Corrective Action Plans

Finding 390416 (2023-009)

Material Weakness 2023

DE

Subrecipient Monitoring Material Weakness Matching / Level of Effort / Earmarking § 200.303

2023-009 Student Financial Assistance Cluster – Federal Assistance Listing Nos. 84.007, 84.063, 84.033 and 84.268 – Gramm-Leach-Bliley Act (GLBA) Recommendation: We recommend the University review is policies and procedures and update the information security plan to be GLBA compliant. Explanation o...

2023-009 Student Financial Assistance Cluster – Federal Assistance Listing Nos. 84.007, 84.063, 84.033 and 84.268 – Gramm-Leach-Bliley Act (GLBA) Recommendation: We recommend the University review is policies and procedures and update the information security plan to be GLBA compliant. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Division of Information Technology is reviewing the written policies and procedures needed to safeguard the University’s applications and data. This includes all 3rd party developed/ implemented applications as well. Name(s) of the contact person(s) responsible for corrective action: Executive Director of Network Services, Russel Weaver & VP/ Chief Information Officer, Darrell McMillion. Planned completion date for corrective action plan: June 2024

View Audit 301226

Finding 390414 (2023-003)

Significant Deficiency 2023

Metropolitan Community College Area

NE

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

COVID-19 Education Stabilization Fund Recommendation: We recommend the College establish a system to ensure reports are submitted in a timely manner. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: All HEERF funds ...

COVID-19 Education Stabilization Fund Recommendation: We recommend the College establish a system to ensure reports are submitted in a timely manner. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: All HEERF funds have been spent and reports are posted on the website. No additional reports will need to be posted. Name(s) of the contact person(s) responsible for corrective action: Brenda Schumacher Planned completion date for corrective action plan: Prior to Summer 2023

View Audit 301214

Finding 390401 (2023-002)

Significant Deficiency 2023

Livingstone College

NC

Student Financial Aid Matching / Level of Effort / Earmarking Allowable Costs / Cost Principles

Finding 2023-002 – U.S. Department of Education (USDE), Title IV Student Financial Aid Programs (Deficiency): 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) One (1) out of six (6) stu...

Finding 2023-002 – U.S. Department of Education (USDE), Title IV Student Financial Aid Programs (Deficiency): 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) One (1) out of six (6) students tested for R2T4 did not have Title IV funds returned to the Federal government within the required 45 days. Title IV HEA 34 CFR 668.22. b) The College was not reconciling between Financial Aid and Business Office on the monthly basis per SFA Handbook Ch. 5 CFR668.161-668.176. Auditor’s Recommendation – We recommend that the College ensure adequate documentation is obtained and kept on file as evidence that all expenditures meet allowable cost and other requirements under the grant program. Corrective Action – Management agrees with this finding. The College will place additional emphasis on the R2T4 of funds. Management is reviewing the timing of presentation of situations to Financial Aid that require returning funds to the Department. Additional focus will be placed on procedures to timely report withdraws to Financial Aid to support returned funds in the required 45 days. In addition, the College prepares monthly reconciliations between Financial Aid and the Business Office, but often delayed in completion. Going forward, the reconciliation will be noted on the monthly closing list and requires both the Assistant Vice President of Financial Aid and Controller to sign and date the reconciliation to demonstrate compliance with the monthly requirement.

View Audit 301203

Finding 390378 (2023-103)

Material Weakness 2023

Coconino County

AZ

Questioned Costs Matching / Level of Effort / Earmarking Allowable Costs / Cost Principles § 200.303

Cluster name: WIOA Cluster Assistance Listings number and program names: 17.258 WIOA Adult Program 17.259 WIOA Youth Program 17.278 WIOA Dislocated Worker Formula Grants Contact person: Billy Francis, Executive Director, Coconino Workforce Development Board, County Administration Anticipated complet...

Cluster name: WIOA Cluster Assistance Listings number and program names: 17.258 WIOA Adult Program 17.259 WIOA Youth Program 17.278 WIOA Dislocated Worker Formula Grants Contact person: Billy Francis, Executive Director, Coconino Workforce Development Board, County Administration Anticipated completion date: June 30, 2024 Concur. The County Administration Department acknowledges the work experience (WEX) requirement was not met for the Workforce Innovation and Opportunity Act (WIOA) Youth Program Year 2021 allocation. The Department has a tracking mechanism in the financial system and other records to account for the percentage of youth expenditures made on WEX activities. Due to an oversight, the percentage of WEX expenditures in relation to the total allocation was not monitored by staff. Additionally, the amount of WEX funding allocated to the Youth program service provider was insufficient to meet the requirement. The Department will write procedures for the monitoring of earmarking requirements, including WEX, to ensure the roles and responsibilities of staff and key stakeholders are clearly defined. The calculation of funds allocated to the service provider will factor in the level of WEX expenditures needed for the County to meet the requirement. The Department will work with the WIOA Youth program service provider to employ best practices and strategies to recruit eligible in-school and out-of-school youth in need of WEX activities to further their skills and job readiness. The Department will monitor WEX expenditures made by the service provider and provide technical assistance as needed. If the Department projects the County will not meet the threshold for a certain program year allocation, it will seek technical assistance from the Arizona Department of Economic Security.

View Audit 301196 Questioned Costs: $1

Finding 390374 (2023-002)

Material Weakness 2023

Collins Career Center

OH

Reporting Matching / Level of Effort / Earmarking § 200.329

I was instructed by our U.S. Department of Education representative to not post additional reports to our website until all prior reports have been corrected.

View Audit 301193

Finding 390307 (2023-002)

Significant Deficiency 2023

University of Massachusetts Global-9 Month Audit

CA

Student Financial Aid Reporting Matching / Level of Effort / Earmarking

University of Massachusetts Global concurs with this finding. The University utilizes the services of National Student Clearinghouse to report student status data to the NSLDS. There were 6 students reported as graduated beyond the 60 days, and 1 student with an error that was not corrected within 1...

University of Massachusetts Global concurs with this finding. The University utilizes the services of National Student Clearinghouse to report student status data to the NSLDS. There were 6 students reported as graduated beyond the 60 days, and 1 student with an error that was not corrected within 10 days. To address this, the Office of the Registrar now has access to NSLDS to ensure that what is reported to NSC is also updated accurately in NLSDS. The Office of the Registrar will also change the reporting dates so that it best aligns with the conferral dates. In addition, the Office of the Registrar will have an additional QA process so that any time status changes are compared against the NSC report that is generated and submitted.

View Audit 301167

Finding 390306 (2023-001)

Significant Deficiency 2023

University of Massachusetts Global-9 Month Audit

CA

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

University of Massachusetts Global concurs with this finding. To address this, a new control has been added beginning with the 2023-2024 fiscal year. The new step added is for a systems specialist to confirm that the batch process for award notifications has been completed, and that the notification...

University of Massachusetts Global concurs with this finding. To address this, a new control has been added beginning with the 2023-2024 fiscal year. The new step added is for a systems specialist to confirm that the batch process for award notifications has been completed, and that the notifications have been sent to students prior to disbursements of Title IV aid.

View Audit 301167

Finding 390289 (2023-001)

Material Weakness 2023

Commonspirit Health

IL

Eligibility Matching / Level of Effort / Earmarking § 200.303

REFERENCE: 2023-001 – Eligibility Medicaid Cluster (Assistance Listing No. 93.778) Federal Grantor: U.S. Department of Health and Human Services Facility: Dignity Health Medical Foundation Finding: The Dignity Health Medical Foundation did not retain evidence of Medicaid eligibility being reviewed...

REFERENCE: 2023-001 – Eligibility Medicaid Cluster (Assistance Listing No. 93.778) Federal Grantor: U.S. Department of Health and Human Services Facility: Dignity Health Medical Foundation Finding: The Dignity Health Medical Foundation did not retain evidence of Medicaid eligibility being reviewed prior to patient services being provided. Corrective Action Plan: For the Medical Assistance Program, eligibility is validated through a Medi-Cal system website. Dignity Health Medical Foundation personnel have implemented procedures to ensure documentation of eligibility checks are retained. The Clinic Operations manager has instructed staff and supervisors to save proof of eligibility for all months. The Clinic Operations manager checks for retention of eligibility documentation on a random basis and an internal audit will be performed to check for compliance with the documentation retention. Person Responsible: Nicole Hill, Clinic Operations Manager, Dignity Health Medical Foundation. Completion: September 1, 2022

View Audit 301158

Finding 390287 (2023-013)

Significant Deficiency 2023

Commonspirit Health

IL

Procurement, Suspension & Debarment Eligibility Reporting § 200.303

REFERENCE: 2023-013 – Activities Allowed or Unallowed Provider Relief Fund and American Rescue Plan (ARP) Rural Distributions (PRF) (Assistance listing No. 93.498) Federal Grantor: U.S. Department of Health and Human Services Facility: Catholic Health Initiatives Colorado (CHIC) Finding: Manageme...

REFERENCE: 2023-013 – Activities Allowed or Unallowed Provider Relief Fund and American Rescue Plan (ARP) Rural Distributions (PRF) (Assistance listing No. 93.498) Federal Grantor: U.S. Department of Health and Human Services Facility: Catholic Health Initiatives Colorado (CHIC) Finding: Management did not consistently retain evidence to support that internal controls were in place and operating effectively for approval of invoices with purchase orders and to ensure that bonuses paid to employees related to COVID-19 were eligible to receive the bonus. Corrective Action Plan: This program has ended. CHIC has no additional funding to apply expenses to.

View Audit 301158

Finding 390285 (2023-012)

Significant Deficiency 2023

Commonspirit Health

IL

Student Financial Aid Matching / Level of Effort / Earmarking Special Tests & Provisions § 200.303

REFERENCE: 2023-012 – Special Tests and Provisions – Return of Title IV Funds SFA Cluster (Assistance Listing No. 84.268) Federal Grantor: U.S. Department of Education Facility: Good Samaritan College of Nursing and Health Science Finding: Good Samaritan College of Nursing and Health Science did no...

REFERENCE: 2023-012 – Special Tests and Provisions – Return of Title IV Funds SFA Cluster (Assistance Listing No. 84.268) Federal Grantor: U.S. Department of Education Facility: Good Samaritan College of Nursing and Health Science Finding: Good Samaritan College of Nursing and Health Science did not calculate and return Title IV funds in a timely manner to the U.S. Department of Education, within 45 days after the date the institution determined that a student withdrew. Good Samaritan College of Nursing & Health Science did not provide evidence of an effective review process to ensure the timely calculation and return of Title IV funds to the U.S. Department of Education. Corrective Action Plan: To ensure timely returns, Financial Aid Services will incorporate an additional step to the return disbursement process. The additional step will occur after each return to ensure the Common Origination and Disbursement (COD) system shows the return successfully processed for the student. Financial Aid Services will review the student’s disbursement detail history in COD to confirm the return credit adjustment has been applied to the appropriate record and it shows an applied date at ED within the appropriate timeframe for the return. To document this process has been completed, Financial Aid Services will maintain a spreadsheet for all returns. The spreadsheet will document the student, amount of the return, date processed in Financial Aid and Student Accounts, date processed in G5, and date applied at ED per COD. If any issues arise during this review where the return did not successfully apply at ED, Financial Aid Services will review and resolve rejects immediately so the record can move forward and process successfully within the required timeframe. The Dean of Financial Services will validate the report submitted by Financial Aid Services on a monthly basis and submit the document to the President. Both will review and sign the documentation. This documentation will be presented to the GSC Compliance Oversight Committee to ensure monthly verification of time return of Title IV funds. Person Responsible: Judy Kronenberger, President Good Samaritan College of Nursing and Health Science Expected Completion: April 2024

View Audit 301158

Finding 390280 (2023-007)

Material Weakness 2023

Commonspirit Health

IL

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

REFERENCE: 2023-007 – Special Tests and Provisions – Disbursements to or on Behalf of Students SFA Cluster (Assistance Listing No. 84.268) Federal Grantor: U.S. Department of Education Facility: Good Samaritan College of Nursing and Health Science and CHI Health School of Radiologic Technology Find...

REFERENCE: 2023-007 – Special Tests and Provisions – Disbursements to or on Behalf of Students SFA Cluster (Assistance Listing No. 84.268) Federal Grantor: U.S. Department of Education Facility: Good Samaritan College of Nursing and Health Science and CHI Health School of Radiologic Technology Finding: Good Samaritan College of Nursing & Health Science did not send loan notifications to 3 of 30 students selected for disbursement testing for direct loans within 30 days of funds being disbursed. CHI Health School of Radiologic Technology did not send loan notifications to 14 of 14 students for disbursement testing with direct loans within 30 days of funds being disbursed. Corrective Action Plan: This finding has been corrected for Good Samaritan. As of May 2023, for April 2023 loan disbursements, compliance is verified monthly through internal audit of student disbursements. A sample of disbursements is checked for proper and timely notifications. Timeliness of notifications is checked and verified by the Compliance Oversight Committee monthly. CHI Health School of Radiologic Technology will review their processes to develop and implement internal controls that ensure compliance with federal regulations. Evidence of the internal control being performed will be retained. Person Responsible: Judy Kronenberger, President, Good Samaritan College of Nursing and Health Science David Velasquez, Nuclear Medicine Technologist Coordinator CHI Health School of Radiologic Technology Completion/Expected Completion: April 2023 (Good Samaritan)/June 2024 (CHI Health School of Radiologic Technology)

View Audit 301158

Finding 390276 (2023-010)

Significant Deficiency 2023

Commonspirit Health

IL

Special Tests & Provisions Eligibility Reporting § 200.303

REFERENCE: 2023-010 – Special Tests and Provision – Enrollment Reporting Student Financial Assistance Cluster (Assistance listing No. 84.063, 84.268) Federal Grantor: U.S. Department of Education Facility: Good Samaritan College of Nursing and Health Science and CHI Health School of Radiologic Tech...

REFERENCE: 2023-010 – Special Tests and Provision – Enrollment Reporting Student Financial Assistance Cluster (Assistance listing No. 84.063, 84.268) Federal Grantor: U.S. Department of Education Facility: Good Samaritan College of Nursing and Health Science and CHI Health School of Radiologic Technology Finding: Good Samaritan College of Nursing & Health Science and CHI Health School of Radiologic Technology did not have internal controls over enrollment reporting. Corrective Action Plan: This finding has been corrected for Good Samaritan as of April 2023. Enrollment reporting to the National Student Clearinghouse is conducted 5 times per year and reconciled monthly with loan borrowers to ensure active enrollment. Additional Status Update: The Dean of Enrollment Management validates and reports to the oversight committee regarding the monthly reporting. Monthly reporting to the GSC Compliance committee has verified completion since May 2023 and has been timely thereafter. CHI Health School of Radiologic Technology will review their processes to develop and implement internal controls that ensure compliance with federal regulations. Evidence of the internal control being performed will be retained. Person Responsible: Judy Kronenberger, President Good Samaritan College of Nursing and Health Science David Velasquez, Nuclear Medicine Technologist Coordinator, CHI Health School of Radiologic Technology Expected Completion: April 2023 (Good Samaritan) and June 2024 (CHI Health School of Radiologic Technology)

View Audit 301158

Finding 390275 (2023-009)

Significant Deficiency 2023

Commonspirit Health

IL

Eligibility Matching / Level of Effort / Earmarking § 200.303

REFERENCE: 2023-009 – Activities Allowed or Unallowed/Eligibility SFA Cluster (Assistance Listing No. 84.063, 84.268) Federal Grantor: U.S. Department of Education Facility: CHI Health School of Radiologic Technology Finding: CHI Health School of Radiologic Technology did not have adequate internal...

REFERENCE: 2023-009 – Activities Allowed or Unallowed/Eligibility SFA Cluster (Assistance Listing No. 84.063, 84.268) Federal Grantor: U.S. Department of Education Facility: CHI Health School of Radiologic Technology Finding: CHI Health School of Radiologic Technology did not have adequate internal controls in place surrounding Activities Allowed or Unallowed and Eligibility. Corrective Action Plan: The financial aid administrator will implement an eligibility checklist to document the review of student documents in line with US Department of Education criteria. The checklist will be completed and a review performed prior sending the financial aid package to the student. Person Responsible: David Velasquez, Nuclear Medicine Technologist Coordinator, CHI Health School of Radiologic Technology Expected Completion: June 2024

View Audit 301158

Finding 390274 (2023-008)

Significant Deficiency 2023

Commonspirit Health

IL

Special Tests & Provisions Student Financial Aid Eligibility § 200.303

REFERENCE: 2023-008 – Special Tests and Provisions – Satisfactory Academic Progress SFA Cluster (Assistance Listing No. 84.063, 84.268) Federal Grantor: U.S. Department of Education Facility: CHI Health School of Radiologic Technology Finding: CHI Health School of Radiologic Technology had no docum...

REFERENCE: 2023-008 – Special Tests and Provisions – Satisfactory Academic Progress SFA Cluster (Assistance Listing No. 84.063, 84.268) Federal Grantor: U.S. Department of Education Facility: CHI Health School of Radiologic Technology Finding: CHI Health School of Radiologic Technology had no documented evidence of review and approval of Satisfactory Academic Policy. Additionally, the Satisfactory Academic Policy did not contain all required elements according to federal regulations. Corrective Action Plan: CHI Health School of Radiologic Technology has revised the Satisfactory Academic Policy to incorporate the required components. Additionally, CHI Health will implement documentation procedures including an agenda and minutes for their annual meeting to review the school policies. Person Responsible: Robert Hughes, Program Director, CHI Health School of Radiologic Technology Expected Completion: June 2024

View Audit 301158

Finding 390273 (2023-006)

Material Weakness 2023

Commonspirit Health

IL

Student Financial Aid Matching / Level of Effort / Earmarking Subrecipient Monitoring § 200.303

REFERENCE: 2023-006 – Reporting – Common Origination and Disbursement (COD) System Student Financial Assistance Cluster (Assistance Listing Nos. 84.063, 84.268) Federal Grantor: U.S. Department of Education Facility: Good Samaritan College of Nursing and Health Science and CHI Health School of Radi...

REFERENCE: 2023-006 – Reporting – Common Origination and Disbursement (COD) System Student Financial Assistance Cluster (Assistance Listing Nos. 84.063, 84.268) Federal Grantor: U.S. Department of Education Facility: Good Samaritan College of Nursing and Health Science and CHI Health School of Radiologic Technology Finding: Good Samaritan College of Nursing & Health Science did not perform its internal control over the requirement to submit Pell and Direct Loan origination and disbursement records to the Department of Education through the COD system, which consists of monthly COD reconciliations. CHI Health School of Radiologic Technology does not have a process in place for updating the COD system for actual disbursement dates. The COD disbursement information reported by CHI Health School of Radiologic Technology was based on “assumed” and “expected” disbursement dates and amounts, but is never updated for actual disbursement dates. Corrective Action Plan: This finding has been corrected for Good Samaritan. In May 2023, for April 2023 data, Good Samaritan implemented a formal monthly reconciliation process, including comparison of all systems for the period, a final review of G5 funds prior to draw down, a cover sheet noting any explaining any differences, proper sign off for preparation and review and the date by Good Samaritan management for presentation to the Compliance Oversight Committee. A year end reconciliation is also performed following the same process. CHI Health School of Radiologic Technology will review their processes to develop and implement internal controls that ensure compliance with federal regulations. Evidence of the internal control being performed will be retained. Person Responsible: Judy Kronenberger, President Good Samaritan College of Nursing and Health Science and Financial Aid Services (FAS) David Velasquez, Nuclear Medicine Technologist Coordinator (CHI Health School of Radiologic Technology) Completion/Expected Completion: April 2023 (Good Samaritan)/June 2024 (CHI Health School of Radiologic Technology)

View Audit 301158

Finding 390270 (2023-005)

Material Weakness 2023

Commonspirit Health

IL

Student Financial Aid Matching / Level of Effort / Earmarking Cash Management § 200.303

REFERENCE: 2023-005 – Cash Management Student Financial Assistance Cluster (Assistance listing No. 84.007, 84.063, 84.268) Federal Grantor: U.S. Department of Education Facility: Good Samaritan College of Nursing and Health Science and CHI Health School of Radiologic Technology Finding: Good Samar...

REFERENCE: 2023-005 – Cash Management Student Financial Assistance Cluster (Assistance listing No. 84.007, 84.063, 84.268) Federal Grantor: U.S. Department of Education Facility: Good Samaritan College of Nursing and Health Science and CHI Health School of Radiologic Technology Finding: Good Samaritan College of Nursing & Health Science has processes in place for determining the amount of student financial aid to be drawn down and disbursed; however, management did not perform internal controls over cash management throughout the year. CHI Health School of Radiologic Technology has processes in place for determining the amount of Direct Loans and Pell grants to be drawn down and disbursed; however, there is no review control in place over the disbursement amounts before funds are drawn down from the G5 system. Corrective Action Plan: This finding has been corrected for Good Samaritan. In May of 2023, for April 2023 data, Good Samaritan implemented a formal monthly reconciliation process, including comparison of all systems for the period, a final review of G5 funds prior to draw down, a cover sheet noting any explaining any differences, proper sign off for preparation and review and the date by Good Samaritan management and FAS management. This review is presented monthly to the Compliance Oversight Committee. A year end reconciliation is also performed following the same process. CHI Health School of Radiologic Technology will implement a review control for accounting staff to review the draw down amount provided by the School prior to completing the drawn down. Documentation of the review will be retained. Person Responsible: Judy Kronenberger, President, Good Samaritan College of Nursing and Health Science and Andrea Heffelfinger, Market Director of Accounting (CHI Health) Completion/Expected Completion: April 2023 (Good Samaritan)/June 2024 (CHI Health School of Radiologic Technology)

View Audit 301158

Finding 390255 (2023-101)

Material Weakness 2023

Maricopa County Community College District

AZ

Questioned Costs Student Financial Aid Special Tests & Provisions § 200.303

Cluster Name: Student Financial Assistance Cluster Assistance Listing number and name: 84.007 Federal Supplemental Educational Opportunity Grants 84.033 Federal Work-Study Program 84.038 Federal Perkins Loan Program-Federal Capital Contributions 84.063 Federal Pell Grant Program 84.268 Fed...

Cluster Name: Student Financial Assistance Cluster Assistance Listing number and name: 84.007 Federal Supplemental Educational Opportunity Grants 84.033 Federal Work-Study Program 84.038 Federal Perkins Loan Program-Federal Capital Contributions 84.063 Federal Pell Grant Program 84.268 Federal Direct Student Loans Award Year: July 1, 2021 through June 30, 2022 Federal Agency: U.S. Department of Education Compliance Requirements: Special tests and provisions Questioned Costs: Unknown Name of Contact Persons: Joshua Lindenberg, District Director of Financial Aid Anticipated Completion Date: December 31, 2024 The Maricopa County Community College District understands the importance of reporting accurate student enrollment statuses and all student enrollment status changes to the National Student Loan Database (NSLDS) for the Pell and Direct Loan programs. System improvements were completed in June 2023 to reduce and prevent enrollment reporting errors. The District will continue to enhance internal controls by expanding procedures to proactively monitor, detect, and correct unresolved enrollment reporting errors and will conduct semi-annual quality assurance reviews of student accounts to ensure enrollment data is reported appropriately to the NSLDS. The district will assess and enhance the existing enrollment reporting transmission schedule, documenting and disseminating a final copy to staff to ensure optimal efficiencies and reduce enrollment reporting errors caused by the timing of data transmission and error processing.

View Audit 301142 Questioned Costs: $1

Finding 390236 (2023-003)

Significant Deficiency 2023

National University

CA

Procurement, Suspension & Debarment Eligibility Significant Deficiency

Finding 2023-003 – Eligibility – Significant Deficiency in Internal Control over Compliance Management acknowledges the audit finding and wants to reinforce that despite challenges in the cost of attendance; there were no over or under-awards to students. To address this finding, our Quality Assuran...

Finding 2023-003 – Eligibility – Significant Deficiency in Internal Control over Compliance Management acknowledges the audit finding and wants to reinforce that despite challenges in the cost of attendance; there were no over or under-awards to students. To address this finding, our Quality Assurance team will oversee a weekly review of the cost of attendance to ensure financial aid packages align with approved budgets, enabling early identification of discrepancies for prompt correction. Based on these reviews, individual and group coaching will be implemented to address areas of concern. A refresher training and updated tools and guidance will be completed to reinforce best practices and align with institutional policy and procedure for calculating the cost of attendance. Through these concerted efforts, NU hopes to demonstrate its full commitment to addressing the audit findings. Contact Person Responsible for Corrective Action: Brandy Baker, Director of Quality Assurance Angela De Angelini, AVP Processing and Fiscal Operations Anticipated Completion Date: June 2024

View Audit 301132

Finding 390235 (2023-002)

Material Weakness 2023

National University

CA

Student Financial Aid Material Weakness Reporting

Finding 2023-002 - Special Tests and Provisions – Enrollment Reporting: Material Weakness in Internal Control Management agrees with this finding. The institution proposes a multifaceted approach aimed at resolving the root causes of the inaccuracies and preventing their recurrence. National Univer...

Finding 2023-002 - Special Tests and Provisions – Enrollment Reporting: Material Weakness in Internal Control Management agrees with this finding. The institution proposes a multifaceted approach aimed at resolving the root causes of the inaccuracies and preventing their recurrence. National University has implemented regular reviews of its enrollment reporting. During this process, errors in reporting are identified and corrected. However, the timing of the review has not allowed enough time to process corrections within compliance. To allow for appropriate adjustments and corrections to be implemented after testing but before the enrollment reporting deadline, National University will shift the timing of its enrollment reporting review from 60 to 30 days. Though NU is currently testing enrollment reporting and adjusting queries in an ongoing effort to improve accuracy, some of those adjustments inadvertently caused students to not appear in our queries. This impact on reporting occurred in edge cases not taken into account in the queries. To ensure this does not happen in the future, NU will implement a testing regime for these queries. This testing will be conducted at regular intervals to verify the effectiveness and accuracy of the queries in identifying students who have ceased attendance as required. Through these concerted efforts, NU hopes to demonstrate its full commitment to addressing the audit findings. We know that these efforts will take time to fully take effect and be reflected in future audits. Contact Person Responsible for Corrective Action: Brandy Baker, Director of Quality Assurance and Sarah Massey, AVP Operations, Student Support and Registrar Anticipated Completion Date: June 2024

View Audit 301132

Finding 390231 (2023-003)

Significant Deficiency 2023

Rider University

NJ

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

Federal Perkins Loan Program – Assistance Listing No. 84.038 Recommendation: We recommend the University implement a procedure with the third party servicer to ensure that their report is completed timely so that the University can perform the necessary due diligence they need to perform. Explanat...

Federal Perkins Loan Program – Assistance Listing No. 84.038 Recommendation: We recommend the University implement a procedure with the third party servicer to ensure that their report is completed timely so that the University can perform the necessary due diligence they need to perform. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to the finding: Recognizing the importance of resolving this finding the University intends to adjust policies and procedures around reviewing the third-party servicer processes around regulations and compliance items therein. Name(s) of the contact person(s) responsible for corrective action: Miranda Cole, Director and Tristan Schmittinger, Associate Director. Planned completion date for a corrective action plan: 3/26/2024

View Audit 301124

Finding 390230 (2023-002)

Significant Deficiency 2023

Rider University

NJ

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

Federal Direct Student Loans – Assistance Listing No. 84.268 Recommendation: CLA recommends the University review its policies and procedures around sending exit counseling information to students to ensure students are receiving proper counseling. Explanation of disagreement with audit finding: T...

Federal Direct Student Loans – Assistance Listing No. 84.268 Recommendation: CLA recommends the University review its policies and procedures around sending exit counseling information to students to ensure students are receiving proper counseling. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to the finding: In addition to the University’s automated procedures, Financial Aid and the Registrar will reconcile the finalized listing of graduates for each semester to confirm that all students are receiving exit counseling requirements and ensure proper counseling is provided to students. Name(s) of the contact person(s) responsible for corrective action: Miranda Cole, Director and Tristan Schmittinger, Associate Director. Planned completion date for a corrective action plan: 3/19/2024

View Audit 301124

Finding 390228 (2023-001)

Significant Deficiency 2023

Rider University

NJ

Student Financial Aid Reporting Matching / Level of Effort / Earmarking

Federal Pell Grant Program, Federal Direct Student Loans – Assistance Listing No. 84.063, 84.268. Recommendation: We recommend the University review procedures around sending the correct information to the NSLDS. In addition, we recommend the University develop a process to help better oversee the ...

Federal Pell Grant Program, Federal Direct Student Loans – Assistance Listing No. 84.063, 84.268. Recommendation: We recommend the University review procedures around sending the correct information to the NSLDS. In addition, we recommend the University develop a process to help better oversee the submissions completed by the third-party servicer. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to the finding: The Registrar's Office can confirm the National Student Clearing House (NSC) enrollment history for all two students is accurate. It appears that there have been challenges with the National Student Loan Data System (NSLDS) receiving current data from NSC in a timely manner. We take action to ensure that we will work with Financial Aid and crossreference the Registrar's monthly submission report and/or weekly Withdrawal Report with an NSLDS' report provided by Financial Aid to address any discrepancies. We will also work with the NSC audit team to ensure if there are any other processes, that we can implement on our end to better oversee the submission with our third-party servicer (NSC). Name(s) of the contact person(s) responsible for corrective action: Justina Nicita, Assistant Registrar, and Miranda Cole, Director of Financial Aid. Planned completion date for a corrective action plan: 3/19/2024.

View Audit 301124

Finding 390204 (2023-006)

Significant Deficiency 2023

Iberville Parish School Board

LA

Procurement, Suspension & Debarment Equipment & Real Property Management Matching / Level of Effort / Earmarking

The Superintendent, Iruis Voiron, Jt, has mandated that all contracts entered into by the District follour the Uniform Guidance for federal procurement. The exact langu€e has been shared with staff and is being used in all contracts.

View Audit 301105

Finding 390202 (2023-003)

None 2023

St. Lukes Health Network, Inc. and Controlled Entities

PA

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

2023-003 -Return of the Title IV R2T4 Calculation Cluster: Student Financial Assistance Sponsoring Agency: Department of Education Award Names: Federal Pell Grant Program and Federal Direct Student Loans Award Numbers: Not applicable Assistance Listing Titles: Federal Pell Grant Program and Federal ...

2023-003 -Return of the Title IV R2T4 Calculation Cluster: Student Financial Assistance Sponsoring Agency: Department of Education Award Names: Federal Pell Grant Program and Federal Direct Student Loans Award Numbers: Not applicable Assistance Listing Titles: Federal Pell Grant Program and Federal Direct Student Loans Assistance Listing Numbers: 84.063 and 84.268 Award Year: 2022-2023 Pass-through entity: Not applicable The Network agrees with the finding, and will make the following enhancement to the process: A review of the R2T4 calculation will be evidenced to ensure the calculation is prepared completely and accurately to determine whether a refund is required as well as to verify any post-withdrawal disbursements. The Network is implementing this process beginning in Q4 of FY2024. For inquiries regarding this finding, please contact Lisa Storck, Senior Associate Dean, and Joe Zelasko, Senior Financial Aid Coordinator, who are responsible for the corrective action.

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Finding 390200 (2023-002)

None 2023

St. Lukes Health Network, Inc. and Controlled Entities

PA

Student Financial Aid Reporting Matching / Level of Effort / Earmarking

2023-002 – Reporting to the Common Origination and Disbursement (COD) System Cluster: Student Financial Assistance Sponsoring Agency: Department of Education Award Names: Federal Pell Grant Program and Federal Direct Student Loans Award Numbers: Not applicable Assistance Listing Titles: Federal Pell...

2023-002 – Reporting to the Common Origination and Disbursement (COD) System Cluster: Student Financial Assistance Sponsoring Agency: Department of Education Award Names: Federal Pell Grant Program and Federal Direct Student Loans Award Numbers: Not applicable Assistance Listing Titles: Federal Pell Grant Program and Federal Direct Student Loans Assistance Listing Numbers: 84.063 and 84.268 Award Year: 2022-2023 Pass-through entity: Not applicable The Network agrees with the finding, and will make the following enhancements to the process: A reconciliation between the amounts of St. Luke’s School of Nursing disbursements compared to COD disbursement records will be completed monthly starting Q4 2024 by downloading the SAS file from COD. Starting FY 2024, these reconciliations will be completed monthly. After Originating a PELL Grant or a Direct Loan, the Financial Aid Office will check COD to ensure that the Origination came back with an “Accepted” value before any disbursement can be made. The student will be notified of the error and Direct Loan proceeds will be refunded to the Department of Education. This will ensure the student was properly reported and sent a direct loan disbursement notification as required to notify the student of the date and amount of disbursement, the right to cancel and procedures to cancel. The Network is implementing this process beginning in Q4 of FY2024. All disbursement records for PELL Grant and Direct Loan payments will be sent to COD on the disbursement date and no later than 15 days of the disbursement occurring. Starting Q4 of FY 2024, all PELL Grant and Direct Loan payments will be checked to ensure that they are sent to COD within this acceptable date range. For inquiries regarding this finding, please contact Lisa Storck, Senior Associate Dean, and Joe Zelasko, Senior Financial Aid Coordinator, who are responsible for the corrective action.

View Audit 301103

Corrective Action Plans

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