Due to challenges related to the implementation and reporting functionality of the Anthology Student system, AGMU temporarily experienced difficulties in identifying students who officially or unofficially withdrew from the payment period. Although the compliance issues identified in this finding are primarily attributable to system implementation challenges, AGMU understands the importance of timely returns to the U.S. Department of Education related to withdrawn students and is engaged in a comprehensive effort to address deficiencies, prevent recurrence, and return any funds due from AGMU as soon as feasible. To resolve this issue and prevent recurrence, AGMU is completing the corrective actions described below. Corrective Action 1: Student eligibility and withdrawn students file review AGMU completed a file review of the 2023-24 and 2024-25 award years to identify students who (1) failed to begin attendance in a course or courses, and/or (2) had ISIR comment codes requiring resolution. As a result of this file review, AGMU has recalculated Title IV awards for impacted students. AGMU has also completed a file review of the 2023-24 and 2024-25 award years to confirm it has identified all students who officially and unofficially withdrew from the payment period. AGMU is now in the process of compiling system data to perform or re-perform R2T4 calculations for these students, as appropriate. Once AGMU has completed the R2T4 file review and confirmed if additional returns are required for the impacted students, AGMU will report the recalculated award amounts to COD and return funds via G5. Corrective Action 2: Development and enhancement of reports to facilitate the identification of withdrawn students and support the R2T4 calculation. AGMU developed new reports and enhanced existing reports that will aid the institution in timely identifying withdrawn students and performing accurate R2T4 calculations, including but not limited to the following reports that AGMU reviews weekly: • A report (“Customized Enrollment Status Change” report) that identifies students with enrollment status changes that may indicate the student ceased attending the payment period and thus a R2T4 is required. • Reports (“AGMU R2T4 Calculation Detail” and “AGMU R2T4 Review by Term” report) that extract data used in the R2T4 calculation from the student information system, such as term dates, module dates, and Title IV disbursements. • A report (“R2T4 Return of Funds” report) that track R2T4s performed in the system for which funds have not yet been returned via COD and potential post-withdrawal disbursements to student and parent borrowers. • A report (“Canvas Last Academic Activity” report) from the learning management system that confirms the student’s last date of academic engagement in an online course to assist in determining the student’s withdrawal date. AGMU uses the above reports jointly with reviewing live student data in the Anthology Student system when performing a R2T4 calculation, returning funds or disbursing or offering a post-withdrawal disbursement to a student or parent borrower. Corrective Action 3: Review and revision of policies and procedures related to student eligibility. AGMU is in the process of revising its existing policies and procedures related to student eligibility determinations to ensure they correctly describe processes in the Anthology system. AGMU is also in the process of revising its existing policies and procedures related to identifying withdrawn students, performing the R2T4 calculation, and returning funds via COD to ensure they correctly describe processes in the Anthology system. Corrective Action 4: Ongoing monitoring by and support from system office personnel SUAGM central office financial aid personnel perform and assist with quality assurance activities related to AGMU’s determination of student eligibility such as: 1. Reporting parameters are reviewed and refined collaboratively by Financial Aid, Registrar, and Information Technology (IT) staff to ensure that custom reports capture accurate, complete, and relevant data. This process includes validating data fields, logic, and calculation criteria used to support enrollment status changes and student eligibility analysis (i.e., the monitoring of ISIR comment codes). 2. Customized reports developed for enrollment status changes and student eligibility analysis are reviewed biweekly to identify changes in enrollment intensity, eligibility indicators, and potential ineligible disbursements. These reports support the timely review of aid adjustments and identification of cases requiring resolutions or returns. 3. Student record samples are selected and discussed at regularly scheduled validation meetings. These meetings include representatives from the Registrar, Financial Aid, Bursar, IT, and Compliance to confirm data accuracy, validate reporting results, and identify any necessary process or reporting adjustments. SUAGM central office financial aid personnel also perform and assist weekly with quality assurance activities related to AGMU’s identification of withdrawn students, performing the R2T4 calculation, and returning funds via COD, such as: 1. Reviewing reports generated by AGMU related to official and unofficial withdrawals, including validation of withdrawal dates, last date of academic activity, and enrollment status changes identified through registrar and financial aid data. 2. Reviewing R2T4 calculations prepared by AGMU to confirm accurate payment period dates and scheduled days for programs offered in modules, earned and unearned aid determinations, and amounts scheduled for return. 3. Monitoring the timely submission of returns through COD, including the review of refund activity reports and confirmation that returns are properly recorded and reconciled. Corrective Action 5: Ongoing training of AGMU personnel on key R2T4 concepts AGMU has mandated additional R2T4 training for personnel who interact with the R2T4 process in the financial aid office, registrar’s office, and bursar’s office. In addition to requiring that personnel attend training organized by SUAGM, AGMU employees have participated in webinars offered by Federal Student Aid, NASFAA, and third-party servicers, accounting firms, and law firms with expertise in R2T4 concepts.