Ana G. Méndez University, Inc.Non-Profit

Due to challenges related to the implementation and reporting functionality of the Anthology Student system, AGMU temporarily experienced difficulties in identifying students who officially or unofficially withdrew from the payment period. Although the compliance issues identified in this finding are primarily attributable to system implementation challenges, AGMU understands the importance of timely returns to the U.S. Department of Education related to withdrawn students and is engaged in a comprehensive effort to address deficiencies, prevent recurrence, and return any funds due from AGMU as soon as feasible. To resolve this issue and prevent recurrence, AGMU is completing the corrective actions described below. Corrective Action 1: Student eligibility and withdrawn students file review AGMU completed a file review of the 2023-24 and 2024-25 award years to identify students who (1) failed to begin attendance in a course or courses, and/or (2) had ISIR comment codes requiring resolution. As a result of this file review, AGMU has recalculated Title IV awards for impacted students. AGMU has also completed a file review of the 2023-24 and 2024-25 award years to confirm it has identified all students who officially and unofficially withdrew from the payment period. AGMU is now in the process of compiling system data to perform or re-perform R2T4 calculations for these students, as appropriate. Once AGMU has completed the R2T4 file review and confirmed if additional returns are required for the impacted students, AGMU will report the recalculated award amounts to COD and return funds via G5. Corrective Action 2: Development and enhancement of reports to facilitate the identification of withdrawn students and support the R2T4 calculation. AGMU developed new reports and enhanced existing reports that will aid the institution in timely identifying withdrawn students and performing accurate R2T4 calculations, including but not limited to the following reports that AGMU reviews weekly: • A report (“Customized Enrollment Status Change” report) that identifies students with enrollment status changes that may indicate the student ceased attending the payment period and thus a R2T4 is required. • Reports (“AGMU R2T4 Calculation Detail” and “AGMU R2T4 Review by Term” report) that extract data used in the R2T4 calculation from the student information system, such as term dates, module dates, and Title IV disbursements. • A report (“R2T4 Return of Funds” report) that track R2T4s performed in the system for which funds have not yet been returned via COD and potential post-withdrawal disbursements to student and parent borrowers. • A report (“Canvas Last Academic Activity” report) from the learning management system that confirms the student’s last date of academic engagement in an online course to assist in determining the student’s withdrawal date. AGMU uses the above reports jointly with reviewing live student data in the Anthology Student system when performing a R2T4 calculation, returning funds or disbursing or offering a post-withdrawal disbursement to a student or parent borrower. Corrective Action 3: Review and revision of policies and procedures related to student eligibility. AGMU is in the process of revising its existing policies and procedures related to student eligibility determinations to ensure they correctly describe processes in the Anthology system. AGMU is also in the process of revising its existing policies and procedures related to identifying withdrawn students, performing the R2T4 calculation, and returning funds via COD to ensure they correctly describe processes in the Anthology system. Corrective Action 4: Ongoing monitoring by and support from system office personnel SUAGM central office financial aid personnel perform and assist with quality assurance activities related to AGMU’s determination of student eligibility such as: 1. Reporting parameters are reviewed and refined collaboratively by Financial Aid, Registrar, and Information Technology (IT) staff to ensure that custom reports capture accurate, complete, and relevant data. This process includes validating data fields, logic, and calculation criteria used to support enrollment status changes and student eligibility analysis (i.e., the monitoring of ISIR comment codes). 2. Customized reports developed for enrollment status changes and student eligibility analysis are reviewed biweekly to identify changes in enrollment intensity, eligibility indicators, and potential ineligible disbursements. These reports support the timely review of aid adjustments and identification of cases requiring resolutions or returns. 3. Student record samples are selected and discussed at regularly scheduled validation meetings. These meetings include representatives from the Registrar, Financial Aid, Bursar, IT, and Compliance to confirm data accuracy, validate reporting results, and identify any necessary process or reporting adjustments. SUAGM central office financial aid personnel also perform and assist weekly with quality assurance activities related to AGMU’s identification of withdrawn students, performing the R2T4 calculation, and returning funds via COD, such as: 1. Reviewing reports generated by AGMU related to official and unofficial withdrawals, including validation of withdrawal dates, last date of academic activity, and enrollment status changes identified through registrar and financial aid data. 2. Reviewing R2T4 calculations prepared by AGMU to confirm accurate payment period dates and scheduled days for programs offered in modules, earned and unearned aid determinations, and amounts scheduled for return. 3. Monitoring the timely submission of returns through COD, including the review of refund activity reports and confirmation that returns are properly recorded and reconciled. Corrective Action 5: Ongoing training of AGMU personnel on key R2T4 concepts AGMU has mandated additional R2T4 training for personnel who interact with the R2T4 process in the financial aid office, registrar’s office, and bursar’s office. In addition to requiring that personnel attend training organized by SUAGM, AGMU employees have participated in webinars offered by Federal Student Aid, NASFAA, and third-party servicers, accounting firms, and law firms with expertise in R2T4 concepts.

Due to challenges related to the implementation and reporting functionality of the Anthology Student system, AGMU temporarily experienced difficulties in identifying enrollment status changes and reporting the changes to NSLDS. Errors and delays related to enrollment reporting were primarily due to AGMU’s delay in identifying withdrawn students (discussed in Finding 2025-2) and identifying the withdrawal date used in the R2T4 calculation so that the date could be reported to NSLDS. AGMU agrees with the auditor’s recommendation that implementing additional processes and controls around enrollment reporting will improve compliance. To resolve this issue and prevent recurrence, AGMU is completing the corrective actions described below. Corrective Action 1: Confirming and reporting withdrawal dates for award years 2023-24 and 2024-25 As part of the withdrawn students file review described in the corrective actions for Finding 2025-2, AGMU is confirming the withdrawal date for students who did not complete the payment period. Once the withdrawal dates have been confirmed (and/or previous withdrawal dates are confirmed), enrollment statuses for impacted students will be updated in NSLDS as appropriate. Corrective Action 2: Monitoring for enrollment status changes To identify enrollment status changes timely, AGMU developed a report (“Customized Enrollment Status Change” report) that identifies students with enrollment status changes, the effective date of enrollment status changes, and potential Title IV adjustments related to enrollment status changes (e.g., Pell Grant recalculations). AGMU generates this report weekly to ensure that any student with an enrollment status change is reviewed, and timely Title IV award revisions are completed, if applicable. Corrective Action 3: Validation of the Enrollment Reporting Roster To validate the accuracy of the Enrollment Reporting Roster, AGMU will be developing a report to identify students with enrollment status changes and the effective date of enrollment status changes. AGMU is determining if it could use the existing report (“Customized Enrollment Status Change” report) for this process. Once AGMU has finalized its process and report, AGMU plans to generate this report monthly to confirm accurate information regarding student enrollment status is being extracted from the Anthology Student system and correctly transmitted to NSLDS via the Enrollment Reporting Roster. Corrective Action 4: Timely identification of ISIR comment codes Although AGMU had policies and procedures related to determining student eligibility, the procedures required revisions due to the Anthology Student implementation. To identify students for whom ISIR comment codes appear after Title IV aid is awarded and/or disbursed (i.e., on a subsequent ISIR), AGMU developed a report (“Customized Ineligible Funds” report) that identifies potentially impacted students, Title IV funds awarded and disbursed, and ISIR comment codes. AGMU generates this report weekly to ensure any student with an ISIR comment code is reviewed and any funds that must be returned are identified timely. Corrective Action 5: Review and revision of policies and procedures related to enrollment reporting. AGMU is in the process of revising its existing policies and procedures related to enrollment reporting to ensure they correctly describe processes in the Anthology system. Corrective Action 6: Ongoing monitoring by and support from system office personnel SUAGM central office financial aid personnel will perform and assist with quality assurance activities related to AGMU’s enrollment reporting such as: 1. Creating reports related to official and unofficial withdrawals to verify that enrollment status changes are identified on a timely basis and accurately reflected in student records in NSLDS. 2. In coordination with the Registrar, creating an enrollment reporting manual. 3. Developing NSLDS enrollment reporting training and requiring that all staff with enrollment reporting responsibilities attend the training. Corrective Action 7: Enrollment reporting file review AGMU is in the process of planning a comprehensive file review of enrollment reporting for the 2023-24 and 2024-25 award years. At this time, AGMU is prioritizing the withdrawn students file review so that unearned funds can be returned to the U.S. Department of Education as soon as possible. Once the withdrawn students file review is completed, AGMU will begin work on the enrollment reporting file review.