Corrective Action Plan: To address the deficiencies identified in Finding 2025-004, the University has implemented and continues to enhance corrective actions focused on automating loan disbursement notifications, standardizing notification content and timing, strengthening documentation and audit t...
Corrective Action Plan: To address the deficiencies identified in Finding 2025-004, the University has implemented and continues to enhance corrective actions focused on automating loan disbursement notifications, standardizing notification content and timing, strengthening documentation and audit trails, and institutionalizing quality assurance oversight to ensure sustained compliance with federal notification requirements. Primary Control Enhancements. Loan disbursement notifications to the student for Subsidized, Unsubsidized, and Graduate PLUS Loans are now system-generated through Ellucian Colleague, providing automated delivery and a documented audit trail. Notifications are issued upon disbursement processing and delivered through system-supported modalities, including electronic communication and student portal updates. Ellucian Colleague retains a system-generated audit trail documenting the timing and content of each notification, strengthening the University’s ability to demonstrate compliance with federal requirements. This system-based approach eliminates reliance on third-party notification tools previously used and brings direct control of notification sequencing, content, and documentation within the University’s financial aid infrastructure. Supporting Controls and Training. The University has revised the Parent PLUS Loan notification process to ensure that required disbursement information—including the date, amount, and type of loan—is provided directly within the notification communication. While Parent PLUS notifications currently require initiation through a controlled manual process, procedures have been amended to ensure timely issuance, content accuracy, and supervisory oversight during this interim period. The University is actively working with the Ellucian Colleague implementation team to further automate Parent PLUS Loan disbursement notifications and eliminate manual triggering. Until full automation is achieved, documented procedures and quality assurance reviews will serve as compensating controls to ensure compliance with notification timing and content requirements. Monitoring and Quality Assurance. The University established and maintains a formal quality assurance framework to monitor loan disbursement notifications. A quality assurance calendar requires reviews at least twice per semester to confirm that notifications are issued within required regulatory timeframes, include all required elements, and are sent to the appropriate recipient (student or parent). As part of ongoing monitoring, the University has conducted multiple quality assurance reviews of loan disbursement notifications. These reviews have demonstrated improved compliance with notification timing and content requirements while also identifying isolated system sequencing issues that were promptly addressed through configuration updates and enhanced scheduling controls within Ellucian Colleague. Sustained Oversight. Any discrepancies identified through quality assurance reviews are documented, corrected, and evaluated to inform process refinement, system configuration, and staff training. Anticipated Completion Date: September 2026