Upon discovery (during 2023) of the failure of the College to perform monthly reconciliations, the College immediately implemented a corrective action plan that included a strengthening of procedures with corresponding internal controls, with immediate return of any excess cash. The Corrective Action Plan included Student Financial Aid training sessions for Business Office Staff responsible for Title IV cash management oversight. To further address this situation, the College engaged an independent consultant to assist in the review and revision of existing Business Office Title IV policies and procedures, which were immediately adopted and implemented