. Anticipated Completion Date: December 8, 2023

Corrective Action Planned: The College has noted the issue and it has since been rectified and has re-ran the process to provide the proper effective dates for withdrawn students to the National Student Clearinghouse. The College does report to the National Student Clearinghouse every 30 days. The College has reviewed their policies and procedures to ensure proper reporting requirement procedures to NSC and NSLDS. Training has been provided to those responsible for manual adjustments to records having extenuating circumstances. Name(s) of Contact Person(s) Responsible for Corrective Action: Eric Dinsmore, Senior Director of Financial Aid Anticipated Completion Date: As of January 2024, withdrawal student status change effective dates have been corrected. The College has reviewed reporting policies and procedures and has provided training to responsible parties for manual reporting whenever extenuating circumstances occur. The College will implement any additional necessary changes in 2024 fiscal year.

Corrective Action Plan 2023-004: The College concurs with the finding and has reviewed and where appropriate made updates to the processes used to package loans when there is an annual or aggregate loan limit reached. Completion Date: August 2023 Contact Person: Haley Wesley, Vice President of Enrollment Management & Marketing

Management concurs with the recommendation. Berklee will review and enhance processes related to reporting key items to the COD System.

Management concurs with the recommendation. Berklee will review and enhance processes related to reporting key items to the COD System. The institution will also update key fields to accommodate changes during the awarding process to ensure they agree with records.

Management concurs with the recommendation. Going forward, there will be at least two reviews of the FISAP prior to the annual filing, including all updates, to better ensure complete and accurate completion prior to filing with the U.S. Department of Education.

ALN: 84.268 Federal Direct Loan Program; 84.063 Federal Pell Grant Program Recommendation: It is recommended that policies and procedures are put in place to verify that the correct effective dates and status changes are reported to NSLDS within required time frames, as well as create accurate reports internally to track all students' whose status changed and verify against the roster submitted to NSLDS. This could include a review of withdrawal or graduation dates compared to the effective dates reported to NSLDS to make sure they are accurate. Action Taken: We have strengthened our procedures for our NSLDS report verification process as we continually strive to comply with all regulations. Once the Ellucian NSC graduation report is run, the Registrar's Office will compare that against at least 10 % of the students on the graduation list to ensure accuracy. There are six times a year that the graduation process occurs. If a student is no longer enrolled but has not completed degree requirements (i.e. takes an incomplete in a course), they would be reported as withdrawn during the next semester. However, once they complete their degree requirements and officially graduate, they will get reported as "graduated" on the next graduation run. Since these students are processed manually, the Registrar's Office will maintain a listing of the "non-traditional graduates" (i.e. finishes degree requirements outside of the six standard times per year) and verify their status is recorded correctly in NSLDS. They will also compare at least 10% of the students on the course drops and withdraw report against the status and date generated by the Ellucian NSC report to ensure accuracy. The Registrar's Office will also realign the NSC reporting schedule for graduating students to align with our processing schedule beginning with the Spring 2024 semester.

Management's Response: We concur. View of Responsible Officials and Corrective Action Plan Based on the review and assessment of findings, the Financial Aid Office at West Hills College Coalinga will add to their establish policies and procedures an annual check of the reporting mechanism used to determine “unofficial withdrawals” and update it as needed in coordination with any changes with the Registration system set up. This will help avoid future reporting errors and keep “unofficial withdrawals” determined within the 30-day requirement.

GLBA non-compliance Finding: The University does not meet the compliance requirements outlined in the GLBA Safeguards Rule. Discrepancies were identified in requirement B.6 which addresses how the institution how the institution will oversee its information system service providers. The University did not have a Vendor Management Program with standards in place to oversee critical system service providers regarding due diligence, risk assessments, and annual reviews as related to 3rd party service providers. Auditors' Recommendation: The University needs to review the updated GLBA requirements and ensure their WISP includes all required elements. School Response: The school agrees with this finding. Corrective Action Plan: The school's director of IT is reviewing the school's Written Information Security Plan (WISP) to ensure GLBA Compliance. A vendor management plan has been added to the WISP which specifies that any information technology vendors and products will be subjected to an IT Acquisition Process prior to use by the University. In the IT Acquisition Process, the vendors and products will be evaluated by the Information Technology Advisory Committee and the Office of Information Technology to determine impact on the current infrastructure and data systems as well as any security concerns that should be addressed prior to implementation. Name(s) of the contact person{s) responsible for corrective action: Point University Director of IT, Bill Dorminy Planned completion date for corrective action plan: • WISP and review of GLBA requirements is ongoing with completion of the current review expected by June 1, 2024.

Pell Award Errors Finding: As noted in the audit report, there were 5 instances out of 60 students with Pell award errors. Auditors' Recommendation: The University should have appropriate policies and procedure, as well as safeguards in place to ensure Pell eligibility and awarding is correctly determined. School Response: The school agrees with this finding and has initiated corrective action. Corrective Action Plan: For student #5, there was a Pell awarding error where the student was under awarded Pell by $172. The school made the correction to the award and disbursed the additional Pell. For student #16, student was over awarded Pell Grant for $1723 due to incorrect refunds made while adjusting for changes in the student's schedule. The school has refunded the $1723 over award back to the fund source. For student #24, the student was initially awarded correctly, but withdrew during their 2nd term. Due to incorrect Pell Recalculation on the R2T4, the school refunded too much Pell grant, and the student was under awarded by $458. The school has disbursed the additional Pell so the student is now paid correctly. For student #27, the student was over awarded Pell by $350 due to in error in Pell Recalculation based on the student's schedule. The school has refunded the over award to the fund source. For student #43, the student was under awarded by $22 due to an error in Pell Recalculation based on the student's schedule. The school has disbursed the additional Pell grant funds to correct the error. Starting with the Fall 2023 semester the school has implemented a new student information system (SIS), Colleague. The school has also partnered with a third-party servicer, Financial Aid Services (FAS), to assist with packaging. The new SIS automatically adjusts Pell grant whenever there is a change to a student's schedule during the term through the school's census date for each term and module. The system will schedule a refund for any over awards and increase the Pell award for any that may have been under awarded. Since this is no longer reviewed solely by the financial aid office, this is expected to reduce the number of errors in Pell awarding. In addition to the system adjustments, the school's third-party servicer, FAS, will review packaging for any students with changes to the number of registered credits during the term to ensure the system is making adjustments properly and the students are correctly packaged. Name(s) of the contact person{s) responsible for corrective action: Financial Aid Director, Holly Hardnett and third-party servicer, FAS, representative Planned completion date for corrective action plan: • New Colleague SIS implemented live beginning in the Fall semester 2023. • Training for Pell Recalculations in Colleague July 2023. • Registration/schedule changes for term reviewed by FAS at least weekly.

NSLDS Enrollment Reporting (repeat) Finding: As noted in the audit report, there were 4 discrepancies found in 17 files in which student information reported to NSLDS was incorrect or untimely. • 2 students' status was incorrectly reported to NSLDS. • 1 student's enrollment effective date was not reported correctly to NSLDS. • 1 student's enrollment status change was not reported to NSLDS within 60 days. Auditors' Recommendation: The University should review their enrollment reporting policies and procedures to ensure accurate reporting. School Response: The school agrees with this finding and has initiated corrective action. Corrective Action Plan: There were two files in which NSLDS reporting errors were found. Student #12 was withdrawn per their school transcript effective 5/14/2023, however, the enrollment status was reported at NSLDS as Less Than Half Time as of 5/8/2023. Student #14 was in a Graduate status on their transcript but was reported as Withdrawn on NSLDS. Also, the student's status was reported 134 days after the status change event. Status changes must be reported to NSLDS within 60 days. The instances for this finding occurred during a time when there was a staffing change in the registrar's office and a new registrar had not yet transitioned into the position. Since this time, a new registrar, Natalie Brown-Motes, was hired, and the process has been reviewed with Assistant Registrar, Lara Ellison, to ensure that there is a back up plan if the registrar is unavailable to complete this process. Additionally, the school switched to a new Student Information System (SIS), Colleague, which was implemented beginning with the Fall semester 2023. The new SIS works with the National Student Clearinghouse enrollment reporting service. In order to ensure timely reporting, the registrar's office creates an enrollment report in Colleague each month. That report is transmitted to Clearinghouse which uses the information to update the enrollment data in NSLDS. If there are any possible errors that need to be reviewed, the registrar receives a report on Clearinghouse of any errors so they can be reviewed and approved or corrected. The error report must be completed within two weeks of receipt. Colleague only reports to Clearinghouse students who have actually registered for classes. Previously, enrolled students who had not registered were included in the report. This inclusion regularly generated additional errors. Since the new system improves the reporting process so only registered students are reported, there is less opportunity for error. Name(s) of the contact person(s) responsible for corrective action: University Registrar, Natalie BrownMotes and Assistant Registrar, Lara Ellison Planned completion date for corrective action plan: • New Colleague SIS implemented live beginning in the Fall semester 2023. • Training on National Student Clearinghouse process with Colleague completed September 23. • Began using Colleague system to report enrollment data to NSLDS through National Student Clearinghouse in September 2023.

Disbursement Dates (repeat) Finding: As noted in the audit report, there were three instances in 60 files in which there were discrepancies in disbursement dates. Disbursement dates recorded on student accounts for Direct Loan and Pell disbursements did not agree to the disbursement date reported to Common Origination and Disbursement (COD). Auditors' Recommendation: The University should review their policies and procedures to ensure accurate reporting to COD. School Response: The University agrees with this finding and has initiated corrective action. Corrective Action Plan: Title IV disbursements must be posted to student accounts within 15 days of the funds drawdown. Also, the disbursement date per COD must match the disbursement date on the student account. There was one instance in which the Disbursement date for a Pell Grant was 10/10/2022 per COD and 10/19/2022 on the student's account. One instance had a disbursement date at COD as 2/16/2023 and at 2/15/2023 on the student's account. The third instance had a disbursement date of 1/25/23 at COD and 1/26/23 on the student's account. Each of these disbursements were posted in the old Student Information System (SIS), Anthology. The posting process that the school used under the previous system relied primarily on manual checks by employees in various departments in which reports could be sent to COD in which the posting dates did not match the COD dates. In order to avoid this finding in the future, the University has sought out and implemented a new Student Information System (SIS), Colleague, beginning with the 2023-24 award year. The school has also contracted with a third-party servicer, Financial Aid Services (FAS}, to assist with packaging students and completing the disbursement process. To disburse funds, the Director of Financial Aid Quality and Compliance or the representative from FAS runs a report in Colleague which pulls scheduled and approved financial aid disbursements for students who have met the enrollment criteria to receive those disbursements. The report goes to the student accounts office where the financial aid is posted to the student ledgers. Then it is transmitted to COD with the posted dates so that the dates reported to COD match the dates in the SIS. If there are any errors in the transmission, the Director of Financial Aid Quality and Compliance or the representative from FAS will review the rejected disbursements and make corrections to get them processed as quickly as possible. The accounting office submits the drawdown request to G-5 for the amount of the approved and posted financial aid. The new process in which the disbursement amounts and dates transmitted to COD match the disbursement amounts and dates posted to the students' ledgers is expected to ensure compliance in the future. Name(s) of the contact person(s) responsible for corrective action: Director of Financial Aid Quality and Compliance, Rachal Wortham Planned completion date for corrective action plan: • New Colleague SIS implemented live beginning in the Fall semester 2023. • Training on new disbursement process completed August 2023. • First disbursements approved using the new SIS done by Director of Financial Aid Quality and Compliance August 2023. • Review of disbursement process with FAS October 2023. • Follow up with Colleague team to review the process and work out any flaws February 2024.

Condition: During our review of the return of Title IV funds, we noted that students were not being properly identified as withdrawn, either officially or unofficially. This resulted in 7 students noted that never had a calculation performed, but should have, and 22 students that were reported late. Criteria: When a recipient of Title IV funds withdraws from an institution during a payment period or period of enrollment in which the recipient began attendance, the institution must perform a Return of Title IV Funds calculation to determine the amount of Title IV assistance the student earned as of the student’s withdrawal date. Cause: Student Financial Aid personnel does not have a method to properly identify students who are required to have a return of funds calculation. After several attempts to obtain a listing of students, the auditors requested assistance from the IT department, who was able to get the auditors a list very quickly. This list was compared to Student Financial Aid recipients to identify the population of students who should have had a calculation performed. Effect: Funds required to be sent back to the Department of Education are either missed or are late. Perspective: There has been high turnover in the SFA department, including a time where there was not a Director in place. Recommendation: We recommend training of Student Financial Aid personnel on the rules and regulations over return of funds. In addition, we recommend that Student Financial Aid personnel work with the IT department to develop a report that can be ran weekly or bi-weekly to identify the students and timely prepare the calculations. Views of Responsible Officials and Planned Corrective Actions: Dodge City Community College staff involved are undergoing training to learn requirements. Processes and procedures are being developed to ensure timely calculations and refunds.

Condition: There were no monthly Title IV reconciliations performed. Criteria: Per SFA requirements, the College is required to reconcile the COD data files with the College’s financial records. Cause: Turnover in the staff and Director positions of the College. The new employees were not aware of this requirement. Effect: Noncompliance with SFA requirements. Perspective: There has been high turnover in the SFA department, including a time where there was not a Director in place. Recommendation: We recommend that the direct loans are reconciled at least monthly between the COD and the College’s general ledger. Views of Responsible Officials and Planned Corrective Actions: Dodge City Community College staff involved have received training and been made aware of requirements. Monthly reconciliations will be performed immediately.

Condition: We examined a sample of Title IV aid recipients to verify that information reported on the Enrollment Reporting roster file sent to the National Student Loan Data System (NSLDS) matched the student's academic files and found instances where students received Title IV aid during a semester but the status of withdrawn or graduate were not reported correctly or timely on the NSLDS Enrollment Reporting roster files sent during that semester. Criteria: Per the NSLDS Enrollment Reporting Guide, a school should report all students that NSLDS includes in its request to the school on a roster file. This includes timely and accurate reporting of the status of the student of withdrawn or graduate. Cause: The status of the students were not timely and accurately reported to NSLDS. Effect: Students could potentially not be placed in grace or repayment status when they should be. Perspective: There has been high turnover in the SFA department, including a time where there was not a Director in place. They have had interim Director who also left in December 2023. A new Director has been hired in January 2024 and has begun working on issues. Recommendation: We recommend that personnel in charge of enrollment reporting be diligent in reviewing the roster file to ensure that all appropriate students are shown and attendance changes are reported in a timely and accurate manner. Views of Responsible Officials and Planned Corrective Actions: Dodge City Community College staff involved in enrollment reporting to the NSLDS have reviewed the NSLDS Reporting Manual to better understand and accurately report the student's enrollment status. There has been high turnover in the SFA department, including a time where there was not a Director in place. The new Director came on in the fall of 2022 and then left in December 2023. The College is still working on fully implementing new procedures and catching up submissions.

Finding No. 2023-002 Corrective Action Plan: The University concurs with the finding. The Financial Aid office is in the process of tightening its policies and procedures to identify all students subject to the required exit counseling, with the goal of delivering said counseling within the prescribed 30-day window. Responsible Official: John Sircy, Interim CFO Anticipated Completion Date: June 2024

Individuals Responsible for Corrective Action Plan Wanda Spradley, Director, Financial Aid Susan Kennon, Registrar Jennifer Sauer, AVP for Finance Corrective Action Plan: The finding is related to required enrollment information being reported to National Student Loan Data System by the registrar’s office. The errors noted in 2023-001, as well as 2022-001, were primarily related to a lack of internal systems, staff, and expertise in the reporting requirements. A new registrar was hired September 2023, and much work has been done to increase staffing and technology support for the office. The administration is working with the registrar’s office to implement controls to reduce errors and improve timeliness. However, reporting requirements are rigorous, and there will always be challenges. With new systems only recently put in place and the staffing issues continuing in FY23-24, this finding may be noted again next year. Anticipated Completion Date: June 30, 2024

Recommendation: We recommend that the University implement a procedure to ensure that all necessary MPNs are retained in accordance with the federal regulation. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Management agrees with the audit finding where some MPNs are missing. We are unable to correct the past but moving forward, the new ones are being retained. Name of the contact person responsible for corrective action: Michelle Hegarty, CFO Planned completion date for corrective action plan: September 1, 2023

Recommendation: We recommend that the University review its procedures related to outstanding student refund checks to ensure they are being returned to the Department of Education after 240 days. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: We agree with the audit finding and will implement procedures related to outstanding student refund checks to ensure they are being returned to the Department of Education after 240 days. Name of the contact person responsible for corrective action: Michelle Hegarty, CFO Planned completion date for corrective action plan: Already in place

Recommendation: We recommend reviewing the components of the enrollment roster file to ensure the correct effective date is reported correctly for both the "Campus Level" and "Program Level". Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Management agrees with the audit finding and will pull a sample of records each week after each NSC submission to ensure information has been passed onto NSLDS. Name of the contact person responsible for corrective action: Kris Ragozzino, Registrar Planned completion date for corrective action plan: Already in place.

Enrollment certifications will be sent to the National Student Clearninghouse on a monthly basis, no later than 10 days following the end of the month. The final degree file will be submitted no later than 30 days after the last day of class, with additional awards submitted individually. The Financial Aid Director will review all NSLDS errors.

Doane has reviewed the finding and is researching ways to improve the process.

The Financial Aid team is conducting staff training regarding return to Title IV calculations and compliance led by the Financial Aid Director. This includes all return to Title IV calculations being reviewed by the Financial Aid Director before final submission.