Corrective Action Plans

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

View Audit 331386

Finding 513490 (2024-001)

Significant Deficiency 2024

Job Training & Employment Corporation

MA

Matching / Level of Effort / Earmarking

JTEC is aware of the requirement and did all it could to be compliant. The lack of enrollment is something that was out of JTEC’s control. JTEC runs one of the many MassHire career centers in the state that struggled meeting this Federal requirement. In addition, JTEC communicated the issue to MDCS....

JTEC is aware of the requirement and did all it could to be compliant. The lack of enrollment is something that was out of JTEC’s control. JTEC runs one of the many MassHire career centers in the state that struggled meeting this Federal requirement. In addition, JTEC communicated the issue to MDCS. JTEC has established a separate youth and testing center, designed to cater to the specific needs and preferences of youth participants. In addition to keeping in regular contact with school guidance departments and student support staff, JTEC’s youth counselor continues to connect with juvenile court and probation officers, and works with the department of transitional assistance young parent program staff to encourage referrals to JTEC’s youth programs. JTEC is running an aggressive schedule of digital marketing campaigns that target youth in our service delivery area. JTEC has contracted with various vendors for content and distribution of these campaigns. JTEC has also increased its youth work experience wage, and has revised its support services and incentives policy to make incentives for youth participation more appealing. Increasing awareness of the out of school youth services available, ensuring that the youth program design and implementation match the needs of youth in our area, and maintaining strong relationships in our referral networks is JTEC’s strategy to increase out of school youth enrollments and youth work experience participation.

View Audit 331372

Finding 513474 (2024-001)

None 2024

Fox Valley Technical College District

WI

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

It is our understanding that issues are occurring for many institutions and appear to be due to changes in processes at the National Student Clearinghouse (NSC). We will monitor steps taken, updates and/or guidance made by NSC and professional organizations such as NASFAA to maintain awareness of an...

It is our understanding that issues are occurring for many institutions and appear to be due to changes in processes at the National Student Clearinghouse (NSC). We will monitor steps taken, updates and/or guidance made by NSC and professional organizations such as NASFAA to maintain awareness of any resolution to the issue identified. We will leverage the capabilities of our new student information system to use last dates of attendance for reporting enrollment statuses to NSC, as well as provide additional communication to faculty regarding the requirement to enter grades and last dates of attendance accurately and timely. Additionally, we will establish an internal process to review and update student status effective dates reported to NSC, ensuring they align with the last dates of attendance used in Return of Title IV calculations.

View Audit 331355

Finding 513461 (2024-001)

Significant Deficiency 2024

Moraine Valley Community College District Number 524

IL

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

Corrective Action Planned: The Director of Financial Aid will identify unofficial withdrawals through the R2T4 process. Financial Aid staff will use the NSLDS Enrollment History Update feature to adjust historical changes directly. This ensures that the Clearinghouse sends an updated certification o...

Corrective Action Planned: The Director of Financial Aid will identify unofficial withdrawals through the R2T4 process. Financial Aid staff will use the NSLDS Enrollment History Update feature to adjust historical changes directly. This ensures that the Clearinghouse sends an updated certification of current enrollment status to NSLDS, avoiding any disruption in the NSLDS SSCR Roster process and preventing data from being unintentionally overwritten. For these historical changes, once the NSLDS is updated, the Director of Financial Aid will notify the Assistant Dean of Enrollment Services. The Assistant Dean will then update the Clearinghouse records accordingly, ensuring the enrollment is rebuilt to prevent backdated data from being overwritten. Anticipated Completion Date: June 30, 2025 Responsible Person: Tasha Campbell, Director of Financial Aid campbellt68@morainevalley.edu

View Audit 331335

Finding 513458 (2024-001)

Significant Deficiency 2024

Gateway Techincal College District

WI

Student Financial Aid Reporting Significant Deficiency

U.S. Department of Education Gateway Technical College District respectfully submits the following corrective action plan for the year ended June 30, 2024. Audit period: July 1, 2023 – June 30, 2024 The findings from the schedule of findings and questioned costs are discussed below. The findings ...

U.S. Department of Education Gateway Technical College District respectfully submits the following corrective action plan for the year ended June 30, 2024. Audit period: July 1, 2023 – June 30, 2024 The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. FINDINGS—FINANCIAL STATEMENT AUDIT Our audit did not disclose any matters required to be reported in accordance with Government Auditing Standards. FINDINGS—FEDERAL AWARD PROGRAMS AUDITS U.S. Department of Education 2024-001 Student Financial Aid Cluster – Assistance Listing No. 84.063, 84.268 Recommendation: We recommend that the District review its processes and internal controls designed to mitigate the risk of noncompliance with the stated criteria to ensure the information reported to NSLDS is consistent with District records. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The District will take corrective action to correct the information for the one (1) exception noted in the audit. In addition, the District will review its procedures for the transmission of the required data to the National Student Clearinghouse, which assists the District in transmitting the data to the National Student Loan Data System. This review will include consideration of process enhancement to mitigate the risk of the error occurring again in future submissions. Name of the contact person responsible for corrective action: Travis Jansen, Registrar Planned completion date for corrective action plan: June 30, 2025 *** If the U.S. Department of Education has questions regarding this plan, please call Travis Jansen, Registrar at 262-564-2450.

View Audit 331307

Finding 513409 (2024-003)

None 2024

The Open Door Network

CA

Questioned Costs Matching / Level of Effort / Earmarking Subrecipient Monitoring

Managements Response/Planned Corrective Action: Beginning immediately, the Organization's Program Directors will review their ESG programs matching requirements to familiarize themselves with the amount of required match, and work with the Organization's Controller to identify program needs for whi...

Managements Response/Planned Corrective Action: Beginning immediately, the Organization's Program Directors will review their ESG programs matching requirements to familiarize themselves with the amount of required match, and work with the Organization's Controller to identify program needs for which matching funds can be used. The Organizations Controller will ensure that these expenditures are tracked in the Accounting software. Led by the Compliance Manager and Controller, a review process will be implemented with the grants, accounting and compliance team before any grant is submitted to ensure the Organization can obtain the match. This will be completed by February 2025.

View Audit 331259 Questioned Costs: $1

Finding 513404 (2024-002)

None 2024

The Open Door Network

CA

Matching / Level of Effort / Earmarking Subrecipient Monitoring

Management's Response/Planned Corrective Action: Beginning immediately, the Organization's Program Directors will review their Continuum of Care Programs matching requirements to familiarize themselves with the amount of required match, and work with the Organizations Controller to identify program...

Management's Response/Planned Corrective Action: Beginning immediately, the Organization's Program Directors will review their Continuum of Care Programs matching requirements to familiarize themselves with the amount of required match, and work with the Organizations Controller to identify program needs for which matching funds can be used. The Organization's Controller will ensure that these expenditures are tracked in the Accounting software. Led by the Compliance Manager and Controller, a review process will be implemented with the grants, accounting, and compliance team before any grant is submitted to ensure the Organization can obtain the match. This will be completed by February 2025.

View Audit 331259

Finding 513383 (2024-003)

Significant Deficiency 2024

Platte Health Center

SD

Significant Deficiency Matching / Level of Effort / Earmarking Internal Control / Segregation of Duties § 200.303

Federal Agency Name: Department of Agriculture Program Name: Communities Facilities Loans and Grants Federal Financial Assistance Listing #10.766 Finding Summary: The Health Center does not have a formally documented review and approval process in place to ensure compliance with the debt service co...

Federal Agency Name: Department of Agriculture Program Name: Communities Facilities Loans and Grants Federal Financial Assistance Listing #10.766 Finding Summary: The Health Center does not have a formally documented review and approval process in place to ensure compliance with the debt service coverage ratio and working capital calculations. Responsible Individuals: Vicki Jensen, Chief Financial Officer Corrective Action Plan: Platte Health Center will perform debt service ratio and working capital calculations as part of their year-end close process. The calculations will be reported to the Board of Directors and be recorded in the meeting minutes. Anticipated Completion Date: June 30, 2025

View Audit 331222

Finding 513260 (2024-002)

None 2024

Dallas Christian College

TX

Questioned Costs Eligibility Matching / Level of Effort / Earmarking

Need Analysis and Estimated Financial Assistance Planned Corrective Action: The new student information system adopted this fall will help avoid this issue. In addition, students with high SAIs will be monitored more closely to ensure scholarships and need based aid are being applied appropriately....

Need Analysis and Estimated Financial Assistance Planned Corrective Action: The new student information system adopted this fall will help avoid this issue. In addition, students with high SAIs will be monitored more closely to ensure scholarships and need based aid are being applied appropriately. Person Responsible for Corrective Action Plan: Jean-Claude St Juste, Financial Aid Director Anticipated Date of Completion: December 31, 2024

View Audit 331201 Questioned Costs: $1

Finding 513244 (2024-001)

Significant Deficiency 2024

Mississippi College

MS

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

2024 –001 Special Tests and Provisions – Return to Title IV Program: Student Financial Assistance Cluster Assistance Listing Numbers 84.007, 84.033, 84.063, 84.268, 84.379 Name of Contact Person: Tawesia Colyer, Director of Financial Aid Corrective Action: Due to turnover in the Financial Aid Depart...

2024 –001 Special Tests and Provisions – Return to Title IV Program: Student Financial Assistance Cluster Assistance Listing Numbers 84.007, 84.033, 84.063, 84.268, 84.379 Name of Contact Person: Tawesia Colyer, Director of Financial Aid Corrective Action: Due to turnover in the Financial Aid Department, the number of break days related to whole week breaks was entered into the academic calendar as 7 days instead of the correct 9 days. The process surrounding the entering of days into the academic calendar for breaks and the process for the calculation of any return of Title IV funds has been corrected for this matter. A new process went into effect as of August 1, 2024, and includes updating Policy and Procedures on R2T4 as well as more in-depth training for the Financial Aid staff. A back-up financial aid counselor to assist in R2T4 has been added and is involved in all training. All R2T4 withdrawals requiring a calculation are being added to a spreadsheet for review with the Director of Financial Aid which will be completed each semester. Additionally, the Office of Business Affairs has begun implementing internal control procedures to serve as a detective control. Of note, the calculations used in the 2023-2024 academic year resulted in no questioned costs and an over-return of funds to the U.S. Department of Education. Anticipated Completion Date: December 31, 2024

View Audit 331197

Finding 513227 (2024-005)

Material Weakness 2024

Southwestern Oregon Community College

OR

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

Student Financial Assistance Cluster – Assistance Listing No. 84.063,84.268 Recommendation: We recommend the college evaluate its policies and procedures around reporting to COD to ensure that information is reported accurately and timely and to retain evidence of the key control having occurred. Ex...

Student Financial Assistance Cluster – Assistance Listing No. 84.063,84.268 Recommendation: We recommend the college evaluate its policies and procedures around reporting to COD to ensure that information is reported accurately and timely and to retain evidence of the key control having occurred. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Additional staff member will review COD reports before they are submitted via EdConnect. Name(s) of the contact person(s) responsible for corrective action: Avena Singh Planned completion date for corrective action plan: November 2024

View Audit 331167

Finding 513223 (2024-004)

Material Weakness 2024

Southwestern Oregon Community College

OR

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

Student Financial Assistance Cluster – Assistance Listing No. 84.007,84.033,84.063,84.268 Recommendation: We recommend the College implement a formal documented review process for the R2T4 process. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Actio...

Student Financial Assistance Cluster – Assistance Listing No. 84.007,84.033,84.063,84.268 Recommendation: We recommend the College implement a formal documented review process for the R2T4 process. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Staff in Business Office to now double-check and sign off on R2T4s after Financial Aid processes. Name(s) of the contact person(s) responsible for corrective action: Avena Singh Planned completion date for corrective action plan: November 2024.

View Audit 331167

Finding 513219 (2024-003)

Material Weakness 2024

Southwestern Oregon Community College

OR

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

Student Financial Assistance Cluster – Assistance Listing No. 84.007,84.033,84.063,84.268 Recommendation: We recommend the college implement changes in process and procedures for NSLDS enrollment reporting and implement an internal control that ensures reporting is both timely and accurate. Explanat...

Student Financial Assistance Cluster – Assistance Listing No. 84.007,84.033,84.063,84.268 Recommendation: We recommend the college implement changes in process and procedures for NSLDS enrollment reporting and implement an internal control that ensures reporting is both timely and accurate. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Continue to review policies and procedures for accurate reporting. Investigate and identify discrepancies being exported by the Student Information System (Jenzabar). Have additional staff member review file and sign off before the data is submitted. Name(s) of the contact person(s) responsible for corrective action: Avena Singh Planned completion date for corrective action plan: March 2025

View Audit 331167

Finding 513215 (2024-002)

Significant Deficiency 2024

Southwestern Oregon Community College

OR

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

Student Financial Assistance Cluster– Assistance Listing No. 84.007,84.033,84.063,84.268 Recommendation: We recommend that the college review the process packaging awards and adjusting awards after they are packaged to ensure that the student’s subsidized loan award is calculated correctly, and stud...

Student Financial Assistance Cluster– Assistance Listing No. 84.007,84.033,84.063,84.268 Recommendation: We recommend that the college review the process packaging awards and adjusting awards after they are packaged to ensure that the student’s subsidized loan award is calculated correctly, and student is not under awarded. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Student’s record has been updated to reflect proper Direct Subsidized Stafford Loan. School will create validation reports run regularly to find any records that may need further review. Name(s) of the contact person(s) responsible for corrective action: Avena Singh Planned completion date for corrective action plan: Incorrect student record fixed November 2024. Validation report shall be completed before February 2025.

View Audit 331167

Finding 513148 (2024-001)

Significant Deficiency 2024

Central Wyoming College

WY

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

The Student Financial Aid Office and The Office of Student Records will work closely to ensure students date of withdrawal from all courses are entered into Colleague correctly and that both offices dates match. The Office of Student Records will provide the National Clearinghouse enrollment reporti...

The Student Financial Aid Office and The Office of Student Records will work closely to ensure students date of withdrawal from all courses are entered into Colleague correctly and that both offices dates match. The Office of Student Records will provide the National Clearinghouse enrollment reporting dates for Central Wyoming College to the Financial Aid Office. This will ensure the Financial Aid Office provides the Office of Student Records the Return to Title IV student report in a timely manner for reporting to the Clearinghouse. The Registrar will make sure any student on the Return to Title IV list has a record on the National Clearinghouse for program - level and campus- level reporting. The Registrar will verify all students on the Return to Title IV list are showing correctly on the Clearinghouse upon submittal. The Director of Financial Aid and the Registrar will meet monthly to review the Return to Title IV lists provided to the Registrar match NSLDS to ensure status dates for all Return to Title IV students are accurately reflected. The Director of Financial Aid will also communicate any issues found with statuses on the NSLDS site with the Registrar. The Director of Financial Aid in collaboration with the Office of Student Records will work to obtain and review the SOC1 report from the third-party servicer (Clearing house) to ensure proper controls are implemented. Anticipated Completion Date – December 1, 2024 Contact Person(s) – DeeAnna Archuleta, SFA Director Connie Nyberg - Registrar

View Audit 331134

Finding 513130 (2024-002)

Significant Deficiency 2024

University of Western States

OR

Student Financial Aid Reporting Matching / Level of Effort / Earmarking

Identifying Number: 2024-002 Finding: Special Tests: Enrollment Reporting – Improper Reporting of Withdrawal Date Applicable Regulation: Per the National Student Loan Data System (NSLDS) enrollment reporting guide (Section 4.4.3) when a student withdraws during a term, the effective date for the wi...

Identifying Number: 2024-002 Finding: Special Tests: Enrollment Reporting – Improper Reporting of Withdrawal Date Applicable Regulation: Per the National Student Loan Data System (NSLDS) enrollment reporting guide (Section 4.4.3) when a student withdraws during a term, the effective date for the withdrawn status is the withdrawal date used by the Institution in accordance with 34 CFR 668.22. Finding: 3 out of a total of 24 students tested for enrollment reporting in NSLDS had an incorrect date listed as the effective date of the student’s enrollment status. Summary: During our enrollment testing, we noted that the effective date of withdrawal in NSLDS for 3 students tested was incorrectly listed as the date of determination by UWS instead of the withdrawal date determined in accordance with 34 CFR 668.22. Internal controls in place did not identify the errors. Three students with incorrect enrollment reporting dates were due to the student’s out of school status treated by the relevant University department as an unofficial withdrawal instead of an official withdrawal for enrollment reporting purposes. The Dates of Determination were therefore used incorrectly. Corrective Action Planned or Taken: The University of Western States has updated its policy for all out of school and reporting for all out of school students. Additionally, an internal Decision Tree resource document has also been created for use when processing student withdrawals and reporting student statuses. All out of school students will have the appropriate out of school date selected and submitted for enrollment roster reporting based on the updated policy and the supplemental Decision Tree. UWS staff has also reviewed all students and confirms reporting statuses align with the updated policy. Contact Person: Michelle Miller, Senior Vice President of Enrollment Management mmiller10@tcsedsystem.edu Anticipated Completion Date: September 17, 2024

View Audit 331120

Finding 513129 (2024-001)

Significant Deficiency 2024

University of Western States

OR

Questioned Costs Eligibility Matching / Level of Effort / Earmarking

Identifying Number: 2024-0001 Finding: Eligibility – Determining Federal Direct Student Loan Awards Applicable Regulation: Per 34 CFR 685.203(b)(iii), in the case of a graduate or professional student for a period of enrollment beginning on or after July 1, 2012, the total amount the student may bo...

Identifying Number: 2024-0001 Finding: Eligibility – Determining Federal Direct Student Loan Awards Applicable Regulation: Per 34 CFR 685.203(b)(iii), in the case of a graduate or professional student for a period of enrollment beginning on or after July 1, 2012, the total amount the student may borrow for any academic year of study under the Unsubsidized Loan program may not exceed $8,500. Per 34 CFR 685.203(c)(2)(v), the additional amount that a student described in paragraph (c)(1)(i) of this section may borrow under the Direct Unsubsidized Loan Program for any academic year of student may not exceed the following: in the case of a graduate or professional student, $12,000. Finding: UWS improperly awarded 6 out of 6 students Unsubsidized Federal Direct Loans in excess of the maximum amount for one academic year of $20,500. Summary: During testing of eligibility, six out six students selected for testing within the Doctor of Naturopathic Program were overawarded Unsubsidized Federal Direct Loans. Eligibility testing was performed over 40 other students with no exceptions. We determined that UWS improperly awarded 6 out of 6 students Unsubsidized Federal Direct Loans in excess of the maximum amount for one academic year of $20,500. The total overawards accumulated to $119,443 in total loan funds. The students were awarded the higher annual Direct Unsubsidized Loan limits for certain graduate and professional health professions students. Schools may award the increased unsubsidized amounts to students who are enrolled at least half time in certain health professions programs. The programs must be accredited by specific accrediting agencies for students to qualify for additional unsubsidized loan amounts. The UWS Naturopathic Medicine Doctoral program has not yet achieved the required accreditation from The Council on Naturopathic Medical Education Corrective Action Planned or Taken: During the course of an internal audit of student awards in the Naturopathic Medicine Doctoral program it was determined that the required programmatic accreditation had not been achieved from the Council on Naturopathic Medical Education to qualify for the additional Health Professions unsubsidized loan eligibility. As a result of this finding a thorough audit was completed for all students that were enrolled in the program since the first class began in October of 2023. In total six students were identified, and awards were adjusted to the proper annual loan limit of $20,500. The Institution made students whole by forgiving any student balances that would have been paid by theover award amount. In addition, the software configuration was changed to ensure moving forward that students receive up to the proper maximum of $20,500 until proper accreditation is achieved. Contact Person: Michelle Miller, Senior Vice President of Enrollment Management mmiller10@tcsedsystem.edu Anticipated Completion Date: September 13, 2024

View Audit 331120 Questioned Costs: $1

Finding 513124 (2024-004)

Material Weakness 2024

Independent School District No 113

MN

Internal Control / Segregation of Duties Material Weakness Matching / Level of Effort / Earmarking

Finding 2024-004 Department of Education Federal Financial Assistance Listing 84.425 COVID-19 Education Stabilization Fund Special Tests – Wage Rate Requirement Material Weakness in Internal Control over Compliance Finding Summary: Eide Bailly LLP noted that the District did not satisfy the requirem...

Finding 2024-004 Department of Education Federal Financial Assistance Listing 84.425 COVID-19 Education Stabilization Fund Special Tests – Wage Rate Requirement Material Weakness in Internal Control over Compliance Finding Summary: Eide Bailly LLP noted that the District did not satisfy the requirements of 2 CFR 656.40 through 2 CFR 656.41. The District did not did not obtain proper support to ensure required certified payrolls were submitted. Responsible Individuals: Kevin Wellen, Superintendent Corrective Action Plan: The District will establish controls to follow all applicable requirements under Uniform Guidance and applicable CFR sections. Anticipated Completion Date: June 30, 2025

View Audit 331097

Corrective Action Plans

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