Corrective Action Plans

Finding 371249 (2023-002)

Significant Deficiency 2023

IA

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

Title: Student Financial Assistance Cluster – Assistance Listing Nos. 84.038, 84.268, 84.033, 84.007, 84.063, 93.264 Recommendation: The University should ensure all necessary employees receive proper training, support, and time to follow the University's policies and federal requirements related to...

Title: Student Financial Assistance Cluster – Assistance Listing Nos. 84.038, 84.268, 84.033, 84.007, 84.063, 93.264 Recommendation: The University should ensure all necessary employees receive proper training, support, and time to follow the University's policies and federal requirements related to monthly reconciliations. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: A policy has been implemented to have a review of reconciliations. The Director of Financial Aid will perform the reconciliations and the Assistant Director of Financial Aid will review and approve the reconciliation. Name(s) of the contact person(s) responsible for corrective action: Mark Freed Planned completion date for corrective action plan: June 30, 2023

View Audit 292961

Finding 371248 (2023-001)

Significant Deficiency 2023

Mount Mercy University

IA

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

2023-001 Title: Student Financial Assistance Cluster – Assistance Listing Nos. 84.038, 84.268, 84.033, 84.007, 84.063, 93.264 Recommendation: We recommend the University implement a procedure moving forward to ensure that all necessary MPN’s are retained for at least 3 years after payment in accorda...

2023-001 Title: Student Financial Assistance Cluster – Assistance Listing Nos. 84.038, 84.268, 84.033, 84.007, 84.063, 93.264 Recommendation: We recommend the University implement a procedure moving forward to ensure that all necessary MPN’s are retained for at least 3 years after payment in accordance with the federal regulation. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The missing Perkins MPNs were from loans that were over 25 years old. I have ensured that our remaining Perkins Loans have MPNs and will be retained for the 3 year period after a loan is paid in full. Name(s) of the contact person(s) responsible for corrective action: Mark Freed Planned completion date for corrective action plan: June 30, 2023

View Audit 292961

Finding 371241 (2023-002)

Significant Deficiency 2023

Milwaukee Institute of Art and Design, Inc.

WI

Special Tests & Provisions Subrecipient Monitoring Significant Deficiency

Corrective Action Plan For the Year Ended May 31, 2023 Finding 2023-002 Assistance Listing Number(s), Federal Agency and Program Name: 84.063, 84.007, 84.033, and 84.268; United States Department of Education (DOE), Student financial assistance cluster. Finding Type: Noncompliance and significant de...

Corrective Action Plan For the Year Ended May 31, 2023 Finding 2023-002 Assistance Listing Number(s), Federal Agency and Program Name: 84.063, 84.007, 84.033, and 84.268; United States Department of Education (DOE), Student financial assistance cluster. Finding Type: Noncompliance and significant deficiency in control over compliance relating to special tests. Criteria: The Institute is responsible for designing, implementing, and maintaining internal control over compliance for special tests and provisions and for safeguarding sensitive data under the Gramm-Leach-Bliley Act, including performing an annual risk assessment that addresses three required areas noted in 16 Code of Federal Regulations (CFR) 314.4 (b). Statement of Condition: The Institute performed a risk assessment however the safeguards for the risks identified were not formally documented through a policy. A formal policy was not reviewed in fiscal year 2023 which would have addressed required areas noted in 16 CFR 314.4 (b). Questioned Costs: Questioned costs could not be determined. Context: A policy and documentation linking the safeguards to the risk assessment was not formally written. The internal controls over compliance at the Institute did not identify the noncompliance. However, the Institute performed risk assessments and has appropriate safeguards for each area identified within 16 CFR 314.4(b). Cause: The Institute did not have internal controls in place to identify the need for the policy documenting the safeguards required by the Gramm-Leach-Bliley Act. Effect: The Institute has no verifiable evidence of the policy and the related safeguards for each risk identified. Recommendation: We recommend management review 16 CFR 314.4 (b) to create a policy that addresses the three required areas, which are (1) employee training and management; (2) information systems, including network and software design, as well as information processing, storage, transmission and disposal; and (3) detecting, preventing and responding to attacks, intrusions, or other systems failures. This policy should be formalized and reviewed annually. We recommend that the Institute document the approval and acceptance of the policy. In addition, we recommend management review internal control processes for special tests and provisions on an annual basis. Status: In progress, anticipated completion September 2024 Corrective Action: Management agrees with the finding. We are currently developing a comprehensive cybersecurity policy to address 16 CFR 314.4 (b), which will be formalized, approved by Senior Staff, and reviewed annually. We are now conducting annual penetration tests, the most recent in December 2023, to address internal control processes. We have contracted with a planning team at CDW to determine best practices and perform training. We have begun providing a quarterly GLBA Compliance update to our board, with an annual comprehensive GLBA review to the board. Contact Matt Ogden Director of Technology 414.847.3223 mattogden@miad.edu Submitted Feb 23, 2024

View Audit 292954

Finding 371211 (2023-003)

Significant Deficiency 2023

Minneapolis College of Art and Design

MN

Student Financial Aid Reporting Matching / Level of Effort / Earmarking

Corrective Action Planned: The third-party service provider was unable to send accurate reports to the college during FY23. The college has terminated its relationship with the previous service provider effective 1/31/2024 and is conducting a final reconciliation with the new agency. Once the final ...

Corrective Action Planned: The third-party service provider was unable to send accurate reports to the college during FY23. The college has terminated its relationship with the previous service provider effective 1/31/2024 and is conducting a final reconciliation with the new agency. Once the final reconciliation has been completed, the college will submit official corrections to the FISAP with the Department of Education. This should enable the college to provide accurate and timely reporting going forward. Name(s) of Contact Person(s) Responsible for Corrective Action: Miguel Granger, Director of Student Accounts and Brian Braden, Controller. Anticipated Completion Date: March 15, 2024

View Audit 292916

Finding 371196 (2023-002)

Material Weakness 2023

Alamance County, North Carolina

NC

Eligibility Material Weakness Internal Control / Segregation of Duties

Name of Contact Person: Candice Gobble, DSS Director Corrective Action/Management’s Response: Management concurs with this finding. Caseworkers will be reminded of appropriate signatures needed within the application process. Training and refresher training on voice and telephonic signatures will be...

Name of Contact Person: Candice Gobble, DSS Director Corrective Action/Management’s Response: Management concurs with this finding. Caseworkers will be reminded of appropriate signatures needed within the application process. Training and refresher training on voice and telephonic signatures will be provided to Energy staff. Supervisors and/or Quality Assurance staff will continue to perform monthly second party reviews. Emphasis will be placed on forms requiring applicant signatures to ensure all signatures are secured and documented accordingly. Proposed Completion Date: The above procedures are currently in place and will be monitored on an ongoing basis.

View Audit 292883

Finding 371195 (2023-001)

Material Weakness 2023

Alamance County, North Carolina

NC

Eligibility Material Weakness Internal Control / Segregation of Duties

Name of Contact Person: Candice Gobble, DSS Director Corrective Action/Management’s Response: Management concurs with this finding. Caseworkers will be reminded of appropriate documentation techniques and when IV-D referrals are necessary within the eligibility determination process. Supervisors and...

Name of Contact Person: Candice Gobble, DSS Director Corrective Action/Management’s Response: Management concurs with this finding. Caseworkers will be reminded of appropriate documentation techniques and when IV-D referrals are necessary within the eligibility determination process. Supervisors and/or Quality Assurance staff will continue to perform monthly second party reviews. Emphasis will be placed on documentation and IV-D referrals to ensure compliance with NC Medicaid policy. Proposed Completion Date: The above procedures are currently in place and will be monitored on an ongoing basis.

View Audit 292883

Finding 371194 (2023-007)

Significant Deficiency 2023

Granville County, North Carolina

NC

Eligibility Matching / Level of Effort / Earmarking Internal Control / Segregation of Duties

Caseworkers are to review and verify income and deductions by policy standards. Food and Nutrition Lead workers and Supervisor will conduct second-party reviews on caseworkers. The Food and Nutrition Supervisor will go over errors found by second parties during their team's monthly meetings. The sup...

Caseworkers are to review and verify income and deductions by policy standards. Food and Nutrition Lead workers and Supervisor will conduct second-party reviews on caseworkers. The Food and Nutrition Supervisor will go over errors found by second parties during their team's monthly meetings. The supervisor will hold individual performance meetings if cited for the same error. Lead Workers and Supervisor will conduct 100% second parties on caseworkers in their probationary period of 6 months unless extended by Supervisor due to performance and 4 for applications workers and 3 for redeterminations workers per month. The supervisor and lead workers will also ensure that caseworkers are up to date on changes that may come up and ensure that they give proper instruction when needed. Supervisor and/or Lead workers will conduct monthly meetings which include mini trainings on errors found in second parties. Refresher training will be held quarterly and annually for in-depth training regarding policy areas in which the Supervisor and lead workers identify the need for. The Human Service Planner Evaluator will help track of repetitive errors and suggest training needed to the Supervisor to ensure that policy/procedures are being implemented accordingly. The supervisor will schedule and hold a meeting each month to inform Program Administrator, Heather Hayes, of the errors found on second-party findings and provide a copy of the individual’s performance meeting held with the worker on any repetitive errors. Supervisor and or Lead workers will send training invite to Program Administrator, Staff Development Specialists, and Human Services Planner Evaluator monthly and at quarterly refresher trainings. To ensure that the caseworkers do not repeat these errors, the following will happen: policy training will be held on Food and Nutrition policy sections 340 Deductions, 310 Budgeting New/Change/Terminated Income, and 315 Special Budgeting Income on January 24, 2024.

View Audit 292856

Finding 371192 (2023-005)

Significant Deficiency 2023

Granville County, North Carolina

NC

Eligibility Reporting Internal Control / Segregation of Duties

Caseworkers are to review the determinations tab and policy manual to properly ensure that the case is showing correctly. Adult Medicaid Lead workers and Supervisor will conduct second-party reviews on caseworkers. Family and Children Medicaid Lead Workers and the Supervisors will conduct second-par...

Caseworkers are to review the determinations tab and policy manual to properly ensure that the case is showing correctly. Adult Medicaid Lead workers and Supervisor will conduct second-party reviews on caseworkers. Family and Children Medicaid Lead Workers and the Supervisors will conduct second-party reviews on caseworkers. Both Adult Medicaid and Family and Children Medicaid supervisors will go over errors found by second parties during their team monthly meetings. The supervisors will hold individual performance meetings if cited for the same error. Lead Workers and Supervisors will conduct 100% second parties on caseworkers in their probationary period of 6 months unless extended by Supervisors due to performance and 5 applications and redeterminations on all other caseworkers per month. The supervisors will also ensure that caseworkers are up to date on changes that may come up and ensure that they give proper instruction when needed. Supervisors and/or Leadworkers will conduct monthly meetings which including mini trainings on errors found in second parties. Refresher trainings will be held quarterly for indept training regarding policy areas in which the Supervisors identify the need for. The Human Service Planner Evaluator will help track of repetitive errors and suggest trainnings needed to Supervisors to ensure that policy/procedures are being implemmented accordingly. Supervisors will schedule and hold a meeting each month to inform Program Administrator of the errors found on second-party findings and provide a copy of the individual’s performance meeting held with the worker on any repetitive errors. Supervisors and or Lead workers will send training invite to Program Administrator, Staff Development Specialists, and Human Services Planner Evaluator for monthly and quarterly refresher trainings. To ensure that the caseworkers do not repeat these errors, the following will happen: policy training was held on Adult Medicaid section MA-2250 on November 29, 2022, DSS Terminial Message regarding Admin Letter 11-22 dated 12/12/2022 on COLA procedures was provided to Adult Medicaid team members on 12/12/2022. Meeting held regarding COLA income on 12/29/2022. Update meeting regarding the COLA increases will be held by December 31, 2023 when policy guidelines are provided by state. Family and Children Medicaid sections MA-3300 was held on November 30, 2022 regarding income. Meeting regarding Incorrect income will be held on by November 30, 2023.

View Audit 292856

Finding 371191 (2023-004)

Significant Deficiency 2023

Granville County, North Carolina

NC

Eligibility Internal Control / Segregation of Duties

Corrective Action: Proposed completion date: Finding 2023-005 Inaccurate Information Entry Name of contact person: Kim Grissom, Family and Children's Medicaid Supervisor, Shelia Morton, Family and Children's Medicaid Supervisor, and Vanness Taylor, Adult Medicaid Supervisor To ensure that the casewo...

Corrective Action: Proposed completion date: Finding 2023-005 Inaccurate Information Entry Name of contact person: Kim Grissom, Family and Children's Medicaid Supervisor, Shelia Morton, Family and Children's Medicaid Supervisor, and Vanness Taylor, Adult Medicaid Supervisor To ensure that the caseworkers do not repeat these errors, the following will happen: Adult Medicaid Documentation Templated was updated November 13, 2023. Training was held on July 6, 2023 for Recertifications for Adult Medicaid. Adult Meeting will be held on November 28, 2023. Family and Children held team meetings on November 30, 2022, January 26, 2023, and May 23, 2023. Family and Children meeting will be held by November 30th, 2023. State mandatory Training was held for all Medicaid Staff on July 25, 26, or 27, 2023 for Mastering Medicaid Policy , MAGI Recertifications and NCFAST 20020, and September 26, 27, or 28, 2023 Authorized Representatives and NCFAST 20020 Reminders. Adult Medicaid Lead workers and Supervisor will conduct second-party reviews on caseworkers. Family and Children Medicaid Lead Workers and the Supervisors will conduct second-party reviews on caseworkers. Both Adult Medicaid and Family and Children Medicaid supervisors will go over errors found by second parties during their team monthly meetings. The supervisors will hold individual performance meetings if cited for the same error. Lead Workers and Supervisor will conduct 100% second parties on caseworkers in their probationary period of 6 months unless extended by the Supervisor due to performance and 5 applications and redeterminations on all other caseworkers per month. The supervisor will also ensure that caseworkers are up to date on changes that may come up and ensure that they give proper instruction when needed. Supervisors and/or Leadworkers will conduct monthly meetings which including mini trainings on errors found in second parties. Refresher trainings will be held quarterly for indept training regarding policy areas in which the Supervisors identify the need for. The Human Service Planner Evaluator will help track of repetitive errors and suggest trainnings needed to Supervisors to ensure that policy/procedures are being implemmented accordingly. The Supervisors will schedule and hold a meeting to inform Program Administrator of the errors found on second-party findings and provide a copy of the individual’s performance meeting held with the worker on any repetitive errors. Supervisors and or Lead workers will send training invite to Program Administrator, Staff Development Specialists, and Human Services Planner Evaluator for monthly and quarterly refresher trainings.

View Audit 292856

Finding 371188 (2023-001)

Significant Deficiency 2023

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

IL

Special Tests & Provisions Matching / Level of Effort / Earmarking Internal Control / Segregation of Duties

Corrective Action Plan – The Chicago School Identifying Number: 2023-001 Finding: Special Tests and Provisions- Lack of Maintaining Verification Documents Applicable Regulation: Per 34 CFR 668.57, if an applicant is selected to verify information, an institution must obtain the specified documentati...

Corrective Action Plan – The Chicago School Identifying Number: 2023-001 Finding: Special Tests and Provisions- Lack of Maintaining Verification Documents Applicable Regulation: Per 34 CFR 668.57, if an applicant is selected to verify information, an institution must obtain the specified documentation. Finding: During testing of students selected for verification, for 1 out of 14 students selected for testing, the College could not provide the supporting verification documents. Summary: According to our records, after this student was selected by the Department of Education for verification, the student submitted the required verification worksheet (V4) on 8/22/22. The financial aid advisor that performed the verification left the College shortly after performing the verification and did not properly save and maintain the documents. On 8/25/23, staff reached out to the student via phone and email to retrieve a copy of the previously submitted V4 worksheet but did not receive a response. The advisor that originally verified the file is no longer employed by The Community Solution. Corrective Action Taken or Planned: On 7/1/23, the Financial Aid Training Department assumed the role and responsibilities of reviewing all financial aid files for accuracy. The department conducts reviews on a weekly basis with oversight provided by the Financial Aid Training Manager. As the result of each weekly audit, a report is compiled and provided to both financial aid leadership and staff. If there are any missing documents or errors found, these are tracked through to completion by the training department. Additionally, the Financial Aid team provides 1:1 training to staff if errors are uncovered during the weekly review. The error in question did not create any financial liabilities for the student or institution as the aid received was not need based. The institution informed RSM of this error and the corrective actions taken. Contact Person Lawrence McGhee, Associate Vice President of Financial Aid lawrencemcghee@tcsedsystem.edu Anticipated Completion Date July 1, 2023

View Audit 292844

Finding 371187 (2023-001)

Material Weakness 2023

Kansas Health Science Center, Inc.

IL

Questioned Costs Student Financial Aid Eligibility

Over Award Review and Correction Action Taken – Kansas Health Science Center (KHSC) Identifying Number: 2023-001 Finding: Eligibility – Determining Federal Direct Student Loan Awards Applicable Regulation: Per 34 CFR 686.203(b)(iii), in the case of a graduate or professional student for a period ...

Over Award Review and Correction Action Taken – Kansas Health Science Center (KHSC) Identifying Number: 2023-001 Finding: Eligibility – Determining Federal Direct Student Loan Awards Applicable Regulation: Per 34 CFR 686.203(b)(iii), in the case of a graduate or professional student for a period of enrollment beginning on or after July 1, 2012, the total amount the student may borrow for any academic year of study under the Direct Unsubsidized Loan program may not exceed $8,500. Per 34 CFR 685.203(c)(2)(v), the additional amount that a student described in paragraph (c)(1)(i) of this section may borrow under the Direct Unsubsidized Loan Program for any academic year of study may not exceed the following: in the case of a graduate or professional student, $12,000. Finding: During testing of eligibility, 7 out of 7 students selected for testing were over awarded Unsubsidized Federal Direct Loans. KHSC improperly awarded 61 out of 61 students Unsubsidized Federal Direct Loan in excess of the maximum amount for one academic year, amounting to [$4,445] per student, for a cumulative over award of [$271,146]. Summary: Prior to the commencement of the independent audit conducted for the fiscal year ended May 31, 2023, the institution discovered that it had over awarded Unsubsidized Federal Direct Loan funds to its students. Specifically, the institution awarded additional Unsubsidized Federal Direct Loan funds based on 12-month academic calendar instead of prorating the award based on a 10-month academic calendar. This error resulted in an over award of [$4,445] per student. The institution conducted a file review and refunded all amounts owed to the Federal Student Aid programs because of the file review. The institution also informed the auditor of this error. Corrective Action Taken or Planned: Once the above noted error was discovered, the institution conducted an audit of all student aid packages for students enrolled in the 2022-2023 academic year. It was determined that 61 current students had been over awarded by a net amount of $4,445, for a total of $271,146. Findings were compiled and a plan was created to return over awarded funds and communicate the error to students. The institution also consulted with the Department of Education to confirm its revised calculation was appropriate. The institution returned the funds between July 5-July 20, 2023. Further, the institution made students whole by forgiving any student balances that would have been paid by the over award amount. Emails were sent to all impacted students on July 3, 2023 notifying them of the error. The institution also subsequently notified students that any account balance that remained based on the reversal of the over award would be forgiven. Students who received an estimate financial aid award with the incorrect figures, but who had not yet received aid, were notified of the error and provided updated award information. To ensure this does not happen again the institution has updated their internal student finance audit to include a review of all aid eligibility in conjunction with the next year’s academic calendar for each class of students. Upon any determination that future aid should be prorated, calculation(s) will be completed and reviewed with leadership before implementation. An internal review and approval process will then be enacted and documented. The institution informed RSM of this error and the corrective actions taken. Contact Person Lawrence McGhee, Associate Vice President of Financial Aid, lawrencemcghee@tcsedsystem.edu Completion Date July 20, 2023

View Audit 292837 Questioned Costs: $1

Finding 371173 (2023-001)

Significant Deficiency 2023

Howard-Winneshiek Community School District

IA

Internal Control / Segregation of Duties

Management is cognizant of this limitation and will implement additional procedures where possible.

View Audit 292809

Finding 371164 (2023-001)

Material Weakness 2023

Detroit Public Schools Community District

MI

Allowable Costs / Cost Principles Internal Control / Segregation of Duties Subrecipient Monitoring § 200.303 § 200.430

Condition: The School District’s controls did not prevent or detect and correct, in a timely manner, an employee’s time being charged to the Special Education Cluster that did not have adequate documentation. Additionally, the School District’s controls did not prevent or detect and correct, in a ti...

Condition: The School District’s controls did not prevent or detect and correct, in a timely manner, an employee’s time being charged to the Special Education Cluster that did not have adequate documentation. Additionally, the School District’s controls did not prevent or detect and correct, in a timely manner, updates to an employee status upon termination for employees charged to the Special Education Cluster and the Education Stabilization Fund. Planned Corrective Action: The School District concurs with the audit finding. The District has worked to strengthen internal controls to eliminate errors. The District will review its internal controls and provide additional training to staff. The School District is in the process of filling a Project Manager role on the Payroll Team who will be responsible for reviewing employee terminations and identifying potential overpayments. Until the role is filled, the Senior Director of Payroll and CFO will review employee exits quarterly to identify any potential overpayments and move funds to the general fund. New procedures for employee exit were rolled out in July in an effort to improve timely exiting of employees. Contact person responsible for corrective action: Jeremy Vidito, Chief Financial Officer Anticipated Completion Date: June 30, 2024

View Audit 292791

Finding 371149 (2023-002)

Significant Deficiency 2023

La Salle University

PA

Reporting Student Financial Aid Significant Deficiency

Student Financial Assistance Cluster – Assistance Listing No. 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...

Student Financial Assistance Cluster – Assistance Listing No. 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: The University has evaluated its policies and procedures around reporting student status changes and will make the following changes to ensure proper data capture and timely reporting: Following the conclusion of a graduation cycle, the NSC Degree Verify extract will be verified via a cross-check with the BANNER ERP system information on degrees awarded to assure no one is missing or mis-reported. Further, the BANNER de-activation process (SHRDEGS) will be run for the proper semester parameters, so that the student record will reflect proper periods of activity and graduation for those who graduated. BANNER’s registration processor has been configured to update time status dynamically. No longer will there be any discrepancy between the status date in BANNER and the date reported to the NSC and subsequently to NSLDS. The NSC extract of enrollment data will be matched to a separate report of registered students for the given semester to assure that no one is being missed. Name(s) of the contact person(s) responsible for corrective action: Gerard J Donahue Planned completion date for corrective action plan: Completed and effective as of February 28, 2024

View Audit 292767

Finding 371148 (2023-003)

Significant Deficiency 2023

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 ...

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: The University will generate a master list of all prior students with Perkins Loans. That master list will track location of files/documentation and provide the tracking to have all files secured all in one properly secured location. Name(s) of the contact person(s) responsible for corrective action: Michele McDevitt Planned completion date for corrective action plan: In progress as of February 28, 2024. A complete master list of students who received Perkins loans will be cross checked against the student’s actual file contained in fire proof cabinets, verifying each student’s master promissory note is on site. This process will be completed no later than August 1, 2024. If the United State Department of Education has questions regarding this plan, please contact Michele McDevitt at mmartin@lasalle.edu or 215.951.1651

View Audit 292767

Finding 371143 (2023-001)

Significant Deficiency 2023

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 retur...

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: The University will evaluate the current refund process and make revisions to process to ensure any credit balances of Title IV aid are returned within the required timeframe. The university’s goals is to automate the refund process to reduce the chance of human error, and placing the refund process on a schedule to ensure refunds are processed within the appropriate window of time. Name(s) of the contact person(s) responsible for corrective action: Michele McDevitt Planned completion date for corrective action plan: September 9, 2024 – first rounds of Fall 2024 refunds

View Audit 292767

Finding 371142 (2023-001)

Significant Deficiency 2023

Our Lady of the Lake University of San Antonio

TX

Student Financial Aid Reporting Matching / Level of Effort / Earmarking

Our Lady of the Lake University of San Antonio FY 2023 Single Financial Audit Finding Response Corrective Action Plan – Reconciliation of COD Monthly School Account Statement Compliance Finding: The Department of Education’s (DoE) School Account Statement (SAS), downloaded electronically from the C...

Our Lady of the Lake University of San Antonio FY 2023 Single Financial Audit Finding Response Corrective Action Plan – Reconciliation of COD Monthly School Account Statement Compliance Finding: The Department of Education’s (DoE) School Account Statement (SAS), downloaded electronically from the Common Origination Destination (COD) website, was not being reconciling monthly as required by the Student Financial Aid/ Direct Loan Program. Criteria or Specific Requirement: Per the Student Financial Aid/ Direct Loan Program requirements with the DoE, every school is required to reconcile their SAS to their accounting system records at least monthly. This statement is issued to each participating school through the SAIG mailbox monthly. The auditors noted 34 CFR 685.102(b), 385.300(b), 685.301, and 303 as the compliance regulation. Cause of Noncompliance: It appears that the SAS was reconciled monthly per the compliance requirement in recent years, but with high turnover and periods of under-staffing in the Accounting department this procedure was changed to one that did not meet the above requirement. Although OLLU did regularly reconcile the accounting system records with reports from COD, it was not the official monthly SAS statement. OLLU’s modified procedures did not completely meet the compliance requirement but did offer some mitigating procedures. Institution Response: OLLU has already begun coordinating processes between its Accounting and Financial Aid departments to download the monthly SAS into the university’s system electronically, where Accounting will then reconcile the statement monthly as a part of its month-end close procedures. The Financial Aid Director will be responsible for ensuring that the statement is downloaded monthly as a part of the regular electronic data file transfer between OLLU and the Department of Education. The Senior Accountant in the Accounting department will generate the report in Colleague via the DRSS process and reconcile the SAS statement to cash records. The Director of Accounting and Reporting will review the reconciliation monthly.

View Audit 292763

Finding 371140 (2023-002)

Significant Deficiency 2023

Bradley University

IN

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

2023-002 Student Financial Assistance Cluster- Assistance Listing Number: 84.063, 84.268 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 w...

2023-002 Student Financial Assistance Cluster- Assistance Listing Number: 84.063, 84.268 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 finding. Action taken in response to finding: The Office of the Registrar will continue to submit enrollment data to the National Student Clearinghouse via the current schedule. The Office of the Registrar will investigate and resolve any errors returned by the National Student Clearinghouse. After the enrollment data is transferred from the NSC to NSLDS a University representative will review the data in NSLDS for any discrepancies including cross-checking graduation files and complete withdrawals. Any inconsistencies will be discussed and timely resolved by the applicable units and officially updated in NSLDS and NSC respectively. The University will keep track of any changes manually made within the NSLDS or NSC database by university representatives, so that the student information system, NSC, and NSLDS records are in-sync. Name of the contact person responsible for corrective action: Dennis Koch, Associate Vice President of Financial Services Planned completion date for corrective action plan: 3/15/2024 If the Department of Education has questions regarding this plan, please call Dennis Koch at 309-667-3119.

View Audit 292762

Finding 371135 (2023-001)

Significant Deficiency 2023

Bradley University

IN

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

2023-001 Student Financial Assistance Cluster- Assistance Listing Number: 84.007, 84.038, 84.063, 84.268, 84.379, 93.364 Recommendation: We recommend that the University review its procedures related to outstanding student refund checks to ensure they are being returned to the Department of Educatio...

2023-001 Student Financial Assistance Cluster- Assistance Listing Number: 84.007, 84.038, 84.063, 84.268, 84.379, 93.364 Recommendation: We recommend that the University 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 finding. Action taken in response to finding: The Financial Services Division of the University (FSD) has implemented a new process to better track the status of student refund checks. After the first week of the month, all outstanding checks from the prior month are investigated in order to identify student refund checks that were the result of Title IV funds (e.g. January outstanding checks are reviewed after the first week of February). A representative from FSD will contact the borrower within 45 days of the original issuance date via email to inform them that the check remains outstanding and provide them with the option to EFT the funds directly to the student or void the check and reduce the borrowing with the Department of Education. The original check will remain valid for the 90 days stated on the face of the check. After 90 days, no additional communication will be made to the borrower. The check will be voided and borrowing will be updated with the Department of Education after 90 days of the original issuance, but prior to the 240 days allowed by the Department of Education. In additional to establishing a process to handle any future refund checks, the University.is also in contact with the Department of Education to provide process clarity on how to return funds related to refund checks for years where the financial aid year has been closed. Name of the contact person responsible for corrective action: Mark Young, Assistant Controller Planned completion date for corrective action plan: 2/29/2024

View Audit 292762

Finding 371107 (2023-002)

Significant Deficiency 2023

Lincoln Christian University

IL

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

Student Financial Aid – Aid – 84.268 – Federal Direct Loan Program, 84.063 – Federal Pell Grant Program Recommendation: We recommend a secondary review be done by someone other than the SFA Director to ensure disbursements and verifications are completed accurately and timely. Explanation of disagre...

Student Financial Aid – Aid – 84.268 – Federal Direct Loan Program, 84.063 – Federal Pell Grant Program Recommendation: We recommend a secondary review be done by someone other than the SFA Director to ensure disbursements and verifications are completed accurately and timely. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Director of Financial Aid will notify the Vice President of Operations of disbursements and verifications, and the Vice President will complete a secondary review. As this is the final year in which Lincoln Christian University will have academic operations, we believe this corrective action to be sufficient for the remainder of the year. Name(s) of the contact person(s) responsible for corrective action: Nancy Siddens, Director of Financial Aid. Planned completion date for corrective action plan: November 1, 2023.

View Audit 292743

Finding 371103 (2023-001)

Significant Deficiency 2023

Lincoln Christian University

IL

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

Student Financial Aid – 84.268 – Federal Direct Loan Program, 84.063 – Federal Pell Grant Program, 84.007 – Federal Supplemental Educational Opportunity Grant Program, 84.033 – Federal Work-Study Program Recommendation: We recommend the review process for awarding be documented and retained as suppo...

Student Financial Aid – 84.268 – Federal Direct Loan Program, 84.063 – Federal Pell Grant Program, 84.007 – Federal Supplemental Educational Opportunity Grant Program, 84.033 – Federal Work-Study Program Recommendation: We recommend the review process for awarding be documented and retained as support for the review and approval process. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Director of Financial Aid will document each change to an award by printing a new award offer and saving to document tracking. As this is the final year in which Lincoln Christian University will have academic operations, we believe this corrective action to be sufficient for the remainder of the year. Name(s) of the contact person(s) responsible for corrective action: Nancy Siddens, Director of Financial Aid. Planned completion date for corrective action plan: November 1, 2023.

View Audit 292743

Finding 371100 (2023-001)

Material Weakness 2023

Umatilla Morrow Head Start, Inc.

OR

Internal Control / Segregation of Duties Material Weakness Reporting § 200.302

Reconciliations and Material Adjustments Corrective Action Plan Umatilla Morrow Head Start, Inc. (UMHS, Inc.) partnered with an independent accounting firm to streamline processes and develop templates for year-end closure. The agency used this opportunity to increase knowledge and understanding o...

Reconciliations and Material Adjustments Corrective Action Plan Umatilla Morrow Head Start, Inc. (UMHS, Inc.) partnered with an independent accounting firm to streamline processes and develop templates for year-end closure. The agency used this opportunity to increase knowledge and understanding of needs associated with this task. As the fiscal department moves forward, systems and tools have been implemented to ensure timely closing and accurate tracking of this process. UMHS will continue to utilize the checklists put in place last fiscal year to guide month-end processes and reconciliations. Fiscal Management will review, monthly, the completion of said duties and will address any issues with staff immediately. Ongoing training will be done to ensure all fiscal staff members understand their role and duties within the agency. Bank reconciliations will continue to be completed monthly. The Executive Director, Director of Finance, Treasurer of the Board of Directors, or Other Designee will review the information and approval will be documented. UMHS will focus on segregation of duties within the fiscal department and ensure proper documentation is maintained. Person(s) Responsible: Executive Director, Director of Finance, Treasurer of the Board of Directors, or Other Designee Timing for Implementation: Immediately and Ongoing Reconciliations and Material Adjustments Corrective Action Plan Umatilla Morrow Head Start, Inc. (UMHS, Inc.) partnered with an independent accounting firm to streamline processes and develop templates for year-end closure. The agency used this opportunity to increase knowledge and understanding of needs associated with this task. As the fiscal department moves forward, systems and tools have been implemented to ensure timely closing and accurate tracking of this process. UMHS will continue to utilize the checklists put in place last fiscal year to guide month-end processes and reconciliations. Fiscal Management will review, monthly, the completion of said duties and will address any issues with staff immediately. Ongoing training will be done to ensure all fiscal staff members understand their role and duties within the agency. Bank reconciliations will continue to be completed monthly. The Executive Director, Director of Finance, Treasurer of the Board of Directors, or Other Designee will review the information and approval will be documented. UMHS will focus on segregation of duties within the fiscal department and ensure proper documentation is maintained. Person(s) Responsible: Executive Director, Director of Finance, Treasurer of the Board of Directors, or Other Designee Timing for Implementation: Immediately and Ongoing Reconciliations and Material Adjustments Corrective Action Plan Umatilla Morrow Head Start, Inc. (UMHS, Inc.) partnered with an independent accounting firm to streamline processes and develop templates for year-end closure. The agency used this opportunity to increase knowledge and understanding of needs associated with this task. As the fiscal department moves forward, systems and tools have been implemented to ensure timely closing and accurate tracking of this process. UMHS will continue to utilize the checklists put in place last fiscal year to guide month-end processes and reconciliations. Fiscal Management will review, monthly, the completion of said duties and will address any issues with staff immediately. Ongoing training will be done to ensure all fiscal staff members understand their role and duties within the agency. Bank reconciliations will continue to be completed monthly. The Executive Director, Director of Finance, Treasurer of the Board of Directors, or Other Designee will review the information and approval will be documented. UMHS will focus on segregation of duties within the fiscal department and ensure proper documentation is maintained. Person(s) Responsible: Executive Director, Director of Finance, Treasurer of the Board of Directors, or Other Designee Timing for Implementation: Immediately and Ongoing

View Audit 292742

Finding 371066 (2023-001)

Significant Deficiency 2023

Furman University

SC

Significant Deficiency Internal Control / Segregation of Duties

Department of Education 2023-001 Gramm-Leach-Bliley Act (GLBA) Recommendation: We recommend that the College review the updated GLBA requirements and ensure their Written Information Security Program (WISP) includes all required elements. We do note that after June 30, 2023 the University has upd...

Department of Education 2023-001 Gramm-Leach-Bliley Act (GLBA) Recommendation: We recommend that the College review the updated GLBA requirements and ensure their Written Information Security Program (WISP) includes all required elements. We do note that after June 30, 2023 the University has updated the WISP to include all of the required elements. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Updated WISP to include all required elements. Name(s) of the contact person(s) responsible for corrective action: Dawn Durham Planned completion date for corrective action plan: 10/19/2023

View Audit 292738

Finding 371047 (2023-001)

Material Weakness 2023

Keokuk County, Iowa

IA

Internal Control / Segregation of Duties

Segregation of Duties Name of contact person - Christy Bates, County Auditor Corrective Action - The duties will be separated as much as possible and alternative contro...

Segregation of Duties Name of contact person - Christy Bates, County Auditor Corrective Action - The duties will be separated as much as possible and alternative controls will be considered to compensate for lack of separation. Proposed Completion Date - Ongoing.

View Audit 292713

Finding 371043 (2023-001)

Significant Deficiency 2023

Davis County, Iowa

IA

Internal Control / Segregation of Duties

Segregation of Duties Name of contact person - Linda Humphrey, County Auditor Corrective Action - The duties will be separated as much as possible and alternative controls will be co...

Segregation of Duties Name of contact person - Linda Humphrey, County Auditor Corrective Action - The duties will be separated as much as possible and alternative controls will be considered to compensate for lack of separation. Proposed Completion Date - Ongoing.

View Audit 292702

Corrective Action Plans

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