Corrective Action Plans

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Management agrees with the finding and the recommendations made by the auditor. Over the next thirty days Management will analyze the enrollment reporting control environment including (but not limited to) how enrollment status effective dates, for students who withdrawal after the completion of the...
Management agrees with the finding and the recommendations made by the auditor. Over the next thirty days Management will analyze the enrollment reporting control environment including (but not limited to) how enrollment status effective dates, for students who withdrawal after the completion of the semester, are identified and accounted for by Management. Within forty-five days, Management will implement enhanced enrollment reporting processes to ensure accurate and timely enrollment statuses are reported to NSLDS in compliance with federal regulations.
The College agrees that Enrollment Reporting should be submitted in a timely manner. The College has been actively working with the new SIS to ensure the ability to produce the reports and has currently submitted reports through the Fall 2023 term. The College anticipates completion of reports throu...
The College agrees that Enrollment Reporting should be submitted in a timely manner. The College has been actively working with the new SIS to ensure the ability to produce the reports and has currently submitted reports through the Fall 2023 term. The College anticipates completion of reports through the Fall 2024 term by the end of December, resulting in compliance with this requirement.
Student Financial Assistance Cluster– 84.038 – Federal Perkins Loans Recommendation: We recommend that the University implement a procedure with the third-party servicer to ensure that its Title IV compliance report is completed in a timely manner so that the University can perform the necessary due...
Student Financial Assistance Cluster– 84.038 – Federal Perkins Loans Recommendation: We recommend that the University implement a procedure with the third-party servicer to ensure that its Title IV compliance report is completed in a timely manner so that the University can perform the necessary due diligence. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: For 22-23, the third-party servicer provided the compliance report in March 2024. For 23-24, the third-party servicer states the report should be available by the end of December 2024. Name(s) of the contact person(s) responsible for corrective action: Michael Dorner Planned completion date for corrective action plan: Already in place
Student Financial Assistance Cluster– Assistance Listing No. Various Recommendation: We recommend the University review its current policies and procedures around credit balances and ensure the processes in place are sufficient to ensure student credit balances due to federal funds are refunded with...
Student Financial Assistance Cluster– Assistance Listing No. Various Recommendation: We recommend the University review its current policies and procedures around credit balances and ensure the processes in place are sufficient to ensure student credit balances due to federal funds are refunded within 14 days. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: An internal tracker has been created for the entire team to report why a credit balance is not released to the student; and to monitor what steps are still needed to take to clear and release the credit balance. This will allow staff and the Financial Aid Director to quickly assist when staff is unexpectedly out of the office and connect with the necessary departments. Name(s) of the contact person(s) responsible for corrective action: Amanda McCaughan Planned completion date for a corrective action plan: Put into place November 2024
View Audit 329180 Questioned Costs: $1
Student Financial Assistance Cluster– Assistance Listing No. Various Recommendation: We recommend the University review its current policies and procedures around credit balances and ensure the processes in place are sufficient to ensure student credit balances due to federal funds are refunded with...
Student Financial Assistance Cluster– Assistance Listing No. Various Recommendation: We recommend the University review its current policies and procedures around credit balances and ensure the processes in place are sufficient to ensure student credit balances due to federal funds are refunded within 14 days. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: An internal tracker has been created for the entire team to report why a credit balance is not released to the student; and to monitor what steps are still needed to take to clear and release the credit balance. This will allow staff and the Financial Aid Director to quickly assist when staff is unexpectedly out of the office and connect with the necessary departments. Name(s) of the contact person(s) responsible for corrective action: Amanda McCaughan Planned completion date for a corrective action plan: Put into place November 2024
View Audit 329180 Questioned Costs: $1
Student Financial Assistance Cluster– Assistance Listing No. Various Recommendation: We recommend that the University implement a review process as it relates to R2T4. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding...
Student Financial Assistance Cluster– Assistance Listing No. Various Recommendation: We recommend that the University implement a review process as it relates to R2T4. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: A report was created in response to 2022-001 that pulls all students to verify no R2T4 are missed, it was put into place and pulled at the end of the semester. This did catch the 5 students, however, instead of running at the end of the semester, it now runs every 30 days to make sure students are processed within 45 days. Name(s) of the contact person(s) responsible for corrective action: Amanda McCaughan Planned completion date for a corrective action plan: The new process started in August 2024
Student Financial Assistance Cluster– Assistance Listing No. Various Recommendation: We recommend that the University implement a review process as it relates to R2T4. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding...
Student Financial Assistance Cluster– Assistance Listing No. Various Recommendation: We recommend that the University implement a review process as it relates to R2T4. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: A report was created in response to 2022-001 that pulls all students to verify no R2T4 are missed, it was put into place and pulled at the end of the semester. This did catch the 5 students, however, instead of running at the end of the semester, it now runs every 30 days to make sure students are processed within 45 days. Name(s) of the contact person(s) responsible for corrective action: Amanda McCaughan Planned completion date for a corrective action plan: The new process started in August 2024
View Audit 329180 Questioned Costs: $1
Student Financial Assistance Cluster– Assistance Listing No. Various Recommendation: We recommend the University review its reporting procedures to ensure the students’ statuses are accurately and timely reported to NSLDS as required by regulations. Explanation of disagreement with audit finding: Th...
Student Financial Assistance Cluster– Assistance Listing No. Various Recommendation: We recommend the University review its reporting procedures to ensure the students’ statuses are accurately and timely reported to NSLDS as required by regulations. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Registrar's Office did note that while nine students were flagged within the audit review, the final report does include an additional 18 students who were not brought to the attention of the Registrar’s Office during the audit. Action taken in response to finding: The Registrar's Office worked with the National Student Clearinghouse to identify new errors with CIP code rejects. We have now updated the curriculum in our SIS to eliminate the error and review the reject report for this specific error. The Registrar's Office will modify the report schedule with the National Student Clearinghouse to every three weeks to assist NSLDS with more time to update their website to align with compliance timelines. The National Student Clearinghouse records show the submission timeline. Name(s) of the contact person(s) responsible for corrective action: Lynn Lundquist Planned completion date for a corrective action plan: The new process started in August 2024
Inaccurate Packaging of Federal Direct Loans (FDL) Planned Corrective Action: Shorter University will provide additional training to Financial Aid Staff regarding the importance of reviewing students financial aid offers after manual adjustments are made. The training will include practice scenarios...
Inaccurate Packaging of Federal Direct Loans (FDL) Planned Corrective Action: Shorter University will provide additional training to Financial Aid Staff regarding the importance of reviewing students financial aid offers after manual adjustments are made. The training will include practice scenarios. In addition to training staff, Shorter University's Director of Information Technology is creating a quality control report that will identify students who may be eligible for a subsidized Stafford loan but have not received one. The report will be monitored by the Assistant Director of Financial Aid Systems who will review the students' financial aid. The quality control report will ensure the proper subsidized and unsubsidized Stafford loan allocation. A manual adjustment error was made to a student's financial aid offer, after financial aid was accepted resulting in an under awarding of a Stafford loan. A $3,500 unsubsidized loan to subsidized loan swap will be completed to hold the student harm less and correct the manual adjustment error. Person Responsible for Corrective Action Plan: Colleen Lassiter Anticipated Date of Completion: Training will be completed November 8, 2024 and Quality Control Report will be completed by December 15, 2024.
View Audit 329160 Questioned Costs: $1
Individual Responsible for Corrective Action: Sarah Christoffersen, Director of Financial Aid Corrective Action: An incorrect satisfactory academic progress tracking status was assigned to a single student, which resulted in the one student receiving federal aid for the spring semester when they sh...
Individual Responsible for Corrective Action: Sarah Christoffersen, Director of Financial Aid Corrective Action: An incorrect satisfactory academic progress tracking status was assigned to a single student, which resulted in the one student receiving federal aid for the spring semester when they should have been marked as ineligible. The spring disbursement was corrected promptly when uncovered and funds have been returned to ED. An enhanced system is now in place to more clearly track the satisfactory academic progress of students who take a leave of absence from the university and return without demonstrating satisfactory academic progress at a different school. Anticipated Completion Date: 11/1/2024
Individual Responsible for Corrective Action: Sarah Christoffersen, Director of Financial Aid Corrective Action: This finding cumulated into three different types of issues, summarized below, and corrective action has been taken for each of the three. In addition to addressing the three issues, tra...
Individual Responsible for Corrective Action: Sarah Christoffersen, Director of Financial Aid Corrective Action: This finding cumulated into three different types of issues, summarized below, and corrective action has been taken for each of the three. In addition to addressing the three issues, training has been provided to the financial aid staff for the verification process as a whole and a report is being run several times a month to identify possible data entry errors of the verification process. 3 of the 8 students had a discrepancy in their documentation that does not result in a change to their federal aid eligibility. This has been addressed by implementing an electronic signature of the verification worksheet through DocuSign. 3 of the 8 students submitted documentation for a professional judgement that was approved, however the professional judgement flag was not properly selected. This has been addressed by reviewing the professional judgement steps taken by the financial aid team and providing training to those who submit professional judgement changes in the FAFSA Partner Portal. 2 of the 8 students had incomplete documentation saved to the student file. This has been addressed by implementing an additional step in the verification process to require a second review of verification documents by two separate staff members. Anticipated Completion Date: 11/1/2024
Individual Responsible for Corrective Action: Sarah Christoffersen, Director of Financial Aid Corrective Action: All instances of this finding occurred during the fall 2023 semester while we were still in the implementation process for joining the National Student Clearinghouse. Since completing im...
Individual Responsible for Corrective Action: Sarah Christoffersen, Director of Financial Aid Corrective Action: All instances of this finding occurred during the fall 2023 semester while we were still in the implementation process for joining the National Student Clearinghouse. Since completing implementation, there have been no further instances. Anticipated Completion Date: Completed
Views of Responsible Officials and Planned Corrective Actions – The National Student Clearinghouse (NSC) Graduation Status submission calendar will be updated to reflect the necessary reporting timeline and appropriate parties within the Office of the Registrar, Student Financial Services, and Offic...
Views of Responsible Officials and Planned Corrective Actions – The National Student Clearinghouse (NSC) Graduation Status submission calendar will be updated to reflect the necessary reporting timeline and appropriate parties within the Office of the Registrar, Student Financial Services, and Office of Institutional Effectiveness will be held responsible for specific deadlines each month. The report will be completed after verification of graduation requirements and credentialing or other status changes are completed in Colleague by the Registrar's Office. Ellucian Colleague processes will be fully utilized for NSC file generation. The Registrar and Associate Registrar complete different steps in the credentialing process, but will review the student records together to ensure accuracy and timely completion. Submission of graduation status to NSC will occur after each academic term (fall and spring semester, January and summer sessions) and submission of other status changes will occur monthly and follow-ups will occur within four business days.
Need Analysis Planned Corrective Action: To ensure compliance with Needs Analysis regulations for the limitations of keeping aid within the Cost of Attendance (COA) both during R2T4 calculations and in overall packaging, Point Loma will use system-specific configuration our new Workday Student Finan...
Need Analysis Planned Corrective Action: To ensure compliance with Needs Analysis regulations for the limitations of keeping aid within the Cost of Attendance (COA) both during R2T4 calculations and in overall packaging, Point Loma will use system-specific configuration our new Workday Student Financial Aid software: • Disbursement Eligibility criteria that flags “Exceeds COA”, preventing disbursement • Automatic calculations of the COA based on the number of weeks in which the student is enrolled. (Our previous software required all manual review and adjustments to COA when a student was only enrolled in a single module.) Any changes to the number of weeks or to enrollment as a whole, will result in a Need Packaging Reaction, prompting staff to re-run Cost of Attendance calculations and Need Packaging as needed. Furthermore, Point Loma will review and revise procedures for mandatory recalculations of COA, and train staff on these procedures. Person Responsible for Corrective Action Plan: Daniel Reed, Director of Financial Aid Jamie Asche, Director of SFS Business Analysis and Compliance Joanna Castro, Associate Director of Financial Aid, GPS Anticipated Date of Completion: December 31,2024
Return of Title IV (R2T4) Calculations Planned Corrective Action: To ensure compliance with R2T4 regulations for modules and the consideration of days, Point Loma will review and revise procedures for completion and clarity, and train staff on these procedures. Person Responsible for Corrective Acti...
Return of Title IV (R2T4) Calculations Planned Corrective Action: To ensure compliance with R2T4 regulations for modules and the consideration of days, Point Loma will review and revise procedures for completion and clarity, and train staff on these procedures. Person Responsible for Corrective Action Plan: Daniel Reed, Director of Financial Aid Jamie Asche, Director of SFS Business Analysis and Compliance Joanna Castro, Associate Director of Financial Aid, GPS Anticipated Date of Completion: December 31,2024
October 22, 2024 RE: Finding 2024-001 Student Financial Aid Cluster Enrollment Reporting - Clearinghouse for National Student Loan Data (NSLDS) enrollment reporting for the Fall 2023 and Spring 2024 semesters. Student Affair’s response and corrective action plan. Purpose of Student Reporting Student...
October 22, 2024 RE: Finding 2024-001 Student Financial Aid Cluster Enrollment Reporting - Clearinghouse for National Student Loan Data (NSLDS) enrollment reporting for the Fall 2023 and Spring 2024 semesters. Student Affair’s response and corrective action plan. Purpose of Student Reporting Student enrollment reporting is critical, as it is sent to the National Student Clearinghouse, which then provides this data to the National Student Loan Data System (NSLDS). This information is used to determine students' enrollment status, which is essential for the administration of financial aid, particularly for calculating grace periods and repayment timelines for student loans. Corrective Actions and Process Changes Once we identified the reporting issue, we re-ran the reports using the previous method, prior to the saved list implementation, to compare the results. We thoroughly reviewed the enrollment numbers for both semesters to ensure all students were correctly reported. In addition, we contacted the National Student Clearinghouse to make the necessary corrections. To ensure this issue is fully resolved moving forward, we have implemented a more rigorous internal process, including thorough testing and random sampling. We now compare reported enrollment data against actual student enrollment for each semester, allowing us to verify that all students are accurately reported. These enhanced measures will safeguard against similar oversights in the future. Challenges with Clearinghouse Resolution While we completed our internal corrections, we experienced significant delays in finalizing the data updates due to customer service challenges on the National Student Clearinghouse’s side. After escalating the issue, we were able to receive assistance from a representative on October 23rd, which we believe will resolve the discrepancies. Expected completion date: 10/31/24 Partys Responsible: Dr. Jason Johnson, Vice President for Student Affairs - Amanda Williams- Mize, Assistant Vice President for Enrollment Services, Registrar Contact Information: jason.k.johnson@occc.edu 405-682-1611 ext. 7784 amanda.williams-mize@occc.edu, 405-682-7537
Significant Deficiencies: Finding: 2024-002 Segregation of Duties Name of Contact Person: Wendy Duckett, Housing Director Corrective Action: The duties will be separated as much as possible and alternative controls will be used to compensate for lack of separation. The governing board will continue ...
Significant Deficiencies: Finding: 2024-002 Segregation of Duties Name of Contact Person: Wendy Duckett, Housing Director Corrective Action: The duties will be separated as much as possible and alternative controls will be used to compensate for lack of separation. The governing board will continue to approve and sign checks and periodically review the financial statements. Proposed Completion Date: The Board will implement the above procedure immediately. Findings and Questioned Costs - Major Federal Awards Programs Audit Finding: 2024-002 Segregation of Duties Same as above.
Finding 2024-001: Internal Controls Over Monthly Meal Claims Reports Type of Finding: Control U.S. Department of Agriculture Pass-through Entity: Michigan Department of Education Assistance Listing Number: 10.553, 10.555 and 10.559 Award Numbers: 231970, 241970, 231960, 241960, Bonus and Ent...
Finding 2024-001: Internal Controls Over Monthly Meal Claims Reports Type of Finding: Control U.S. Department of Agriculture Pass-through Entity: Michigan Department of Education Assistance Listing Number: 10.553, 10.555 and 10.559 Award Numbers: 231970, 241970, 231960, 241960, Bonus and Entitlement Commodities, 230900 and 240900 Award Year End: September 30, 2023 and September 30, 2024 Recommendation: The School District should follow established procedures to require the documented review and approval of all reports by an individual with adequate skills, knowledge, and experience prior to submission. Action Taken: The School District has implemented a new procedure requiring that all reports be reviewed and approved by a designated reviewer before submission. The reviewer, who must possess the appropriate skills, knowledge, and experience relevant to the report's content, will ensure that the information is accurate, complete, and compliant with organizational standards and regulatory requirements. Responsible Person and Anticipated Completion Date: Food Service Director, October 2024 If the Michigan Department of Education has questions regarding this plan, please call Todd Hronek at (231) 788-7109.
2024-003 FINDING Contact Person – Mark Lundin, Superintendent Corrective Action Plan – The District will review policies and procedures for submitted certified payrolls. Completion Date – November 30, 2024
2024-003 FINDING Contact Person – Mark Lundin, Superintendent Corrective Action Plan – The District will review policies and procedures for submitted certified payrolls. Completion Date – November 30, 2024
2024-001: Late Return of Title IV Financial Aid - Student Financial Aid Cluster – Assistance Listing #s 84.007, 84.033, 84.063, 84.268 - Grant Period - Year Ended June 30, 2024 Condition Found During our Return of Title IV Fund testing, we noted that the College did not calculate or return Title IV ...
2024-001: Late Return of Title IV Financial Aid - Student Financial Aid Cluster – Assistance Listing #s 84.007, 84.033, 84.063, 84.268 - Grant Period - Year Ended June 30, 2024 Condition Found During our Return of Title IV Fund testing, we noted that the College did not calculate or return Title IV Student Financial Aid for two out of twenty-five students tested until after 45 days when the student ceased attendance. We consider the untimely calculation and Return of Title IV Student Financial Aid to be an instance of noncompliance relating to the Special Tests and Provisions Compliance Requirement. Corrective Action Plan The weekly R2T4 report that identifies student withdrawals will be reviewed on a weekly basis. During these reviews we will focus on the timely calculation and disbursement of earned Title IV aid. Responsible Person for Corrective Action Plan Ana Mirnic, Financial Aid Program Manager Leana Davis, Executive Director of Financial Aid Implementation Date of Corrective Action Plan October 1, 2024
View Audit 328820 Questioned Costs: $1
The District did not familiarize itself with all the types of compliance requirements for federal grants received. In the future, the District will designate the employee responsible for each grant to become educated on all grant compliance items, and to communicate those items to all necessary par...
The District did not familiarize itself with all the types of compliance requirements for federal grants received. In the future, the District will designate the employee responsible for each grant to become educated on all grant compliance items, and to communicate those items to all necessary parties. The Superintendent will discuss this matter with all applicable personnel on or before November 1, 2024.
View Audit 328715 Questioned Costs: $1
Finding 2024-002 Reporting-According to 34 CFR 690.83, Dear Colleague Letter Gen 13-13, and Federal Register Volume 84, Number 212, November 1, 2019 an institution must submit Pell and Direct Loan Origination and Disbursement (COD) in imely and accurate manner Condition-Cost of attendance per the C...
Finding 2024-002 Reporting-According to 34 CFR 690.83, Dear Colleague Letter Gen 13-13, and Federal Register Volume 84, Number 212, November 1, 2019 an institution must submit Pell and Direct Loan Origination and Disbursement (COD) in imely and accurate manner Condition-Cost of attendance per the College's system did not agree with the reported cost of attendance reported per COD records. Corrective Action Plan-A periodic check will be done to ensure Banner and the COD system have the same COA. If systems do not match Financial Aid Director will work with COD and Ellucian to resolve the issue Responsible contact-Lynette Viskozki, Financial Aid Director Anticipated Completion-December 1, 2024
2024-005 Initial Fiscal Year End, 2024 Summary of Finding- During the audit, it was noted that the University returned funds in an incorrect sequence during the Return to Title IV Funds process upon student withdrawal. Name and Title of Responsible Contact Person(s)- Sara Shepherd, Vice President fo...
2024-005 Initial Fiscal Year End, 2024 Summary of Finding- During the audit, it was noted that the University returned funds in an incorrect sequence during the Return to Title IV Funds process upon student withdrawal. Name and Title of Responsible Contact Person(s)- Sara Shepherd, Vice President for Finance and Nicole Umphlett, Financial Aid Administrator Corrective Action Plan Summary-The University's Vice President of Finance and Financial Aid Administrator recently attended a week-long workshop and received training to complete the R2T4 calculation via COD. The training was received after the infringements and a plan has been adapted to utilize COD for future R2T 4 calculations and sequence. The school calendar has been updated in COD for correct future calculations and sequence. Anticipated Completion Date- July 1, 2025
2024-004 Initial Fiscal Year End, 2024 Summary of Finding- During the audit, it was noted that the University used the incorrect sum of aid disbursed or disbursable to the student when applying the percentage earned in calculating the return to Title IV Funds upon student withdrawal. Name and Title ...
2024-004 Initial Fiscal Year End, 2024 Summary of Finding- During the audit, it was noted that the University used the incorrect sum of aid disbursed or disbursable to the student when applying the percentage earned in calculating the return to Title IV Funds upon student withdrawal. Name and Title of Responsible Contact Person(s)- Sara Shepherd, Vice President for Finance and Nicole Umphlett, Financial Aid Administrator Corrective Action Plan Summary-The University has enhanced the process of completing return to Title IV calculations by incorporating additional training and workshops provided by the Department of Education. The financial aid office has continued with the implementation of the calendar that displays the attendance days from the first day of school to the last day of school, referring to the school's master calendar. The financial aid office added an extra verification step of written notification from the Registrar's office of beginning and end days for each semester. The return calculations were one day off due to the misinterpretation of the semester's ending date. Anticipated Completion Date- July 1, 2025
View Audit 328701 Questioned Costs: $1
2024-003 Initial Fiscal Year End, 2024 Summary of Finding- During the audit, it was noted that the University used the incorrect number of total days in the payment period or period of enrollment in calculating the percentage of payment period and/or period of enrollment completed. Name and'Title of...
2024-003 Initial Fiscal Year End, 2024 Summary of Finding- During the audit, it was noted that the University used the incorrect number of total days in the payment period or period of enrollment in calculating the percentage of payment period and/or period of enrollment completed. Name and'Title of Responsible Contact Person(s)- Sara Shepherd, Vice President for Finance and Nicole Umphlett, Financial Aid Administrator Corrective Action Plan Summary-The University improved the process for completing return to Title IV calculations by adding in additional training and workshops offered through the Department of Education. The financial aid office continued with the calendar process showing days of attendance from the first day of school to the last using the school's master calendar as a reference. This will be used also as a double check of days when calculating returns. The dates used in the return calculations were off a day due to misreading the ending date of semester. The Financial Aid Administrator verified the beginning and last day of each semester with the Registrar's office in writing. Anticipated Completion Date- July 1, 2025
View Audit 328701 Questioned Costs: $1
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