Corrective Action Plans

Finding 520894 (2024-001)

Significant Deficiency 2024

Bryant University

RI

Student Financial Aid Reporting Matching / Level of Effort / Earmarking

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

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

View Audit 340765

Finding 520888 (2024-001)

Significant Deficiency 2024

Rainbow Fleet, Inc.

OK

Eligibility Reporting Matching / Level of Effort / Earmarking § 200.512

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

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

View Audit 340750

Finding 520857 (2024-002)

None 2024

Williams College

MA

Student Financial Aid Reporting Eligibility

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

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

View Audit 340686

Finding 520845 (2024-002)

None 2024

Simpson University

CO

Student Financial Aid Reporting Matching / Level of Effort / Earmarking

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

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

View Audit 340662

Finding 520842 (2024-001)

Material Weakness 2024

Simpson University

CO

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

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

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

View Audit 340662

Finding 520751 (2024-002)

Significant Deficiency 2024

Loogootee Community School Corporation

IN

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

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

View Audit 340471

Finding 520743 (2024-001)

Material Weakness 2024

Loogootee Community School Corporation

IN

Special Tests & Provisions Subrecipient Monitoring Material Weakness § 200.303

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

View Audit 340471

Finding 520704 (2024-001)

Significant Deficiency 2024

San Joaquin College of Law

CA

Student Financial Aid Reporting Matching / Level of Effort / Earmarking

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

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

View Audit 340442

Finding 520624 (2024-001)

Material Weakness 2024

Milwaukee Institute of Art and Design, Inc.

WI

Reporting Special Tests & Provisions Student Financial Aid

2024-001 Assistance Listing Number(s), Federal Agency and Program Name: 84.063, 84.007, 84.033, and 84.268; United States Department of Education (DOE), Student financial assistance cluster. Finding Type: Noncompliance and material weakness in internal control over compliance relating to special tes...

2024-001 Assistance Listing Number(s), Federal Agency and Program Name: 84.063, 84.007, 84.033, and 84.268; United States Department of Education (DOE), Student financial assistance cluster. Finding Type: Noncompliance and material weakness in internal control over compliance relating to special tests. Criteria: The Institute is responsible for designing, implementing, and maintaining internal control over compliance for special tests and provisions and for accurately and timely reporting significant data elements under the Campus-Level and Program-Level records within the National Student Loan Data System (NSLDS) that DOE considers high risk. Statement of Condition: Management implemented controls that specifically addressed the some of the circumstances surrounding prior year finding 2023-001. Management's review of the enrollment reporting did not detect errors on certain student Program-Level data elements or timely reporting. Certain student records within the NSLDS were identified with inaccurate Program-Level data elements and not timely reported. Questioned Costs: There were no questioned costs. Context: 9 students were identified with inaccurate Program-Level data elements and not timely reported out of a total of 27 student statuses tested. The Campus-Level data elements were accurately and timely reported. Cause: The Institute’s internal control over compliance did not detect and correct the errors. The preparer incorrectly reported graduate file impacting the student's effective dates and statuses during submission process to NSLDS resulting in inaccuracies in significant Program-Level enrollment data elements that ED considers high risk. The Institute’s internal control over compliance did not detect and correct the error. Effect: The Institute incorrectly reported certain Program-Level records in NSLDS which is information that DOE considers high risk and the Institute’s internal controls over compliance did not detect and correct the errors. Recommendation: We recommend management review policies and procedures surrounding enrollment reporting submissions to ensure the accuracy of Program-Level data elements reported to DOE. A review performed by an appropriate individual separate from the preparer prior to the submission of the enrollment reports to NSLDS may improve the accuracy of enrollment reporting. Management’s Response: Management agrees with the finding. Through internal investigation, it was determined that the date field issues found in 2023 also impacted “special” files, which include graduate data files and are processed differently in-house. This error has been fixed so that both fields will always be the same and accurate using the same method as the 2023-001 finding. The registrar will now confirm both the student-level and program-level data fields upon submission to NSC. Status: Completed January 2024 Contact: Mark Fetherston Vice President for Enrollment Management 414-847-3215 markfetherston@miad.edu

View Audit 340289

Finding 520614 (2024-008)

Material Weakness 2024

Harmony Area School District

PA

Internal Control / Segregation of Duties Subrecipient Monitoring Reporting

Action Taken: Management agrees with the recommendations. The management team involved with grants will work to modify and improve the current procedures and will implement the controls surrounding grant compliance, from the application process through final reporting. The team will also continue to...

Action Taken: Management agrees with the recommendations. The management team involved with grants will work to modify and improve the current procedures and will implement the controls surrounding grant compliance, from the application process through final reporting. The team will also continue to work to enhance our grant monitoring, including resuming management team meetings to keep everyone abreast of the status of grants. In addition, we will begin to gradually involve the new business office employee in grant reporting to improve on compliance with grant reporting requirements.

View Audit 340240

Finding 520605 (2024-005)

None 2024

Harmony Area School District

PA

Questioned Costs Subrecipient Monitoring Reporting

Action Taken: Management agrees with the recommendations. The unique situation with the COVID-19 funding, coupled with shifts in the business manager’s duties over the last few years and the staff retirement has resulted in grant report filings becoming a lower priority. The management team will wor...

Action Taken: Management agrees with the recommendations. The unique situation with the COVID-19 funding, coupled with shifts in the business manager’s duties over the last few years and the staff retirement has resulted in grant report filings becoming a lower priority. The management team will work together and will resume management team meetings to determine and monitor the duties for which each is responsible. Strides have been made in this regard, as the principals have become involved in Federal program training, budgeting, and scheduling. Although the aforementioned report submissions are delinquent and funding was suspended, some filings have been completed, and certain payments are forthcoming. However, management will begin to gradually involve the new business office employee in grant reporting to improve on compliance with grant reporting requirements.

View Audit 340240

Finding 520596 (2024-001)

Significant Deficiency 2024

Nebraska Aids Project, Inc.

NE

Subrecipient Monitoring Matching / Level of Effort / Earmarking Internal Control / Segregation of Duties

U.S. Department of Health and Human Services, Pass-through Programs from: Nebraska Department of Health and Human Services and the Iowa Department of Health and Human Services HIV Care Formula Grants, AL #93.917 Award No. 24X07HA00042, 24X07HA00041, 5884HC14 Award Periods: April 1, 2023 to March 31,...

U.S. Department of Health and Human Services, Pass-through Programs from: Nebraska Department of Health and Human Services and the Iowa Department of Health and Human Services HIV Care Formula Grants, AL #93.917 Award No. 24X07HA00042, 24X07HA00041, 5884HC14 Award Periods: April 1, 2023 to March 31, 2024 and April 1, 2024 to March 31, 2025 Eligibility: Significant Deficiency in Internal Control over Compliance Finding Summary: For 1 of 25 program participants selected for testing from the State of Nebraska, the participant file was missing documentation of HIV status. For 1 of 13 program participants selected for testing from the State of Iowa, the participant file was missing documentation for the annual recertification. Responsible Individuals: Brent Koster, Executive Director Corrective Action Plan: Procedures will be developed to ensure proper eligibility determinations are maintained in the file. Additionally, recertifications will be completed timely and documentation maintained in the file. Anticipated Completion Date: June 2025

View Audit 340211

Finding 520434 (2024-002)

Significant Deficiency 2024

Board of Education of Allegany County

MD

Subrecipient Monitoring Matching / Level of Effort / Earmarking Special Tests & Provisions

The Board acknowledges its lack of compliance relative to contractor and subcontractor payroll monitoring and omitting this requirement within the contract. The Board did provide the prevailing wage requirements within the contracts. Going forward when federal funds are utilitized for construction...

The Board acknowledges its lack of compliance relative to contractor and subcontractor payroll monitoring and omitting this requirement within the contract. The Board did provide the prevailing wage requirements within the contracts. Going forward when federal funds are utilitized for construction projects, management will reference the Code of Federal Regulations and relevant compliance supplements and cross-cutting supplements for expenditures of federal awards.

View Audit 340104

Finding 520374 (2024-001)

Material Weakness 2024

Erie County Metropolitan Housing Authority

OH

Eligibility Subrecipient Monitoring HUD Housing Programs § 200.303

Case Managers will ensure all documents are scanned and retained for the Authority’s files prior to destroying them.

View Audit 340087

Finding 520351 (2024-003)

Material Weakness 2024

Baugo Community Schools

IN

Matching / Level of Effort / Earmarking Special Tests & Provisions Subrecipient Monitoring § 200.303

Subject: Education Stabilization Fund – Special Tests and Provisions - Wage Rate Requirements Federal Agency: Department of Education Federal Program: COVID-19 - Education Stabilization Fund Assistance Listing Number: 84.425U Federal Award Numbers: S425U210013 Pass-Through Entity: Indiana Department...

Subject: Education Stabilization Fund – Special Tests and Provisions - Wage Rate Requirements Federal Agency: Department of Education Federal Program: COVID-19 - Education Stabilization Fund Assistance Listing Number: 84.425U Federal Award Numbers: S425U210013 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Special Tests and Provisions - Wage Rate Requirements Audit Findings: Material Weakness Condition: An effective internal control system was not in place at the School Corporation in order to ensure compliance with requirements related to the grant agreement and the Special Tests and Provisions – Wage Rate Requirements compliance requirements. The School Corporation did not include Davis Bacon wage rate requirements in its contract with vendor which includes labor installation. The School Corporation did not obtain the weekly payroll reports certifications from vendor installing equipment. Context: The School Corporation had three projects during the audit period which included construction or labor installation which were charged to the ESSER III (84.425U) grant award. For one of two vendors selected for testing, the School Corporation did not include federal wage rate requirement clauses in the contract with the vendor and did not have an internal control designed to collect the weekly payroll reports certifications from vendors and its subcontractors, as applicable, to comply with Davis Bacon wage rate requirements. The amount disbursed for the project totaled $50,000. Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: Management will ensure all construction projects anticipated to incur labor costs greater than $2,000 include a signed contract containing a Davis-Bacon wage rate provision and will monitor the vendor to ensure compliance with certified payroll reporting requirements. Responsible Party and Timeline for Completion: David Wolford and Wyatt Schmicker will review wage rate provisions with vendors before initiating contracts when using federal funds.

View Audit 340079

Finding 520312 (2024-003)

Significant Deficiency 2024

Chaffey Community College District

CA

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

The Financial Aid department will continue to review and update the reporting procedures. The Director of Financial Aid will review the origination and posting of loans with staff and train them to ensure that dates are consistent and in compliance with Title IV regulations.

View Audit 340029

Finding 520305 (2024-002)

Significant Deficiency 2024

Chaffey Community College District

CA

Student Financial Aid Reporting Significant Deficiency

The departments involved in the enrollment reporting process are continuing to review and enhance the workflow in order to report accurately. Monthly submissions by Information Technology Systems (ITS) will be completed in a timely manner to allow for prompt communication of corrections that are req...

The departments involved in the enrollment reporting process are continuing to review and enhance the workflow in order to report accurately. Monthly submissions by Information Technology Systems (ITS) will be completed in a timely manner to allow for prompt communication of corrections that are required, which are communicated to Admissions and Records by the National Student Clearinghouse (NSCH). Admissions and Records will ensure that error reports provided by NSCH are returned to NSCH within 10 business days to allow for a timely submission to the National Student Loan Database (NSLDS). Staff in Admissions and Records has been specifically assigned to complete error reports to contribute to a prompt submission. The Admissions and Records department will collaborate and communicate with the Financial Aid department to identify students with error codes in NSLDS in an effort to correct them. The Admissions and Records and Financial Aid departments will work with the Internal Auditor to perform semiannual reviews of NSLDS data to ensure accuracy of student records.

View Audit 340029

Finding 520293 (2024-003)

Significant Deficiency 2024

T.a. Lawson State Community College

AL

Allowable Costs / Cost Principles Questioned Costs Significant Deficiency

Management's Response: The College will strengthen its policies and procedures surrounding payroll grant disbursements to ensure expenses are properly approved and allowable under the specific grant budget. Management will ensure that budgets are amended when changes in pay rates occur during the ...

Management's Response: The College will strengthen its policies and procedures surrounding payroll grant disbursements to ensure expenses are properly approved and allowable under the specific grant budget. Management will ensure that budgets are amended when changes in pay rates occur during the grant award periods. Anticipated Completion Date: February 28, 2025

View Audit 340025 Questioned Costs: $1

Finding 520291 (2024-002)

Significant Deficiency 2024

T.a. Lawson State Community College

AL

Allowable Costs / Cost Principles Questioned Costs Cash Management

Management's Response: The College will strengthen its policies and procedures surrounding non-payroll grant disbursements to ensure disbursements are approved, allowable, and calculations supported. Management will review budgets on a monthly basis to ensure expenses do not exceed the budget. M...

Management's Response: The College will strengthen its policies and procedures surrounding non-payroll grant disbursements to ensure disbursements are approved, allowable, and calculations supported. Management will review budgets on a monthly basis to ensure expenses do not exceed the budget. Management will review indirect cost calculations to ensure they are calculated at the correct percentages. Management will review invoices three months past year end to ensure the proper accrual of expenses. Anticipated Completion Date: February 28, 2025

View Audit 340025 Questioned Costs: $1

Finding 520287 (2024-001)

Significant Deficiency 2024

Calvin University

MI

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

Condition: The University does not have controls in place for review of Return of Title IV calculation. Planned Corrective Action: All R2T4 calculations will be reviewed by a second individual within the Calvin Financial Aid Office. Calculations will not become final until both individuals agree wit...

Condition: The University does not have controls in place for review of Return of Title IV calculation. Planned Corrective Action: All R2T4 calculations will be reviewed by a second individual within the Calvin Financial Aid Office. Calculations will not become final until both individuals agree with the specifics of each calculation. Contact person responsible for corrective action: James Koeman, Director of Financial Aid Anticipated Completion Date: Already completed as of the 24FA term.

View Audit 340021

Finding 520227 (2024-003)

Material Weakness 2024

Covington Community School Corporation

IN

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

Context: The School Corporation was required to submit two Annual Data Reports to the Indiana Department of Education (IDOE) during the audit period to meet federal reporting requirements for ESSER grant awards. We noted that the ESSER II and ESSER III amounts reported on the Year 3 report ($347,59...

Context: The School Corporation was required to submit two Annual Data Reports to the Indiana Department of Education (IDOE) during the audit period to meet federal reporting requirements for ESSER grant awards. We noted that the ESSER II and ESSER III amounts reported on the Year 3 report ($347,591 and $337,851 respectively) did not agree to the underlying expenditure records ($135,355 and $159,811 respectively). Additionally, we noted that the ESSER II amount reported on the Year 4 report ($233,093) did not agree to the underlying expenditure records ($267,310) of the School Corporation. Contact Person Responsible for Corrective Action: Vicki Jones Contact Phone Number: 765-793-4877 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: Annual report data will be submitted with the requested information and will be verified with a sign-off by the Superintendent. Anticipated Completion Date: July 2025

View Audit 339860

Finding 520216 (2024-001)

Material Weakness 2024

Tri-County School Corporation

IN

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

Finding 2024-001 – Child Nutrition Cluster – Eligibility Context: During sample testing of 60 students for eligibility, we noted 7 instances where there was no documented review by someone other than the individual making the eligibility determination. The lack of review was isolated to paper appl...

Finding 2024-001 – Child Nutrition Cluster – Eligibility Context: During sample testing of 60 students for eligibility, we noted 7 instances where there was no documented review by someone other than the individual making the eligibility determination. The lack of review was isolated to paper applications. Contact Person Responsible for Corrective Action: Mr. Patrick Culp Contact Phone Number: 219-279-2418 Views of Responsible Official: We concur with the finding. Of note, this is a new finding as we have never experienced this problem before. For this audit period, the Tri-County Food Service Director suffered a serious foot injury, requiring her to miss an extended period of time. When the accident with the Food Service Director occurred, one of the first actions the corporation took was to contact IDOE about our situation. The IDOE was aware how the review the process would look during that time. While the Food Service Director was recovering, student eligibility was not reviewed properly. Description of Corrective Action Plan: The Tri-County School Corporation food service director will complete all initial reviews of student eligibility. The initial review will be for both electronic and paper applications. Once the initial review is complete, the Tri-County central office secretary will complete a second review. The secretary works in a different building and does not have a role in eligibility determinations. Anticipated Completion Date: Our corrective action plan began in August 2024, upon the return of our food service director, and this is the plan moving forward.

View Audit 339770

Finding 520161 (2024-002)

Significant Deficiency 2024

Tri-City Healthcare District

CA

HUD Housing Programs Questioned Costs Cash Management

Finding 2024-002: Reporting – Significant Deficiency in Internal Control Over Compliance and Instance of Noncompliance Corrective Action Planned: The District agrees with the findings and management has implemented a corrective action plan to ensure the required reports are filed timely. Starting Ja...

Finding 2024-002: Reporting – Significant Deficiency in Internal Control Over Compliance and Instance of Noncompliance Corrective Action Planned: The District agrees with the findings and management has implemented a corrective action plan to ensure the required reports are filed timely. Starting January 2024, all financial reports were filed on time. Person Responsible for Corrective Action: Anh Nguyen, Controller Anticipated Completion Date: June 30, 2025

View Audit 339746

Finding 520055 (2024-001)

Significant Deficiency 2024

Champaign-Urbana Mass Transit District

IL

Reporting Matching / Level of Effort / Earmarking § 200.303

We have reviewed the control procedures around preparation and review of the schedule of expenditures of federal awards (SEFA) and implemented an independent review of the assistance listing numbers (ALN} per the grant agreements in the initial review of the SEFA. The improved procedures will provid...

We have reviewed the control procedures around preparation and review of the schedule of expenditures of federal awards (SEFA) and implemented an independent review of the assistance listing numbers (ALN} per the grant agreements in the initial review of the SEFA. The improved procedures will provide the needed structure to fulfill management's responsibility to accurately report the grantor agency/ pass-through grantor, assistance listing number, federal program name and number, and expenditures. Identification of major programs, utilizing the guidelines in the Office of Management and Budget's (0MB) Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance} are the responsibility of the auditor.

View Audit 339560

Finding 520054 (2024-001)

None 2024

The Cleveland Institute of Art and Subsidaries

OH

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

Management acknowledges that there was an error with one over award of subsidized loan on a student. Student was given $448 (gross) over the aggregate subsidized limit. The overage was sent back to the Direct lender. Since the student graduated, the $448 was covered by a grant. A survey of all stude...

Management acknowledges that there was an error with one over award of subsidized loan on a student. Student was given $448 (gross) over the aggregate subsidized limit. The overage was sent back to the Direct lender. Since the student graduated, the $448 was covered by a grant. A survey of all students was completed and no other students were discovered to have been over their aggregate subsidized limit. • A student’s aggregate subsidized amount on NSLDS from his FAFSA record was listed at $17,948, allowing only $5,052 in remaining to reach the $23,000 aggregate limit on subsidized loan. Student was given $5,500 when it should have been $5,052. The $448 should have been given as unsubsidized loan. Student had previous loans from another school. (Powerfaids will catch this error if all of the historic loans were processed within our database.) • The student ISIR record did have Comment code 258: “Based upon data provided by the National Student Loan Data System (NSLDS) and your grade level, we have determined that you may have received a total amount of undergraduate student loans that is close to or equal to the loan limits established for the federal loan programs. Therefore, your eligibility for additional student loans may be limited.“ • The Federal processor usually sends a post-screening after federal aid is disbursed with warnings of limits: 255, 256, 258. 260 ad 261. This would cause a C-code on the student record. We did not receive a subsequent ISIR record on said student. Corrective Action Plan: Include in the Quality Assurance rules one for the ISIR codes associated with NSLDS overawarding of loans whether it be annual limits or aggregate limits. We will monitor these codes regularly during packaging season and subsequent to loan disbursing.

View Audit 339558

Corrective Action Plans

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