CONVERSE UNIVERSITYHigher Education

Enrollment Reporting - Withdrawal Corrective Action Plan Issue Identified: An enrollment reporting error occurred due to a student’s withdrawal date not being transmitted to the National Student Loan Data System (NSLDS). The student submitted a withdrawal form after the last enrollment file for the semester had been reported to the National Student Clearinghouse (NSC). Upon receipt, the withdrawal date was entered retroactively as the final day of the semester. Because the semester had already been reported, the withdrawal was not included until the subsequent first-ofterm enrollment report, resulting in a reporting delay that exceeded the 60-day submission requirement. Corrective Action Taken: The University Registrar consulted with the National Student Clearinghouse to verify the appropriate process for reporting withdrawals received after the final enrollment submission for a term. Based on this guidance, the following corrective measures have been implemented: 1. Manual Reporting of Late Withdrawals: If a withdrawal form is received after the final enrollment file for a term has been submitted, the Registrar’s Office will manually update NSC with the correct withdrawal date. 2. Implementation Date: This procedure became effective at the beginning of the Fall 2025 semester. 3. Ongoing Compliance: The Registrar’s Office will continue to submit timely and accurate enrollment reports to NSLDS, ensuring that all changes to student enrollment status are reported within required federal deadlines. Responsible Office: The Office of the Registrar, under the direct supervision of the University Registrar, is responsible for the implementation, monitoring, and ongoing adherence to this corrective action plan. Enrollment Reporting - Graduation Corrective Action Plan Issue Identified: A reporting error occurred in which a student’s graduation date did not appear in the National Student Loan Data System (NSLDS). The discrepancy was caused by the graduation date being recorded as the commencement date of May 17, 2025, while the official semester end date was May 15, 2025.The final enrollment file was submitted to the National Student Clearinghouse (NSC) on May 15, 2025, prior to the entry of the graduation date, resulting in the omission from the report. Corrective Action Taken: The University Registrar reviewed the reporting procedures and determined that graduation dates must align with the official academic calendar, specifically the last day of class for the semester. To ensure compliance, the following measures have been implemented: 1. Standardization of Graduation Dates: All future graduation dates will be recorded as the official last day of class for the semester, rather than the commencement ceremony date. 2. Adjustment of Final Reporting Timeline: The final enrollment report for each term will not be submitted until all graduation records have been updated in the system to ensure accurate transmission to NSC and NSLDS. 3. Implementation Date: This procedure is effective beginning with the Fall 2025 and Spring 2026 graduation reporting cycle. 4. Ongoing Compliance: The Registrar’s Office will continue to monitor reporting practices to ensure all graduation and enrollment data are transmitted to NSLDS in accordance with federal reporting requirements. Responsible Office: The Office of the Registrar, under the direct supervision of the University Registrar, is responsible for the implementation, oversight, and continued compliance of this corrective action plan. Shannon Bishop Shannon.bishop@converse.edu University Registrar

2024-002

Management Response to Section III-Federal Award Findings and Questioned Costs, Student Financial Aid Cluster, Assistance Listing # 84.007, 84.033, 84.038, 84.063, 84.268 – Finding No. 2024-01 Compliance Requirement Finding: Eligibility Students receiving federal aid are required to be U.S. citizens, Nationals, or provide evidence from the U.S. Citizenship and Immigration Services that he or she is a permanent resident or in the U.S. with the intention of becoming a citizen or permanent resident (eligible noncitizen). The financial aid counselor did not obtain proper documentation and approval to determine that the student was an eligible noncitizen. As such, the University disbursed federal aid to a student that was improperly documented as an eligible noncitizen. The federal aid was reversed and replaced with institutional funds. Corrective Action Plan In response to the finding on the FY2024 Single Audit, the University conducted an additional internal review on 25% of the student records that were not pulled in the audit sample where citizenship verification was required. This review included verification of having valid documentation in accordance with the U.S. Department of Education regulations and confirmation that the secondary verification was completed per existing operating protocol. The University found no additional instances and therefore believes this to be an isolated incident. As a preventative measure and to mitigate potential recurrence, additional training has been conducted with the Student Financial Aid Staff to reemphasize and reinforce University policy and procedures concerning verification in accordance with the University’s Policy for Verification, in particular section 3(B), which states: “All completed verification must have a secondary review by the Associate Vice President for Student Financial Services, Associate Director of Student Financial Services, or another financial aid counselor. Appropriate signatures must be noted on all verifications completed.” Throughout the FY2025 year, the University will also provide randomized internal audits on a sampling of the student files containing citizenship verification to ensure the protocols are being followed as presented. This review will be conducted by the Associate Vice President for Student Financial Services for files where not part of the initial secondary review process or by the Vice President of Operations and Chief Financial Officer or the Assistant Vice President and Controller when the Associate Vice President for Student Financial Services is the secondary reviewer. J.W. Kellam james.kellam@converse.edu Associate Vice President for Student Financial Services

Compliance Requirement Finding: Special Test and Provisions – Enrollment Reporting The University had not reported changes of the sampled graduated or withdrawn students to the National Student Loan Data System (“NSLDS”) as required under the Uniform Grant Guidance for the year ended June 30, 2024, accurately or timely. Student Financial Aid Cluster, Assistance Listing # 84.007, 84.033, 84.038, 84.063, 84.268 Corrective Action Plan The finding was due to a lack of a process to correctly backdate administrative withdrawals when a student receives a "W" grade after the withdrawal deadline. This inconsistency led to inaccurate reporting to the National Student Loan Data System (NSLDS) and the academic file. To address this, management has collaborated with the Offices of Campus Technology, Student Financial Services, and the Registrar and has developed and implemented better procedures for handling administrative withdrawals. These procedures will ensure: • Consistent reporting of withdrawal dates to NSLDS. • Ensuring that withdrawal dates are recorded uniformly in both the Registrar’s office and Student Financial Services. • Accurate assignment of "W" grades according to the academic calendar. These new procedures were implemented in the beginning of 2024. The Registrar’s office will continue to submit regular enrollment reports to NSLDS, promptly reporting any changes to student enrollment as required. The Office of the Registrar will be responsible for implementing the corrective action plan, under the supervision of the University Registrar and Director of Institutional Research and Effectiveness. Shannon Bishop Shannon.bishop@converse.edu University Registrar

2023-001

The finding was due in part to the lack of a process to correctly backdate administrative withdrawals when a student is awarded a grade of W after the stated date. This resulted in inconsistent dates reported to NSLDS and in the academic file. Management has met to address this issue. The Offices of Campus Technology, Financial Planning and Registrar have met to discuss processes in place and create new methods by which administrative withdrawals will be handled going forward. Additionally, management is working with Jenzabar to ensure the dates are consistent with the withdrawal option, specifically the awarding of W grades and the related date of last attendance. This process will assist the University in the following ways: students will be reported on the NSLDS report in the appropriate timeframe, a uniform withdrawal date will be recorded in the Offices of the Registrar and Financial Planning and students receive the appropriate grade as indicated by the official academic calendar. This action has been implemented for the final grading period ending on Monday, December 11, 2023. Management will continue to submit enrollment reports to the NSLDS on the schedule submitted annually, ensuring that any changes to student enrollment will be reported as required. The corrective action plan will be undertaken by the Office of the Registrar, under the supervision of the University Registrar and Director of Institutional Research and Effectiveness, Kendra Woodson (Kendra.woodson@converse.edu).

Management Response to Section III-Federal Award Findings and Questioned Costs, CFDA# 84.268 The finding indicated that for the year ended June 30, 2020, the College did not have a system in place for timely reporting of unofficial withdrawals. The lack of a system caused a delay in reporting current statuses to the Clearinghouse. In addition, the College did not have an internal control in place to ensure that student statuses were being properly tracked for National Student Loan Data System (NSLDS) reporting purposes. Corrective Action Plan The finding was due in part to the lack of a process to identify unofficial withdrawals. This resulted in inconsistent dates reported to NSLDS and in the academic file. Management has met to address this issue. The Offices of Student Success, Financial Planning and Registrar will meet after the midterm grading period to review early alerts, grades of F and attendance records for currently enrolled students. This meeting will help Management identify students who have stopped attending classes early in the semester. Because the attendance records are critical to this meeting, Management will send emails and alerts to faculty about maintaining attendance records for each course. At that point, those students will receive an Administrative Withdrawal for the semester. This process will assist the College in the following ways: students will be reported on the NSLDS report in the appropriate timeframe, a uniform withdrawal date will be recorded in the Offices of the Registrar and Financial Planning and students receive grades of W instead of an F for the semester. This action has been implemented for the midterm grading period ending on Tuesday, March 30, 2021. Management will continue to submit enrollment reports during the January term, despite regular enrollment reports not occurring during that term. However, this additional step will ensure that all unofficial withdrawals have been properly processed for the fall term. The corrective action plan will be undertaken by the Office of the Registrar, under the supervision of the Associate Provost for Institutional Research and Registrar, Dr. Gee Sigman (gee.sigman@converse.edu). Dr. Sigman will serve as the contact for this finding and will report progress and status updates to the Provost, Dr. Jeffrey Barker.

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