Corrective Action Plans

Finding 524785 (2024-003)

Significant Deficiency 2024

MN

Questioned Costs Student Financial Aid Matching / Level of Effort / Earmarking

Student Financial Assistance Cluster – Assistance Listing No. Various Recommendation: We recommend the University review the R2T4 requirements and implement procedures to ensure the R2T4 calculations are completed timely and accurately. Explanation of disagreement with audit finding: There is no dis...

Student Financial Assistance Cluster – Assistance Listing No. Various Recommendation: We recommend the University review the R2T4 requirements and implement procedures to ensure the R2T4 calculations are completed timely and accurately. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: On October 26, 2024, three modifications were made to the reporting tool the financial aid office uses for Return of Title IV Funds calculations to draw attention to situations when the “student completed more than 49% of a course” exception applies. First, we added a formula to the "5 - Title IV Checklist Revised" sheet in cell D16:F17. If the answer to question 11 "Exemption 3b: Successfully complete >49%?" is Yes, the following narrative will appear in blue, bold, font: "Student Completed more than 49% of a modular course; Exemption 3b applies; NOT a Withdrawal. R2T4 NOT Required. Might need to recalc aid." Second, we modified a formula in cell J34 on the "2 - R2T4 Calc Required" sheet, so that if there is a "yes" in cell C45 (indicating the student qualifies for the "completed more than 49% of a modular course" exemption), then the following phrase will appear in bold, red font: "Student Completed more than 49% of a modular course; Exemption 3b applies; NOT a Withdrawal. R2T4 NOT Required. Might need to recalc aid." Third, we added a formula to cell E36 on the "2 - R2T4 Calc Required" sheet, so that if there is a "yes" in cell C45 (indicating the student qualifies for the "completed more than 49% of a modular course" exemption), then the following phrase will appear in bold, blue font: "Student Completed more than 49% of a modular course; Exemption 3b applies; NOT a Withdrawal. R2T4 NOT Required. Might need to recalc aid." In addition, we completed additional training with the financial aid staff who complete R2T4 calculations to ensure they (a) understand rules related to the “student completed more than 49% of a course” exception, and (b) are aware of the additional warning messages that will appear in our R2T4 calculation spreadsheet. Name of the contact person responsible for corrective action: Jeffrey D Olson, Interim Director of Financial Aid Planned completion date for corrective action plan: October 26, 2024.

View Audit 344164 Questioned Costs: $1

Finding 524779 (2024-002)

Material Weakness 2024

Bethel University and Affiliates

MN

Student Financial Aid Material Weakness Reporting

Student Financial Assistance Cluster – Assistance Listing No. Various Recommendation: We recommend the University review its reporting procedures to ensure that students’ statuses are accurately and timely reported to NSLDS as required by regulations. Explanation of disagreement with audit finding: ...

Student Financial Assistance Cluster – Assistance Listing No. Various Recommendation: We recommend the University review its reporting procedures to ensure that students’ statuses are accurately and timely reported to NSLDS as required by regulations. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Background: The Bethel University Registrar is responsible for ensuring timely and accurate reporting to NSLD via the National Student Clearinghouse. Cheryl Fisk was appointed to serve as University Registrar on August 1, 2022. While new to Bethel, she is not new to Clearinghouse reporting. She assumed the oversight of the Clearinghouse reporting and is working to ensure timely, accurate submissions. • Bethel reports student enrollment to NSLDS via the National Student Clearinghouse • Currently, the people involved in the process include: o Data Management Team: Ana Ortiz, Records and Data Specialist o Registrar Staff: Cheryl Fisk, University Registrar o Information Technology Service Staff: Bethel Information Technology Staff Based on the previous audit, adjustments were made to standardize the submissions to the Clearinghouse. Extra efforts were made to ensure that needed corrections were done within the required time frame. We have started to simplify our degree conferral policy to improve the accuracy of the reporting of graduates. However, because of major changes in the Information Technology Department staffing, we were not able to research how the submission reports are compiled or the automatic process that is used to clean and prepare the data before it is added to the submission reports. We have reviewed the Clearinghouse training. We have also sought the advice from other institutions who report to the Clearinghouse. We originally thought that the frequency of our batches was the problem. However, it appears that the issues may be in the way the submission data are prepared and compiled into the submission reports. Multiple reports must be compiled and then combined to create the submission for both branches. Corrective Action: Our corrective action will involve several parts. • First, we will work ITS staff to determine which fields and tables the submissions are using to create the Clearinghouse reports. Currently, the submission batches are reporting on two branches where multiple terms (i.e. termcodes) are involved. The reports may need to some revision. • Second, we will be proactive in confirming that the Clearinghouse has received our submissions and has processed them in a timely manner • Third, we will monitor closely what the Clearinghouse records show for graduation and withdrawal dates for students in comparison to what is in our student information system to ensure they are in sync. Then we will double check that information to what is showing at NSLDS. Corrections will be made if needed. • Fourth, we will continue to adjust our conferral process to ensure that graduation information is reported in a timely way • Fifth, we will confer with the Financial Aid Office when dealing with complicated registration changes. This will ensure we are in sync in our interpretations of the situation. • Sixth, we will continue to take advantage of Clearinghouse, Banner, and any other related training opportunities. Name of Contact person Responsible for Corrective Action: Cheryl Fisk Planned completion date for the correction action plan: June 1, 2025. This will provide time to test corrective measures to ensure everything is submitting properly.

View Audit 344164

Finding 524777 (2024-001)

Significant Deficiency 2024

Mercyhurst University

PA

Student Financial Aid Matching / Level of Effort / Earmarking Internal Control / Segregation of Duties

Finding: During testing of Perkins Loan Recordkeeping and Record Retention, the University could not provide a signed promissory note for three out of four loans selected for testing. View of responsible officials and corrective action: Management understands the recommendation and the need to ret...

Finding: During testing of Perkins Loan Recordkeeping and Record Retention, the University could not provide a signed promissory note for three out of four loans selected for testing. View of responsible officials and corrective action: Management understands the recommendation and the need to retain the records of former students. While we are certain that required documentation exists or existed at one time, the passage of time and lack of digital backups impaired our ability to produce the documents. Since the loans related to the missing documents are currently in repayment status, we feel that provides assurance that the former students did sign the loan agreement. However, we understand the need to retain all critical forms for our students.

View Audit 344161

Finding 524775 (2024-002)

Significant Deficiency 2024

Mercyhurst University

PA

Questioned Costs Student Financial Aid Internal Control / Segregation of Duties

Finding: During the course of testing return of Title IV funds, the calculation was not accurate for one student from the sample and therefore the proper amount of funds to be returned in the appropriate time required was not accurate. View of responsible officials and corrective action: Managemen...

Finding: During the course of testing return of Title IV funds, the calculation was not accurate for one student from the sample and therefore the proper amount of funds to be returned in the appropriate time required was not accurate. View of responsible officials and corrective action: Management understands the need for accurate calculation of funds to be returned. An additional step has been added to the process for the return of Title IV funds process. All calculations are now reviewed by a manager before release to ensure funds are calculated correctly and returned in the appropriate timeframe.

View Audit 344161 Questioned Costs: $1

Finding 524761 (2024-004)

Significant Deficiency 2024

Resources for Human Development, INC

PA

Special Tests & Provisions Significant Deficiency Internal Control / Segregation of Duties § 200.302

Management will review the SFDS protocols and processes with the appropriate staff in order enable the consistent application of sliding fees. This will be completed by June 30, 2025.

View Audit 344160

Finding 524737 (2024-002)

None 2024

Resources for Human Development, INC

PA

Reporting Internal Control / Segregation of Duties

Management agrees that the closing process needs to be improved to allow for timely closing of the general ledger and financial reporting in compliance with federal and other regulatory deadlines. Effective May 2024, RHD has implemented a shortened monthly and year-end closing schedule to assist in ...

Management agrees that the closing process needs to be improved to allow for timely closing of the general ledger and financial reporting in compliance with federal and other regulatory deadlines. Effective May 2024, RHD has implemented a shortened monthly and year-end closing schedule to assist in meeting this goal. Management also believes that audit timing for the fiscal year ended June 30, 2023 was an anomaly based on the identified need for corporate restructuring that was occurring concurrently with audit process. This added complexity to the subsequent event disclosures and testing required. Additionally, RHD formally affiliate with Inperium as disclosed in Note 3 of the accompanying financial statements. The affiliation was closed on December 11, 2024. Systems and closing procedures will be evaluated and redesigned as part of the affiliation integration process.

View Audit 344160

Finding 524706 (2024-002)

Significant Deficiency 2024

Housing and Redevelopment Authority of Austin

MN

Questioned Costs Cash Management Internal Control / Segregation of Duties

Cash Management Federal Agency: Department of Housing and Urban Development Federal Program Name: Housing Voucher Cluster Assistance Listing Number: 14.871 Award Period: October 1, 2023 – September 30, 2024 Type of Finding: Significant Deficiency in Internal Control over Compliance and Complia...

Cash Management Federal Agency: Department of Housing and Urban Development Federal Program Name: Housing Voucher Cluster Assistance Listing Number: 14.871 Award Period: October 1, 2023 – September 30, 2024 Type of Finding: Significant Deficiency in Internal Control over Compliance and Compliance Recommendation: We recommend that the HRA continue to evaluate their procedures and controls in place over the draw down of funds. Management’s Response: Management agrees with the finding and will continue to monitor the draws to ensure they are spent within the required timeframe. Explanation of Disagreement with Audit Finding: There is no disagreement with the audit finding. Actions Planned in Response to Finding: The HRA will ensure that all draws of funds are spent within the required timeframe. Official Responsible for Ensuring CAP: Angela Maiden, Finance Director, is the official responsible for ensuring corrective action of the deficiency. Planned Completion Date for CAP: September 30, 2025 Plan to Monitor Completion of CAP: Taggert Medgaarden, Executive Director, will ensure that the draw downs are properly managed through discussions with the Finance Director.

View Audit 344136 Questioned Costs: $1

Finding 524703 (2024-001)

Significant Deficiency 2024

Abbotsford Housing Authority

WI

Internal Control / Segregation of Duties Reporting

Corrective Action Planned: Due to the Authority's size, it is cost-prohibitive and impractical to achieve the ideal level of segregation of duties. The Authority has implemented as many controls and segregation of duties as practically possible for an organization of this size. Completion Date: Ongo...

Corrective Action Planned: Due to the Authority's size, it is cost-prohibitive and impractical to achieve the ideal level of segregation of duties. The Authority has implemented as many controls and segregation of duties as practically possible for an organization of this size. Completion Date: Ongoing

View Audit 344133

Finding 524683 (2024-001)

Significant Deficiency 2024

Texas Association for the Education of Young Children, Inc.

TX

Internal Control / Segregation of Duties Allowable Costs / Cost Principles Reporting

Management Response: TXAEYC’s Payroll Processing section of the Accounting Manual will be updated to reflect the following changes: “Direct supervisors will review and approve their direct reports’ timesheets to ensure time is accurately recorded and all hours worked are assigned a cost allocation...

Management Response: TXAEYC’s Payroll Processing section of the Accounting Manual will be updated to reflect the following changes: “Direct supervisors will review and approve their direct reports’ timesheets to ensure time is accurately recorded and all hours worked are assigned a cost allocation. The Director of Operations conducts a second layer of approval for all employee timesheets and processes payroll via the payroll platform. The Director of Operations may not process payroll without ensuring Supervisor Approval has been entered for all timesheets within the payroll platform. Additionally, the Director of Operation shall approve the timesheet of the Executive Director/Chief Executive Officer.” Parties Responsible and Timeline Updates to the Accounting Manual will be approved by TXAEYC’s Finance Committee and Governing board by April 30, 2025. The Director of Operation will implement changes to approved by the Finance Committee and Governing Committee immediately following their approval.

View Audit 344111

Finding 524679 (2024-004)

Significant Deficiency 2024

La Salle University

PA

Questioned Costs Student Financial Aid Significant Deficiency

Student Financial Assistance Cluster-Assistance Listing No. 84.0007, 84.033, 84.063, 84.268 Recommendation: We recommend the University review its policies and procedures related to Title IV outstanding checks to ensure they are being returned to the Department of Education after 240 days. Explanati...

Student Financial Assistance Cluster-Assistance Listing No. 84.0007, 84.033, 84.063, 84.268 Recommendation: We recommend the University review its policies and procedures related to Title IV outstanding checks to ensure they are being returned to the Department of Education after 240 days. Explanation of disagreement with audit finding: There is no disagreement with the audit finding . Action taken in response to finding : La Salle University will identify outstanding not cashed checks for each term. A term is normally 4 months in total as each semester generates a list of uncashed checks. Within two weeks of establishing outstanding checks, we will send letters to students informing them that they have outstanding refund checks. For approximately six months, the process of reviewing the outstanding list repeats, and if a check has not been cashed, another letter of notice is mailed. After six months, finance will send the outstanding list to Student Financial Services for a 30-day final review/outreach. At 21 O days from original refund issuance, Finance will provide the list to Financial Aid who will return balances to DOE. Name(s) of the contact person(s) responsible for corrective action: Zak Thornton, Assistant Vice President of Finance Planned completion date for corrective action plan: Corrected as of Spring 2025.

View Audit 344109 Questioned Costs: $1

Finding 524678 (2024-003)

Significant Deficiency 2024

La Salle University

PA

Student Financial Aid Significant Deficiency Matching / Level of Effort / Earmarking

Student Financial Assistance Cluster - Assistance Listing No. 84.038 Recommendation: We recommend the University evaluate its procedures and policies around recordkeeping and record retention. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action tak...

Student Financial Assistance Cluster - Assistance Listing No. 84.038 Recommendation: We recommend the University evaluate its procedures and policies around recordkeeping and record retention. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: We have contracted with RPK, a leading higher educating consulting firm who has been assisting us with examining our systems, practices, policies, and procedures. We have reorganized the student accounts receivable functions into a seamless student financial service and created a student financial operations backend where all database maintenance, automation, processing, and audits are being coordinated by a team separate from those servicing students directly. We have replaced all ineffective staff members including those who oversaw the record keeping process based on the support and recommendations of RPK, and are completing audits of all files, current and past, in a manual review of all cabinets to correctly alphabetize and organize. Name(s) of the contact person(s) responsible for corrective action: Michele McDevitt, Assistant Vice President, Student Financial Services Planned completion date for corrective action plan: Summer 2025

View Audit 344109

Finding 524677 (2024-002)

Significant Deficiency 2024

La Salle University

PA

Reporting Student Financial Aid Significant Deficiency

Student Financial Assistance Cluster - Assistance Listing No. 84.063, 84.268 Recommendation: We recommend the University evaluate its policies and procedures around reporting student status changes to the NSLDS to ensure that all relevant information is being captured and reported timely in accordan...

Student Financial Assistance Cluster - Assistance Listing No. 84.063, 84.268 Recommendation: We recommend the University evaluate its policies and procedures around reporting student status changes to the NSLDS to ensure that all relevant information is being captured and reported timely in accordance with applicable regulations. Explanation of disagreement with audit finding: There is no disagreement with the audit finding . Action taken in response to finding : Like many US institutions, La Salle contractually relies on the National Student Clearinghouse (NSC) to conduct its enrollment reporting to NSLDS. In order to comply with established regulations, we set up an Enrollment Reporting Submission Schedule with the NSC. La Salle's schedule for 2025 is below: Term Begin Date Term End Date Transmission Type : Schedule Transmission Date Received Date Transmission Status 1/ 13/ 2025 5/ 9/ 2025 F rst of Term 1/ 31/ 2025 1/ 31 /2 25 Edtts Comp eted 1/13/ 2025 5/9/2025 Subsequent of - erm 2/ 17/ 2025 Not Yet Rece ed 1/ 13/ 2025 5/ 9/ 2025 Subsequent of Term 3/ 17/ 2025 Not Yet Rece'ved 1/ 13/ 2025 5/ 9/ 2 25 Subsequent of-erm t./ 15/ 2025 Not Yet Rece'ved 1/ 13/ 2025 5_/9/ 2025 Subsequent of -e,m 5/ 20/ 2025 Not Yet Rece v ed 5/ 19/ 2025 8/ 22/ 2025 Sumr,er F,r;.: 6/ 3/ 2025 Not Yet Rece ved 5/ 19/ 2025 8/ 22/2025 Summer Subsequent 7/ 9/ 2025 Not Yet Recewed 5/ 19/ 2025 8/ 22/ 2025 Sumr,er Subsequent 8/ 13/ 2025 Not Yet Recev ed 8/ 25/ 2025 12/ 13/2025 F rst of Terr, 9/ 23/ 2025 Not Yet Rece'ved 8/ 25/ 2025 12/13/ 2025 Subsequent of Term 10/ 28/ 2025 Not Yet ReceiVed 8/ 25 / 2025 12/ 13/ 2::>25 Subsequent of-erm 11/ 15/ 2025 Not Yet Rece·ved 8/ 25/ 2025 12/ 13/ 2025 Subsequent of-erM 12/16/ 2025 Not vet Receved Adherence to this reporting schedule would ensure timely reporting, as the NSC subsequently transmits data monthly to NSLDS, throughout the academic year, well within the requirement to report student enrollment status at least every 60 days. Our Associate Registrar for Academic Information Systems is specifically charged with maintaining, executing, and adhering to this schedule, as part of the routine duties assigned to that position in our office. Regarding accuracy, data structures are defined in our BANNER database to classify a given student's enrollment status in a given semester as full, three-quarter, half, or less-than-half time, and withdrawn. Those structures are long-established by student level (graduate, undergrad, doctoral), and do not change from semester to semester. BANNER processes extract the registration data and its timing, in light of those definitions and the data is formatted for transmission to the NSC as prescribed. Sound data entry practices have been established to make certain dates associated with those statuses, and the transition of a student within them, are accurately recorded. Consequently, we rely on the BANNER NSC extract, and the NSC's reporting relationship with NSLDS to accurately transmit that data accordingly. The NSC does work with us to rectify or resolve any seemingly inconsistent or incorrect data, based on prior transmissions and current regulations, prior to committing the given enrollment extract to the NSC database for our institution. They help us stay in compliance and consistent on both the campus-level and program-level basis upon which we're required to report. Name(s) of the contact person(s) responsible for corrective action: Gerard Donahue, Registrar Planned completion date for corrective action plan: Corrected as of Fall 2024

View Audit 344109

Finding 524672 (2024-001)

Significant Deficiency 2024

La Salle University

PA

Student Financial Aid Significant Deficiency Internal Control / Segregation of Duties

Student Financial Assistance Cluster - Assistance Listing No. 84.007, 84.033, 84.038, 84.063, 84.268 Recommendation: We recommend the University evaluate its procedures and review policies in overseeing student credit balances to ensure that any credit balances as a result of Title IV aid are return...

Student Financial Assistance Cluster - Assistance Listing No. 84.007, 84.033, 84.038, 84.063, 84.268 Recommendation: We recommend the University evaluate its procedures and review policies in overseeing student credit balances to ensure that any credit balances as a result of Title IV aid are returned within the required timeframe. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: In order to ensure that there is not an instance where a student does not receive their credit balance within the required 14-day window, the disbursement scheduled has been re-configured to ensure that there are no automatic disbursements running overnight the week leading up to a university and/or federal holiday. A new financial operations team has been created within the student financial services structure to ensure that processes are running smoothly and that systems between both financial aid and the finance office are effectively communicating with each other. Name(s) of the contact person(s) responsible for corrective action: Michele McDevitt, Assistant Vice President for Student Financial Services Planned completion date for corrective action plan: Corrected as of Fall 2024.

View Audit 344109

Finding 524671 (2024-001)

Significant Deficiency 2024

Selma Housing Authority

NC

Eligibility HUD Housing Programs Reporting

Finding 2024-001 Name of Contact Person: Melody Wilkins Executive Director Corrective Action: We will implement proper internal control procedures for the Public and Indian Housing program eligibility requirements. Proposed Completion Date: Immediately

View Audit 344104

Finding 524659 (2024-001)

Material Weakness 2024

University of Southern Indiana

IN

Student Financial Aid Internal Control / Segregation of Duties Matching / Level of Effort / Earmarking § 200.303

FINDING 2024-001 Finding Subject: Student Financial Assistance Cluster - Special Tests and Provisions - Verification Summary of Finding: The University had designed a key control that one employee would perform the required verifications, and a second employee would then review a sample of those ver...

FINDING 2024-001 Finding Subject: Student Financial Assistance Cluster - Special Tests and Provisions - Verification Summary of Finding: The University had designed a key control that one employee would perform the required verifications, and a second employee would then review a sample of those verifications. However, the control was not properly implemented or operating effectively as the University had not established proper segregation of duties. The same employee was responsible for performing and reviewing verifications during the audit period without an independent oversight, review, or approval process involving a second employee. Contact Person Responsible for Corrective Action: Joanna Riney, Director of Student Financial Assistance Contact Phone Number and Email Address: 812-465-7049; jriney@usi.edu Views of Responsible Officials: We concur with the finding. While the University of Southern Indiana had internal controls in place to prevent aid from disbursing before verification was marked complete and assigned responsibility for verification processing to a well-trained employee with 20 years of verification processing experience, staff vacancies in the department in addition to training and preparation for vast changes in application, award calculation, and system controls for the 2024-2025 aid year limited the ability to conduct an independent review on a sample of students for which verification had been performed. Given the fact that there were very minimal changes to the verification process from the verification process performed in the last several years, in lieu of an independent review, management determined that for the 2023-2024 aid year, utilizing an after-the-fact review on a sample of completed verifications by the employee performing the verification, to review/double-check the verification procedures, provided reasonable assurance that compliance would be achieved. No instances of non-compliance in verification procedures were detected in the audit. Description of Corrective Action Plan: Staffing levels are returning to normal and new staff have a more complete understanding of overall financial aid including the verification process. Also, the Department of Education has provided additional clarification and guidance for all 2024-2025 processing and reduced the number of students selected for verification, allowing management the ability to resume the performance of an independent review on a sample of students for which verification had been performed. Anticipated Completion Date: The independent review was reinstated effective for verifications performed in Fall 2024 and going forward.Per Uniform Guidance: 2 CFR § 200.511(a) – “The auditee is responsible for follow-up and corrective action on all audit findings. . .The auditee must also prepare a corrective action plan for current year audit findings. . .􀀃The corrective action plan and summary schedule of prior audit findings must include findings relating to the financial statements which are required to be reported in accordance with GAGAS. ” 2 CFR § 200.511(c) – “At the completion of the audit, the auditee must prepare, in a document separate from the auditor's findings described in § 200.516, a corrective action plan to address each audit finding included in the current year auditor's reports. The corrective action plan must provide the name(s) of the contact person(s) responsible for corrective action, the corrective action planned, and the anticipated completion date. If the auditee does not agree with the audit findings or believes corrective action is not required, then the corrective action plan must include an explanation and specific reasons.”

View Audit 344100

Finding 524649 (2024-007)

Significant Deficiency 2024

Eureka College

IL

Student Financial Aid Special Tests & Provisions Significant Deficiency

2024-007 - Student Financial Aid Cluster - (a) Federal Pell Grant (b) Federal Supplemental Educational Opportunity Grant (c) Federal Work Study Grant (d) Federal Perkins Loan Program (e) Federal Direct Student Loans (f) Teacher education Assistance for College and Higher Education ALN No. (a) 84.063...

2024-007 - Student Financial Aid Cluster - (a) Federal Pell Grant (b) Federal Supplemental Educational Opportunity Grant (c) Federal Work Study Grant (d) Federal Perkins Loan Program (e) Federal Direct Student Loans (f) Teacher education Assistance for College and Higher Education ALN No. (a) 84.063 (b) 84.007 (c) 84.033 (d) 84.038 (e) 84.268 (f) 84.379 - Year Ended June 30, 2024. Condition: The College did not complete monthly reconciliations for Direct Loan funds. We consider this condition to be a significant deficiency in internal control over compliance relating to the Special Tests and Provisions compliance requirement. Management Response: Management agrees with the finding Corrective Action Plan: JFA deletes prior reconciliation reports. Separate file location on the cloud has been created to hold these monthly reconciliation files. Corresponding reconciliation within Sonis (see above corrective action plan for excess cash) will also occur. Responsible Person: Tim Marten and Beth Collingwood Implementation Date: 7/01/2024

View Audit 344088

Finding 524638 (2024-002)

Significant Deficiency 2024

Eureka College

IL

Student Financial Aid Special Tests & Provisions Significant Deficiency

2024-002 - Student Financial Aid Cluster - (a) Federal Pell Grant (b) Federal Supplemental Educational Opportunity Grant (c) Federal Work Study Grant (d) Federal Perkins Loan Program (e) Federal Direct Student Loans (f) Teacher education Assistance for College and Higher Education ALN No. (a) 84.063...

2024-002 - Student Financial Aid Cluster - (a) Federal Pell Grant (b) Federal Supplemental Educational Opportunity Grant (c) Federal Work Study Grant (d) Federal Perkins Loan Program (e) Federal Direct Student Loans (f) Teacher education Assistance for College and Higher Education ALN No. (a) 84.063 (b) 84.007 (c) 84.033 (d) 84.038 (e) 84.268 (f) 84.379 - Year Ended June 30, 2024. Condition: The College did not report actual loan disbursement dates to the COD system for 4 of 40 students in the sample (10%). We consider this condition to be a significant deficiency of internal control over compliance relating to the Special Tests and Provisions compliance and is part a repeat finding shown in Section IV of this report as prior year finding 2023-003. Statistical sampling was not used in making sample selections. Management Response: Management agrees with the finding Corrective Action Plan: Implementation of a newer process based on the system and program defaults in Jenzabar Financial Aid. Will use posted dates in Sonis to ensure they match COD within the 3-day regulatory requirement. New reporting usages of SAS loan files will be checked in Sonis to ensure matching disbursement dates. Responsible Person: Tim Marten and Beth Collingwood Implementation Date: 7/01/2024

View Audit 344088

Finding 524609 (2024-003)

Significant Deficiency 2024

Marymount University

VA

Student Financial Aid Matching / Level of Effort / Earmarking Internal Control / Segregation of Duties

Student Financial Aid Cluster – Assistance Listing Numbers 84.007, 84.033, 84.038, 84.063, and 84.268 Recommendation: We recommend the University review its reporting procedures to ensure that enrollment and program information is accurately reported to NSLDS as required by regulations. Explanatio...

Student Financial Aid Cluster – Assistance Listing Numbers 84.007, 84.033, 84.038, 84.063, and 84.268 Recommendation: We recommend the University review its reporting procedures to ensure that enrollment and program information is accurately reported to NSLDS as required by regulations. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The findings stemmed from how the Student Information System (SIS) transmitted graduation dates and the accuracy of submission files. Our previous SIS was unable to determine the correct graduation dates, leading to incorrect data uploads to the National Student Clearinghouse (NSC). We reviewed the NSC error report and made individual corrections. Unfortunately, we missed the data transmission at the beginning of the month and had to wait for the corrections to be sent to the National Student Loan Data System (NSLDS) the following month. Additionally, we did not conduct a comprehensive review of the file to ensure that all data matched after the upload. Marymount has transitioned to a new SIS starting in Fall 2024. We are working closely with the NSC during this transition to provide more timely and accurate data. We have also improved our processes by having multiple staff members review data files before posting them to the NSC, ensuring that every data point is correct. Furthermore, we have joined user groups related to our SIS and NSC reports to stay informed about changes made by the SIS vendor and to be aware of potential complications faced by other universities. Any errors identified during the data upload to the NSC will be corrected within 2-3 business days. This process will ensure that the enrollment status is certified within 60 days and that all dates match. If we are unable to update the NSC before the file is submitted to the NSLDS, we will collaborate with our Financial Aid department to manually update the NSLDS. Name(s) of the contact person(s) responsible for corrective action: Courtney Carey, University Registrar, 703-284-1523 Planned completion date for corrective action plan: March 2025

View Audit 344056

Finding 524601 (2024-005)

Significant Deficiency 2024

Vance County

NC

Eligibility Internal Control / Segregation of Duties

Corrective Action Plan For the Year Ended June 30, 2024 Finding 2024-005 Name of contact person: Corrective Action: Proposed Completion Date: Finding 2024-006 Name of contact person: Corrective Action: Proposed Completion Date: Finding 2024-007 Name of contact person: Corrective Action: Proposed Com...

Corrective Action Plan For the Year Ended June 30, 2024 Finding 2024-005 Name of contact person: Corrective Action: Proposed Completion Date: Finding 2024-006 Name of contact person: Corrective Action: Proposed Completion Date: Finding 2024-007 Name of contact person: Corrective Action: Proposed Completion Date: Review of Verifications needed for Adult cases to determine eligibility correctly will be presented by supervisor to ensure workers know what verifications are needed at time of review or application. Documentation standards will be implemented to ensure workers are applying the correct documentation to the case. For the untimely reviews, Magi and Traditional Recertification Recertification Job Aid will be discussed. Acceptable timeframes and processing times will be discussed. Magi pending recertification details report and traditional recertification details report will be reviewed with staff. 1/31/2025 Section III - Federal Award Findings and Question Costs (continued) 1/31/2025 Ebony Mitchell, Medicaid Program Manager Ebony Mitchell, Medicaid Program Manager Ebony Mitchell, Medicaid Program Manager Review of Adult Policy section 2230 (Financial resources) and acknowledgement required with signature. 1/31/2025 NC Fast Learning gateway (Magi Budgeting: Income Determination) training. Review of family and children’s Medicaid policy section MA – 3300 Income and MA – 3306 Modified adjusted gross income (MAGI). Review of Adult Medicaid income policy section MA – 2250 Income. 145

View Audit 344037

Finding 524564 (2024-001)

Significant Deficiency 2024

The Chicago School-Cal INC Dba the Chicago Sch of Pro Psychology

IL

Student Financial Aid Cash Management Matching / Level of Effort / Earmarking § 200.303

Corrective Action Plan – The Chicago School Identifying Number: 2024-001 Finding: Excess Cash – Student Financial Aid Applicable Regulation: According to Uniform Grant Guidance (34 CFR 668.166), the Secretary considers excess cash to be any amount of Title IV, HEA program funds, other than Federa...

Corrective Action Plan – The Chicago School Identifying Number: 2024-001 Finding: Excess Cash – Student Financial Aid Applicable Regulation: According to Uniform Grant Guidance (34 CFR 668.166), the Secretary considers excess cash to be any amount of Title IV, HEA program funds, other than Federal Perkins Loan program funds, that an institution does not disburse to students within the required timeframe. Institutions must return any amount of excess cash over the one-percent tolerance and any remaining cash after the seven-day tolerance period. Finding: The College had excess cash for the Federal Direct Student Loan program, ranging from $528,450 to $1,238,306, from November 13, 2023, to December 18, 2023. While the excess cash did not exceed the one-percent tolerance of prior year drawdowns, the amounts were not returned within the seven-day period as required. Summary: The College draws a portion of funds for student stipends while award reconciliation is in progress to ensure timely disbursement. An administrative oversight led to excess cash being held longer than allowed. Specifically, the prior stipend drawdown was not netted out when calculating subsequent fund requests, resulting in excess cash being held for 24 business days. Corrective Action Planned or Taken: 1. Procedure Update: The College has updated its cash management procedures to ensure compliance with the seven-day return requirement. 2. Process Change: Going forward, the College will refrain from drawing funds for student stipends until reconciliations have been fully completed. This will ensure that funds are drawn in alignment with actual disbursement needs, reducing the risk of excess cash. 3. Internal Control Strengthening: The College will enhance internal controls around cash management to ensure that excess cash instances are identified and corrected promptly. 4. Staff Training: All relevant staff will undergo training on revised cash management procedures and the importance of timely reconciliation and returns. 5. Improved Monitoring: The College will implement a more robust monitoring process to track excess cash and ensure compliance with Federal regulations, including daily checks during peak disbursement periods. Contact Person: Theresa Cowan, Associate Vice President, Compliance and Student Finance tcowan@tcsedsystem.edu Anticipated Completion Date: December 16, 2024

View Audit 343996

Finding 524524 (2024-004)

Significant Deficiency 2024

Cornish College of the Arts and Cornish Foundation

WA

Student Financial Aid Reporting Significant Deficiency

Student Financial Assistance Cluster – Assistance Listing No. Various Recommendation: We recommend the University review its reporting procedures to ensure the students’ statuses are accurately and timely reported to NSLDS as required by regulations. Explanation of disagreement with audit finding:...

Student Financial Assistance Cluster – Assistance Listing No. Various Recommendation: We recommend the University review its reporting procedures to ensure the students’ statuses are accurately and timely reported to NSLDS as required by regulations. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: • Fully implement and utilize existing reporting functionality in Jenzabar for National Student Clearinghouse • Review existing reporting procedures and process configurations for NSC reporting in Jenzabar to ensure that things are working correctly and being reported in a timely manner • Document the full process internally in the Registration and Records department Name(s) of the contact person(s) responsible for corrective action: Chris Cook, Registrar Planned completion date for corrective action plan: January 31, 2025

View Audit 343891

Finding 524519 (2024-003)

Significant Deficiency 2024

Cornish College of the Arts and Cornish Foundation

WA

Significant Deficiency Internal Control / Segregation of Duties

Student Financial Assistance Cluster – Assistance Listing No. Various Recommendation: We recommend that the College review the updated GLBA requirements and ensure their WISP includes all required elements. Explanation of disagreement with audit finding: There is no disagreement with the audit fin...

Student Financial Assistance Cluster – Assistance Listing No. Various Recommendation: We recommend that the College review the updated GLBA requirements and ensure their WISP includes all required elements. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The College is reviewing the updated GLBA requirements and updating the WISP to ensure it includes all of the required elements. Name(s) of the contact person(s) responsible for corrective action: Justin Sin, IT Director Planned completion date for corrective action plan: May 31, 2025

View Audit 343891

Finding 524514 (2024-002)

Significant Deficiency 2024

Cornish College of the Arts and Cornish Foundation

WA

Student Financial Aid Significant Deficiency Matching / Level of Effort / Earmarking

Student Financial Assistance Cluster – Assistance Listing No. Various Recommendation: We recommend that the College review their records to locate the missing promissory notes. If the signed promissory notes can’t be located, the College should assess if there is sufficient documentation to support...

Student Financial Assistance Cluster – Assistance Listing No. Various Recommendation: We recommend that the College review their records to locate the missing promissory notes. If the signed promissory notes can’t be located, the College should assess if there is sufficient documentation to support the loan such as repayment history, documentation showing the original payment was accepted by the student, etc. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Subsequent to the audit testing, all Perkins loan MPNs were located and the College is finalizing its assignment of the loans to the Department of Education. Name(s) of the contact person(s) responsible for corrective action: Cheryl Wynne, Interim CFO and Grant Drinnen, Cash and Accounts Receivable Specialist Planned completion date for corrective action plan: January 31, 2025

View Audit 343891

Finding 524509 (2024-001)

Significant Deficiency 2024

Cornish College of the Arts and Cornish Foundation

WA

Questioned Costs Student Financial Aid Significant Deficiency

Student Financial Assistance Cluster – Assistance Listing No. Various Recommendation: We recommend that the College review its procedures related to outstanding student refund checks to ensure they are being returned to the Department of Education after 240 days. Explanation of disagreement with a...

Student Financial Assistance Cluster – Assistance Listing No. Various Recommendation: We recommend that the College review its procedures related to outstanding student refund checks to ensure they are being returned to the Department of Education after 240 days. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The College has reviewed and updated its procedures related to the process of reviewing and remitting unclaimed student refund checks. Name(s) of the contact person(s) responsible for corrective action: Cheryl Wynne, Interim CFO Planned completion date for corrective action plan: January 31, 2025

View Audit 343891 Questioned Costs: $1

Finding 524497 (2024-001)

Material Weakness 2024

Franklin Community School Corporation

IN

Internal Control / Segregation of Duties Subrecipient Monitoring Material Weakness § 200.303

FINDING 2024-001 Finding Subject: COVID-19 - Education Stabilization Fund - Reporting Summary of Finding: The School Corporation had not designed, nor implemented a system of internal controls, to ensure the annual Elementary and Secondary School Emergency Relief (ESSER) annual Data Collection repor...

FINDING 2024-001 Finding Subject: COVID-19 - Education Stabilization Fund - Reporting Summary of Finding: The School Corporation had not designed, nor implemented a system of internal controls, to ensure the annual Elementary and Secondary School Emergency Relief (ESSER) annual Data Collection reports (Reports) were complete and accurately submitted. The School Corporation Reports were reviewed by the Assistant Deputy Treasurer and submitted by the Chief Financial Officer; however, there was no documentation provided to verify that the oversight or review process to prevent, or detect and correct, errors were performed during the audit period. The State Board of Accounts recommends that the School Corporation’s management establish a system of internal controls related to the federal award and the Reporting compliance requirement which includes documentation of the operation of the controls. Contact Person Responsible for Corrective Action: Camilla Hoffman, Assistant Deputy Treasurer Contact Phone Number and Email Address: hoffmanca@franklinschools.org, 317-346-8748 Views of Responsible Officials: We concur with the finding, but we would like to emphasize that the review had been implemented. It just was not documented by the reviewer. Description of Corrective Action Plan: The Assistant Deputy Treasurer will begin documenting her review of the required ESSER reporting via email, so that this review can be verified by auditors or other inquirers. Anticipated Completion Date: This corrective action will be added to the district’s procedures immediately, but ESSER reporting is not anticipated until later in the Spring 2025.

View Audit 343871

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