Upon discovery (during 2023) of the failure of the College to determine the amount of excess cash it had retained, and to timely return it ot the Secretary of Education, the College immediately implemented a corrective action plan that included a strengthening of procedures with corresponding internal controls, and the immediate return of any excess cash. The Correction 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 revisiion of existing Business Office Title IV policies and procedures, which were immediately adopted and implemented.