Corrective Action Plans

Finding 521209 (2024-001)

Material Weakness 2024

New American Association of Massachusetts, Inc.

MA

Subrecipient Monitoring Matching / Level of Effort / Earmarking § 200.331 § 200.332

We acknowledge that the timing of these actions did not fully align with the requirements of Uniform Guidance, which specifies that subaward information must be communicated with the subrecipients in writing at the time the subaward is made. However, the Organization worked diligently to address the...

We acknowledge that the timing of these actions did not fully align with the requirements of Uniform Guidance, which specifies that subaward information must be communicated with the subrecipients in writing at the time the subaward is made. However, the Organization worked diligently to address the issue once identified. To prevent recurrence of this issue, the Organization has taken corrective actions. As soon as we were made aware of the status of the recipients of the awards as subrecipients, we informed them of their status orally and outlined the general terms and compliance requirements associated with their subaward. We formalized this notification process by providing written agreements detailing the subaward terms, as required, in June 2024. These agreements were subsequently signed and returned by the subrecipients in July 2024. To avoid similar compliance challenges, the Organization worked with the Commonwealth of Massachusetts to revise its agreement. Effective September 30, 2024, the Organization no longer serves as a pass-through entity and does not pass federal funds through to subrecipients. For the remaining period during which the Organization acted as a pass-through entity, we implemented procedures to ensure timely and accurate communication of subaward information in writing, aligning with Uniform Guidance requirements. Management believes these actions fully address the cause of the finding and ensure compliance with federal regulations in the future.

View Audit 341176

Finding 521164 (2024-001)

Material Weakness 2024

Southwestern Child Development Commission, Inc.

NC

Matching / Level of Effort / Earmarking Special Tests & Provisions Procurement, Suspension & Debarment

Finding 2024-001 - Employee Record Retention and Health and Safety Training Federal Program: CCDF Cluster: AL# 93.575 - Child Care and Development Block Grant AL# 93.596 - Child Care Mandatory and Matching Funds of the CCDF U.S. Department of Health and Human Services MATERIAL WEAKNESS NONCO...

Finding 2024-001 - Employee Record Retention and Health and Safety Training Federal Program: CCDF Cluster: AL# 93.575 - Child Care and Development Block Grant AL# 93.596 - Child Care Mandatory and Matching Funds of the CCDF U.S. Department of Health and Human Services MATERIAL WEAKNESS NONCOMPLIANCE Special Tests and Provisions Name of Contact Person: Juanita Dillard Corrective Action: As of January 2024, all childcare centers operated by the Organization have been closed. Health and safety training courses will no longer be required. Completion Date: January 31, 2024

View Audit 341119

Finding 521162 (2024-003)

Significant Deficiency 2024

Eastern Wyoming College

WY

Student Financial Aid Allowable Costs / Cost Principles Reporting

Corrective actions: The Financial Aid Office has historically received a copy of the Fund 10 and Fund 13 ledgers from the Business Office and then calculated the tuition and fees, making sure to remove the concurrently enrolled students and inapplicable fees. This calculation was completed without k...

Corrective actions: The Financial Aid Office has historically received a copy of the Fund 10 and Fund 13 ledgers from the Business Office and then calculated the tuition and fees, making sure to remove the concurrently enrolled students and inapplicable fees. This calculation was completed without knowledge that some of the Fund 13 Fees pass through and are already included the Fund 10 details. This resulted in a number of Fund 13 Fees being counted twice. This process has been corrected starting with the 24-25 FISAP. The CFO and Financial Aid Director worked together and the CFO calculated the tuition and fees for Part II Section E of the FISAP. This ensured the correct calculation and eliminated the inclusion of fees that were flowing through the two different GL fund accounts. Anticipated completion date: September 30,2024 Contact person: Rebecca McAllister/Kwin Wilkes

View Audit 341116

Finding 521160 (2024-002)

Significant Deficiency 2024

Eastern Wyoming College

WY

Student Financial Aid Reporting Significant Deficiency

Corrective actions: Eastern Wyoming College currently has a service arrangement with National Student Clearinghouse (NSC) to provide enrollment reporting to the National Student Loan Data System (NSLDS) per the requirements outlined in CFR 690.83 (b)(2), 685.309(b), and per the NSLDS Enrollment Repo...

Corrective actions: Eastern Wyoming College currently has a service arrangement with National Student Clearinghouse (NSC) to provide enrollment reporting to the National Student Loan Data System (NSLDS) per the requirements outlined in CFR 690.83 (b)(2), 685.309(b), and per the NSLDS Enrollment Reporting Guide. These regulations require institutions to report changes in enrollment within a 60-day period. In fulfilling these requirements, EWC's Data Analyst utilizes reports in Colleague to complete the enrollment reporting requirements and submit these reports to NSC. This occurs every thirty days, which exceeding meets the 60-day requirement. EWC's Office of Institutional Research, through the Data Analyst, works with the Registrar and the Financial Aid Office to review and resolve any reporting errors with NSC. Historically, this process worked with minimal errors, but the HCM2 processes posed some unforeseen challenges in the reporting process. To meet these challenges, the Data Analyst sends the student rosters to the NSC. If the students on the SSCR roster are not part of the NSLDS database as a current borrower or recipient of federal student aid, then the Data Analyst must manually upload the information to the NSLDS instead of relying on NSC to initiate the reporting. The Student Financial Aid and Registrar Offices have implemented controls to ensure the proper and timely reporting of student status changes. Upon the implementation of an effective reporting control process, EWC will directly review the student status changes at the NSLDS rather than rely solely on its third-party service provider. For instances where students program length was not reporting correctly, this was resolved at the end of 2022-2023 award year, and the Financial Aid office updated all the Colleague screens used to pull the reports utilized by Institutional Research in submitting the report. EWC has developed and distributed Standard Operating Procedures to ensure the withdrawal dates reported in each office are using the same information. Anticipated completion date: October 2024 Contact person: Rebecca McAllister/Xi Feng

View Audit 341116

Finding 521130 (2024-005)

Material Weakness 2024

Sheridan Community Schools

IN

School Nutrition Programs Internal Control / Segregation of Duties Eligibility § 200.303

FINDING 2024-005 Finding Subject: Child Nutrition Cluster (School Lunch) – Eligibility Summary of Finding: Café Director uploaded the Direct Certification reports from the state into the software system without following a documented oversight or review process to ensure that direct certified studen...

FINDING 2024-005 Finding Subject: Child Nutrition Cluster (School Lunch) – Eligibility Summary of Finding: Café Director uploaded the Direct Certification reports from the state into the software system without following a documented oversight or review process to ensure that direct certified students were accurately processed. This highlights a lack of documented controls for directly certified students. Contact Person Responsible for Corrective Action: Robin Popejoy Contact Phone Number and Email Address: 317.758.4172 – rpopejoy@sheridan.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The Data Department will collaborate with the Café Department to input and ensure the accuracy of the information. Anticipated Completion Date: Already started in August of 2024.

View Audit 341082

Finding 521110 (2024-001)

Material Weakness 2024

Deliverance Manor Housing Corporation

IL

Questioned Costs Student Financial Aid Cash Management

CORRECTIVE ACTION PLAN Finding No. 2024-001: Credit Card was not reconciled and receipts were not obtained. Expenses were not properly recorded in the general ledger. Recommendation: Management should reconcile credit card accounts monthly and secure receipts for purchases and expenses should be pos...

CORRECTIVE ACTION PLAN Finding No. 2024-001: Credit Card was not reconciled and receipts were not obtained. Expenses were not properly recorded in the general ledger. Recommendation: Management should reconcile credit card accounts monthly and secure receipts for purchases and expenses should be posted to the proper general ledger account. Action Taken or Planned: Credit card accounts will be reconciled and receipts will be requested for purchases. Accounting will review the nature of purchases and properly post to the general ledger. Responsible Person: Mary Amador, Property Manager Completion Date: October 31, 2024

View Audit 341047 Questioned Costs: $1

Finding 521105 (2024-004)

Material Weakness 2024

City of Auburn

CA

Internal Control / Segregation of Duties Material Weakness Reporting § 200.303

The City has documented in its reporting procedures to ensure supporting financial information is kept with the submitted report. The report that was compiled to procedure the report in FY 2023-24 was overwritten as ongoing expenses were being tracked in the report. Anticipated Completion Date: Dece...

The City has documented in its reporting procedures to ensure supporting financial information is kept with the submitted report. The report that was compiled to procedure the report in FY 2023-24 was overwritten as ongoing expenses were being tracked in the report. Anticipated Completion Date: December 30, 2024 Responsible Contact Person: Gretchen Johnson, Finance Director

View Audit 341029

Finding 521072 (2024-002)

Material Weakness 2024

Brown County Schools

IN

Special Tests & Provisions Subrecipient Monitoring Material Weakness § 200.303

Information on the federal program: Subject: Education Stabilization Fund – Special Tests and Provisions - Wage Rate Requirements Federal Agency: Department of Education Federal Program: COVID-19 - Education Stabilization Fund Assistance Listing Number: 84.425U Federal Award Numbers and Years (or Ot...

Information on the federal program: Subject: Education Stabilization Fund – Special Tests and Provisions - Wage Rate Requirements Federal Agency: Department of Education Federal Program: COVID-19 - Education Stabilization Fund Assistance Listing Number: 84.425U Federal Award Numbers and Years (or Other Identifying Numbers): S425U200013 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Special Tests and Provisions - Wage Rate Requirements Audit Findings: Material Weakness, Material Noncompliance, Qualified Opinion Context: For the one project sampled for Davis-Bacon requirements, the School Corporation did not obtain the weekly payroll reports certifications from the company that performed renovations on the School Corporation’s roof. Therefore, no review was performed to ensure that pay rates complied with the federal wage rate requirements. Additionally, the School Corporation did not have contracts with the companies that included the clauses for the federal wage rate requirements. The amount disbursed and reported on the SEFA during the audit period is $467,094. Contact Person Responsible for Corrective Action: Dawn Ray Contact Phone Number: 812.988.6601 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: Brown County Schools will require notification of certified payroll reviews be sent to us with the monthly work updates after the contractor has reviewed them for accuracy and compliance with prevailing wage requirements. Anticipated Completion Date: Immediately upon the completion of the audit.

View Audit 340994

Finding 521071 (2024-003)

Material Weakness 2024

Brown County Schools

IN

Internal Control / Segregation of Duties Material Weakness Reporting § 200.302 § 200.303 § 200.328

Information on the federal program: Subject: Education Stabilization Fund (ESSER) – Internal Controls Federal Agency: Department of Education Federal Program: COVID-19 – Education Stabilization Fund Assistance Listing Number: 84.425D, 84.425U Federal Award Numbers and Years (or Other Identifying Num...

Information on the federal program: Subject: Education Stabilization Fund (ESSER) – Internal Controls Federal Agency: Department of Education Federal Program: COVID-19 – Education Stabilization Fund Assistance Listing Number: 84.425D, 84.425U Federal Award Numbers and Years (or Other Identifying Numbers): S425D210013, S425U200013 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Reporting Audit Finding: Material Weakness Context: The School Corporation was required to submit two Annual Data Reports to the Indiana Department of Education (IDOE) during the audit period to meet federal reporting requirements for ESSER grant awards. We noted that the ESSER II and ESSER III amounts reported on the Year 3 report ($397,392 and $294,138, respectively) did not agree to the underlying expenditure records ($498,259 and $1,509,413, respectively, for the period of July 1, 2021 through June 30, 2022). Additionally, we noted that the ESSER II and ESSER III amounts reported on the Year 4 report ($400,501 and $294,129, respectively) did not agree to the underlying expenditure records ($412,324 and $287,065, respectively, for the period of July 1, 2022 through June 30, 2023). We noted that the 195 number of Full-time equivalent (FTE) positions on September 30, 2023 on the second report did not agree to the underlying records supporting number of 274 Full-time equivalent (FTE) positions on September 30, 2023. Contact Person Responsible for Corrective Action: Dawn Ray Contact Phone Number: 812.988.6601 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: We will have someone other than the preparer of the report perform a documented review prior to submission to validate the accuracy and completeness of the data submitted. Anticipated Completion Date: Immediately upon the completion of the audit.

View Audit 340994

Finding 521069 (2024-001)

Material Weakness 2024

Northwestern Michigan College

MI

Student Financial Aid Subrecipient Monitoring Material Weakness

Condition: The College did not send out the post-disbursement email notifications to a group of students. Planned Corrective Action: While the College has documented procedures in place for the disbursement of federal funds and required post-disbursement notifications to students, the College did no...

Condition: The College did not send out the post-disbursement email notifications to a group of students. Planned Corrective Action: While the College has documented procedures in place for the disbursement of federal funds and required post-disbursement notifications to students, the College did not properly send a post-disbursement notification to 591 out of 659 students who received federal financial aid loans in Fall 2023. The College will adjust its internal processes to ensure all students who receive federal loans are sent post-disbursement email notifications by performing a weekly review of the report that generates a names list of students that are receiving federal loans. If names exist on the report, a verification in the student record will be conducted to be sure the email was sent. After further investigation, all 608 students that received federal loans in spring semester 2024 and all 56 students in summer of 2024 received a post-disbursement notification. Contact person responsible for corrective action: Lisa Eiden, Director of Student Financial Services Anticipated Completion Date: Immediately

View Audit 340980

Finding 521061 (2024-002)

Significant Deficiency 2024

Watertown School District No. 14-4

SD

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

Finding 2024-002 Federal Agency Name: Department of Education Assistance Listing Number: #84.268 Program Name: Federal Direct Student Loans Finding Summary: 1 of the 60 students selected for testing the reporting of student status changes were reported with the incorrect enrollment status based on N...

Finding 2024-002 Federal Agency Name: Department of Education Assistance Listing Number: #84.268 Program Name: Federal Direct Student Loans Finding Summary: 1 of the 60 students selected for testing the reporting of student status changes were reported with the incorrect enrollment status based on NSLDS Enrollment Reporting guidance. 3 of the 60 students selected for testing the reporting of student status changes were reported to NSLDS with incorrect program begin dates based on NSLDS Enrollment Reporting guidance. 1 of the 60 students selected for testing the reporting of student status changes were reported to NSLDS with an incorrect status effective date based on NSLDS Enrollment Reporting guidance. Corrective Action Plan: LATC currently runs a SQL database script against the enrollment file before sending it to NSC. This script checks for missing and erroneous data (race/ethnicity, nondegree seeking majors, anticipated grad dates, etc.) in the file and updates it to correct values. The Director of Enrollment will work with the Database Administrator to regularly update these tables and review to ensure accurate information is being imported. The Registrar’s office will manually investigate these records and (if necessary) updated before sending the file to NSC. Every 30 days, representatives from the Financial Aid and the Registrar’s departments will pull 10 randomly selected student files to compare information in National Student Clearinghouse, PowerFaids, and NSLDS. The Director of Enrollment will work the error reports that the National Student Clearinghouse sends to LATC after every enrollment file upload with the assistance of the Database Administrator to ensure data submitted is compliant with DOE regulations. The Director of Financial Aid will review NSLDS to ensure corrections submitted by the Director of Enrollment are being properly recorded. Responsible Individual(s): Eric Schultz, Director of Enrollment and Kayla Bossly, Director of Financial Aid Anticipated Completion Date: Corrections complete by December 31, 2024. New process is ongoing.

View Audit 340969

Finding 521058 (2024-004)

Significant Deficiency 2024

Wagner Community Memorial Hospital

SD

Special Tests & Provisions Subrecipient Monitoring Significant Deficiency § 200.303

Federal Agency Name: Department of Agriculture Program Name: Community Facilities Loans and Grants Federal Financial Assistance Listing #10.766 Compliance Requirement: Special Test and Provisions Finding Summary: The Hospital’s reserve account is fully funded per the requirements in the loan resol...

Federal Agency Name: Department of Agriculture Program Name: Community Facilities Loans and Grants Federal Financial Assistance Listing #10.766 Compliance Requirement: Special Test and Provisions Finding Summary: The Hospital’s reserve account is fully funded per the requirements in the loan resolution security agreement. However, there is no documented secondary monitoring of the reserve balance as compared to the required minimum reserve balance. Responsible Individuals: Joshua Christensen, CFO Corrective Action Plan: The reserve account balance is monitored at each of the bi-monthly board of directors’ meetings. This review will include the current reserve account balance, the required minimum reserve account balance and a calculation to show the current balance is within compliance. The review and approval by the board of directors will be documented within the board minutes. Anticipated Completion Date: December 2024

View Audit 340965

Finding 520916 (2024-003)

Significant Deficiency 2024

Wheeling Jesuit University INC

WV

Student Financial Aid Special Tests & Provisions Reporting

Name of Responsible Individual: Shelia Yates-Mattingly, Registrar Corrective Action: In response to Finding 2024-003, Wheeling University will continue the enrollment reporting process that was implemented in October 2023, which was in response to Finding 2022-005 and continued with the Finding 2...

Name of Responsible Individual: Shelia Yates-Mattingly, Registrar Corrective Action: In response to Finding 2024-003, Wheeling University will continue the enrollment reporting process that was implemented in October 2023, which was in response to Finding 2022-005 and continued with the Finding 2023-005. With the stability of staffing in the Registrar’s Office and Financial Aid Office and the level of experience and competence of this staff, enrollment reporting has been completed within the parameters of regulatory guidelines. The Registrar’s Office submits enrollment reports as scheduled and subsequent error resolution reports as appropriate. The Financial Aid Office reviews identified NSLDS errors, corrects and resubmits them timely. Regularly scheduled meetings, including the Registrar’s and Financial Aid Offices, continue as noted in corrective actions for Findings 2022-005 and 2023-005. These meetings serve as the platform to discuss and address identified enrollment reporting concerns/issues timely, resulting in improved accuracy in enrollment reporting and timeliness in error resolution. In addition, attendance through Census will be monitored in an effort better identify registered but not enrolled students for administrative action and timely reporting. Institutional enrollment reports will be used to identify students who have chosen not to continue their studies at the University but without withdrawing from the institution to alert departments to execute their operational protocols for students who have discontinued enrollment. Students who officially withdraw pursuant to established University protocols will be required to consult with Financial Aid during this process. University departments will continue to be informed of student withdrawals as they occur to inform their practices. Anticipated Completion Date: Processes in place since October 2023 continue and new measures implemented January 2025

View Audit 340797

Finding 520912 (2024-004)

Significant Deficiency 2024

Wheeling Jesuit University INC

WV

Internal Control / Segregation of Duties Special Tests & Provisions Student Financial Aid

Name of Responsible Individual: Tracy Jenkins, Student Account Billing Coordinator Corrective Action: We recognized that students were not receiving the Right to Cancel notifications in a timely manner. We also understood the need for students to receive this information to make an important educ...

Name of Responsible Individual: Tracy Jenkins, Student Account Billing Coordinator Corrective Action: We recognized that students were not receiving the Right to Cancel notifications in a timely manner. We also understood the need for students to receive this information to make an important educational/fiscal decision. As of September 2023, on a monthly basis, notifications were sent to student University emails and parent’s personal email (Plus Loan recipients) informing them of their Right to Cancel. Anticipated Completion Date: September 2023

View Audit 340797

Finding 520909 (2024-009)

Significant Deficiency 2024

Wheeling Jesuit University INC

WV

Internal Control / Segregation of Duties Special Tests & Provisions Student Financial Aid

FINDING 2024-009 Name of Responsible Individual: Tracy Jenkins, Student Account Billing Coordinator Corrective Action: Wheeling University worked with ECSI regarding Perkins information. With the Perkins program ending, we realized that we needed to move in the direction of closing out Perkins ...

FINDING 2024-009 Name of Responsible Individual: Tracy Jenkins, Student Account Billing Coordinator Corrective Action: Wheeling University worked with ECSI regarding Perkins information. With the Perkins program ending, we realized that we needed to move in the direction of closing out Perkins files/information. The University is currently working with ECSI so that we are able to submit Perkins information/files to the Department of Education. We are gathering information (promissory notes, bankruptcy details, payment information, etc.) to assist ECSI with the process. Anticipated Completion Date: June 2025

View Audit 340797

Finding 520904 (2024-005)

Significant Deficiency 2024

Wheeling Jesuit University INC

WV

Questioned Costs Internal Control / Segregation of Duties Special Tests & Provisions

Name of Responsible Individual: Dylan J. Nowakowski, Director of Financial Aid Corrective Action: After Colleague was properly set up for Financial Aid for R2T4’s, the Director discovered that the calendars did not match the actual publicized academic calendar. Had the calendar been accurate with...

Name of Responsible Individual: Dylan J. Nowakowski, Director of Financial Aid Corrective Action: After Colleague was properly set up for Financial Aid for R2T4’s, the Director discovered that the calendars did not match the actual publicized academic calendar. Had the calendar been accurate with the correct dates of breaks of five days or more, then the R2T4 would have been accurate. The calendar in Colleague has now been corrected. For the years moving forward this will be verified before any R2T4 is calculated and submitted. All breaks that are five days or more are accurate. At Wheeling, we have a comprehensive R2T4 policy. This policy outlines how to count calendar days in a semester and provides clear instructions on what to do when a student withdraws during a break. Anticipated Completion Date: July 2024

View Audit 340797 Questioned Costs: $1

Finding 520894 (2024-001)

Significant Deficiency 2024

Bryant University

RI

Student Financial Aid Reporting Matching / Level of Effort / Earmarking

The University has taken the following steps to improve the accuracy and timeliness of enrollment reporting with respect to federal requirements. Summer withdrawals will now be reported directly to the National Student Clearinghouse (the Clearinghouse) as a service provider for transmissions of its ...

The University has taken the following steps to improve the accuracy and timeliness of enrollment reporting with respect to federal requirements. Summer withdrawals will now be reported directly to the National Student Clearinghouse (the Clearinghouse) as a service provider for transmissions of its enrollment reporting changes to the NSLDS at the time of withdrawal, ensuring timely and accurate reporting. The Registrar’s Office will submit a manual enrollment status change to the Clearinghouse. Since this audit finding was identified in the fall of 2024, the University had already reported all summer 2024 withdrawals during the first fall roster submission.

View Audit 340765

Finding 520888 (2024-001)

Significant Deficiency 2024

Rainbow Fleet, Inc.

OK

Eligibility Reporting Matching / Level of Effort / Earmarking § 200.512

Recommendation: We recommend that management implement processes to ensure timely completion and submission of the Single Audit report in future years. This could include setting internal deadlines, increasing oversight, and coordinating with the audit firm to identify and address potential delays e...

Recommendation: We recommend that management implement processes to ensure timely completion and submission of the Single Audit report in future years. This could include setting internal deadlines, increasing oversight, and coordinating with the audit firm to identify and address potential delays earlier in the audit process. Action Taken: Management agrees with the finding and will take steps to improve the timeliness of the audit process. Specifically, management has hired a new Chief Operating Officer and Chief Executive Officer who have been notified of the reporting requirements of the federal awards. Anticipated completion date: January 31, 2025 Name of contact person and title: Quisha Beardsley, Chief Executive Officer

View Audit 340750

Finding 520857 (2024-002)

None 2024

Williams College

MA

Student Financial Aid Reporting Eligibility

Management agrees with the finding and in concurrence with the recommendations the Registrar’s Office processes and documentation will be updated as follows: Major change process: If a request is submitted to drop a major while a student is on leave, the effective date will be recorded as the date...

Management agrees with the finding and in concurrence with the recommendations the Registrar’s Office processes and documentation will be updated as follows: Major change process: If a request is submitted to drop a major while a student is on leave, the effective date will be recorded as the date of the leave rather than the date the change was initiated. Leave of absence process: All withdrawals will be reported to the National Student Clearinghouse (NSC) manually within 2 weeks of being processed to avoid any delays or issues with the regularly scheduled Peoplesoft delivered report. If due to the schedule, a W status is reported via the delivered report instead of by hand, the person responsible for enrollment reporting will verify the status with the NSC, including program-level data. Ongoing training will be provided and a senior member of our staff will audit the major change and leave of absence processes moving forward. This corrective action plan has been implemented as of January 2025.

View Audit 340686

Finding 520845 (2024-002)

None 2024

Simpson University

CO

Student Financial Aid Reporting Matching / Level of Effort / Earmarking

Incorrect Enrollment Reporting to National Student Loan Data System (NSLDS) Planned Corrective Action: Our records indicate that the student's account at Simpson University was reported to the National Student Clearinghouse (NSC) on several occasions while the student was enrolled. It is the duty o...

Incorrect Enrollment Reporting to National Student Loan Data System (NSLDS) Planned Corrective Action: Our records indicate that the student's account at Simpson University was reported to the National Student Clearinghouse (NSC) on several occasions while the student was enrolled. It is the duty of the NSC program to ensure the accurate transmission of information to the National Student Loan Data System (NSLDS). Once the data leaves Simpson University, the university does not track its progress to other entities. It is recommended that any necessary adjustments be discussed directly with the NSC, particularly if issues arise from their data transfer to third parties. To ensure accuracy, various methods can be implemented, such as conducting random data audits to verify that the information sent to NSC matches that in the NSLDS. This process can be quite exhaustive. Alternatively, a sample audit might involve reviewing a certain error threshold; for instance, if 300 records are submitted, a check of 15-30 records could be performed, reflecting an error tolerance of approximately 5-10%. Another option is for the reporting body to collaborate with NSC in identifying any errors or complications that may affect the correct data transmission. Simpson University maintains evidence that all data submissions to the NSC have been properly reported, accepted, and timely without any discrepancies. Person Responsible for Corrective Action Plan: Adrienne Currington, Registrar Anticipated Date of Completion: Next NSC reporting cycle

View Audit 340662

Finding 520842 (2024-001)

Material Weakness 2024

Simpson University

CO

Student Financial Aid Matching / Level of Effort / Earmarking Material Weakness

Incorrect and Untimely Returns of Title IV Funds (R2T4) Calculations Planned Corrective Action: The University agrees with these findings. It was determined that these issues primarily resulted from a critical staff shortage in the Financial Aid Office during the audit period. This shortage signific...

Incorrect and Untimely Returns of Title IV Funds (R2T4) Calculations Planned Corrective Action: The University agrees with these findings. It was determined that these issues primarily resulted from a critical staff shortage in the Financial Aid Office during the audit period. This shortage significantly impacted our ability to complete R2T4 calculations accurately and withing the required timeframe. To address these findings, the institution will prioritize the recruitment and onboarding of additional qualified staff to alleviate workload challenges and support timely processing of R2T4s. Concurrently, we will provide comprehensive training to all financial aid staff, focusing on federal regulations, calculation methods, and deadlines. To reduce errors, we will establish a robust quality assurance process that includes a secondary review of all R2T4 calculations before finalization. Person Responsible for Corrective Action Plan: Shondra Dickson, Director of Financial Aid Anticipated Date of Completion: September 1, 2025

View Audit 340662

Finding 520751 (2024-002)

Significant Deficiency 2024

Loogootee Community School Corporation

IN

Internal Control / Segregation of Duties Subrecipient Monitoring Reporting § 200.302 § 200.303 § 200.328

The Corporation will have a secondary review process in place to assure the information and timeline are correct before submission.

View Audit 340471

Finding 520743 (2024-001)

Material Weakness 2024

Loogootee Community School Corporation

IN

Special Tests & Provisions Subrecipient Monitoring Material Weakness § 200.303

1. Anytime funds from Impace Aid are used for construction projects the Davis - Bacon wage rate requirements will be monitored. 2. An effective internal control system will be put in place.

View Audit 340471

Finding 520704 (2024-001)

Significant Deficiency 2024

San Joaquin College of Law

CA

Student Financial Aid Reporting Matching / Level of Effort / Earmarking

Financial aid will use an exception report created by IT to identify all currently enrolled students who are not included in the NSLDS Enrollment Report received every 60 days. Financial aid will use this exception report to verify all enrolled students who have current or previous loans are reporte...

Financial aid will use an exception report created by IT to identify all currently enrolled students who are not included in the NSLDS Enrollment Report received every 60 days. Financial aid will use this exception report to verify all enrolled students who have current or previous loans are reported correctly to NSLDS. The Financial Aid Dept will add a task to the August financial aid calendar to manually add/update all incoming 1L students' enrollment in NSLDS who have a current loan originated or showing previous loans in NSLDS. Financial Aid department will use the Enrolled Student Report for the fall semester from the student information system, Sonis, along with the actual disbursement report from Dept of Education's software, EDExpress, to identify students whose enrollment needs to be updated with NSLDS.

View Audit 340442

Finding 520624 (2024-001)

Material Weakness 2024

Milwaukee Institute of Art and Design, Inc.

WI

Reporting Special Tests & Provisions Student Financial Aid

2024-001 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 material weakness in internal control over compliance relating to special tes...

2024-001 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 material weakness in internal 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 accurately and timely reporting significant data elements under the Campus-Level and Program-Level records within the National Student Loan Data System (NSLDS) that DOE considers high risk. Statement of Condition: Management implemented controls that specifically addressed the some of the circumstances surrounding prior year finding 2023-001. Management's review of the enrollment reporting did not detect errors on certain student Program-Level data elements or timely reporting. Certain student records within the NSLDS were identified with inaccurate Program-Level data elements and not timely reported. Questioned Costs: There were no questioned costs. Context: 9 students were identified with inaccurate Program-Level data elements and not timely reported out of a total of 27 student statuses tested. The Campus-Level data elements were accurately and timely reported. Cause: The Institute’s internal control over compliance did not detect and correct the errors. The preparer incorrectly reported graduate file impacting the student's effective dates and statuses during submission process to NSLDS resulting in inaccuracies in significant Program-Level enrollment data elements that ED considers high risk. The Institute’s internal control over compliance did not detect and correct the error. Effect: The Institute incorrectly reported certain Program-Level records in NSLDS which is information that DOE considers high risk and the Institute’s internal controls over compliance did not detect and correct the errors. Recommendation: We recommend management review policies and procedures surrounding enrollment reporting submissions to ensure the accuracy of Program-Level data elements reported to DOE. A review performed by an appropriate individual separate from the preparer prior to the submission of the enrollment reports to NSLDS may improve the accuracy of enrollment reporting. Management’s Response: Management agrees with the finding. Through internal investigation, it was determined that the date field issues found in 2023 also impacted “special” files, which include graduate data files and are processed differently in-house. This error has been fixed so that both fields will always be the same and accurate using the same method as the 2023-001 finding. The registrar will now confirm both the student-level and program-level data fields upon submission to NSC. Status: Completed January 2024 Contact: Mark Fetherston Vice President for Enrollment Management 414-847-3215 markfetherston@miad.edu

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