Corrective Action Plans

Title: Student Financial Assistance Cluster – Assistance Listing Nos. 84.038, 84.268, 84.033, 84.007, 84.063, 93.264 Recommendation: We recommend the Institute review its reporting procedures to ensure that students’ statuses are accurately and timely reported to NSLDS as required by regulations. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Registrar’s Office has implemented a review to help identify students who may not be returning the following semester so they can be reported in a timely manner. Name(s) of the contact person(s) responsible for corrective action: Mark Freed Planned completion date for corrective action plan: June 30, 2023

Title: Student Financial Assistance Cluster – Assistance Listing Nos. 84.038, 84.268, 84.033, 84.007, 84.063, 93.264 Recommendation: CLA recommends that the Organization enhance its policies and procedures to meet GLBA compliance pertaining to the following control areas: - Implement and periodically review access controls - Encrypt sensitive information at rest and in transit - Dispose of customer information securely and follow appropriate data retention requirements Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Mount Mercy University’s Information Technology department will update its Information Security Program to include statements related to implementing and periodically reviewing access controls. The following statements will be included: o Authentication methods are performed to ensure access is only provided to authorized individuals to protect against harmful use of sensitive information o There is a formal review of user access rights on a periodic basis to ensure changes are accurately reflected for access controls o Authorized users are further limited to access only sensitive information which is required to perform individual roles and responsibilities (role-based access) Name(s) of the contact person(s) responsible for corrective action: Curtis Sanders Planned completion date for corrective action plan: June 1, 2024

Title: Student Financial Assistance Cluster – Assistance Listing Nos. 84.038, 84.268, 84.033, 84.007, 84.063, 93.264 Recommendation: The University should ensure all necessary employees receive proper training, support, and time to follow the University's policies and federal requirements related to monthly reconciliations. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: A policy has been implemented to have a review of reconciliations. The Director of Financial Aid will perform the reconciliations and the Assistant Director of Financial Aid will review and approve the reconciliation. Name(s) of the contact person(s) responsible for corrective action: Mark Freed Planned completion date for corrective action plan: June 30, 2023

2023-001 Title: Student Financial Assistance Cluster – Assistance Listing Nos. 84.038, 84.268, 84.033, 84.007, 84.063, 93.264 Recommendation: We recommend the University implement a procedure moving forward to ensure that all necessary MPN’s are retained for at least 3 years after payment 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: The missing Perkins MPNs were from loans that were over 25 years old. I have ensured that our remaining Perkins Loans have MPNs and will be retained for the 3 year period after a loan is paid in full. Name(s) of the contact person(s) responsible for corrective action: Mark Freed Planned completion date for corrective action plan: June 30, 2023

Corrective Action Plan For the Year Ended May 31, 2023 Finding 2023-001 Assistance Listing Number(s), Federal Agency and Program Name: 84.063, 84.007, 84.033, and 84.268; United States Department of Education (DOE), Student financial assistance cluster. Finding Type: Noncompliance and material weakness in internal control over compliance relating to special tests. Criteria: The Institute is responsible for designing, implementing, and maintaining internal control over compliance for special tests and provisions and for accurately and timely reporting significant data elements under the Campus- Level and Program-Level records within the National Student Loan Data System (NSLDS) that DOE considers high risk. Statement of Condition: Management implemented controls that specifically addressed the circumstances surrounding prior year finding 2022-001. Management's review of the enrollment reporting did not detect other errors on certain student data elements or timely reporting. Certain student records within the NSLDS were identified with inaccurate data elements and not timely reported. Questioned Costs: Questioned costs could not be determined. Context: 10 students were identified with inaccurate data elements and not timely reported out of a total of 25 students tested. Cause: The Institute’s internal control over compliance did not detect and correct the errors. The preparer incorrectly input the student's effective date and status into NSLDS resulting in inaccuracies in significant Campus- Level and Program-Level enrollment data elements that DOE considers high risk. Effect: The Institute incorrectly reported certain Campus-Level and Program-Level records in NSLDS which is information that DOE considers high risk and the Institute’s internal controls over compliance did not detect and correct the errors. Recommendation: We recommend management review policies and procedures surrounding enrollment reporting submissions to ensure the accuracy of data elements reported to DOE. A review performed by an appropriate individual separate from the preparer prior to the submission of the enrollment reports to NSLDS may improve the accuracy of enrollment reporting. Status: Completed February 2024 Corrective Action: Management agrees with the finding. Through internal investigation, it was determined that there was a procedural issue with the manual entry of two date fields which both need to be the same when submitted to National Student Clearinghouse (NSC). Human error during these manual checks caused one data field to be correct, and the other incorrect. This error has been fixed so that both fields will always be the same and accurate. We have also updated our enrollment reporting procedures to have the registrar log into NSLDS monthly to confirm that the prior month NSC status changes are properly recorded in NSLDS. Contact Jean Weimer Registrar 414-847-3272 jeanweimer@miad.edu Submitted Feb 23, 2024

The universities have partnered both financial aid and academic departments to work on all return of Title IV calculations in a timely manner. The financial aid department will educate all students at the time of initial packaging on the importance of attendance and grades as it pertains to all aid. The registrar's office will notify the financial aid office and business office of all withdrawals and/or drop by emailing the applicable form to them for the students record keeping and processing. The financial aid office will than process the R2T4 (through the COD R2T4 calculator, no manual FA withdraw checklist needed) upon notification from the business office of any applicable student account adjustments. The student will be notified via email and funds will be returned within the 45-day return window. Or a PWD notice will be mailed to the student for applicable loan processing. The four students will be reviewed, and aid returned if applicable.

Subsequent to the audit, for those students who had been over awarded, the Institution refunded $1,724 to the 2022-2023 Federal Pell Grant program on behalf of student #24. In addition for those students who had been under awarded, the Institution awarded and disbursed $863 in Institutuional funds to student #21. The universities will switch processing systems from two to one eliminating manual errors. Moving to the one system (Campus Anyware) will allow all departments (academics, business office, financial aid, and admissions) to have access to the same information in real time. Campus Anyware will also allow financial aid to auto package federal aid ensuring accurate calculation of Pell grant awards. This transition will be in effect for the 2024/2025 award year.

February 28, 2024 Audit Response to Finding 2023-001 to Uniform Guidance Audit - Enrollment reporting to National Student Clearinghouse Analysis: During the spring 2023 graduate only submission to the National Student Clearinghouse (NSC), Robert Morris University (University) incorrectly queried the wrong student population of graduates from Banner (student information system) as a result of human error, which resulted in the untimely reporting of spring 2023 graduates to the NSC. There were also exceptions found attributable to off-cycle graduates who had degrees conferred but the University had not updated their status to “graduated” in the NSC in a timely manner. Upon further review, the University determined extenuating circumstances (i.e. completion of all paperwork, and assignments, incomplete grade(s) existed for these students’ and their graduation date fell outside of the normal graduation date of their peers for that semester cohort. Since the University only typically submits graduate only files to the NSC three times a year (Spring, Summer, and Fall), these students were not reported to the NSC in a timely manner. Based on the findings noted above - and in the prior year Uniform Guidance audit, Robert Morris University (University) voluntarily undertook an exercise to self-audit the accuracy of all clearinghouse data submissions dating back to the implementation of the Banner Student Information System (SIS) in Fall 2021. At the conclusion of the self-audit, 127 students were found to have records of enrollment at the University, but were excluded from clearinghouse submissions during the period (July 2021 - November 2023) under self-audit. The University determined the omissions to be a combination of several factors; including, initial limitations in reporting capabilities as result of the Banner SIS conversion in Fall 2021 and overall process regarding review and submission of clearinghouse data. Response: Graduate Reporting The spring 2023 graduate file submission error was identified internally by RMU in July 2023 and all spring 2023 graduates were reported to the NSC at that time - albeit untimely. The University deemed this to be an isolated incident. For the off-cycle graduate exceptions, the University is increasing the frequency of submissions to the NSC to include mid-term submissions in addition to the end of semester submissions as usual practice. By increasing the frequency of submissions, the University believes this will capture the off-cycle graduates in a timely manner. Expected completion prior to May 31, 2024. Lookback Analysis As of the date of this letter, RMU has corrected all but 15 of the 127 errors and is working directly with representatives from the National Student Clearinghouse (NSC) and National Student Loan Data System (NSLDS) to resolve the remaining 15 errors as soon as possible. Expected completion prior to May 31, 2024. As a result of the findings noted above, the University’s Office of Data and Analytics (UDA) independently reviews all NSC files/extractions (graduate only and monthly enrollment reporting) from Banner prior to submission to the NSC. A member of UDA cross references the NSC file’s/extractions with other Banner student enrollment information for that time period to make sure the file is complete and accurate. The Registrar only submits files to the NSC after approval by the UDA and reports submission results back to the UDA after they are processed by the NSC. Conclusion: The University deems that the correction action steps outlined above will sufficiently resolve the findings and prevent any future instances of untimely reporting of enrollment and graduate data to the NSC and the NSLDS. Regards, Keith A. Roeper Chief Financial Officer and Vice President for Business Affairs Responsible Party

We identified two issues that lead to inaccurate reporting of enrollment statuses to NSLDS. One was human error; the other was a result of an override we had in the report to pull enrollment data. Our Institutional Research Office had the overrides in the enrollment report removed and developed a system where they will upload enrollment reports monthly to the Clearinghouse which will then update enrollment in NSLDS. This will also eliminate the need for the human task we had embedded in the withdraw reporting process. In addition, we are researching the possibility of reviewing withdrawal or graduation dates compared to the effective dates and enrollment statuses reported to the NSLDS to make sure they are accurate. At the time of the audit, a graduation date that past had not been reported to NSLDS. We did not have the final transcript from the study abroad institution to confirm all graduation requirements had been met. The graduation date has since been reported but it was not within the required timeframe. In the future we plan to do more aggressive outreach to the study abroad institution to receive final transcripts sooner. Name(s) of Contact Person(s) Responsible for Corrective Action: Jen Sassman, Executive Director of Financial Aid and Henrique Donat, Director of IT Application Services and Jen Beck, Institutional Researcher Anticipated Completion Date: The overrides were removed from the enrollment reports on June 28, 2023. The schedule to report enrollment monthly was also developed in June 2023.

Corrective Action Planned: Due to insufficient staffing, review of reconciliations was inconsistent. New permanent staff have been hired in all critical business office roles so that reconciliations are now regularly reviewed by a second staff member. Name(s) of Contact Person(s) Responsible for Corrective Action: Brian Braden, Controller Anticipated Completion Date: February 12, 2024

Corrective Action Planned: The registrar has been processing NSC files at least every 28 days during MCAD’s three academic terms. They will implement additional checks on enrollment to locate status changes within term. Also, they will begin reporting status changes that occur between terms, rather than at the beginning of the following term. Name(s) of Contact Person(s) Responsible for Corrective Action: River Gordon, Registrar Anticipated Completion Date: March 1, 2024 for in-term updates; Jun 30, 2024 for between-term updates.

Corrective Action Planned: The third-party service provider was unable to send accurate reports to the college during FY23. The college has terminated its relationship with the previous service provider effective 1/31/2024 and is conducting a final reconciliation with the new agency. Once the final reconciliation has been completed, the college will submit official corrections to the FISAP with the Department of Education. This should enable the college to provide accurate and timely reporting going forward. Name(s) of Contact Person(s) Responsible for Corrective Action: Miguel Granger, Director of Student Accounts and Brian Braden, Controller. Anticipated Completion Date: March 15, 2024

Over Award Review and Correction Action Taken – Kansas Health Science Center (KHSC) Identifying Number: 2023-001 Finding: Eligibility – Determining Federal Direct Student Loan Awards Applicable Regulation: Per 34 CFR 686.203(b)(iii), in the case of a graduate or professional student for a period of enrollment beginning on or after July 1, 2012, the total amount the student may borrow for any academic year of study under the Direct Unsubsidized Loan program may not exceed $8,500. Per 34 CFR 685.203(c)(2)(v), the additional amount that a student described in paragraph (c)(1)(i) of this section may borrow under the Direct Unsubsidized Loan Program for any academic year of study may not exceed the following: in the case of a graduate or professional student, $12,000. Finding: During testing of eligibility, 7 out of 7 students selected for testing were over awarded Unsubsidized Federal Direct Loans. KHSC improperly awarded 61 out of 61 students Unsubsidized Federal Direct Loan in excess of the maximum amount for one academic year, amounting to [$4,445] per student, for a cumulative over award of [$271,146]. Summary: Prior to the commencement of the independent audit conducted for the fiscal year ended May 31, 2023, the institution discovered that it had over awarded Unsubsidized Federal Direct Loan funds to its students. Specifically, the institution awarded additional Unsubsidized Federal Direct Loan funds based on 12-month academic calendar instead of prorating the award based on a 10-month academic calendar. This error resulted in an over award of [$4,445] per student. The institution conducted a file review and refunded all amounts owed to the Federal Student Aid programs because of the file review. The institution also informed the auditor of this error. Corrective Action Taken or Planned: Once the above noted error was discovered, the institution conducted an audit of all student aid packages for students enrolled in the 2022-2023 academic year. It was determined that 61 current students had been over awarded by a net amount of $4,445, for a total of $271,146. Findings were compiled and a plan was created to return over awarded funds and communicate the error to students. The institution also consulted with the Department of Education to confirm its revised calculation was appropriate. The institution returned the funds between July 5-July 20, 2023. Further, the institution made students whole by forgiving any student balances that would have been paid by the over award amount. Emails were sent to all impacted students on July 3, 2023 notifying them of the error. The institution also subsequently notified students that any account balance that remained based on the reversal of the over award would be forgiven. Students who received an estimate financial aid award with the incorrect figures, but who had not yet received aid, were notified of the error and provided updated award information. To ensure this does not happen again the institution has updated their internal student finance audit to include a review of all aid eligibility in conjunction with the next year’s academic calendar for each class of students. Upon any determination that future aid should be prorated, calculation(s) will be completed and reviewed with leadership before implementation. An internal review and approval process will then be enacted and documented. The institution informed RSM of this error and the corrective actions taken. Contact Person Lawrence McGhee, Associate Vice President of Financial Aid, lawrencemcghee@tcsedsystem.edu Completion Date July 20, 2023

Student Financial Assistance Cluster – Assistance Listing No. 84.268 Recommendation: We recommend the University evaluate its policies and procedures around reporting student status changes to the NSLDS to ensure that all relevant information is being captured and reported timely in accordance with applicable regulations. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The University has evaluated its policies and procedures around reporting student status changes and will make the following changes to ensure proper data capture and timely reporting: Following the conclusion of a graduation cycle, the NSC Degree Verify extract will be verified via a cross-check with the BANNER ERP system information on degrees awarded to assure no one is missing or mis-reported. Further, the BANNER de-activation process (SHRDEGS) will be run for the proper semester parameters, so that the student record will reflect proper periods of activity and graduation for those who graduated. BANNER’s registration processor has been configured to update time status dynamically. No longer will there be any discrepancy between the status date in BANNER and the date reported to the NSC and subsequently to NSLDS. The NSC extract of enrollment data will be matched to a separate report of registered students for the given semester to assure that no one is being missed. Name(s) of the contact person(s) responsible for corrective action: Gerard J Donahue Planned completion date for corrective action plan: Completed and effective as of February 28, 2024

Student Financial Assistance Cluster – Assistance Listing No. 84.038 Recommendation: We recommend the University evaluate its procedures and policies around recordkeeping and record retention. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The University will generate a master list of all prior students with Perkins Loans. That master list will track location of files/documentation and provide the tracking to have all files secured all in one properly secured location. Name(s) of the contact person(s) responsible for corrective action: Michele McDevitt Planned completion date for corrective action plan: In progress as of February 28, 2024. A complete master list of students who received Perkins loans will be cross checked against the student’s actual file contained in fire proof cabinets, verifying each student’s master promissory note is on site. This process will be completed no later than August 1, 2024. If the United State Department of Education has questions regarding this plan, please contact Michele McDevitt at mmartin@lasalle.edu or 215.951.1651

Student Financial Assistance Cluster – Assistance Listing No. 84.007, 84.033, 84.038, 84.063, 84.268 Recommendation: We recommend the University evaluate its procedures and review policies in overseeing student credit balances to ensure that any credit balances as a result of Title IV aid are returned within the required timeframe. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The University will evaluate the current refund process and make revisions to process to ensure any credit balances of Title IV aid are returned within the required timeframe. The university’s goals is to automate the refund process to reduce the chance of human error, and placing the refund process on a schedule to ensure refunds are processed within the appropriate window of time. Name(s) of the contact person(s) responsible for corrective action: Michele McDevitt Planned completion date for corrective action plan: September 9, 2024 – first rounds of Fall 2024 refunds

Our Lady of the Lake University of San Antonio FY 2023 Single Financial Audit Finding Response Corrective Action Plan – Reconciliation of COD Monthly School Account Statement Compliance Finding: The Department of Education’s (DoE) School Account Statement (SAS), downloaded electronically from the Common Origination Destination (COD) website, was not being reconciling monthly as required by the Student Financial Aid/ Direct Loan Program. Criteria or Specific Requirement: Per the Student Financial Aid/ Direct Loan Program requirements with the DoE, every school is required to reconcile their SAS to their accounting system records at least monthly. This statement is issued to each participating school through the SAIG mailbox monthly. The auditors noted 34 CFR 685.102(b), 385.300(b), 685.301, and 303 as the compliance regulation. Cause of Noncompliance: It appears that the SAS was reconciled monthly per the compliance requirement in recent years, but with high turnover and periods of under-staffing in the Accounting department this procedure was changed to one that did not meet the above requirement. Although OLLU did regularly reconcile the accounting system records with reports from COD, it was not the official monthly SAS statement. OLLU’s modified procedures did not completely meet the compliance requirement but did offer some mitigating procedures. Institution Response: OLLU has already begun coordinating processes between its Accounting and Financial Aid departments to download the monthly SAS into the university’s system electronically, where Accounting will then reconcile the statement monthly as a part of its month-end close procedures. The Financial Aid Director will be responsible for ensuring that the statement is downloaded monthly as a part of the regular electronic data file transfer between OLLU and the Department of Education. The Senior Accountant in the Accounting department will generate the report in Colleague via the DRSS process and reconcile the SAS statement to cash records. The Director of Accounting and Reporting will review the reconciliation monthly.

2023-002 Student Financial Assistance Cluster- Assistance Listing Number: 84.063, 84.268 Recommendation: We recommend the University review its reporting procedures to ensure that students' statuses are accurately and timely reported to NSLDS as required by regulations. Explanation of disagreement with audit finding: There is no disagreement with the finding. Action taken in response to finding: The Office of the Registrar will continue to submit enrollment data to the National Student Clearinghouse via the current schedule. The Office of the Registrar will investigate and resolve any errors returned by the National Student Clearinghouse. After the enrollment data is transferred from the NSC to NSLDS a University representative will review the data in NSLDS for any discrepancies including cross-checking graduation files and complete withdrawals. Any inconsistencies will be discussed and timely resolved by the applicable units and officially updated in NSLDS and NSC respectively. The University will keep track of any changes manually made within the NSLDS or NSC database by university representatives, so that the student information system, NSC, and NSLDS records are in-sync. Name of the contact person responsible for corrective action: Dennis Koch, Associate Vice President of Financial Services Planned completion date for corrective action plan: 3/15/2024 If the Department of Education has questions regarding this plan, please call Dennis Koch at 309-667-3119.

2023-001 Student Financial Assistance Cluster- Assistance Listing Number: 84.007, 84.038, 84.063, 84.268, 84.379, 93.364 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 finding. Action taken in response to finding: The Financial Services Division of the University (FSD) has implemented a new process to better track the status of student refund checks. After the first week of the month, all outstanding checks from the prior month are investigated in order to identify student refund checks that were the result of Title IV funds (e.g. January outstanding checks are reviewed after the first week of February). A representative from FSD will contact the borrower within 45 days of the original issuance date via email to inform them that the check remains outstanding and provide them with the option to EFT the funds directly to the student or void the check and reduce the borrowing with the Department of Education. The original check will remain valid for the 90 days stated on the face of the check. After 90 days, no additional communication will be made to the borrower. The check will be voided and borrowing will be updated with the Department of Education after 90 days of the original issuance, but prior to the 240 days allowed by the Department of Education. In additional to establishing a process to handle any future refund checks, the University.is also in contact with the Department of Education to provide process clarity on how to return funds related to refund checks for years where the financial aid year has been closed. Name of the contact person responsible for corrective action: Mark Young, Assistant Controller Planned completion date for corrective action plan: 2/29/2024

A plan has been developed to take corrective action regarding findings 2023-001 in our audit for the year ended May 31, 2023. Due to previous manual processes and significant staffing turnover in the Accounting and Financial Aid areas, this summer, we discovered some of the R2T4 calculations were missed. Once this was discovered, we went back through and ensured all the withdrawal calculations were done and funds returned, even though they were outside the compliance timeframe. While testing the return of Title IV funds from a sample, FORVIS noted that two students did not have a refund calculation completed in a timely manner. These findings had been discovered by SBU and corrected, and funds were returned earlier, but they were still outside the compliance timeframe, which required an audit finding. To address these issues, SBU employees have taken the following corrective measures: 1. We reworked the reporting process for withdrawals. All withdrawals now go to the Associate Provost regardless of campus or program. They are then processed by the Registrar’s Office and placed in a shared drive. Once there, they are reviewed weekly by the Financial Aid Office, and R2T4s are completed in a timely manner. This process no longer relies on a member of the Accounting Office to notify Financial Aid of a withdrawal. 2. R2T4 requests are completed by one Financial Aid staff member and verified and processed by another to ensure accuracy and reliability. 3. We have implemented an administrative withdrawal process to give campus and program directors the ability and authority to withdraw students who are no longer in attendance to limit the number of all Fs at the end of the semester. Sincerely, Terri Rogers Controller

Student Financial Aid – Aid – 84.268 – Federal Direct Loan Program, 84.063 – Federal Pell Grant Program Recommendation: We recommend a secondary review be done by someone other than the SFA Director to ensure disbursements and verifications are completed accurately and timely. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Director of Financial Aid will notify the Vice President of Operations of disbursements and verifications, and the Vice President will complete a secondary review. As this is the final year in which Lincoln Christian University will have academic operations, we believe this corrective action to be sufficient for the remainder of the year. Name(s) of the contact person(s) responsible for corrective action: Nancy Siddens, Director of Financial Aid. Planned completion date for corrective action plan: November 1, 2023.

Student Financial Aid – 84.268 – Federal Direct Loan Program, 84.063 – Federal Pell Grant Program, 84.007 – Federal Supplemental Educational Opportunity Grant Program, 84.033 – Federal Work-Study Program Recommendation: We recommend the review process for awarding be documented and retained as support for the review and approval process. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Director of Financial Aid will document each change to an award by printing a new award offer and saving to document tracking. As this is the final year in which Lincoln Christian University will have academic operations, we believe this corrective action to be sufficient for the remainder of the year. Name(s) of the contact person(s) responsible for corrective action: Nancy Siddens, Director of Financial Aid. Planned completion date for corrective action plan: November 1, 2023.

Views of Responsible Officials and Planned Corrective Actions - Drury University accepts this finding. • Upon discovery of a programming error within the enrollment report obtained from the Jenzabar system for transmission to the National Student Clearinghouse (NSC), the report was immediately corrected by the Registrar and rechecked prior to its transmission to NSC in October 2023. The Registrar has expressed confidence that the error is corrected but has set up additional system queries to be checked against the report to ensure accuracy prior to transmission of future reports. • Financial Aid Office and Registrar’s Office will review and compare actual enrollment and program information with the data reported in NSLDS after each submission. Any corrections will be made as soon as is practicable, but not later than 30 days after the discrepancy is identified.

View of Responsible Officials and Planned Corrective Actions – Drury University accepts this finding and has created a Corrective Action Plan (CAP). In all four cases identified in the finding, the late return of funds were for students who unofficially withdrew (ceased attending) and did not notify the institution. Henceforth, within 10 days of grades being posted at the end of each semester, Financial Aid will liaise with the Registrar’s Office to review all unearned F grades and determine if a return of funds is required. Additional automated tasks already have been created in the PowerFAIDs software that notify the Financial Aid Administrator (FAA) when a Return of Title IV Funds (R2T4) has been completed but not processed. The FAA will monitor R2T4 processing and returns to ensure that returns are processed within the required timeframe.

Saint Mary's believes that the switch to J1 and upcoming J1 software patch should solve the reporting issues. We anticipate that all students will be submitted to the Clearinghouse correctly, and will set up ad hoc reports to verify no students are missed. As for the NSC reporting correctly to NSLDS, we anticipate that the two entities have resolved the issues that they were having in communicating with each other. The Registrar's Office will ask the Financial Aid office to verify that students are being reported to NSLDS correctly. The Registrar's Office does not have access to NSLDS, but the prior Financial Aid Director did, so the current one should as well.