Corrective Action Plans

Finding 504825 (2024-002)

None 2024

IL

Student Financial Aid Matching / Level of Effort / Earmarking

MANAGEMENT’S CORRECTIVE ACTION PLAN CHICAGO THEOLOGICAL SEMINARY For The Year Ended June 30, 2024 Finding 2024-002 Gramm-Leach-Bliley Act-Student Information Security Federal Agency: U.S. Department of Education Program Name: Student Financial Assistance Cluster Assistance List...

MANAGEMENT’S CORRECTIVE ACTION PLAN CHICAGO THEOLOGICAL SEMINARY For The Year Ended June 30, 2024 Finding 2024-002 Gramm-Leach-Bliley Act-Student Information Security Federal Agency: U.S. Department of Education Program Name: Student Financial Assistance Cluster Assistance Listing #: 84.268 Questioned Costs: None Corrective Action: We agree with the auditor’s comments, and actions stated in the recommendation. The Seminary has updated its information security program to include the timeline for disposing of customer information securely and anticipating and evaluating changes to the information security network. Contact Person: Darnell Payne, Director of Information Technology Completion Date: September 30, 2024

View Audit 327528

Finding 504824 (2024-001)

None 2024

Chicago Theological Seminary

IL

Student Financial Aid Eligibility Matching / Level of Effort / Earmarking

MANAGEMENT’S CORRECTIVE ACTION PLAN CHICAGO THEOLOGICAL SEMINARY For The Year Ended June 30, 2024 Finding 2024-001 Verification Federal Agency: U.S. Department of Education Program Name: Student Financial Assistance Cluster Assistance Listing #: 84.268 Questioned Costs: None ...

MANAGEMENT’S CORRECTIVE ACTION PLAN CHICAGO THEOLOGICAL SEMINARY For The Year Ended June 30, 2024 Finding 2024-001 Verification Federal Agency: U.S. Department of Education Program Name: Student Financial Assistance Cluster Assistance Listing #: 84.268 Questioned Costs: None Corrective Action: We agree with the auditor’s comments, and actions stated in the recommendation. The Seminary will be amending its Policies and Procedures to incorporate required language to be in compliance. Furthermore, the Seminary has hired a consultant with 15 years of experience managing Federal Awards. In partnership with the consultant, the Seminary will implement additional controls to ensure application of new policies and procedures. Contact Person: Michele Carr, Controller Anticipated Completion Date: October 31, 2024

View Audit 327528

Finding 504815 (2024-004)

Significant Deficiency 2024

Madison Community Hospital

SD

Special Tests & Provisions Student Financial Aid Significant Deficiency

Department of Agriculture Federal Financial Assistance Listing #10.766 Communities Facilities Loans and Grants Finding Summary: There was no documented independent review of the monthly reserve fund account reconciliations as compared to the required minimum balance. Responsible Individuals: Teres...

Department of Agriculture Federal Financial Assistance Listing #10.766 Communities Facilities Loans and Grants Finding Summary: There was no documented independent review of the monthly reserve fund account reconciliations as compared to the required minimum balance. Responsible Individuals: Teresa Mallett, Chief Financial Officer Corrective Action Plan: The Board of Directors will be given an update at each board meeting with the balance in the reserve account with the required minimum balance covenant requirement. This notification will be documented in the board minutes. Anticipated Completion Date: September 24, 2024

View Audit 327501

Finding 504806 (2024-002)

Significant Deficiency 2024

Saint Leo University, INC

FL

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

Recommendation: We recommend the University review the R2T4 requirements and implement procedures to ensure the R2T4 calculations are using the correct payment periods and are completed accurately. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Act...

Recommendation: We recommend the University review the R2T4 requirements and implement procedures to ensure the R2T4 calculations are using the correct payment periods and are completed accurately. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The staff responsible for R2T4 calculations have changed. The staff currently completing these calculations have gone through training and a new tool has been provided, a quality control (QC) spreadsheet. This spreadsheet will be used to double-check payment period dates, used in the system calculation, to ensure ensure it is consistently pulling accurate data and is reviewed weekly. Name(s) of the contact person(s) responsible for corrective action: Brenda Clark Planned completion date for corrective action plan: December 2024

View Audit 327479

Finding 504804 (2024-001)

Significant Deficiency 2024

Saint Leo University, INC

FL

Questioned Costs Student Financial Aid Significant Deficiency

NSLDS Reporting Recommendation: We recommend the Institution review its reporting procedures to ensure that students’ program begin dates and program enrollment effective dates are accurately reported to NSLDS as required by regulations. Explanation of disagreement with audit finding: There is no d...

NSLDS Reporting Recommendation: We recommend the Institution review its reporting procedures to ensure that students’ program begin dates and program enrollment effective dates are accurately reported to NSLDS as required by regulations. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The policy regarding program start dates has been changed and training has occurred to inform the community of the change in processes; data accuracy is consistently monitored by the Registrar’s Office. Name(s) of the contact person(s) responsible for corrective action: Kelsea Gonzalez Planned completion date for corrective action plan: Older program start dates for separated students have been updated with the conclusion of the corrective action plan from 2022-23, ending on 6/30/24, which overlapped with the 2023-24 audit.

View Audit 327479 Questioned Costs: $1

Finding 504775 (2024-005)

None 2024

Wayland Baptist University

TX

Student Financial Aid Matching / Level of Effort / Earmarking

Documentation of Reconciliations Recommendation: We recommend the University explore options to make the year-to-date reconciliations and documentation of student Pell and Direct Loans more efficient. Planned Corrective Action: The Executive Director of Financial Aid and the Assistant Director of Co...

Documentation of Reconciliations Recommendation: We recommend the University explore options to make the year-to-date reconciliations and documentation of student Pell and Direct Loans more efficient. Planned Corrective Action: The Executive Director of Financial Aid and the Assistant Director of Compliance & Reporting have provided in-house training to all pertinent financial aid staff on monthly reconciliation procedures. Progress has been made importing the monthly Pell SAS file to WBU’s financial aid system, PowerFAIDS. Work will continue on importing the Direct Loan SAS file into PowerFAIDS. Person Responsible for Corrective Action Plan: Robert Hamilton, Executive Director of Financial Aid and Brooke Tyler, Assistant Director of Compliance & Reporting Anticipated Date of Completion: December 15, 2024.

View Audit 327385

Finding 504764 (2024-001)

Significant Deficiency 2024

Wayland Baptist University

TX

Reporting Student Financial Aid Eligibility

Incorrect Enrollment Reporting to National Student Loan Data System (NSLDS) Recommendation: We recommend the University work with the third-party to determine why the data is not transferring correctly to NSLDS. We further recommend the University complete spot checks of enrollment statuses to NSLDS...

Incorrect Enrollment Reporting to National Student Loan Data System (NSLDS) Recommendation: We recommend the University work with the third-party to determine why the data is not transferring correctly to NSLDS. We further recommend the University complete spot checks of enrollment statuses to NSLDS, particularly for those students who withdrew. Planned Corrective Action: An internal SSRS report for official and unofficial withdrawals which accurately reflects withdrawn students remains available to the WBU offices of Financial Aid and the Registrar for verification as part of the planned corrective action. The custom NSC reporting tool(s) will continue to be updated to make sure the correct combination of fields and corresponding data sources are reported as accurately as possible. WBU will continue to work with NSC to mitigate issues related to data not transferring correctly between NSC and NSLDS. § A field-by-field analysis plus any needed corrections to the queries will be performed. • By default, term “W” withdrawals are reconsidered by the updated tool each time a report is generated for NSC. • Some date fields have been corrected that were previously misunderstood by the custom tool’s historical authors. • Post-submission error corrections by registrar staff via NSC’s website are spot-checked by Information Technology when requested. • If certain data issues cannot be resolved satisfactorily via NSC alone, then corrective measures via NSLDS directly may be considered. • The PowerCampus 9.1.2 baseline product’s NSC reporting tool was determined to be insufficient for timely and accurate reporting to NSC with WBU’s current data on several counts. WBU has upgraded the PowerCampus system to version 9.2.3 and will continue to work towards a solution for the baseline reporting tool with the upgraded system. • Some of the recurring data updates needed before running the PC baseline tool, are still being run periodically as a source data benefit for the custom tool. Person Responsible for Corrective Action Plan: Cagan Cummings, Chief Information Officer Anticipated Date of Completion: Ongoing

View Audit 327385

Finding 504696 (2024-004)

Significant Deficiency 2024

Village of Rantoul

IL

Reporting Allowable Costs / Cost Principles Significant Deficiency § 200.303

Significant Deficiency in Internal Control over Compliance (Reporting) Recommendation: We recommend the Village strengthen internal controls over the review process of the annual grant reporting prior to the report submission. This review should be documented. Explanation of disagreement with aud...

Significant Deficiency in Internal Control over Compliance (Reporting) Recommendation: We recommend the Village strengthen internal controls over the review process of the annual grant reporting prior to the report submission. This review should be documented. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: A procedure will be implemented for the review of the report submission including the proper documentation of the review Name of the contact person responsible for corrective action: Angela Schults, Comptroller Planned completion date for corrective action plan: 1 April 2025

View Audit 327310

Finding 504695 (2024-003)

Significant Deficiency 2024

Village of Rantoul

IL

Procurement, Suspension & Debarment Matching / Level of Effort / Earmarking § 200.303

Significant Deficiency in Internal Control over Compliance (Suspension and Debarment) Recommendation: We recommend the Village carefully review federal suspension and debarment requirements for proper documentation needed. The Village should consider use of a Federal procurement checklist. Explana...

Significant Deficiency in Internal Control over Compliance (Suspension and Debarment) Recommendation: We recommend the Village carefully review federal suspension and debarment requirements for proper documentation needed. The Village should consider use of a Federal procurement checklist. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Village has developed a review process which satisfies the requirements for suspension and debarment per the Uniform Guidance. Staff is assigned to monitoring the need for this process and when appropriate, complete necessary procedure to document findings relative to suspension or debarment. Name of the contact person responsible for corrective action: Angela Schultz, Comptroller Planned completion date for corrective action plan: April 30, 2025

View Audit 327310

Finding 504669 (2024-001)

Significant Deficiency 2024

Anne Arundel Community College

MD

Special Tests & Provisions Student Financial Aid Reporting § 200.303

MANAGEMENT RESPONSE AND CORRECTIVE ACTION PLAN U.S. Department of Education 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—FE...

MANAGEMENT RESPONSE AND CORRECTIVE ACTION PLAN U.S. Department of Education 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—FEDERAL AWARD PROGRAMS AUDITS U.S. Department of Education 2024-01: Special Tests and Provisions – NSLDS Enrollment Reporting Student Financial Aid Cluster – Assistance Listing No. 84.063, 84.268 Condition: During testing of the enrollment status reporting, we noted that the incorrect enrollment status and effective date was included in NSLDS. Recommendation: The institution should evaluate their procedures and policies related to reporting status changes and effective dates to NSLDS and enhance as deemed necessary to ensure that accurate information is reported to NSLDS. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The college has reviewed and updated procedures to ensure that graduation and enrollment files are submitted in the necessary sequence to reflect the appropriate enrollment status and effective dates. Name(s) of the contact person(s) responsible for corrective action: Nanci A. Beier, Registrar Planned completion date for corrective action plan: Completed

View Audit 327260

Finding 504665 (2024-001)

Significant Deficiency 2024

Art Center College of Design

CA

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

October 31, 2024 Corrective Action Plan To whom it may concern: This letter includes the corrective action plan in response to the audit finding from the Single Audit for the 2023-2024 award year. Audit Finding 2024-001: For students who did not return from an approved leave of absence or tho...

October 31, 2024 Corrective Action Plan To whom it may concern: This letter includes the corrective action plan in response to the audit finding from the Single Audit for the 2023-2024 award year. Audit Finding 2024-001: For students who did not return from an approved leave of absence or those that took a leave of absence that did not meet the requirements of an approved leave of absence, predominantly being leaves of absences in excess of 180 days in any 12-month period, Art Center did not consistently report to the NSLDS the effective date of the withdrawal as the date the student began the leave of absence. Management Response: ArtCenter management acknowledges that some incorrect Enrollment Reporting data were transmitted through the National Student Clearinghouse (“NSC”) to the National Student Loan Data System (“NSLDS”). However, this error was not due to any insufficiencies in ArtCenter’s policies, but rather, was due to a technical misunderstanding regarding which data fields are extracted from Colleague for NSC reporting. More specifically, if a student takes a second Leave of Absence (“LOA”), it had been ArtCenter’s practice to record the student’s actual last date of attendance in the “Last Date of Attendance” field on the Student Hiatus Summary screen in Colleague, but the file that NSC requires schools to use to extract reporting data does not pull data from this field, and as a result, the resulting reported information was inaccurate. Corrective Action Plan: To remediate this finding and avoid future inaccuracies in Enrollment Reporting, we have adjusted our procedures to ensure the appropriate withdrawal date is submitted to NSC for transmission to NSLDS, in alignment with NSLDS Enrollment Reporting definitions and expectations. Please let us know if you have any additional questions. Sincerely, Kaitlin Wallace Executive Director, Financial Aid Art Center College of Design 1700 Lida St. Pasadena, CA 91103 626.396.2214

View Audit 327259

Finding 504653 (2024-003)

None 2024

Life Pacific University

CA

Student Financial Aid Matching / Level of Effort / Earmarking Reporting

Common Origination and Disbursement (COD) Reporting) Planned Corrective Action: The employee in place handling student accounts was trained on COD and Disbursement, she did well in the fall. When it was discovered that she was not continuing with the processes, she disclosed she was struggling with ...

Common Origination and Disbursement (COD) Reporting) Planned Corrective Action: The employee in place handling student accounts was trained on COD and Disbursement, she did well in the fall. When it was discovered that she was not continuing with the processes, she disclosed she was struggling with physical and emotional issues. This caused her to forget some of her training and also, she did not notify anyone she needed assistance. When the retired Director of Student Accounts was brought in, she uncovered the fact that funds were not being monitored monthly and funds not being posted to student accounts in a timely manner. This employee was let go from this position at LPU. Consultants, former Director of Student Accounts and new Associate VP have stepped in and worked together to be sure funds were reconciled. LPU has always had a monthly reconciliation plan, and the former Director of Student Accounts is working with the Associate VP to ensure the monthly reconciliation and posting of aid to students' accounts are being processed when funds are received. Person Responsible for Corrective Action Plan: Amber Burnett, Associate Vice President of Enrollment Services Anticipated Date of Completion: 6/30/2024

View Audit 327230

Finding 504651 (2024-002)

Significant Deficiency 2024

Life Pacific University

CA

Student Financial Aid Eligibility Reporting

Inaccurate and Untimely Return of Title IV Funds (R2T4) Planned Corrective Action: The reason that R214 were done late/inaccurately was due to an employee who was new to the position and instead of seeking assistance in a timely manner, waited until the prior retired Director of Student accounts was...

Inaccurate and Untimely Return of Title IV Funds (R2T4) Planned Corrective Action: The reason that R214 were done late/inaccurately was due to an employee who was new to the position and instead of seeking assistance in a timely manner, waited until the prior retired Director of Student accounts was contracted in to assist. This employee was transferred from enrollment department oversight and then transferred to business office oversight mid-year. Neither department could provide the necessary management of this position and that is when they reached out to contract back the former Director of Student Accounts. Our only other trained R2T4 employee left LPU in Spring 24 and due to staffing challenges with FAFSA Simplification, we could not get someone new trained in time. We have been working with a consulting firm, JM Solutions, and with consultants' input, we are restructuring the financial aid and Student Accounts department to fall under one direct oversight. LPU created an Associate Vice President of Enrollment Services who oversees FinancialAid, Student Accounts and Registrar. Underthe Associate VP, there is a new Director of Student FinancialServices (this combined role is the Director of Financial aid and Student Accounts). Going forward R2T4 will be done on the COD system per consultants' recommendation. Currently the Director of Student Financial Services is being trained on R2T4, and they are seeking to hire a fulltime position of a Financial Aid processor who will be trained on R2T4 as well. For now, the Associate VP and Director of Student Financial Services will be working together to ensure R2T4 are completed according to regulations, with additional oversight by consultants throughout the academic year. Person Responsible for Corrective Action Plan: Amber Burnett, Associate Vice President of Enrollment Services and Angel Cavazos, Director of Student Financial Services Anticipated Date of Completion: At this time oversight and changes are in place for the R2T4 process

View Audit 327230

Finding 504604 (2024-002)

None 2024

Texas College

TX

Questioned Costs Student Financial Aid Matching / Level of Effort / Earmarking

Finding 2024-002 – U.S. Department of Education (USDE), Title IV Student Financial Aid Programs: We observed the following conditions in connection with our testing of the various U.S. Department of Education, Title IV, Student Financial Assistance Programs. (a) The College had a difference in the F...

Finding 2024-002 – U.S. Department of Education (USDE), Title IV Student Financial Aid Programs: We observed the following conditions in connection with our testing of the various U.S. Department of Education, Title IV, Student Financial Assistance Programs. (a) The College had a difference in the Federal Work-Study program, which was not reconciled to the general ledger. (b) One (1) out of sixty (60) students tested for verification was missing their parent’s tax return. Total questioned cost was $3,698. Auditor’s Recommendation – The College should implement corrective actions to ensure that the above findings are resolved and will not recur in future periods. Corrective Action – The College accepts the auditor’s recommendations. Following the receipt of the recommendation, College staff (the VP for Business and Finance, the VP for Student Affairs, and staff from the Financial Aid Office) were informed of the findings. Staff noted the unwillingness of a student to provide parent’s tax document for verification, which lead to audit finding. Business Office and Financial Aid staff were advised to review the reported variance with the Federal Work-Study program; the College will have the FWS variance reconciled prior to the physical “closing of its books”. The College has a process that it uses to reconcile accounts and has no immediate plans to change the process. Staff are reminded of the process; the VP for Business and Finance will become more active in reviewing reconciliations for accuracy.

View Audit 327190 Questioned Costs: $1

Finding 504576 (2024-001)

Significant Deficiency 2024

Youngstown State University

OH

Student Financial Aid Reporting Significant Deficiency

Youngstown State University respectfully submits the following corrective action plan for the year ended June 30, 2024. Audit period: July 1, 2023 – June 30, 2024 The finding from the schedule of Federal Program Audit Findings is discussed below. The finding is numbered consistently with the number ...

Youngstown State University respectfully submits the following corrective action plan for the year ended June 30, 2024. Audit period: July 1, 2023 – June 30, 2024 The finding from the schedule of Federal Program Audit Findings is discussed below. The finding is numbered consistently with the number assigned in the schedule. FINDING – FEDERAL PROGRAM AUDIT FINDING SIGNIFICANT DEFICIENCY 2024-001 Assistance Listing, Federal Agency and Program Name – 84.063, 84.268, U.S. Department of Education, Student Financial Assistance Cluster - Federal Pell Grant Program, Federal Direct Student Loans Federal Award Identification Number and Year - 84.063 - P063P192025, P063P202025, P063P212025, P063P222025, P063P232025 - 84.268 - P268K222025, P268K232025, P268K242025 Recommendation: We recommend the University implement controls to ensure that all campus level detail and program level detail is being appropriately reported through National Student Clearinghouse (NSC) to National Student Loan Data System (NSLDS) to ensure accurate enrollment status changes are reported to NSLDS via NSC. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned/taken in response to finding: The University Registrar and Financial Aid Director investigated the issue and developed additional procedures. The University Registrar will continue to cross-check 15 currently enrolled students with the NSC monthly enrollment data submission. The Financial Aid Director will supply the University Registrar with an additional 15 currently enrolled students with financial aid to cross-check with the NSC monthly enrollment data submissions. The Financial Aid Director will cross-check both sample lists with NSLDS enrollment data for accuracy. Names of the contact people responsible for corrective action: Tysa Egleton, University Registrar and Melissa McKenney, Financial Aid Director Planned completion date for corrective action plan: November 1, 2024

View Audit 327162

Finding 504569 (2024-001)

None 2024

Roger Williams University

RI

Special Tests & Provisions Student Financial Aid Reporting

Finding – Special Tests and Provisions: Enrollment Reporting – Federal Direct Student Loan Program, Assistance Listing Number 84.268; June 30, 2024 Award Year; U.S. Department of Education Criteria or Specific Requirement ...

Finding – Special Tests and Provisions: Enrollment Reporting – Federal Direct Student Loan Program, Assistance Listing Number 84.268; June 30, 2024 Award Year; U.S. Department of Education Criteria or Specific Requirement When a student withdraws during a term, the effective date reported to the National Student Loan Data System (“NSLDS”) for the withdrawn status is the withdrawal date used by the institution in accordance with 34 CFR 668.22 (b) or (c). In the case of the student who completes a term and does not return for the next term, leaving the course of study incomplete, the effective date is the final day of the term in which the student was last enrolled. The effective date for a completion/graduation status is the date the school assigns to the completion/graduation. (NSLDS Enrollment Reporting Guide November 20, and 34 CFR 682.610.) Condition Four students with status changes, out of seven selected for testing, had the incorrect effective date reported to NSLDS. The dates reported to NSLDS were between 6 and 26 days later than the actual effective date of the student’s status change. Views of Responsible Officials and Planned Corrective Actions The University concurs with the finding. The University intends to report the actual effective date of the student status changes. Names of Contact Person Responsible for Correction Action: Gloria Arcia, Executive Vice President for Finance and Administration and Chief Financial Officer Anticipated Completion Date: September 24, 2024

View Audit 327156

Finding 504530 (2024-001)

Significant Deficiency 2024

University of the Cumberlands, Inc.

KY

Student Financial Aid Significant Deficiency Matching / Level of Effort / Earmarking

2024-001 Significant Deficiency: Disbursement Notifications (U.S. Department of Education, William D. Ford Direct Loan Program, ALN #84.268) The University did not include the estimated amount of disbursement in the Federal Direct Loan disbursement notifications. Name of Contact Person Management ag...

2024-001 Significant Deficiency: Disbursement Notifications (U.S. Department of Education, William D. Ford Direct Loan Program, ALN #84.268) The University did not include the estimated amount of disbursement in the Federal Direct Loan disbursement notifications. Name of Contact Person Management agrees with finding 2024-001. When disbursement notifications were built for the 2023-24 award year, the calculated fields to notify students of the amount of aid being disbursed were not properly updated. Alex Campbell, Director of Financial Aid, and Kaitrin Parrett, Assistant Director of Financial Aid, are the responsible parties for the corrective action. Contact information for the responsible parties is alex.campbell@ucumberlands.edu (606) 539-5569 and kaitrin.parrett@ucumberlands.edu (606) 539-5591 Corrective Action Plan Upon identifying the deficiencies in meeting regulations for disbursement notifications, immediate corrective actions were undertaken. In collaboration with software engineers, the disbursement notification template was updated to notify students of the type of Federal Direct Loan, the date of disbursement, the amount of aid disbursed, and all other required information related to regulatory requirements. The Financial Aid Office tested and reviewed disbursement notifications for Direct Subsidized Loans, Direct Unsubsidized Loans, and Direct PLUS Loans across all student populations and confirmed that the notifications were updated and all necessary information was communicated to students before the disbursement of Fall 2024 Federal Direct Loans. In future aid years, disbursement notification templates will be internally reviewed and tested by the Director and Assistant Director of Financial Aid each semester before the disbursement of Federal Direct Loans to ensure continued compliance. Testing of the configurations for the disbursement notification template will be completed in our Student Information System’s sandbox environment. In this environment, staff will be able to simulate and disburse all Federal Direct Loans to ensure notification templates are properly set up before moving into the production tenant. Periodic reports will be generated in the production tenant to confirm that students received the appropriate disbursement notification based on their award type and disbursement date. Expected Completion Date This corrective action plan was implemented on August 1, 2024, before Fall 2024 aid disbursements began on August 30, 2024.

View Audit 327110

Finding 504488 (2024-001)

Significant Deficiency 2024

North Muskegon Public Schools

MI

Internal Control / Segregation of Duties Subrecipient Monitoring Allowable Costs / Cost Principles

Finding 2024-001: Internal Controls Over the Federal Expenditure Report Type of Finding: Control U.S. Department of Education Pass-through Entity: Michigan Department of Education Assistance Listing Number: 84.425D Award Numbers: COVID-19 213712-2021, COVID-19 213782-2223 Award Year End: Sep...

Finding 2024-001: Internal Controls Over the Federal Expenditure Report Type of Finding: Control U.S. Department of Education Pass-through Entity: Michigan Department of Education Assistance Listing Number: 84.425D Award Numbers: COVID-19 213712-2021, COVID-19 213782-2223 Award Year End: September 30, 2023 Recommendation: The School District should establish 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: Director of Business Services, September 2024. If the Michigan Department of Education has questions regarding this plan, please call Mark Mesbergen at (231) 719-4102.

View Audit 327050

Finding 504474 (2024-002)

Significant Deficiency 2024

Bellevue Fire Control Board

MI

Procurement, Suspension & Debarment Subrecipient Monitoring Allowable Costs / Cost Principles

Management is in the process of drafting an updated procurement policy to comply with the requirements of the Uniform Guidance.

View Audit 327007

Finding 504421 (2024-002)

Significant Deficiency 2024

Missouri Baptist University

MO

Student Financial Aid Subrecipient Monitoring Reporting

Student Status Changes The process of reporting enrollment to the NSLDS has historically been housed within the Student Financial Services department. The compliance issues with enrollment reporting during the prior award year were a result of having only one individual trained in transmitting our m...

Student Status Changes The process of reporting enrollment to the NSLDS has historically been housed within the Student Financial Services department. The compliance issues with enrollment reporting during the prior award year were a result of having only one individual trained in transmitting our monthly file to the National Student Clearinghouse. Over the past few months, staff from our Records Office have been receiving training on preparing enrollment reporting files for transmission to the National Student Clearinghouse. During the current award year, collaborative meetings have been scheduled to have the principal agent from the Records Office and the principal agent from the Student Financial Services department meet to transmit data files to the Clearinghouse. Subsequent meetings are scheduled within 24-48 hours of each file transmission date to ensure error reports posted to the Clearinghouse are resolved in a timely manner. Zach Greenlee Director, Student Financial Services Phone: 314-392-2398 Email: zach.greenlee@mobap.edu

View Audit 326979

Finding 504417 (2024-001)

Material Weakness 2024

Missouri Baptist University

MO

Student Financial Aid Subrecipient Monitoring Matching / Level of Effort / Earmarking

Return of Title IV Funds (R2T4) Due to the specialized skills and knowledge required for processing returning funds through the R2T4 process, Missouri Baptist University will be reassigning the responsibility for reviewing withdrawals within the Student Financial Services department to the Director ...

Return of Title IV Funds (R2T4) Due to the specialized skills and knowledge required for processing returning funds through the R2T4 process, Missouri Baptist University will be reassigning the responsibility for reviewing withdrawals within the Student Financial Services department to the Director of Student Financial Services. All withdrawals will be evaluated by the Director and all calculations using the R2T4 calculator available on the Common Origination and Disbursement (COD) system will be performed by the Director. Additional staff within the department will be tasked with verifying accuracy of returns to help provide exposure to the highly technical work of R2T4, thus providing training that will enable broader sharing of the responsibility in the future. An internal report has been created to give a daily summary of students who have withdrawn since the following day. This will complement the existing reporting structure which consists of individual withdrawal paperwork processed by our Records Department. Bi-weekly reports will be given to the Senior Vice President for Business Affairs to monitor compliance. Zach Greenlee Director, Student Financial Services Phone: 314-392-2398 Email: zach.greenlee@mobap.edu

View Audit 326979

Finding 504328 (2024-001)

None 2024

Oklahoma Wesleyan University

OK

Student Financial Aid Matching / Level of Effort / Earmarking

FINDING 2024-001 – Notification of Loan Disbursements Program Name: Federal Direct Student Loan Program ALN and Program Expenditures: 84.268 ($5,702,366) Award Number: P268K242030 Federal Award Year: July 1, 2023 to June 30, 2024 Questioned Costs: N/A Condition Found: The University could ...

FINDING 2024-001 – Notification of Loan Disbursements Program Name: Federal Direct Student Loan Program ALN and Program Expenditures: 84.268 ($5,702,366) Award Number: P268K242030 Federal Award Year: July 1, 2023 to June 30, 2024 Questioned Costs: N/A Condition Found: The University could not provide documentation that the required loan disbursement notifications were made to the student at the time disbursement for the forty-one students who received Federal Direct Student Loans in our sample. This represented the entire population of students who received Federal Direct Student Loans in our sample. Corrective Action Plan: Management agrees with the auditors’ finding and their recommendation. The Financial Aid Office discovered the error in July 2024 before the audit began. Up to that point, the Financial Aid Office believed the software was automatically sending loan disbursement notification emails. The Financial Aid Office worked with the information technology staff to correct the software error. Loan disbursement notification emails are being sent timely as of August 2024. Anticipated Completion Date: The corrective action was completed in August 2024. Contact Person Shala LaTorraca, Director of Financial Aid 918-335-6260

View Audit 326881

Finding 504301 (2024-006)

Significant Deficiency 2024

University of Idaho

ID

Reporting Significant Deficiency Matching / Level of Effort / Earmarking § 200.303

Partnerships for Climate-Smart Commodities – Assistance Listing No. 10.937. Recommendation: We recommend the University revise their procedures to include documentation of the review over FFATA reporting. The documentation should include the date of the review and the individual(s) performing the re...

Partnerships for Climate-Smart Commodities – Assistance Listing No. 10.937. Recommendation: We recommend the University revise their procedures to include documentation of the review over FFATA reporting. The documentation should include the date of the review and the individual(s) performing the review. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: We recognize the need to enhance our documentation of internal controls to ensure testability and maintain compliance with federal reporting standards. While our existing internal processes ensured data accuracy, timeliness, and submission compliance, we acknowledge that documentation of the review process is beneficial. Moving forward, the Contract Review Officer (CRO) will review FFATA reports submitted by another team member. When the CRO submits the report, her supervisor or an OSP employee will perform the review. Each review instance will be documented with the reviewer’s name and date to reinforce control transparency and testability, aligning our process more closely with compliance requirements. Name(s) of the contact person(s) responsible for corrective action: Sarah Martonick, Director, Office of Sponsored Programs, 208-885-2145. Planned completion date for corrective action plan: October 31, 2024

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Finding 504300 (2024-005)

Significant Deficiency 2024

University of Idaho

ID

Matching / Level of Effort / Earmarking Student Financial Aid Significant Deficiency § 200.303

Student Financial Assistance Cluster – Assistance Listing No. 84.268. Recommendation: We recommend the University evaluate its procedures around disbursements of loans and ensure that notifications of disbursements are sent and contain all of the required elements outlined in the FSA handbook. Expla...

Student Financial Assistance Cluster – Assistance Listing No. 84.268. Recommendation: We recommend the University evaluate its procedures around disbursements of loans and ensure that notifications of disbursements are sent and contain all of the required elements outlined in the FSA handbook. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: We created a weekly report for all communications. We also reviewed the populations selection. Name(s) of the contact person(s) responsible for corrective action: Randi Croyle, Director of Financial Aid. Planned completion date for corrective action plan: 12/31/24

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Finding 504296 (2024-003)

Significant Deficiency 2024

University of Idaho

ID

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

Student Financial Assistance Cluster – Assistance Listing No. 84.268, 84.063. Recommendation: We recommend the College evaluate its procedures and policies around reporting disbursements to COD to ensure that student information is reported accurately and timely. Explanation of disagreement with aud...

Student Financial Assistance Cluster – Assistance Listing No. 84.268, 84.063. Recommendation: We recommend the College evaluate its procedures and policies around reporting disbursements to COD to ensure that student information is reported accurately and timely. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: We created a report to track the timing of reporting disbursements to COD. Currently we load the disbursement record to COD once a week. If there is an issue and the file is rejected it creates issues with timeliness. We have a meeting on 10/9/2024 to evaluate how we want to resolve the issue. Name(s) of the contact person(s) responsible for corrective action: Randi Croyle, Danial Carlos, and Brady Nelsen. Planned completion date for corrective action plan: December 2024

View Audit 326827

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