Corrective Action Plans

Finding 513858 (2024-001)

Material Weakness 2024

CO

Reporting Student Financial Aid Eligibility

Incorrect Enrollment Reporting to National Student Loan Data System (NSLDS) Planned Corrective Action: ABU started working on partnering with the National Clearing House in the fall 2023 for NSLDS reporting. Due to a system conversion at the time this process took longer than anticipated. However,...

Incorrect Enrollment Reporting to National Student Loan Data System (NSLDS) Planned Corrective Action: ABU started working on partnering with the National Clearing House in the fall 2023 for NSLDS reporting. Due to a system conversion at the time this process took longer than anticipated. However, the first error free report was uploaded 09/01/2024. ABU now has a schedule with set reminders from the clearinghouse to ensure timely and regular reporting. Person Responsible for Corrective Action Plan: Stephanie Castillo, Director of Financial Aid Anticipated Date of Completion: Fall 2024

View Audit 331877

Finding 513853 (2024-001)

Significant Deficiency 2024

Carroll Community College

MD

Reporting Matching / Level of Effort / Earmarking Student Financial Aid § 200.303

U.S. Department of Education 2024-001 Special Tests and Provisions – NSLDS Program-Level Reporting Student Financial Aid Cluster – Assistance Listing No. 84.063, 84.268 Condition: The associate degree programs were not reported as two years per the recommendation in the NSLDS enrollment reporting...

U.S. Department of Education 2024-001 Special Tests and Provisions – NSLDS Program-Level Reporting Student Financial Aid Cluster – Assistance Listing No. 84.063, 84.268 Condition: The associate degree programs were not reported as two years per the recommendation in the NSLDS enrollment reporting guide. Recommendation: We recommend the College report associate degree program length to NSLDS as two years. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: After being made aware of the NSLDS calculation for programs reported that aren’t reported in years, we looked into solving the issue. We learned that there is a screen within our student information system that sets the default time to years rather than months. Our degree programs prior to 2017 were entered into that screen but degree programs after that time and all of our certificate programs, needed to be calculated as years and entered into our SIS. We did a small trial sample of adjusting three programs in the spring to make sure the changes did not cause any issues with the Clearinghouse and NSLDS. When the data proved to be transmitted and corrected in both systems without issue, we tackled the rest of the programs at the start of this fall. We worked with the Clearinghouse to notify them that we were going to be adjusting a large number of programs that were effecting many student records. They did some alignment of our programs on their end to make the data transition go smoothly to the NSLDS. Issues with reported program lengths having the additional calculation should no longer. We have built in processes to make sure this step will be taken for any new programs. Name(s) of the contact person(s) responsible for corrective action: Greg Bricca, Director of Institutional Effectiveness

View Audit 331869

Finding 513848 (2024-002)

Material Weakness 2024

Department of Transportation - Airports Division, State of Hawaii

HI

Matching / Level of Effort / Earmarking Subrecipient Monitoring Material Weakness

Finding Number: 2024-002 Condition: During the audit, it was determined that there is no control function in place by the Airports staff to ensure that wage rate compliance with weekly certified payrolls is occurring. Planned Corrective Action: N/A - corrective action detailed above was implemented ...

Finding Number: 2024-002 Condition: During the audit, it was determined that there is no control function in place by the Airports staff to ensure that wage rate compliance with weekly certified payrolls is occurring. Planned Corrective Action: N/A - corrective action detailed above was implemented during February 2024 in full. Contact person responsible for corrective action: Karen Honda, Fiscal Management Officer Anticipated Completion Date: February 1, 2024

View Audit 331853

Finding 513837 (2024-001)

Significant Deficiency 2024

Logan City School District

UT

Special Tests & Provisions Matching / Level of Effort / Earmarking Internal Control / Segregation of Duties § 200.326

2024‐001 Special Tests and Provision – Wage Rate Requirements Person Responsible for Corrective Action: Jeff Barben, Business Administrator Correction Action Planned: The District will review, update and train staff on the processes and internal controls related to construction contracts to ensure c...

2024‐001 Special Tests and Provision – Wage Rate Requirements Person Responsible for Corrective Action: Jeff Barben, Business Administrator Correction Action Planned: The District will review, update and train staff on the processes and internal controls related to construction contracts to ensure compliance with the Wage Rate Requirements as published in 29 CFR Part 5, Labor Standards Provisions Applicable to Contracts Governing Federally Financed and Assisted Construction when applicable. Anticipate Completion Date: November 30, 2024

View Audit 331816

Finding 513831 (2024-001)

Significant Deficiency 2024

Doane University

NE

Student Financial Aid Subrecipient Monitoring Significant Deficiency

To address this finding, we will implement a documented system of controls for all Title IV refund calculations. This will include: Each R2T4 calculation will undergo a documented review by a secondary individual. This review will be recorded via either a signature and date on the worksheet or an em...

To address this finding, we will implement a documented system of controls for all Title IV refund calculations. This will include: Each R2T4 calculation will undergo a documented review by a secondary individual. This review will be recorded via either a signature and date on the worksheet or an email confirmation. Name(s) of Contact Person(s) Responsible for Corrective Action: Federico Peña Jr. (Fred), Financial Aid Director Anticipated Completion Date: November 6, 2024

View Audit 331806

Finding 513794 (2024-001)

None 2024

McFarland Unified School District

CA

Subrecipient Monitoring Allowable Costs / Cost Principles Reporting

The ESSER III 2024 Fall Report submitted to the California Department of Education on October 15, 2024, reflected the correction made to include the credit not reported on the prior ESSER III quarterly report. The Business Department has been added as an additional reviewer prior to submission.

View Audit 331746

Finding 513770 (2024-003)

Significant Deficiency 2024

Childfund International, USA

VA

Subrecipient Monitoring Allowable Costs / Cost Principles Period of Performance

Internal Control over Compliance and Compliance with Activities Allowed or Unallowed and Allowable Costs and Cost Principles Contact: Laura Meloy, VP, Finance Completion Date: June 30, 2025 Corrective Action: The ChildFund Management team has taken immediate action to discuss the importance of p...

Internal Control over Compliance and Compliance with Activities Allowed or Unallowed and Allowable Costs and Cost Principles Contact: Laura Meloy, VP, Finance Completion Date: June 30, 2025 Corrective Action: The ChildFund Management team has taken immediate action to discuss the importance of proper period end cut-offs with the Accounting and Grants Teams. Moving forward, the Grants and Project Management team will discuss expense cut-offs during the kick-off meetings and the importance of year-end accruals. The Accounting Department will also provide additional training and reminders around year-end cut-offs and the importance of reviewing invoice dates for accruals that are under our normal threshold of $1,000 USD for grants.

View Audit 331718

Finding 513760 (2024-001)

Significant Deficiency 2024

St. Catherine University

MN

Student Financial Aid Reporting Significant Deficiency

Student Financial Aid 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 i...

Student Financial Aid 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: The Registrar's Office partnered with IT to automate the transmission of enrollment and graduation files to the National Student Clearinghouse to avoid late submissions or confusion about which branch the transmission is reporting. They have been set up to be sent on the same day each month, rather than being sent manually by a staff member. Several staff members met with our NSC representative to review the transmission schedule to ensure the selected dates will lead to timely submissions. Name of the contact person responsible for corrective action: Kerri Vickers, Registrar Planned completion date for corrective action plan: December 2024

View Audit 331691

Finding 513758 (2024-001)

Material Weakness 2024

Clarke University of Dubuque, Iowa

IA

Student Financial Aid Special Tests & Provisions Matching / Level of Effort / Earmarking

Student Financial Assistance Program Cluster – Department of Education Federal Financial Assistance Listing/CFDA #84.268 Federal Direct Student Loans ‐ 2023/2024 P268K211430 Federal Financial Assistance Listing/CFDA #84.063 Federal Pell Grant Program ‐ 2023/2024 P063P201430 Special Tests & Provisio...

Student Financial Assistance Program Cluster – Department of Education Federal Financial Assistance Listing/CFDA #84.268 Federal Direct Student Loans ‐ 2023/2024 P268K211430 Federal Financial Assistance Listing/CFDA #84.063 Federal Pell Grant Program ‐ 2023/2024 P063P201430 Special Tests & Provisions:– Return of Title IV Funds Material Weakness in Internal Control over Compliance and Noncompliance Finding Summary: One instance was identified where there was no documented return of Title IV calculation, and fourteen instances were identified where there was no documented review of the return of Title IV calculation. Responsible Individuals: Robert Hoover, Director of Financial Aid and Sylma Fernandez, Assistant Director of Financial Aid Corrective Action Plan: The Financial Aid Director recently completed R2T4 process training with the Controller. This added expertise will enhance the secondary review process, providing an independent assessment by a reviewer not involved in daily operations. This additional oversight will strengthen quality control through sampled calculation reviews. Furthermore, expanded attendance and withdrawal reports will support comprehensive control processes for this cluster. Anticipated Completion Date: Commenced December 1, 2024

View Audit 331672

Finding 513748 (2024-006)

Significant Deficiency 2024

Oklahoma Panhandle State University

OK

Allowable Costs / Cost Principles Significant Deficiency Matching / Level of Effort / Earmarking § 200.303

Higher Education Institutional Aid-Assistance Listing No. 84.031S Recommendation: We recommend the University adhere to their existing internal control policy regarding scholarship awards made from federal award funds. Explanation of disagreement with audit finding: There is no disagreement with the...

Higher Education Institutional Aid-Assistance Listing No. 84.031S Recommendation: We recommend the University adhere to their existing internal control policy regarding scholarship awards made from federal award funds. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Title V Grant personnel will submit awards to the Financial Aid Office for official award letter notice, adhering to existing internal control policy regarding scholarship awards. Name(s) of the contact person(s) responsible for corrective action: Connie Owens and Dasha Smith Planned completion date for corrective action plan: January 31, 2025

View Audit 331630

Finding 513747 (2024-005)

Significant Deficiency 2024

Oklahoma Panhandle State University

OK

Questioned Costs Allowable Costs / Cost Principles Matching / Level of Effort / Earmarking § 200.303 § 200.430

Higher Education Institutional Aid-Assistance Listing No. 84.031S Recommendation: We recommend the University review policies and procedures to ensure all personnel on federal grants documented time and effort reports as stated in federal regulations. Explanation of disagreement with audit finding: ...

Higher Education Institutional Aid-Assistance Listing No. 84.031S Recommendation: We recommend the University review policies and procedures to ensure all personnel on federal grants documented time and effort reports as stated in federal regulations. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Time and effort reports will be reviewed and submitted monthly. Name(s) of the contact person(s) responsible for corrective action: Elizabeth McMurphy Planned completion date for corrective action plan: January 31, 2025

View Audit 331630 Questioned Costs: $1

Finding 513740 (2024-004)

Significant Deficiency 2024

Oklahoma Panhandle State University

OK

Student Financial Aid Matching / Level of Effort / Earmarking Special Tests & Provisions § 200.303

ederal Supplemental Educational Opportunity Grant - Assistance List No. 84.007 Federal Work Study Program- Assistance Listing No. 84.033 Federal Pell Grant Program - Assistance Listing No. 84.063 Federal Direct Student Loans - Assistance Listing No. 84.268 ...

ederal Supplemental Educational Opportunity Grant - Assistance List No. 84.007 Federal Work Study Program- Assistance Listing No. 84.033 Federal Pell Grant Program - Assistance Listing No. 84.063 Federal Direct Student Loans - Assistance Listing No. 84.268 Recommendation: We recommend the University review current processes for reporting to NSLDS and implement procedures to ensure submissions are reported timely and accurately. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Registrar reviews an error report each month, resolves the errors, and then submits the report to NSLDS. NSLDS responds with an error resolution report, which is then used to resolve any further issues, and confirm the final reporting to NSLDS. Name(s) of the contact person(s) responsible for corrective action: Erin Moore and Dasha Smith Planned completion date for corrective action plan: December 15, 2024

View Audit 331630

Finding 513739 (2024-003)

Material Weakness 2024

Oklahoma Panhandle State University

OK

Questioned Costs Special Tests & Provisions Student Financial Aid § 200.303

ederal Supplemental Educational Opportunity Grant - Assistance List No. 84.007 Federal Work Study Program- Assistance Listing No. 84.033 Federal Pell Grant Program - Assistance Listing No. 84.063 Federal Direct Student Loans - Assistance Listing No. 84.269Recommendation: We recommend that the Univer...

ederal Supplemental Educational Opportunity Grant - Assistance List No. 84.007 Federal Work Study Program- Assistance Listing No. 84.033 Federal Pell Grant Program - Assistance Listing No. 84.063 Federal Direct Student Loans - Assistance Listing No. 84.269Recommendation: We recommend that the University review policies and procedures related to R2T4 calculations to ensure calculations are performed accurately. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Financial Aid will update the unofficial withdrawal process with successful completion definition to be inclusive of requiring a passing grade. Name(s) of the contact person(s) responsible for corrective action: Dasha Smith Planned completion date for corrective action plan: December, 15 2024

View Audit 331630 Questioned Costs: $1

Finding 513738 (2024-002)

Significant Deficiency 2024

Oklahoma Panhandle State University

OK

Eligibility Procurement, Suspension & Debarment Student Financial Aid § 200.303

ederal Supplemental Educational Opportunity Grant - Assistance List No. 84.007 Federal Work Study Program- Assistance Listing No. 84.033 Federal Pell Grant Program - Assistance Listing No. 84.063 Federal Direct Student Loans - Assistance Listing No. 84.268 Recommendation: We recommend the University...

ederal Supplemental Educational Opportunity Grant - Assistance List No. 84.007 Federal Work Study Program- Assistance Listing No. 84.033 Federal Pell Grant Program - Assistance Listing No. 84.063 Federal Direct Student Loans - Assistance Listing No. 84.268 Recommendation: We recommend the University review internal controls related to Eligibility and ensure appropriate checks are in place to identify students who are not meeting the University's qualitative and quantitative criteria for maintaining SAP. Explanation of disagreement with audit finding: There is no disagreement with the audit finding . Action taken in response to finding: The Registrar's Office procedure will be to convert clock hours to credit hours to avoid this situation moving forward. Name(s) of the contact person(s) responsible for corrective action: Erin Moore and Dasha Smith Planned completion date for corrective action plan: December 15, 2024

View Audit 331630

Finding 513700 (2024-002)

Significant Deficiency 2024

City Colleges of Chicago

IL

Student Financial Aid Subrecipient Monitoring Reporting § 200.303

Finding 2024-002 – Enrollment Reporting Condition • For one out of sixty students tested (2%) who withdrew from City Colleges, the students’ withdrawal date reported to the National Student Loan Data System (NSLDS) for campus level and program level did not match the institution’s records. Also, th...

Finding 2024-002 – Enrollment Reporting Condition • For one out of sixty students tested (2%) who withdrew from City Colleges, the students’ withdrawal date reported to the National Student Loan Data System (NSLDS) for campus level and program level did not match the institution’s records. Also, the student’s program level withdrawal was not reported to NSLDS within 60 days. • For one out of sixty students tested (2%) who withdrew from City Colleges, the student’s withdrawal date reported to the NSLDS for campus level was not reported to NSLDS within 60 days. • For two out of sixty students tested (3%) who withdrew from City Colleges were not reported to NSLDS within 60 days. Cause CCC sends enrollment files of all students to National Student Clearinghouse (NSC) monthly, who then reports CCC enrollment data to National Student Loan Data System (NSLDS). It was discovered that two of the errors occurred due to an update in NSLDS and CCC was not aware the update caused missing files. In the other instances files were sent in late February, but not corrected within NSC until March 5th thus, it missed the beginning of the March roster. Corrective Action Taken or Planned CCC will work with NSC to monitor future updates and ensure files are accurately shared with NSLDS. Records, Financial Aid, Decision Support and OIT continue to meet bi-weekly to review and update the enrollment reporting logic to ensure the dates for student enrollment actions align at the campus level and the program level. In addition, the compliance team will monitor updates and announcements from NSC regarding file errors to ensure timely updates are submitted. Contact Person: Laura Clark, Associate Vice Chancellor, Academic Systems and Tiffany Morrison, Associate Vice Chancellor, Financial Aid Anticipated Completion Date: December 20, 2024

View Audit 331604

Finding 513692 (2024-001)

Significant Deficiency 2024

Montello School District

WI

Internal Control / Segregation of Duties Procurement, Suspension & Debarment Matching / Level of Effort / Earmarking

Finding #2024-001 – Limited Segregation of Duties (Prior Year Finding #2023-001) Condition: The available office staff precludes a proper segregation of duties in the control areas reviewed. Effect: Because of the lack of segregation of duties, errors or irregularities could occur and not be detec...

Finding #2024-001 – Limited Segregation of Duties (Prior Year Finding #2023-001) Condition: The available office staff precludes a proper segregation of duties in the control areas reviewed. Effect: Because of the lack of segregation of duties, errors or irregularities could occur and not be detected on a timely basis. Cause: The condition is due to limited staff available. Criteria: Internal controls should be in place that provide adequate segregation of duties. Generally, a system of internal control contemplates separation of duties such that no individual has responsibility to execute a transaction, have physical access to the related assets, and have responsibility or authority to record the transaction. Recommendation: Procedures should be implemented segregating duties among different employees. Management should continue to maintain a working knowledge of matters relating to the district’s operations. Response: We agree with this finding and continue to work to achieve segregation of duties whenever cost effective. The cash disbursements process includes approval of purchase orders and matching of approved purchase orders with invoices. Review of account coding is performed by the district accounting staff. The payroll disbursement process includes approval of timesheets and review of coding on an ongoing basis. The Board of Education reviews budget to actual information along with disbursement information monthly. Contact Person: Cheryl Troost Anticipated Completion: Not Applicable

View Audit 331602

Finding 513661 (2024-002)

Significant Deficiency 2024

Vanguard University of Southern California and Affiliates

CA

Student Financial Aid Subrecipient Monitoring Reporting

FINDING 2024-002 – Special Tests and Provisions – Enrollment Reporting: Significant Deficiency in Internal Control Over Compliance Corrective Action Plan: An undergraduate student in a year-round program was reported to National Student Clearinghouse (NSC) as a student for whom summer term was nonst...

FINDING 2024-002 – Special Tests and Provisions – Enrollment Reporting: Significant Deficiency in Internal Control Over Compliance Corrective Action Plan: An undergraduate student in a year-round program was reported to National Student Clearinghouse (NSC) as a student for whom summer term was nonstandard. Non-standard summer term students are not reported to NSC over summer if they are not enrolled. Since this student was in a year-round program, the student should have been reported with summer as a standard term. Based on Vanguard’s NSC transmission schedule, had this student’s NSC Branch been classified correctly, the student would have been in a NSC transmission standard term data file and reported within 30 days of the enrollment adjustment. Annually, the Registrar’s Office will review all programs to ensure that year-round program students are reported to NSC with summer as a standard term. The assistant registrar who is responsible for both NSC reporting and updating program degree audits will manage this process with the dean of academic records oversight. The Registrar’s Office will create a column in the annual degree audit log that indicates standard/non-standard classification has been properly determined and set up correctly in the student information system for accurate reporting to NSC. A sample set of students within each NSC transmission will be checked following transmission in NSC by the Registrar’s Office and NSLDS by the Financial Aid Office to ensure that enrollment status is accurate. Name of Contact Person: Julie Cowen, Dean of Academic Records, 714-662-5204 Projected Completion Date: Program review for standard/non-standard classification for 2024-25 was completed on October 28, 2024 and will be completed annually in March-April beginning in 2025.

View Audit 331568

Finding 513656 (2024-001)

Significant Deficiency 2024

Vanguard University of Southern California and Affiliates

CA

Special Tests & Provisions Student Financial Aid Significant Deficiency

FINDING 2024-001 – Special Tests and Provisions – Return of Title IV Funds: Significant Deficiency in Internal Controls Over Compliance Corrective Action Plan: A traditional undergraduate who withdrew did not have an R2T4 calculation completed within 30 days of withdrawal and federal funding was not...

FINDING 2024-001 – Special Tests and Provisions – Return of Title IV Funds: Significant Deficiency in Internal Controls Over Compliance Corrective Action Plan: A traditional undergraduate who withdrew did not have an R2T4 calculation completed within 30 days of withdrawal and federal funding was not returned within 45 days of withdrawal. The withdrawal process by the student and academic staff was not completed according to process or timeframe. The course deregistration and withdrawal process for a traditional undergraduate student did not occur following standard procedures or timeframe. The Registrar’s Office entered two different course deregistration dates, within the two-week add/drop period, into the student information system and the withdrawal was entered nearly 60 days after the first day of class. The withdrawal and leave of absence reports generated daily and enrollment adjustment report generated weekly had inadequate queries to catch this complicated course deregistration and withdrawal situation to trigger timely R2T4 calculation and return of federal funding. Following this finding, the Financial Aid Office identified the reporting deficiencies and started dialog with the Registrar’s Office and Information Technology regarding student information system screens and fields being used by the Registrar’s Office that need to be adjusted on the reports. The Registrar’s Office understands the interdependency between its office and the Financial Aid Office with regards to enrollment adjustments and completing an R2T4 calculation, returning federal funding, monitoring Common Origination and Disbursement transmission and any necessary communication with students. With daily and weekly monitoring of said reports, and the Registrar’s Office proactively notifying the Financial Aid Office of any enrollment adjustments that are nearing the R2T4 deadlines rather than solely relying on reports, the Financial Aid Office will be positioned to be compliant with the federal deadlines. The Financial Aid Office will begin a two-person review of calculation and funding return and a recorded acknowledgement of such. Name of Contact Person: Kim Johnson, Vice President for Enrollment Management, 714-966-5415 Projected Completion Date: Review of all fall 2024 enrollment adjustment/withdrawal/leave of absence students after the first day of class (August 26, 2024) will be done by the vice president for enrollment management (serving as director of financial aid) and assistant director during November 2024. Going forward, said two-person review will be done daily by the assistant director and at a minimum biweekly by a senior manager.

View Audit 331568

Finding 513630 (2024-001)

Material Weakness 2024

Clarke University of Dubuque, Iowa

IA

Student Financial Aid Special Tests & Provisions Matching / Level of Effort / Earmarking

Student Financial Assistance Program Cluster – Department of Education Federal Financial Assistance Listing/CFDA #84.268 Federal Direct Student Loans ‐ 2023/2024 P268K211430 Federal Financial Assistance Listing/CFDA #84.063 Federal Pell Grant Program ‐ 2023/2024 P063P201430 Special Tests & Provisio...

Student Financial Assistance Program Cluster – Department of Education Federal Financial Assistance Listing/CFDA #84.268 Federal Direct Student Loans ‐ 2023/2024 P268K211430 Federal Financial Assistance Listing/CFDA #84.063 Federal Pell Grant Program ‐ 2023/2024 P063P201430 Special Tests & Provisions:– Return of Title IV Funds Material Weakness in Internal Control over Compliance and Noncompliance Finding Summary: One instance was identified where there was no documented return of Title IV calculation, and fourteen instances were identified where there was no documented review of the return of Title IV calculation. Responsible Individuals: Robert Hoover, Director of Financial Aid and Sylma Fernandez, Assistant Director of Financial Aid Corrective Action Plan: The Financial Aid Director recently completed R2T4 process training with the Controller. This added expertise will enhance the secondary review process, providing an independent assessment by a reviewer not involved in daily operations. This additional oversight will strengthen quality control through sampled calculation reviews. Furthermore, expanded attendance and withdrawal reports will support comprehensive control processes for this cluster. Anticipated Completion Date: Commenced December 1, 2024

View Audit 331542

Finding 513617 (2024-002)

Material Weakness 2024

Calvary University

MO

Student Financial Aid Matching / Level of Effort / Earmarking Procurement, Suspension & Debarment

Condition Found: The University has an adequate Satisfactory Academic Progress policy. Student GPAs and completion rates are reviewed at the end of each academic year. However, the University is not informing students when they are placed on financial aid suspension and how to appeal the decision. C...

Condition Found: The University has an adequate Satisfactory Academic Progress policy. Student GPAs and completion rates are reviewed at the end of each academic year. However, the University is not informing students when they are placed on financial aid suspension and how to appeal the decision. Corrective Action Plan: Management agrees with the auditors’ finding and their recommendation. The Business Office and the Director of Financial Aid is in the process of creating a Financial Aid Suspension Letter to notify students of the financial aid ramifications of being placed on financial aid suspension. Anticipated Completion Date: The corrective action will be completed by December 31, 2024. Contact Person: Tasha Young, CFO 816-425-6151

View Audit 331527

Finding 513616 (2024-001)

Material Weakness 2024

Calvary University

MO

Student Financial Aid Reporting Matching / Level of Effort / Earmarking

Condition Found: The bi-monthly National Student Loan Database System (“NSLDS”) Enrollment Reporting Summary Reports were not updated and returned to NSLDS during the year ended June 30, 2024. Therefore, student enrollment status changes were not reported timely to NSLDS. Corrective Action Plan: Man...

Condition Found: The bi-monthly National Student Loan Database System (“NSLDS”) Enrollment Reporting Summary Reports were not updated and returned to NSLDS during the year ended June 30, 2024. Therefore, student enrollment status changes were not reported timely to NSLDS. Corrective Action Plan: Management agrees with the auditors’ finding and their recommendation. The Director of Financial Aid or business office staff will update the enrollment status for all students who obtained Federal Direct Student Loans from the University. The University will review its contract with their third-party financial aid administrator. The University will update their policies and procedures as needed. Anticipated Completion Date: The corrective action will be completed by December 31, 2024. Contact Person: Tasha Young, CFO 816-425-6151

View Audit 331527

Finding 513610 (2024-007)

Significant Deficiency 2024

Cleveland State University

OH

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

Name of the contact person responsible for corrective actions planned: Rachel Schmidt Financial Aid Director Cleveland State University 2121 Euclid Avenue, UN 402 Cleveland, OH 44115 Phone: 216.687.5594 E-mail: r.m.schmidt@csuohio.edu Corrective actions planned: During the audit of Perkins Loan fil...

Name of the contact person responsible for corrective actions planned: Rachel Schmidt Financial Aid Director Cleveland State University 2121 Euclid Avenue, UN 402 Cleveland, OH 44115 Phone: 216.687.5594 E-mail: r.m.schmidt@csuohio.edu Corrective actions planned: During the audit of Perkins Loan files, it was identified that 5 out of the 25 files tested did not contain a signed Perkins Loan form. Management understands the recommendation to review and strengthen its procedures for collecting and retaining Perkins Loan forms and the need to retain the records of former students. While we are certain that the 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 the former students did sign the loan agreement. However, we understand the need to retain all critical forms for our students. Completion date: November 2024

View Audit 331516

Finding 513583 (2024-002)

Significant Deficiency 2024

Cankdeska Cikana Community College

ND

Special Tests & Provisions Significant Deficiency Matching / Level of Effort / Earmarking

2024-002 Contact Person Chelly Merkel-Veer Planned Corrective Action The College collects weekly payrolls from contractors. They will be checked by the Facilities Director and CFO to assure they are being reported on the required form WH-347. Planned Completion Date Immediately

View Audit 331509

Finding 513576 (2024-002)

Material Weakness 2024

Woodbury University

CA

Student Financial Aid Subrecipient Monitoring Material Weakness

Woodbury University Corrective Action Plan For the Year Ended June 30, 2024 Agency: U.S. Department of Education Name of Federal Program or Cluster: Student financial assistance cluster Award Year: 2023-2024 Finding 2024-002 – Special Tests and Provisions – Enrollment Reporting – Material Weakness ...

Woodbury University Corrective Action Plan For the Year Ended June 30, 2024 Agency: U.S. Department of Education Name of Federal Program or Cluster: Student financial assistance cluster Award Year: 2023-2024 Finding 2024-002 – Special Tests and Provisions – Enrollment Reporting – Material Weakness in Internal Control Over Compliance Conditions: From a system generated population of 119 students who received federal aid and either graduated, withdrew, or changed their permanent address during the year ended June 30, 2024, auditors selected a sample of 17 students who received direct loans. The enrollment information and withdrawal or graduation date per the Woodbury University’s records were compared to the information reported to NSLDS in order to determine if status changes were reported accurately and within the required timeframes. Of the 17 students selected for testing, 17 were not reported to the NSLDS within the required timeframe and had an incorrect status reported to the NSLDS. Corrective Action Plan: If the student is planning to leave the University. Students must withdraw from all classes before the withdraw date. Also, the students must circulate their form to the listed departments for a signature. The issue is something this was completed by email with several forms for the same student. We will work with Redlands to create a Soft Doc/ electronic withdraw form which can be completed by the student on line. This form will be accessible to the offices listed on the form paper. Also, this will aid in the Registrar's Office and Financial Aid to have more accurate record of the students who have completed the withdraw process. Name of Contact Person: Verletta Jackson, Registrar, (818) 252-5277 Projected Completion Date: Spring 2025

View Audit 331458

Finding 513532 (2024-005)

Significant Deficiency 2024

North Kansas City School District No.74

MO

School Nutrition Programs Reporting Significant Deficiency § 200.303

Identifying Number: 2024-005 Reporting – Significant Deficiency U.S. Department of Agriculture Passed through Missouri Department of Elementary and Secondary Education Child Nutrition Cluster, Assistance Listing No. 10.555 (National School Lunch Program), 10.553 (School Breakfast Program), 10.582...

Identifying Number: 2024-005 Reporting – Significant Deficiency U.S. Department of Agriculture Passed through Missouri Department of Elementary and Secondary Education Child Nutrition Cluster, Assistance Listing No. 10.555 (National School Lunch Program), 10.553 (School Breakfast Program), 10.582 (Fresh Fruit and Vegetable Program) Federal award year 2023-2024 U.S. Department of Education Passed through Missouri Department of Elementary and Secondary Education Education Stabilization Fund, Assistance Listing No. 84.425C (Governor’s Emergency Education Relief Fund), 84.425D (Elementary and Secondary School Emergency Relief Fund), 84.425U (American Rescue Plan-Elementary and Secondary School Emergency Relief), 84.425W (American Rescue Plan-Elementary and Secondary School Emergency Relief-Homeless Children and Youth) Federal award year 2023-2024 Summary of Finding: Criteria: The Uniform Guidance (2 CFR 200.303) requires nonfederal entities receiving federal awards to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance retirements. This includes controls to ensure that reports submitted are timely, complete, and accurate. Condition: The District did not have internal controls in place for federal reports to be reviewed for completeness and accuracy prior to submission. Cause: A lack of controls that could reasonably ensure this review had been performed by someone other than the preparer of the information. Effect or potential effect: The potential effect is submitting incomplete or inaccurate reports. Questioned costs: None Context: For all sample selections tested in the major programs, all reports were submitted timely and appeared to be accurate, however, there was no evidence that these reports were reviewed for completeness and accuracy prior to submission. Identification as a repeat finding, if applicable: Not applicable. Corrective Action: To ensure the accuracy of Federal reports/claims, Food service will implement the following procedures: Federal reporting and claims will be reviewed for accuracy and completeness by the Food service director or designee before they are submitted. The food service director or designee will initial report to document this review. Finance department personnel will implement the following procedures for other federal programs: One employee will start the ePeGS process. This employee will forward the documentation that they used to prepare the ePeGS filing to their supervisor. The supervisor will review the documentation and the items entered into ePeGS for accuracy. Once the supervisor is satisfied that the ePeGS filing is correct, he or she will submit the ePeGS filing. This process will be documented in the ePeGS history. Anticipated Completion Date: June 2025 (for the year ending June 30, 2025). Contact Person: Steve Marriott, Controller 816-321-5000 Steve.marriott@nkcschools.org

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