Name of Responsible Individuals: Matthew Cooper, VP of Student Financial Services and Tracy Price, Executive Director of Accounting Corrective Action: Liberty acknowledges that there were two instances in which Federal Work Study funds were overdrawn for longer than the permissible time-frames thus creating a scenario in which cash management rules were not followed. While Liberty diligently manages the draw and disbursement of funds, some aspects are dependent on manual data entry. For the two instances in which funds were overdrawn, a data entry error was made which did not include a draw that was completed for 20-21 Federal Work Study that were to be used for 21-22. In response, the Director of Financial Aid Compliance and the Assistant Director of Financial Aid Compliance will implement an additional quality control process in which all campus-based fund draws done through Accounting are manually reviewed for accuracy within 24 hours of the initial draw. This will allow time for any corrections within the allowable time-frames. In addition, whenever funds are carried forward from one aid year to the next, workbooks for both aid years will be presented and reviewed. Anticipated Completion Date: October 31, 2022