November 17, 2022 To: Chair of the Audit Committee From: Debra Martin, Vice President for Finance and Administration RE: Response to Baker Tilly Audit Communication ? Uniform Guidance Audit Findings Finding 2022-004: Nursing Student Loans Program: Nursing Student Loans (NSL) Assistance Listing Number (ALN): 93.364 Federal Agency: U.S. Department of Education Federal Award Identification Number: Unknown Federal Award Year: June 30, 2022 Criteria: U.S. Department of Education regulations require for a NSL loan, repayment must begin nine months after the student ceases to be a full-time or half-time student, except as required in 42 CFR 57.310(a). For NSL loans after November 13, 1998, the 10 ?year repayment period may be extended for ten years for any student borrower who, during the repayment period failed to make consecutive payments and who, during the last 12 months of the repayment period, has made at least 12 consecutive payments. Institutions must exercise due care and diligence in the collection of loans. Many institutions engage third-party servicers for billing, collection, and processing deferment and cancellation requests, although these institutions remain responsible for compliance. Institutions are required to timely convert loans to repayment, establish repayment plans, process cancellation requests, and service loans as required. Condition: Seven of seven students who were tested had errors. The University had difficulty providing a listing of students who entered repayment on their NSL during fiscal year 2022. ? For one student, selected from an initial listing that ended up not being correct, the system screen showed the student separated from the University on May 8, 2020, however, the student was not noted as graduated for reporting to the NSLDS or provided with exit counseling to establish the repayment plan. ? Two students were noted as missing from the final listing provided and the servicer screen showed their status as `in school?, however they should have been indicated as `in repayment?. For one of these students, the exit counseling was provided but the student did not complete/sign it and the University did not follow-up to ensure it was completed or the repayment plan established. ? For three students that had separated from the University, the dates differed between system screens and servicer screens and exit counseling. One of these students was provided exit counseling but the student did not complete/sign it and the University did not follow-up to ensure it was completed or the repayment plan established. ? For one additional student, the exit counseling was provided but the student did not complete/sign it and the University did not follow-up to ensure it was completed or the repayment plan established. The sample was not a statistically valid sample as the auditors ended up testing the entire population. Cause: The University?s processes are not ensuring that information for NSL students is correct in the University or servicer systems, or that exit counseling is being performed or repayment plans established. Effect: Students with NSL are not being converted to repayment timely with established payment plans that can result in loans not being repaid. Questioned costs: Not applicable Context: Not applicable. Recommendation: It is recommended that the University review policies and procedures in place to resolve issues in a timely manner to facilitate compliance with NSL regulations. Management?s Response: The University agrees with the recommendation and will review system, reporting functionalities and business processes contributing to these errors and implement corrective measures. Correction Action: The University will dedicate a Student Accounts staff to manage the loan program by providing addition policy training on processes and technology training with the third party loan processor. Student Account Staff will perform timely reconciliations on all Federal nursing loan programs with the external loan servicer to ensure the student?s status is accurate. We will be exploring the possibility of reporting directly to the NLDS.