Corrective Action Plans

Finding 503116 (2024-002)

Significant Deficiency 2024

WA

Student Financial Aid Special Tests & Provisions Reporting

Special Tests and Provisions – Enrollment Reporting – Significant Deficiency in Internal Controls over Compliance - Federal Assistance Listing Number 84.063, 84.268 Recommendation: The auditors recommend the University further educate and train those involved in the reporting of enrollment status ch...

Special Tests and Provisions – Enrollment Reporting – Significant Deficiency in Internal Controls over Compliance - Federal Assistance Listing Number 84.063, 84.268 Recommendation: The auditors recommend the University further educate and train those involved in the reporting of enrollment status changes to the NSLDS. The auditors also recommend the University review our documented policies and procedures and ensure controls exist and are well documented in order to ensure enrollment data is reported timely and accurately to NSLDS. Action taken: The Director of Financial Aid will continue education on enrollment reporting requirements. The Director and the Registrar will continue to work together on enrollment reporting requirements. The Director of Financial Aid will now report withdrawals due to R2T4, as well as conferrals, to the National Student Loan Data System directly once the University receives notice of either withdrawal or completion of a degree. Weekly, withdrawals for R2T4 are monitored and reported and now SFA will report directly to NSLDS to avoid any lag time in relying on reporting to the Clearinghouse. At the end of each term, after the Registrar has conferred degrees, SFA will also acquire the list of students who have graduated and report their graduation status to NSLDS. Name of Responsible Party: Erin Schaffer Anticipated completion date: 9/30/2024

View Audit 325123

Finding 503110 (2024-001)

Significant Deficiency 2024

Saint Martin's University

WA

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

Gramm-Leach-Bliley Act – Student Information Security – Significant Deficiency in Internal Controls over Compliance – Federal Assistance Listing Number 84.063, 84.268, 84.007, 84.033, 84.379, 84.038 Recommendation: The auditors recommend the University review the compliance requirements and update o...

Gramm-Leach-Bliley Act – Student Information Security – Significant Deficiency in Internal Controls over Compliance – Federal Assistance Listing Number 84.063, 84.268, 84.007, 84.033, 84.379, 84.038 Recommendation: The auditors recommend the University review the compliance requirements and update our written policy to ensure that it addresses all the required elements. Action taken: The CIO, Mary Donahoo, worked in conjunction with prior CFO to create a timeline for implementation for the requirements of GLBA. The Information Technology Services (ITS) department had begun policy development pertaining to the Gramm-Leach- Bliley Act (GLBA) specific elements in 16 CFR 314.4 during fiscal year 2024 but was unable to complete all the required implementations. The ITS department implemented, during fiscal year 2024, improvements to cyber security and minor elements of GLBA, including multifactor authentication. The action plan anticipates completion of all elements of GLBA by the end of the calendar year. Name of Responsible Party: Mary Donahoo Anticipated completion date: 12/31/2024

View Audit 325123

Finding 503018 (2024-001)

Significant Deficiency 2024

Dean College

MA

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

Finding – Special Tests and Provisions: Enrollment Reporting – Federal Direct Student Loans, Assistance Listing Number 84.268; May 31, 2024 Award Year; U.S. Department of Education Condition ...

Finding – Special Tests and Provisions: Enrollment Reporting – Federal Direct Student Loans, Assistance Listing Number 84.268; May 31, 2024 Award Year; U.S. Department of Education Condition Of the 17 students selected for enrollment reporting testing, 4 students within the sample were reported to NSLDS outside the maximum 60-day window. This was not a statistically valid sample. View of Responsible Officials and Planned Corrective Actions Effective with the 2023-2024 Academic Catalog year, Dean College implemented a leave of absence policy (LOA) and a medical leave of absence policy (MLOA). These are intended as a temporary interruption of a student’s program of study for a semester. In the case of an MLOA, the reason for the leave is for health reasons (physical, mental or emotional). Extensions of a leave may be granted on a semester-by-semester basis for up to two years. Students on LOA or MLOA must notify the College after the end of their semester’s leave to indicate if they are planning to return in the subsequent semester, if they want to extend their leave by a semester, or if they are withdrawing from the College. As noted in the catalog, from a financial and financial aid perspective, both types of leave (LOA, MLOA) are treated the same as a withdrawal and is reported as such to the National Student Clearinghouse. Medical withdrawals and voluntary withdrawals are reported as withdrawals. Dean College also has a medical withdrawal policy and a voluntary withdrawal policy. These are not temporary interruptions of a student’s studies with an intent to return but are full withdrawals and reported as such. Students who later decide that they do want to return to Dean College must complete the readmission application. In this situation, it appears that the internal code used to record students who were leaving for medical reasons triggered a leave of absence coding to the Clearinghouse, not a withdrawal code as intended by College policy. Dean College reviewed all processes related to leaves of absence, medical leave of absence, and withdrawals, including all coding, to ensure that this does not happen in the future. Coding updates have been implemented, and we will monitor students during the Fall 2024 semester to ensure they are reported appropriately. Responsible Officials: Colleen Crane Expected Completion Date: 8/9/2024

View Audit 324963

Finding 502668 (2024-001)

None 2024

Dallas Theological Seminary

TX

Reporting Student Financial Aid Eligibility

Enrollment Reporting to National Student Loan Data System (NSLDS) Planned Corrective Action: The Registrar’s Office will add additional reporting for the non-standard term to ensure that student enrollment statuses are updated to NSLDS within the 60 day time frame for reporting. An additional chec...

Enrollment Reporting to National Student Loan Data System (NSLDS) Planned Corrective Action: The Registrar’s Office will add additional reporting for the non-standard term to ensure that student enrollment statuses are updated to NSLDS within the 60 day time frame for reporting. An additional check of students that received loans and withdrew officially or unofficially will be done in NSLDS to ensure that dates were entered correctly within the system and transferred over correctly each semester. Person Responsible for Corrective Action Plan: Matthew Adams, Assistant Director of Academic Records and Registrar Anticipated Date of Completion: June 30, 2025

View Audit 324682

Finding 502618 (2024-002)

Significant Deficiency 2024

Oklahoma Christian University and Subsidiaries

OK

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

Criteria or Specific Requirement - Special Tests and Provisions - Enrollment Reporting - 34 CFR Section 690.83(b)(2) and 685.309 Condition - Eight student status changes were not communicated to the NSLDS timely Questioned Costs - N/A Context - Out of the population of 312 students with enrollment s...

Criteria or Specific Requirement - Special Tests and Provisions - Enrollment Reporting - 34 CFR Section 690.83(b)(2) and 685.309 Condition - Eight student status changes were not communicated to the NSLDS timely Questioned Costs - N/A Context - Out of the population of 312 students with enrollment status changes requiring reporting to NSLDS, a sample of 25 students was selected for testing. Of those 25 students, 8 student status changes were not reported to NSLDS within the required 60 days. Our sample was not, and was not intended to be, statistically valid. Effect - NSLDS was not notified of student status changes in accordance with compliance requirements Cause - The University did not have effective internal control processes in place to ensure the accurate collection, review and reporting of student status changes occurred timely. Recent turnover in personnel resulted in a lack of oversight as well. Indication as a Repeat Finding - N/A Recommendation - The University should review its internal controls surrounding the enrollment reporting process and ensure internal controls provide for the timely and accurate reporting of student status changes. Views of Responsible Officials and Planned Corrective Actions - Amy Schlup, Director of Student Financial Services, and Rachel Hart, Registrar, will oversee the corrective action plan. New personnel in the Registrar's office have received training for student enrollment reporting and will submit reporting to NSLDS every 30 days in order to stay within the required 60 days. This reporting will take place around the 25th of every month and be completed by the Registrar only. The Associate Registrar and Director of Administrative Computing will retain alternate access in case of emergency. Error reports will be reviewed and resolved within one week ensuring that accurate information is provided to NSLDS well within the required time frame. The corrective action plan has already been completed as of October 9, 2024. Contact information for responsible officials: Office of Financial Services Box 11000 Oklahoma City, OK 73136 405.425.5190 financialservices@oc.edu

View Audit 324604

Finding 502570 (2024-001)

Significant Deficiency 2024

Meds Apartments

IL

HUD Housing Programs Reporting Matching / Level of Effort / Earmarking

Finding No. 2024-001; Section 207/223(f) Mortgage Insurance, Assistance Listing 14.134 Criteria Uniform Guidance and Federal Audit Clearinghouse requirements require that non-federal entities transmit their annual reporting package to the Federal Audit Clearinghouse within the earlier of 30 days aft...

Finding No. 2024-001; Section 207/223(f) Mortgage Insurance, Assistance Listing 14.134 Criteria Uniform Guidance and Federal Audit Clearinghouse requirements require that non-federal entities transmit their annual reporting package to the Federal Audit Clearinghouse within the earlier of 30 days after receipt of the auditor's report or nine months after the end of the audit period. Condition The annual reporting package for the year ended June 30, 2023 has not been submitted to the Federal Audit Clearinghouse within the required time frame. Cause Procedures in place were not adequate to ensure the timely submission of the reporting package. Effect or Potential Effect Noncompliance with Uniform Guidance and Federal Audit Clearinghouse requirements. Questioned Costs N/A Context N/A Identification as a Repeat Finding Finding 2023-001 Recommendation Annual reporting packages should be submitted to the Federal Audit Clearinghouse no later than March 31st of the subsequent year. Auditor Noncompliance Code: Section 207/223(f) Mortgage Insurance Finding Resolution Status: Resolved - Reviewed the Federal Audit Clearinghouse website, the annual report package was submitted and approved on June 10, 2024. Views of Responsible Officials MEDS Apartments agrees with the finding and the auditor's recommendation have been adopted. The Corporation has implemented procedures to ensure the timely completion and submission of the annual reporting package.

View Audit 324579

Finding 502569 (2024-001)

Significant Deficiency 2024

Grant Village

IL

HUD Housing Programs Reporting Matching / Level of Effort / Earmarking

Finding No. 2024-001; Section 207/223(f) Mortgage Insurance, Assistance Listing 14.134 Criteria Uniform Guidance and Federal Audit Clearinghouse requirements require that non-federal entities transmit their annual reporting package to the Federal Audit Clearinghouse within the earlier of 30 days aft...

Finding No. 2024-001; Section 207/223(f) Mortgage Insurance, Assistance Listing 14.134 Criteria Uniform Guidance and Federal Audit Clearinghouse requirements require that non-federal entities transmit their annual reporting package to the Federal Audit Clearinghouse within the earlier of 30 days after receipt of the auditor's report or nine months after the end of the audit period. Condition The annual reporting package for the year ended June 30, 2023 has not been submitted to the Federal Audit Clearinghouse within the required time frame. Cause Procedures in place were not adequate to ensure the timely submission of the reporting package. Effect or Potential Effect Noncompliance with Uniform Guidance and Federal Audit Clearinghouse requirements. Questioned Costs N/A Context N/A Identification as a Repeat Finding Finding 2023-001 Recommendation Annual reporting packages should be submitted to the Federal Audit Clearinghouse no later than March 31st of the subsequent year. Auditor Noncompliance Code: Section 207/223(f) Mortgage Insurance Finding Resolution Status: Resolved – Reviewed the Federal Audit Clearinghouse website, the annual report package was submitted and approved on June 10, 2024. Views of Responsible Officials Grant Village agrees with the finding and the auditor's recommendation has been adopted. The Corporation has implemented procedures to ensure the timely completion and submission of the annual reporting package.

View Audit 324578

Finding 502516 (2024-002)

Significant Deficiency 2024

Cabrini University

PA

Questioned Costs Student Financial Aid Significant Deficiency

Student Financial Assistance Cluster – Assistance Listing No. 84.268 Recommendation: The University should ensure all necessary employees receive proper training, support, and time to follow the University’s policies and federal requirements related to monthly reconciliations. There should be a proc...

Student Financial Assistance Cluster – Assistance Listing No. 84.268 Recommendation: The University should ensure all necessary employees receive proper training, support, and time to follow the University’s policies and federal requirements related to monthly reconciliations. There should be a process to maintain all reconciliations to support these were performed as required monthly. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: In June 2023, the University announced that the 2023-2024 academic year would be the final year of operations due to continued declines in enrollment and operating deficits. On May 11, 2024 the University provided it’s final day of instruction to students and thereby ended its participation in the Title IV Federal Student Aid (FSA) programs. Name(s) of the contact person(s) responsible for corrective action: Lynda Buzzard, Vice President Finance & Administration Planned completion date for corrective action plan: May 11, 2024

View Audit 324498 Questioned Costs: $1

Finding 502508 (2024-001)

Significant Deficiency 2024

Cabrini University

PA

Questioned Costs Student Financial Aid Significant Deficiency

Student Financial Assistance Cluster – Assistance Listing No. 84.063, 84.007, 84.268, 84.379 & 84.033 Recommendation: We recommend that the University evaluate its procedures and policies around packaging Title IV based on need. Explanation of disagreement with audit finding: There is no disagreemen...

Student Financial Assistance Cluster – Assistance Listing No. 84.063, 84.007, 84.268, 84.379 & 84.033 Recommendation: We recommend that the University evaluate its procedures and policies around packaging Title IV based on need. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: In June 2023, the University announced that the 2023-2024 academic year would be the final year of operations due to continued declines in enrollment and operating deficits. On May 11, 2024 the University provided it’s final day of instruction to students and thereby ended its participation in the Title IV Federal Student Aid (FSA) programs. Name(s) of the contact person(s) responsible for corrective action: Lynda Buzzard, Vice President Finance & Administration Planned completion date for corrective action plan: May 11, 2024

View Audit 324498 Questioned Costs: $1

Finding 502363 (2024-003)

None 2024

The Master's University & Seminary and Subsidiary

CA

Reporting Student Financial Aid Eligibility

Enrollment Reporting to NSLDS Planned Corrective Action: The Master’s University will review a sample batch of students sent to NSC to make sure that the batch was successfully processed to NSLDS. Person Responsible for Corrective Action Plan: Kenneth Piester Anticipated Date of Completion: 09/30/20...

Enrollment Reporting to NSLDS Planned Corrective Action: The Master’s University will review a sample batch of students sent to NSC to make sure that the batch was successfully processed to NSLDS. Person Responsible for Corrective Action Plan: Kenneth Piester Anticipated Date of Completion: 09/30/2024

View Audit 324397

Finding 502078 (2024-002)

Significant Deficiency 2024

Augustana College

IL

Questioned Costs Student Financial Aid Significant Deficiency

Recommendation: We recommend that the College review their awarding procedures and implement procedures to ensure the subsidized direct loans are awarded within a students’ need. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in respon...

Recommendation: We recommend that the College review their awarding procedures and implement procedures to ensure the subsidized direct loans are awarded within a students’ need. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Augustana corrected this student’s over-award during the audit process by reallocating the loan funds from subsidized to unsubsidized. In the future, Augustana intends to develop and utilize a report that will identify students who have negative unmet need and who have a subsidized loan. Staff will review students who appear on this report and revise aid as necessary to ensure students are within their eligibility for need-based financial aid. Name of the contact person responsible for corrective action: John Cage at johncage@augustana.edu Planned completion date for corrective action plan: January 1, 2025

View Audit 324271 Questioned Costs: $1

Finding 501926 (2024-001)

Significant Deficiency 2024

Chapman University and Affiliates

CA

Student Financial Aid Reporting Matching / Level of Effort / Earmarking

As of September 2024, we will upload our grad outlier report weekly instead of monthly in order to prevent future delays. We will be reviewing the error reports after every submission to the Clearinghouse to resolve the error CE75 issue manually until the Clearinghouse and NSLDS fix error 75 on thei...

As of September 2024, we will upload our grad outlier report weekly instead of monthly in order to prevent future delays. We will be reviewing the error reports after every submission to the Clearinghouse to resolve the error CE75 issue manually until the Clearinghouse and NSLDS fix error 75 on their end, so we will not have to do this manually.

View Audit 324097

Finding 501868 (2024-003)

Significant Deficiency 2024

Canyon Village Senior Citizens Housing, Inc.

WY

Questioned Costs Subrecipient Monitoring HUD Housing Programs

Comments on the Finding and Each Recommendation: The Corporation did not make the total required reserve for replacement deposits during the year ended June 30, 2024. Additionally, the required monthly deposits for the period from August 1, 2022 through June 30, 2023 were not made in the amounts spe...

Comments on the Finding and Each Recommendation: The Corporation did not make the total required reserve for replacement deposits during the year ended June 30, 2024. Additionally, the required monthly deposits for the period from August 1, 2022 through June 30, 2023 were not made in the amounts specified by HUD which resulted in the reserve for replacements account being underfunded by $623 as of June 30, 2024. The management agent should transfer funds of $623 from the operating account in order to bring the reserve for replacements account to current, and confirm with HUD monthly reserve for replacements deposits requirements at least annually. Action(s) taken or planned on the finding Management agrees with the recommendation. Management transferred $623 from the operating account to the reserve for replacements account on September 25, 2024. No further action is required.

View Audit 323965 Questioned Costs: $1

Finding 501867 (2024-002)

Significant Deficiency 2024

Canyon Village Senior Citizens Housing, Inc.

WY

Questioned Costs HUD Housing Programs Subrecipient Monitoring

Comments on the Finding and Each Recommendation: The Corporation's required deposit into the residual receipts account of $41,019 per the June 30, 2023 Computation of Surplus Cash, Distributions and Residual Receipts was not deposited within 90 days of the fiscal year end. Management should make all...

Comments on the Finding and Each Recommendation: The Corporation's required deposit into the residual receipts account of $41,019 per the June 30, 2023 Computation of Surplus Cash, Distributions and Residual Receipts was not deposited within 90 days of the fiscal year end. Management should make all required residual receipts deposits per the annual Computation of Surplus Cash, Distributions and Residual Receipts within 90 days after the fiscal year end. Action(s) taken or planned on the finding Management agrees with the recommendation. Management deposited $41,019 into the residual receipts fund on October 30, 2023. No further action is required.

View Audit 323965 Questioned Costs: $1

Finding 501866 (2024-001)

Significant Deficiency 2024

Canyon Village Senior Citizens Housing, Inc.

WY

Subrecipient Monitoring HUD Housing Programs Matching / Level of Effort / Earmarking

Comments on the Finding and Each Recommendation: The Corporation's Flexible Subsidy Loan was due in full upon maturity of the Corporation's Section 202 mortgage loan, which occurred in March 2017. As of June 30, 2024, the Flexible Subsidy Loan has not been repaid and the Corporation is in technical ...

Comments on the Finding and Each Recommendation: The Corporation's Flexible Subsidy Loan was due in full upon maturity of the Corporation's Section 202 mortgage loan, which occurred in March 2017. As of June 30, 2024, the Flexible Subsidy Loan has not been repaid and the Corporation is in technical default on the Flexible Subsidy Loan. Management should continue communicating with HUD in order to obtain approval for the deferment request for the Section 201 Flexible Subsidy Loan. Action(s) taken or planned on the finding Management agrees with the recommendation. Management has submitted a request for deferment of the Flexible Subsidy Loan. Management is awaiting HUD approval of the deferment request.

View Audit 323965

Finding 501689 (2024-001)

Significant Deficiency 2024

MacAlester College

MN

Questioned Costs Significant Deficiency Matching / Level of Effort / Earmarking

Student Financial Assistance – Assistance Listing No. 84.063, 84.268 Recommendation: CLA recommends that the College update their procedures to identify changes in breaks for purposes of R2T4 calculations. Explanation of disagreement with audit finding: There is no disagreement with the audit findi...

Student Financial Assistance – Assistance Listing No. 84.063, 84.268 Recommendation: CLA recommends that the College update their procedures to identify changes in breaks for purposes of R2T4 calculations. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Corrective action was taken immediately. R2T4 calculations for 2024-25 include a five-day break for fall semester (Thanksgiving Break November 27 – December 1). Name(s) of the contact person(s) responsible for corrective action: Jenae Schmidt Planned completion date for corrective action plan: September 1, 2024 If the Department of Education has questions regarding this plan, please call Jenae Schmidt at 651-696-6214.

View Audit 323740 Questioned Costs: $1

Finding 501682 (2024-002)

None 2024

Central Christian College of the Bible

MO

Student Financial Aid Matching / Level of Effort / Earmarking Reporting

Inaccurate and Untimely Return of Title IV Funds (R2T4): Planned Corrective Action: The Financial Aid Department corrected the current year errors by completing the R2T4s for the students identified. In addition to those corrections, a full file review was done to ensure that no other students were...

Inaccurate and Untimely Return of Title IV Funds (R2T4): Planned Corrective Action: The Financial Aid Department corrected the current year errors by completing the R2T4s for the students identified. In addition to those corrections, a full file review was done to ensure that no other students were missed. To prevent the recurrence of this issue going forward, the Financial Aid Office will pull a 0 credit hour report at the end of each module to ensure that all unofficial withdrawals are followed up on and that all R2T4s are filed in a timely manner. Persons Responsible for Corrective Action Plan: Veronica L. Hamblin, Director of Accounting Anticipated Date of Completion: The corrections for the 2023-2024 Academic year have already been completed, and the new process will be implemented by October 18, 2024 following the completion of the August online module.

View Audit 323722

Finding 501651 (2024-002)

None 2024

John Brown University and Affiliates

AR

Student Financial Aid Reporting Matching / Level of Effort / Earmarking

Inaccurate Enrollment Reporting to National Student Loan Data System (NSLDS) Planned Corrective Action: To ensure that both accurate and timely enrollment reporting is transmitted to the National Student Loan Data System (NSLDS) an NSC / NSLDS enrollment confirmation process will be established and ...

Inaccurate Enrollment Reporting to National Student Loan Data System (NSLDS) Planned Corrective Action: To ensure that both accurate and timely enrollment reporting is transmitted to the National Student Loan Data System (NSLDS) an NSC / NSLDS enrollment confirmation process will be established and implemented by Student Financial Services. For official withdrawals, an additional processing step will be added to the SFS Withdrawal Tracker. The Student Financial Services rep will confirm that the correct withdrawal date has been accurately reported to the National Student Clearinghouse (NSC) by the Registrar’s office and then correctly transmitted to the National Student Loan Data System (NSLDS). If the reported enrollment date does not align with the Last Date of Academic Related Activity, the SFS Representative will notify either the Director of Student Financial Services (Michelle Baker) or the Chief Student Finance Officer (David Burney) to manually adjust the dates in NSLDS. The SFS office will then notify the Registrar’s office that the dates have been manually updated. For unofficial withdrawals, if a student is identified as an unofficial withdrawal (e.g. lack of attendance in a course resulting in an R2T4 calculation being performed) once the withdrawal list has been reported at the end of each semester by the Registrar’s office, the Student Financial Services Representative will confirm that the correct withdrawal date has been accurately reported to the National Student Clearinghouse (NSC) by the Registrar’s office and then correctly transmitted to the National Student Loan Data System (NSLDS). If the reported enrollment date does not align with the Last Date of Academic Related Activity, the SFS Representative will notify either the Director of Student Financial Services (Michelle Baker) or the Chief Student Finance Officer (David Burney) to manually adjust the dates in NSLDS. The SFS office will then notify the Registrar’s office that the dates have been manually updated. Person Responsible for Corrective Action Plan: David Burney, Chief Student Finance Officer Anticipated Date of Completion: Implementation of process will begin 9/30/2024

View Audit 323688

Finding 501570 (2024-001)

Significant Deficiency 2024

Florida Institute of Technology, Inc.

FL

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

Student financial aid programs cluster Significant Deficiency in Internal Control Condition: During our testing of the regulations, one student who was identified as a withdrawn student did not have the proper calculation performed to determine if funds should be returned in accordance with the ...

Student financial aid programs cluster Significant Deficiency in Internal Control Condition: During our testing of the regulations, one student who was identified as a withdrawn student did not have the proper calculation performed to determine if funds should be returned in accordance with the regulations. Auditor Recommendations: The University should continue to update processes and procedures to ensure compliance in the future. These updated processes should include adequate segregation of duties and review steps to ensure that all students who are subject to potential recapture and return of funds are analyzed in the time frame dictated by the CFR. Action Taken: A new weekly quality assurance report has been created that identifies all withdrawn students. It identifies any student that requires a return calculation in the financial aid management system, and that all required Title IV aid has been returned. The report is generated and reviewed by both the Associate Director and Assistant Director of Financial Aid to ensure adequate segregation of duties and review. This report was run for the entirely of fiscal year 2024 and no other returns were found to be outstanding.

View Audit 323625

Finding 501244 (2024-002)

Significant Deficiency 2024

The Corporation of Gonzaga University

WA

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

FINDING 2024‐002 – Special Tests and Provisions – Return of Title IV (R2T4) Funds Significant Deficiency in Internal Control over Compliance Recommendation: The University should design and implement a robust review process of all R2T4 calculations for official and unofficial withdrawals. This will ...

FINDING 2024‐002 – Special Tests and Provisions – Return of Title IV (R2T4) Funds Significant Deficiency in Internal Control over Compliance Recommendation: The University should design and implement a robust review process of all R2T4 calculations for official and unofficial withdrawals. This will help ensure the accuracy of the calculation before the return of funding. Response: There is no disagreement with this audit finding. Action taken in response to finding: To ensure the accuracy of R2T4 calculations, the Student Financial Services Office will take the following actions: • Implementation of R2T4 Module: Starting with the 2024-2025 academic year, the Financial Aid Office will utilize the Banner-delivered R2T4 module to perform calculations, ensuring more accurate and consistent data management. • Multi-Step Review Process: A multi-step review process has been implemented by Student Financial Services staff to ensure thorough verification of all R2T4 calculations and timely returns of funds. • Enhanced Training: Staff are pursuing additional training on R2T4 regulations and procedures to further strengthen their expertise and reduce the risk of future discrepancies. These actions are in process currently, and expected to be fully implemented and corrected by October 2024 to ensure that R2T4 calculations are prepared and reviewed for accuracy for the 2024-2025 award year. Enhanced training will continue on a go forward basis. Contact Person(s): Louisa Diana, Director of Compliance; Sarah Everitt, Dean of Student Financial Services;

View Audit 323529

Finding 501237 (2024-001)

Significant Deficiency 2024

The Corporation of Gonzaga University

WA

Student Financial Aid Reporting Significant Deficiency

FINDING 2024‐001 – Special Tests and Provisions – Enrollment Reporting Significant Deficiency in Internal Control over Compliance Recommendation: The University should implement a policy to ensure graduates for all semesters/terms are reported timely. Response: There is no disagreement with this aud...

FINDING 2024‐001 – Special Tests and Provisions – Enrollment Reporting Significant Deficiency in Internal Control over Compliance Recommendation: The University should implement a policy to ensure graduates for all semesters/terms are reported timely. Response: There is no disagreement with this audit finding. Action taken in response to finding: Upon identifying this deficiency, Gonzaga University immediately updated its enrollment reporting schedules to ensure timely reporting of mid-summer conferrals. Going forward, all mid-summer degree conferrals will be reported within the required federal timeframe to maintain compliance with Title IV regulations. This adjustment guarantees accurate and timely data submission to the National Student Loan Data System (NSLDS), preventing future delays or discrepancies in reporting. Our new schedule has 9 reporting dates for degree transmission and 14 reporting dates for enrollment transmission in a calendar year. The increased frequency ensures compliance with the 60-day threshold and guarantee that no student will be reported outside the 60-day threshold. We consider this to be remediated. Contact Person(s): Sarah Everitt, Dean of Student Financial Services; Maxwell Kwenda, University Registrar & Director of Institutional Research

View Audit 323529

Finding 501172 (2024-006)

Significant Deficiency 2024

Virginia Union University

VA

Student Financial Aid Reporting Matching / Level of Effort / Earmarking

Criteria: Under the Pell grant and ED loan programs, Institutions are responsible for timely enrollment reporting to NSLDS whether they report directly or via a third-party servicer such as the National Student Clearinghouse (NSC). Enrollment Reporting in a timely and accurate manner is critical for...

Criteria: Under the Pell grant and ED loan programs, Institutions are responsible for timely enrollment reporting to NSLDS whether they report directly or via a third-party servicer such as the National Student Clearinghouse (NSC). Enrollment Reporting in a timely and accurate manner is critical for effective management of the programs. Enrollment information must be reported within 60 days whenever the enrollment status changes for students, unless a roster will be submitted within 60 days. These changes include reductions or increases in attendance levels, withdrawals, graduations, or approved leaves-of-absences. The University concurs with the audit finding and will adhere to the corrective action plan. Corrective Action Plan: Viginia Union University has signficiantly imprved its compliance with federal regulations for enrollment reporting to the National Student Loan Data System (NSLDS). During FY24, a comprehensive review of all files from FY21 to FY23 was conduted to ensure accurate and timely reporting of students' enrollment statuses to the NSLDS. In addition to reviewing previous years, any delinquent reporting for FY24 was also updated to reflect the current status. By April 2024, reporting to NSLDS was synched to a cycle to ensure compliance with the 60-day window. In October 2023, Virginia Union revised its Enrollment Reporting Policy to outline the reporting schedule for submissions to the National Student Clearinghouse (NSC). This updated policy sets forth the timeline and guidelines for enrollment reporting. In addition, Virginia Union University implemented a process to code students who are identified as Unofficial Withdrawal in teh Jenzabar system. This process will ensure these students are included in the monthly reporting to the National Student Clearinghouse even if they do not complete the formal withdrawal process. Responsible person(s): Doreen Dixon, Registrar, ddixon@vuu.edu, 804-257-5845. Robert Merino, Executive Director of Financial Aid, jrmerino@vuu.edu, 804-254-3973. Planned Date of Completion of Corrective Action: August 31, 2024.

View Audit 323427

Finding 499625 (2024-001)

Significant Deficiency 2024

University of Saint Francis

IN

Questioned Costs Student Financial Aid Special Tests & Provisions

We will implement the following solutions immediately to help mitigate our R2T4 processes: the Business Office (BO) will submit refunds to the Department of Education (DOE) as separate transactions rather than netting them with drawdowns; Financial Aid (FA) will confirm correct withdrawal date befor...

We will implement the following solutions immediately to help mitigate our R2T4 processes: the Business Office (BO) will submit refunds to the Department of Education (DOE) as separate transactions rather than netting them with drawdowns; Financial Aid (FA) will confirm correct withdrawal date before starting R2T4 processes and the BO will also confirm after FA has completed these processes; and the BO will save the Student Complete Withdrawal Form, R2T4 Workflow item, ROFC screenshot, FATP email and file from FA, Student Statement, G5/G6 screenshot and email confirmation of refund

View Audit 322507 Questioned Costs: $1

Finding 499522 (2024-003)

Significant Deficiency 2024

Richardton Health Center

ND

Special Tests & Provisions Significant Deficiency Matching / Level of Effort / Earmarking § 200.303

Finding 2024-003 Federal Agency Name: United States Department of Agriculture Program Name: Community Facilities Loans and Grants Federal Assistance Listing #10.766 Finding Summary: During our testing, there was no formal review separate from the preparer over the reserve fund reconciliation for the...

Finding 2024-003 Federal Agency Name: United States Department of Agriculture Program Name: Community Facilities Loans and Grants Federal Assistance Listing #10.766 Finding Summary: During our testing, there was no formal review separate from the preparer over the reserve fund reconciliation for the federal program and there was no formal review of the balance in comparison to the required minimum reserve balance. Responsible Individual: Mandy Robinson, Administrator Corrective Action Plan: We will implement additional control processes to ensure a formal review over the reserve fund reconciliation and a formal review of the balance in comparison to the required minimum reserve balance is completed by staff separate from the preparer. Anticipated Completion Date: 12/31/2024

View Audit 322385

Finding 499462 (2024-008)

Material Weakness 2024

Outpatient Medical Center, Inc.

LA

Questioned Costs Cash Management Subrecipient Monitoring § 200.305

2024-008 Cash Management Corrective action planned: Federal draws will be made with approval of the Director of Financial Operations or their designee for expenditures that have been incurred and recorded in the general ledger. Electronic documentation will be organized by draw to ensure proper d...

2024-008 Cash Management Corrective action planned: Federal draws will be made with approval of the Director of Financial Operations or their designee for expenditures that have been incurred and recorded in the general ledger. Electronic documentation will be organized by draw to ensure proper documentation is maintained. Anticipated completion date: 11-30-2024 Contact person responsible for corrective action: Cathy Liles, Director of Fiscal Operations

View Audit 322303 Questioned Costs: $1

Corrective Action Plans

Filters