Finding No.: 2024-03 - Reporting Recommendation The College should establish a systematic process for reviewing and updating the origination records prior to submission to the COD System. Response The College acknowledges the audit finding regarding the use of outdated cost of attendance (COA) figures and the uniform application of full-time enrollment status in COD origination records for the 2022-2023 academic year. In response, the Financial Aid Office (FAO) is committed to strengthening its policies and procedures to ensure accuracy, compliance, and proper stewardship of the Title IV funds. To this end, the College will implement the following corrective actions: 1. Policy and Procedure Enhancement a. The FAO will develop and implement a formal Standard Operating Procedure (SOP) for COD reporting. This SOP will include: • A COA validation checklist to ensure the correct, current-year COA from the approved financial aid handbook is applied. • The college has continuously considered the applicants’ enrollment status (full-time, %-time, half-time, or less-than-half-time) when determining the cost of attendance and awards but publishes only one cost of attendance for full time for the purpose of illustration. Hence, the college will start publishing all COA for all enrollment categories in the student financial aid handbook as a published guideline for awarding • A timeline that aligns record origination with student registration/enrollment confirmation to minimize errors and fully utilize the published Pell Recalculation Date (PRD) in the student financial aid handbook b. The SOP will be reviewed annually. 2. Staff Training and Certification a. FAO staff will participate in mandatory annual internal training and refresher workshops on the EDExpress system, COD reporting procedures, and Title IV compliance. The first round of enhanced training will be completed by August 30, 2025. Staff will also complete Federal Student Aid (FSA) training modules related to COD and verification processes to ensure understanding of federal expectations and system updates. 3. Manual Data Verification Protocol • The Financial Aid Office (FAO) will implement a structured manual data verification protocol to ensure accuracy when transferring information from the Student Information System (SIS) to EDExpress. This protocol will include: Use of pre- submission checklists to verify each student’s cost of attendance (COA), enrollment status, and other required data fields against the official records in the SIS. • Designated FAO staff will perform a two-tiered review process, where one staff member enters data and another independently verifies accuracy prior to COD submission. • Maintenance of record logs for each batch of COD submissions, documenting the review steps taken and any discrepancies corrected before submission. 4. Oversight and Accountability a. The Director of the Financial Aid Office (FAO) will be responsible for monitoring adherence to COD reporting requirements to ensure accuracy and compliance. This includes tracking staff training completion related to EDExpress and Title IV regulations, conducting quarterly internal reviews of origination and disbursement records, and verifying the correct use of current cost of attendance figures and enrollment status classifications. The Director will document findings, implement corrective actions as needed, and provide quarterly progress reports to the Vice President for Enrollment Management and Student Services (VPEMSS). Contact: VPEMSS Completion Date: September 30, 2025