Corrective Action Plans

Untimely Returns of Title IV Funds (R2T4) Planned Corrective Action: We have engaged an outside vendor to provide knowledgeable staff augmentation to help us improve our processes and the timeliness of completing R2T4s. Additionally, we have planned supplemental training for our staff to complete R2T4s. Person Responsible for Corrective Action Plan: Cathy Morgan, Director of Student Financial Services Anticipated Date of Completion: March 1, 2024

Common Origination and Disbursement (C OD) Reporting Planned Corrective Action: We are working to put a double check process in place, and to understand which step in the internal aid process has the opportunity to ensure this date exactly matches the COD disbursement date. The team had not realized that the date must match exactly. We have engaged an outside vendor to provide knowledgeable staff augmentation to help us improve our processes and the timeliness of our disbursing of Title IV funds. Person Responsible for Corrective Action Plan: Cathy Morgan, Director of Student Financial Services Anticipated Date of Completion: March 1, 2024

2023-004 Treatment of a student who fails to receive a passing grade in any class (Significant Deficiency), Department of Education, Student Financial Aid Cluster. Criteria: An institution must have a procedure for determining whether a Title IV aid recipient who began attendance during a period completed the period or should be treated as a withdrawal. If a student who began attendance and has not officially withdrawn fails to earn a passing grade in at least one course offered over an entire period, the school must assume, for Title IV purposes, that the student has unofficially withdrawn, unless the institution can document that the student completed the period. In the absence of evidence of a last day of attendance, a school must consider a student who failed to earn a passing grade in all classes to be an unofficial withdrawal. Condition: From a population of 35 students that received all failing grades in a term, we tested five students and noted that documentation of the last date of attendance could not be provided for any of the students tested. Action Taken: The Provost’s Office has drafted a memo to faculty explaining the requirement to enter the last day attended for any student receiving a failing grade.  The Registrar’s Office has added this requirement to their routine reminders to faculty about entering grades.  The Clerk of the Faculty has agreed to bring this change in policy to the faculty to add to the Faculty Handbook in section 3.1.10 Reading Day, Final Examinations, and Course Grades.  Plan for auditing effectiveness of corrective action: The Register’s Office is turning on the requirement in Bannerweb (student system) that any F or NC grade cannot be entered in the system without a last date of attendance. An audit report will be able to be generated on this data. Responsible Party: Provost, Registrar, and Faculty, under the supervision of the Provost is responsible for implementing this corrective action plan and ensuring compliance. Point of Contact: Maria Rosales, Provost, mrosales@guilford.edu, 336-316-2205 Expected date of correction: April 2024

The University experienced staffing turnover in the financial aid department during the 2022-2023 aid year, resulting in certain established processes to go unfollowed. In March 2023, the University hired a full time on campus Director of Financial Aid, which has stabilized the department staffing. The Director has established clear roles and responsibilities so that established processes are not missed going forward.

The University experienced staffing turnover in the financial aid department during the 2022-2023 aid year, resulting in certain established processes to go unfollowed. In March 2023, the University hired a full-time on campus Director of Financial Aid, which has stabilized the department staffing. The Director has established clear roles and responsibilities so that established processes are not missed going forward. Additionally, the University has reviewed all procedures for identifying official and unofficial withdrawals, adding a new requirement for all faculty members to include a last date of attendance for all unsatisfactory grades input into our student information system. Additionally, job duties have been reallocated to ensure calculations on official and unofficial withdrawals and exit counseling communications are done on a timely basis going forward.

There is no disagreement with the audit finding. Corrections for this finding started in January 2023. Initial months selected were prior to that date. Additional months were provided, tested and complied. NCU will continue to do our monthly reconciliations in the same manner.

There is no disagreement with the finding. All program lengths have been corrected in our NSLDS reporting cycle. Unfortunately, the implementation went beyond the May 31, 2023, fiscal year. During a recent internal audit of 20 students we can now see the published length correctly reporting in NSLDS for all investigated students.

There is no disagreement with the audit finding. We have diligently reviewed our procedures and implemented robust measures to ensure strict adherence to the regulations governing Return of Title IV Funds. Our efforts have focused on establishing comprehensive double checks throughout the process to mitigate any potential errors or oversights. This includes enhanced annual training, dual verification process - every Return of Title IV fund calculation must now be calculated first by our Financial Aid Data and Reporting Analyst and then re-calculated and reviewed by the Executive Director of One Stop. We now have a robust documentation process for each return and prior to the end of the fiscal implemented internal audits of all withdrawn students. We are confident these measures will maintain compliance and ensure accuracy.

Christopher Cartmill, Director of Financial Aid, Telephone 716-375-7888. We are in agreement with the auditors' recommendation to ensure personnel involved with R2T4 calculations receive appropriate training and update the policies and procedures manaual to require formal review and approval of all R2T4 calculations. We have developed additional procedures to ensure institutionally scheduled breaks are being considered in determining a student's percentage of Title IV aid earned. The procedures include participation in training webinars and updates to the policies and procedures manual with detailed instructions on how to calculate the number of days in the semester and formal review and approval of all R2T4 calculations. The procedures also include secondary check by the Director or designate, of entered dates in the calculation set up. The training and updated policies and procedures were completed on September 14, 2023, effective with the Fall 2023 term and forward.

Corrective Action Plan: The College acknowledges that the noted three off-cycle disbursements did not meet the notification requirement. The College has evaluated its current procedures for releasing its financial aid notifications and identified system improvements that will result in notifications being sent prior to the disbursements being processed to ensure all requirements for this program are met. Timeline for Implementation of Corrective Action Plan: These process and system updates will be implemented before the end of fiscal year 2024.

The Office of Student Financial Aid will update their procedures to verify the proper aid is packaged and awarded based on the student status.

2023-004 Student Financial Assistance Cluster – Assistance Listing No. 84.038 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: With one year until the program is fully sunset, we will continue to manage and safeguard the promissory notes that we have in our possession. We do not disagree that some MPNs were not able to be found, but with only 90 accounts remaining, we are confident that we have the grand majority of MPN’s needed to close the program in the near future. Name(s) of the contact person(s) responsible for corrective action: Michael Johnson, Controller Planned completion date for corrective action plan: March 1, 2024

2023-003 Student Financial Assistance Cluster – Assistance Listing No. Various 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 are working with IT to allow for the auditing of uncashed checks to be an action that can be fulfilled with minimal human resource used. We have resumed the monthly audit of student uncashed Title IV resources. Name of the contact person responsible for corrective action: Michael Johnson, Controller Planned completion date for corrective action plan: February 29, 2024

2023-002 Student Financial Assistance Cluster – Assistance Listing No. Various 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 audit finding. Action taken in response to finding: The Bethel University Registrar is responsible for ensuring timely and accurate reporting to NSLD via the National Student Clearinghouse. Cheryl Fisk was appointed to serve as University Registrar on August 1, 2022. While new to Bethel, she is not new to Clearinghouse reporting. She assumed the oversight of the Clearinghouse reporting and is working to ensure timely, accurate submissions. • Bethel reports student enrollment to NSLDS via the National Student Clearinghouse • Currently, the people involved in the process include: o Data Management Team: Ana Ortiz, Data Coordinator o Registrar Staff: Cheryl Fisk, University Registrar o Information Technology Service Staff: Kurt Jarvi, Systems Analyst Based on the previous audit, adjustments were made to the timing of the Clearinghouse enrollment submissions. This has been accomplished with enrollment being reported every month on the same date to enable automated submissions. As we tried to systematize graduation reporting, we encountered multiple technical issues. These issues involved both Information Technology and the Clearinghouse, which resulted in a delay in the reporting of graduates from May through August 2023. Additional training has been provided by the Clearinghouse and other sources which have been viewed by those involved in Clearinghouse reporting. We have also sought the advice from other institutions who report to the Clearinghouse. Our corrective action will involve several parts. • First, we will add more graduation only submissions to our Clearinghouse schedule to ensure they are getting reported in a timely manner. • Second, we will investigate where our Clearinghouse reports are pulling the graduation date form our Student Information System (Banner) to ensure those fields are accurate. • Third, we will review our process for determining degree conferral dates to ensure it aligns with our reporting schedule. • Fourth, over this past summer (2023) we worked with staff to clarify student withdrawal procedures. We will continue to do that. • Fifth, we will continue to take advantage of Clearinghouse training and other related training opportunities. • Sixth, we will be proactive in confirming that the Clearinghouse has received our submissions and has processed them in a timely manner. Name of the contact person responsible for corrective action: Cheryl Fisk, Registrar Planned completion date for corrective action plan: June 1, 2024

A recalculation of the student financial aid was completed using the corrected spring semester start date. The corrected financial aid was credite to the student's account.

Inaccurate Return of Title IV Funds Calculations Planned Corrective Action: The University will work with FA Solutions weekly to ensure funds are calculated correctly and timely returns of IV Funds are processed. Person Responsible for Corrective Action Plan: Donnie Purvis, Director of Financial Services Anticipated Date of Completion: Effective Immediately, February 15, 2024

Recommendation: CLA recommends someone other than the preparer of Return of Title IV calculations review said calculations. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned/taken in response to finding: All Return of Title IV calculations will be reviewed by another person in the Financial Aid Department, other than the preparer, for accuracy, completeness, and timeliness. Name(s) of the contact person(s) responsible for corrective action: David Fisher, dlfisher@neo.edu Planned completion date for corrective action plan: November 2023

The University has made all corrections to the identified records. The 21-22 audit, which ended in the Spring of 2023, identified similar issues regarding NSLDS enrollment reporting of some records. A corrective action plan was put in place at that time, however, a portion of the 22-23 year had already transpired, thus these additional findings in the current audit year. The errors were partly the result of reporting data challenges between the University's Anthology system, the National Student Loan Clearinghouse and NSLDS. The University also recently completed the institutional alignment of term and enrollment status definitions between the Financial Aid and the Center for Graduate and Professional Studies. Additional controls and staff training have also been implemented to identify errors and processes to correct records going forward, which will include adding NSLDS access for the Registrar. The University is continuing its review of practices and determination of any additional control needs.

The University agrees with the finding. The 21-22 audit, which ended in the spring of 2023, identified similar issues regarding Title IV credit balances. A corrective action plan was put in place at that time, however, a portion of the 22-23 year had already transpired, thus these additional findings in the current audit year. The occurrence of Title IV credit balances occurs primarily with graduate program students. A review was conducted of current internal control processes and an evaluation of additional reporting within the student information system was done to assist in identifying these Title IV credit balances in a more timely manner. Title IV credit balances were monitored during the Spring 2023 terms and new procedures have been put in place for the Fall 2024 term.

Condition: The University did not return Title IV funds within the required time frame for certain students who required a post withdrawal disbursement. Planned Corrective Action: In response to identified delays in returning Title IV funds within the stipulated time frame for post withdrawal disbursements, an immediate corrective action plan has been initiated. This plan involves a thorough review of internal processes to identify and rectify procedural gaps contributing to the delays. Staff training sessions are being conducted to reinforce understanding and compliance with Title IV regulations, with a particular emphasis on the importance of timely disbursements. Contact person responsible for corrective action: N. Chad Curley Anticipated Completion Date: December 2022

After consultation with the National Clearinghouse (NCH), and written guidance from the U.S. Department of Education (ED), the Campus-Level enrollment effective date would not change because the enrollment level did not change. Clemson University will work with the NCH and utilize their audit support to further explore this scenario and determine what would need to be changed with field mapping and review, if anything. Anticipated Completion Date: June 1, 2024 Person Responsible for Corrective action: Cecil (Rock) McCaskill, Associate Registrar Contact/Responsible Party: Sherri Rowland, AVP and Controller Contact Information: sherrir@clemson.edu

The staff performing stale-dated check processing were notified of the audit finding and have received training. We have engaged with our banking partners to develop a report of outstanding checks to be available to Student Financial Services staff to identify aged outstanding student refund checks. Student Financial Services staff will communicate with students who have outstanding checks as a proactive measure to decrease the volume of uncashed stale-dated checks. Anticipated Completion Date: October 31, 2023 Person Responsible for Corrective action: Rebecca Pruitt, Director of Student Financial Services Contact/Responsible Party: Sherri Rowland, AVP and Controller Contact Information: sherrir@clemson.edu

The Office of Student Financial Aid will engage with the Office of Internal Audit (IA) to review the FISAP, and if any errors are found, will make corrections during the allotted time in December. Supporting schedules are centrally stored and will be made available to IA. Anticipated Completion Date: December 1, 2023 Person Responsible for Corrective action: Elizabeth Milam, Director of Financial Aid Contact/Responsible Party: Sherri Rowland, AVP and Controller Contact Information: sherrir@clemson.edu

The University’s Director of Financial Compliance will implement an additional step to email the University’s Controller for approval prior to drawdown of federal funds and will follow up with a screenshot of the actual drawdown for validation. Anticipated Completion Date: September 18, 2023 Person Responsible for Corrective action: Karen Robbins, Director of Financial Compliance Contact/Responsible Party: Sherri Rowland, AVP and Controller Contact Information: sherrir@clemson.edu

Condition: The University is not following its Satisfactory Academic Progress (SAP) policy. There was one error identified that attributed to this noncompliance. 1) Of the 25 students tested, there was 1 student who had fallen below the threshold of 67% per CMU's SAP at the time academic progress would be measured and the SAP policy was not followed to address student progress. Planned Corrective Action: A policy update to the quantitative component of satisfactory academic progress was implemented to measure SAP based on cumulative data. The full policy, informational website, student communications, and financial aid system were all updated. This policy update is effective for the 2023-24 academic year with the first official evaluation point assessing cumulative data at the end of fall 2023. Contact person responsible for corrective action: Sarah Kasabian-Larson, Director of Scholarships and Financial Aid Anticipated Completion Date: 2023-24 academic year with the first official evaluation point at the end of fall 2023.