Need Analysis Planned Corrective Action: North Greenville University recognizes that this finding represents a recurrence of the prior-year need analysis finding. Although procedures were implemented after the prior finding, the current-year audit identified a specific gap in monitoring changes to the Cost of Attendance (COA) and their impact on subsidized loan eligibility. The enhanced procedures described below address this risk by identifying instances where a student's subsidized loan exceeds remaining financial need after changes to COA. The Financial Aid Office (FAO) has implemented the following enhanced procedures: • The FAO has developed a targeted PowerFAIDS report to identify students whose subsidized loan award exceeds their remaining financial need. The report will be used as a specific exception report to identify potential subsidized loan over-awards resulting from changes to a student's financial aid eligibility. • The targeted PowerFAIDS report will be reviewed as part of the FAO’s pre-disbursement compliance process. Student records identified by the report will be reviewed to determine whether a change in COA, enrollment, or other financial aid resulted in a subsidized loan over-award. • The Financial Aid staff responsible for packaging, COA adjustments, loan adjustments, and disbursement review will receive additional guidance regarding the relationship between COA, remaining need, and subsidized loan eligibility. Staff will be specifically instructed to reevaluate loan eligibility when changes to housing status or other components of COA affect a student's remaining need. The PowerFAIDS exception report identifying subsidized loan awards that exceed remaining financial need will be reviewed each term and as part of the pre-disbursement review process. Additionally, the FAO will monitor significant changes to COA, particularly housing status changes, to ensure that changes in need are appropriately reflected in federal loan eligibility. Any exceptions identified will be reviewed and corrected promptly. Documentation of the review and any resulting adjustments will be retained as evidence of the control being performed. Regarding the one locked student record identified, PowerFAIDS currently has a task that identifies students in DR (Data Review) status and assigns the record to a Financial Aid counselor for review. As an enhancement to this existing control, counselors will verify the student's ISIR processing status and confirm that applicable ISIR fields are unlocked when an updated ISIR is expected. This additional verification is intended to ensure that a subsequent ISIR can successfully upload and update the student's financial aid record. Counselors will review the student's record to determine whether the locked ISIR prevented updated FAFSA information from being received or processed and will take the appropriate corrective action before finalizing the student's eligibility. As part of the DR review, counselors will verify that the student's most recent ISIR has processed correctly and that applicable federal aid eligibility, including Pell Grant eligibility, has populated appropriately. If the student's record remains in DR because of an ISIR processing issue, the counselor will resolve the issue and document the review before the student's aid is finalized. Person Responsible for Corrective Action Plan: Cindi Patterson, Director of Financial Aid Anticipated Date of Completion: October 1, 2026