Corrective Action Plans

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Cash Management Planned Corrective Action: The SFS office will provide the Business Office the types and amounts of funds disbursed. The Business Office will drawdown those amounts from the G5 system. The SFS Office will maintain a roster of the disbursements to validate the amount of funds request...
Cash Management Planned Corrective Action: The SFS office will provide the Business Office the types and amounts of funds disbursed. The Business Office will drawdown those amounts from the G5 system. The SFS Office will maintain a roster of the disbursements to validate the amount of funds requested. Person Responsible for Corrective Action Plan: Bryan Taylor, Associate Director of SFS Processing Anticipated Date of Completion: April 2024
Aggregate Federal Direct Loan Limits Planned Corrective Action: Staff training and new reports to identify situations where comment codes related to aggregate limits are identified and reviewed to prevent over awarded funds. Person Responsible for Corrective Action Plan: Bryan Taylor, Associate Di...
Aggregate Federal Direct Loan Limits Planned Corrective Action: Staff training and new reports to identify situations where comment codes related to aggregate limits are identified and reviewed to prevent over awarded funds. Person Responsible for Corrective Action Plan: Bryan Taylor, Associate Director of SFS Processing Anticipated Date of Completion: February 2024
View Audit 299440 Questioned Costs: $1
Federal Direct Loan (FOL) Monthly Reconciliations Planned Corrective Action: Additional oversight and accountability measures have been put in place to ensure reconciliation is conducted monthly and timely. Person Responsible for Corrective Action Plan: Bryan Taylor, Associate Director of SFS Proc...
Federal Direct Loan (FOL) Monthly Reconciliations Planned Corrective Action: Additional oversight and accountability measures have been put in place to ensure reconciliation is conducted monthly and timely. Person Responsible for Corrective Action Plan: Bryan Taylor, Associate Director of SFS Processing Anticipated Date of Completion: January 2024
Higher Education Emergency Relief Fund (HEERF) Earmarking Planned Corrective Action: Funds are to be returned. Person Responsible for Corrective Action Plan: Gary E Estes, Director of Accounting Anticipated Date of Completion: June 2024
Higher Education Emergency Relief Fund (HEERF) Earmarking Planned Corrective Action: Funds are to be returned. Person Responsible for Corrective Action Plan: Gary E Estes, Director of Accounting Anticipated Date of Completion: June 2024
View Audit 299440 Questioned Costs: $1
Finding 387124 (2023-002)
Significant Deficiency 2023
Eligibility and Certification Approval Report (ECAR) Award Period: July 1, 2022 to June 30, 2023 Type of Finding: Significant Deficiency in Internal Control over Compliance; Other Matters Recommendation: We recommend the College review its reporting procedures surrounding updating the ECAR to ensure...
Eligibility and Certification Approval Report (ECAR) Award Period: July 1, 2022 to June 30, 2023 Type of Finding: Significant Deficiency in Internal Control over Compliance; Other Matters Recommendation: We recommend the College review its reporting procedures surrounding updating the ECAR to ensure reporting is accurate and completed. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Tabor College will ensure that ECAR is updated in a timely manner when there is a change in a position of an official for the institution. The two third-party collection agencies for Perkins were added to ECAR on October 31, 2023. Name(s) of the contact person(s) responsible for corrective action: Erica Clark, Director of Financial Aid Planned completion date for corrective action plan: March, 2024
2023-004 – Student Financial Aid Cluster – (a) Federal Pell Grant (b) Federal Supplemental Educational Opportunity Grant (c) Federal Work Study Grant (d) Federal Perkins Loan Program (e) Federal Direct Student Loans (f) Teacher education Assistance for College and Higher Education ALN No. (a) 84.063...
2023-004 – Student Financial Aid Cluster – (a) Federal Pell Grant (b) Federal Supplemental Educational Opportunity Grant (c) Federal Work Study Grant (d) Federal Perkins Loan Program (e) Federal Direct Student Loans (f) Teacher education Assistance for College and Higher Education ALN No. (a) 84.063 (b) 84.007 (c) 84.033 (d) 84.038 (e) 84.268 (f) 84.379 – Year Ended June 30, 2023 Condition: We examined 40 student files and we noted one student was not properly awarded their Pell grant. We consider this condition to be an instance of noncompliance relating to the Eligibility compliance requirement. Management Response: This was a student transferring from a college that had closed (Lincoln College) the Financial Aid staff did not calculate new PELL eligibility with the Eureka College COA and awarded Pell from the wrong matrix on the Pell payment chart. Corrective Action Plan: All pell awards are now being offered based on correct COA and Pell Grant matrix with the Eureka costs. Responsible Person: Tim Marten, Director of Financial Aid Implementation Date: Spring 2024
2023-003 – Student Financial Aid Cluster – (a) Federal Pell Grant (b) Federal Supplemental Educational Opportunity Grant (c) Federal Work Study Grant (d) Federal Perkins Loan Program (e) Federal Direct Student Loans (f) Teacher education Assistance for College and Higher Education ALN No. (a) 84.063...
2023-003 – Student Financial Aid Cluster – (a) Federal Pell Grant (b) Federal Supplemental Educational Opportunity Grant (c) Federal Work Study Grant (d) Federal Perkins Loan Program (e) Federal Direct Student Loans (f) Teacher education Assistance for College and Higher Education ALN No. (a) 84.063 (b) 84.007 (c) 84.033 (d) 84.038 (e) 84.268 (f) 84.379 – Year Ended June 30, 2023 Condition: We examined 40 student files and we noted 3 out of 40 students were not properly awarded Direct Loans. One of these students was improperly awarded subsidized loans and instead should have received unsubsidized loans. Additionally, the College did not report actual loan disbursement dates to the Common Origination and Disbursement (COD) system for 1 of the 40 students in the sample (2.5%). We consider these conditions to be instances of noncompliance in internal control over compliance relating to the Eligibility compliance requirement. Management Response: Cost of Attendance (COA) calculations were not updated to ensure ratio of subsidized versus unsubsidized loans were correct. It looks like awards were not being recalculated as additional need based aid was added to awards for these students. Corrective Action Plan: New financial aid software (JFA) was implemented for the 2023-2024 academic year. A component of this software is a compliance check for COA and other issues. The compliance check for over awards should catch instances of the wrong sub/unsub ratio in the future. Responsible Person: Tim Marten, Director of Financial Aid Implementation Date: Fall 2023
View Audit 299424 Questioned Costs: $1
Finding 387116 (2023-002)
Significant Deficiency 2023
2023-002 – Student Financial Aid Cluster – (a) Federal Pell Grant (b) Federal Supplemental Educational Opportunity Grant (c) Federal Work Study Grant (d) Federal Perkins Loan Program (e) Federal Direct Student Loans (f) Teacher education Assistance for College and Higher Education ALN No. (a) 84.063...
2023-002 – Student Financial Aid Cluster – (a) Federal Pell Grant (b) Federal Supplemental Educational Opportunity Grant (c) Federal Work Study Grant (d) Federal Perkins Loan Program (e) Federal Direct Student Loans (f) Teacher education Assistance for College and Higher Education ALN No. (a) 84.063 (b) 84.007 (c) 84.033 (d) 84.038 (e) 84.268 (f) 84.379 – Year Ended June 30, 2023 Condition: The College did not report graduate status changes within 60 days for ten out of twenty students (50%) tested. We consider this condition to be a significant deficiency of internal control over compliance relating to the Special Tests and Provisions compliance. Management response: From October 2022 to August 2023, the Registrar's Office was short staffed (we only had one employee in the office). We also switched email service providers in the second half of May 2023. The degree file reminder email from the National Student Clearinghouse was missed by the Registrar in the email transition period and because of the change in calendar systems, it was also missed on the Registrar's calendar. When the email migration was complete, the Registrar had thousands emails that were showing as unread. By the time the email cleanup was complete, and the Registrar realized she had not submitted the May 2023 degree file, the 60 day window had passed. The file was submitted in late July as soon as it was discovered that it hadn't gotten submitted (15 days past the 60 day window) Corrective Action Plan: The Summer 2023 and Fall 2023 degree files were submitted on time. The Registrar's office is once again fully staffed and our email and calendar systems are stable again as well. Responsible Person: Kendi Onnen, Registrar Implementation Date: 7/27/2023
Finding 387115 (2023-001)
Significant Deficiency 2023
2023-001 – Student Financial Aid Cluster – (a) Federal Pell Grant (b) Federal Supplemental Educational Opportunity Grant (c) Federal Work Study Grant (d) Federal Perkins Loan Program (e) Federal Direct Student Loans (f) Teacher education Assistance for College and Higher Education ALN No. (a) 84.063...
2023-001 – Student Financial Aid Cluster – (a) Federal Pell Grant (b) Federal Supplemental Educational Opportunity Grant (c) Federal Work Study Grant (d) Federal Perkins Loan Program (e) Federal Direct Student Loans (f) Teacher education Assistance for College and Higher Education ALN No. (a) 84.063 (b) 84.007 (c) 84.033 (d) 84.038 (e) 84.268 (f) 84.379 – Year Ended June 30, 2023 Condition: During our testing of forty individuals receiving federal work study, we noted 26 individuals (65%) that had timecards for hours worked that were not approved by a supervisor. We consider this condition to be a significant deficiency relating to the Activities Allowed or Unallowed compliance requirement. Management response: Timecard approval was completed by email notification. During 2022/23, a new email system was installed, and many emails related to timecards were lost. Corrective Action Plan: Starting in August 2023 all timecard approvals were documented in the payroll system (Paycor). HR prior to processing payroll requires all timecards be system documented as approved. Responsible Person: Kathleen Hermacinski, Human Resources Coordinator Implementation Date: August 2023
View Audit 299424 Questioned Costs: $1
2023-004 Special Tests (Enrollment Reporting) Federal Agency: Student Financial Assistance Cluster - U.S. Department of Education Program Titles and ALN: Federal Pell Grant Program (ALN 84.063) and Federal Direct Student Loans (ALN 84.268) Federal Grant Numbers: E-P063P130272 (7/1/2022 - 6/30/2023...
2023-004 Special Tests (Enrollment Reporting) Federal Agency: Student Financial Assistance Cluster - U.S. Department of Education Program Titles and ALN: Federal Pell Grant Program (ALN 84.063) and Federal Direct Student Loans (ALN 84.268) Federal Grant Numbers: E-P063P130272 (7/1/2022 - 6/30/2023), P268K130272 (7/1/2022 - 6/30/2023) Contact Person: Jean McDonald Rash, AVP Enrollment Services, 848-932-2605 Corrective Action: The University Registrar will send a memorandum to all degree certifying officers at the University reminding them that degree certification must be completed by the appropriate date to be certain all students are included on the file that updates NSLDS with the graduation date. The Chancellor Unit registrars will be asked to send out reminders in the weeks leading up to the required submission date and to track the completion of degree certifications. A process will be developed to allow for the proper reporting of graduation information on the Program-Level Record to NSLDS even when the student remains currently enrolled at the University and is being reported as such on the Campus-Level Record. Anticipated Completion Date: The anticipated completion date for degree certifications is June 2024. The anticipated completion date for dual enrollment reporting statuses is January 2025.
2023-003 Reporting (Financial) Federal Agency: Student Financial Assistance Cluster - U.S. Department of Education Program Titles and ALN: Federal Pell Grant Program (ALN 84.063) and Federal Direct Student Loans (ALN 84.268) Federal Grant Numbers: E-P063P130272 (7/1/2022 - 6/30/2023), P268K130272 ...
2023-003 Reporting (Financial) Federal Agency: Student Financial Assistance Cluster - U.S. Department of Education Program Titles and ALN: Federal Pell Grant Program (ALN 84.063) and Federal Direct Student Loans (ALN 84.268) Federal Grant Numbers: E-P063P130272 (7/1/2022 - 6/30/2023), P268K130272 (7/1/2022 - 6/30/2023) Contact Person: Jean McDonald Rash, AVP Enrollment Services, 848-932-2605 Corrective Action: OSFP was notified of the error in reporting the correct cost of attendance to the Common Origination and Disbursement (COD) system and the code was changed to prevent the error from reoccurring. The correct cost of attendances are now being reported to COD. A testing plan has been developed that includes confirmation that all system start and end dates align with the University’s published academic calendar. Anticipated Completion Date: Completed
2023-002 Eligibility Federal Agency: Student Financial Assistance Cluster - U.S. Department of Education Program Titles and ALN: Federal Pell Grant Program (ALN 84.063) and Federal Direct Student Loans (ALN 84.268) Federal Grant Numbers: E-P063P130272 (7/1/2022 - 6/30/2023), P268K130272 (7/1/2022 ...
2023-002 Eligibility Federal Agency: Student Financial Assistance Cluster - U.S. Department of Education Program Titles and ALN: Federal Pell Grant Program (ALN 84.063) and Federal Direct Student Loans (ALN 84.268) Federal Grant Numbers: E-P063P130272 (7/1/2022 - 6/30/2023), P268K130272 (7/1/2022 - 6/30/2023) Contact Person: Jean McDonald Rash, AVP Enrollment Services, 848-932-2605 Corrective Action: In order to correct the issue of students being awarded in excess of their cost of attendance, a weekly report has been developed to capture any student whose financial aid, from any source, exceeds the assigned cost of attendance. The Financial Aid Processing team in University Enrollment Services receives and resolves the issues in the report weekly to ensure that students are not awarded in excess of their assigned cost of attendance. In order to correct the issue of the incorrect calculation of the cost of attendance components, a testing plan has been developed that includes manually checking each program cost of attendance prior to signing off for production aid packaging. The script that caused the cost of attendance components to be doubled was corrected prior to the 2023-2024 aid year. Anticipated Completion Date: Completed
View Audit 299417 Questioned Costs: $1
2023-007 Allocation of Grant Expenses U.S. Department of Labor Assistance Listing Number 17.258/17.259/17.278 Recommendation: We recommend that the Board implement policies and procedures to ensure that all expenses are for actual expenses incurred, and that timely reconciliations are performed to ...
2023-007 Allocation of Grant Expenses U.S. Department of Labor Assistance Listing Number 17.258/17.259/17.278 Recommendation: We recommend that the Board implement policies and procedures to ensure that all expenses are for actual expenses incurred, and that timely reconciliations are performed to ensure the expenses are properly charged to the correct assistance listing number and grant. Action Taken: The Board has developed a process to correctly allocate expenditures to the correct funding stream. At each month’s end, all employees complete an allocation spreadsheet. When all spreadsheets are completed, approved, and turned in, the Board determines the allocation of payroll and expenditures. Expenditures that occurred in March will be allocated using the allocation chart for February. Also, this procedure is backup for each cash request that is submitted for funding. And, this is reviewed for the reconciliation between the cash request and the Board’s accounting software.
2023-006 Eligibility U.S. Department of Labor Assistance Listing Number 17.258/17.259/17.278 Recommendation: We recommend that the Board implement policies and procedures to ensure that the necessary controls are in place to properly verify the eligibility of all Youth and Adult Activities particip...
2023-006 Eligibility U.S. Department of Labor Assistance Listing Number 17.258/17.259/17.278 Recommendation: We recommend that the Board implement policies and procedures to ensure that the necessary controls are in place to properly verify the eligibility of all Youth and Adult Activities participants. Action Taken: The Board’s Youth Liaison monitors the In School and Out of School Youth eligibility every six months following the policy and procedures referencing the CF200. The Board’s Youth Liaison reviews the Youth files to determine if the Youth meets the eligibility criteria for the Youth program. Her monitoring is reviewed every six months during the State Audit. The Board will review her monitoring along with copies of the completed registrations from the Board’s subrecipient which determines which program the youth (Youth In or Youth Out) is eligible for the fiscal year. The Board will state that they have reviewed the eligibility perimeters and these were followed by the subrecipient and verified by the Youth Liaison. For the Adult Program, the Board has implemented internal controls to ensure each applicant completes the applications and to determine if they are eligible for the programs the Board offers. Our Business Services Manager reviews each application taken by the Board’s Career Services Coordinator and ensures they are in the correct program by the application.
2023-004 Reporting U.S. Department of Labor Assistance Listing Number 17.258/17.259/17.278 Recommendation: We recommend that the Board design and implement controls to ensure that all required reporting is submitted accurately and in a timely fashion. Action Taken: The Board added an internal cont...
2023-004 Reporting U.S. Department of Labor Assistance Listing Number 17.258/17.259/17.278 Recommendation: We recommend that the Board design and implement controls to ensure that all required reporting is submitted accurately and in a timely fashion. Action Taken: The Board added an internal control for the sake of reporting, for reports that are submitted to Workforce WV. Reports will be reviewed and approved by one of the managers of the Board within the time the report is due. For the ETA-9130 Financial report, the Board cannot submit this report since the Board is not a grantee for a Federal organization. Workforce WV submits this report by gathering the information they receive from all Development Boards and consolidates in this report for the Department of Labor. To send Workforce WV the reports they need to file this report, the Board will have the reports prepared and not submit them until another of the Board’s managers has reviewed and approved the preparation and submission of these reports in a timely manner.
2023-003 Earmarking U.S. Department of Labor Assistance Listing Number 17.258/17.259/17.278 Recommendation: We recommend that the Board implement controls and procedures to ensure that all requirements for earmarking within the Uniform Guidance are properly followed. Action Taken: The Board will c...
2023-003 Earmarking U.S. Department of Labor Assistance Listing Number 17.258/17.259/17.278 Recommendation: We recommend that the Board implement controls and procedures to ensure that all requirements for earmarking within the Uniform Guidance are properly followed. Action Taken: The Board will create a spreadsheet that shows the earmarking percentage for each category. The Board will review various reports for each funding stream at month end and record the actual earmarking percentage for each month. With this information, the Board will discuss these percentages at the monthly manager’s meeting, budget meeting and Board of Directors meeting. If a plan of action is needed, a plan of action will be developed. Also, Workforce WV has a software system that takes the expenditures reported for each funding stream, for each month, called the MACC report in which each Region completes a report that will verify which percentages are not in compliance. The Board will be comparing this report to the analysis report from the State.
2023-002 Activities Allowed or Unallowed U.S. Department of Labor Assistance Listing Number 17.258/17.259/17.278 Recommendation: We recommend that the Board design and implement controls to ensure that all charges to federal programs are adequately reviewed and approved prior to payment. Action Ta...
2023-002 Activities Allowed or Unallowed U.S. Department of Labor Assistance Listing Number 17.258/17.259/17.278 Recommendation: We recommend that the Board design and implement controls to ensure that all charges to federal programs are adequately reviewed and approved prior to payment. Action Taken: The Board is taking adequate action to review and approve all charges to the federal programs. The Board’s steps have been reviewed with Workforce WV and has approved our procedures. Supporting documentation is kept both in physical and electronic forms. Each check the Board distributes has an approved Purchase Order attached, (if applicable), Invoice, or if it is a monthly recurring charge, statement or bill attached and once the bill is entered into our system and the bill is paid, the check has the Executive Director’s initials and date showing it is approved in our accounting system. Also, if the expenditures are questionable, we will receive approval before submission of the bill from our liaison in the Workforce WV office.
Finding 387003 (2023-004)
Significant Deficiency 2023
Finding 2023-004 Personnel Responsible for Corrective Action: Senior Vice President, Student Experience – Joseph Sallustio Anticipated Completion Date: March 2024 Corrective Action Plan: The University has completed its implementation of Anthology, a student information system, during the 2023-...
Finding 2023-004 Personnel Responsible for Corrective Action: Senior Vice President, Student Experience – Joseph Sallustio Anticipated Completion Date: March 2024 Corrective Action Plan: The University has completed its implementation of Anthology, a student information system, during the 2023-2024 fiscal year. The new system has several built in features that are supplemented with internal controls to ensure that exit interviews are completed with students in a timely fashion. There was also a transition in leadership during this time. The new leader did not realize the exits were being sent manually. The system has since been configured to send out exits upon graduation and an exit is triggered for when the student graduates, withdraws or drops to less than half-time.
Finding 387001 (2023-003)
Significant Deficiency 2023
Finding 2023-003 Personnel Responsible for Corrective Action: Senior Vice President, Student Experience – Joseph Sallustio Anticipated Completion Date: March 2024 Corrective Action Plan: The University has completed its implementation of Anthology, a student information system, during the 202...
Finding 2023-003 Personnel Responsible for Corrective Action: Senior Vice President, Student Experience – Joseph Sallustio Anticipated Completion Date: March 2024 Corrective Action Plan: The University has completed its implementation of Anthology, a student information system, during the 2023-2024 fiscal year. During the go-live in Spring 2023, the University experienced critical system reporting issues which were addressed a quickly as possible. The new system has several built in features that are supplemented with internal controls to ensure enrollment reporting requirements are completed in a timely fashion. In Spring 2024, Anthology provided the University with a audit tool to review data before uploading to promote efficiency and accuracy.
Finding 386999 (2023-002)
Significant Deficiency 2023
Finding 2023-002 Personnel Responsible for Corrective Action: Senior Vice President, Student Experience – Joseph Sallustio Anticipated Completion Date: March 2024 Corrective Action Plan: The University has completed its implementation of Anthology, a student information system, during the 2023-...
Finding 2023-002 Personnel Responsible for Corrective Action: Senior Vice President, Student Experience – Joseph Sallustio Anticipated Completion Date: March 2024 Corrective Action Plan: The University has completed its implementation of Anthology, a student information system, during the 2023-2024 fiscal year. The new system has several built in features that are supplemented with internal controls to ensure that changes in students enrollment status that trigger a return of title IV funds are completed within the required 45 day time period. During the transition of systems the report used to look at students who might need to be a withdrawal and have a R2T4 calculation performed needed to be rebuilt for the new system. During this process the report did not always work correctly. Those flaws have been fixed the report is being worked on a weekly basis.
The District paid $219,500 for installation of an HVAC system from the Education Stabilization Fund without obtaining a written contract that included the prevailing wage rate clause. Additionally, weekly certified payrolls were not submitted to the District. ANSWER : The architect responsible for...
The District paid $219,500 for installation of an HVAC system from the Education Stabilization Fund without obtaining a written contract that included the prevailing wage rate clause. Additionally, weekly certified payrolls were not submitted to the District. ANSWER : The architect responsible for the project and supervision of subcontractors was contacted regarding the non-compliance issue. He obtained the required documentation from the sub-contractor which provided proof of compliance and is now on file in our offices. The Superintendent, Assistant Superintendent and CFO/Business Manager have all reviewed the prevailing wage requirements within Davis-Bacon. All corrective action has been completed as of March 15, 2024.
Boone-Apache Public Schools will develop internal control policies and procedures to meet the requirements and procedures of the Davis-Bacon Act. The updated policies and procedures will assure that the district is in compliance with contracts, including inserting the prevailing wage clauses and en...
Boone-Apache Public Schools will develop internal control policies and procedures to meet the requirements and procedures of the Davis-Bacon Act. The updated policies and procedures will assure that the district is in compliance with contracts, including inserting the prevailing wage clauses and ensuring that federal wage rates and fringes are met by an affective monitoring process which includes collecting and reviewing weekly certified payroll reports from the contractor or subcontractor. The updated policies and procedures will ensure that all items are posted at the work site to ensure compliance. The internal control policies and procedures will be completed on March 12, 2024.
Finding 386970 (2023-001)
Significant Deficiency 2023
Corrective Action Plan 2023‐001: The Controller and Associate Vice President of Compliance are working together to correct the previously filed reports to reflect the updated format. The initial due date for the required file form update was missed and the correct form is now completed and provided ...
Corrective Action Plan 2023‐001: The Controller and Associate Vice President of Compliance are working together to correct the previously filed reports to reflect the updated format. The initial due date for the required file form update was missed and the correct form is now completed and provided on the University’s website. Completion Date: March 25, 2024 Contact Person: Donna Ferguson, Controller, and Carrie Stevens, Associate Vice President of Compliance
The University concurs with the above mentioned finding that, while University processes defined to address GLBA are in place, the Information Security Policy does not specifically address Gramm-Leach-Bliley Act (GLBA) security criteria. It is now understood that the defined processes that address ...
The University concurs with the above mentioned finding that, while University processes defined to address GLBA are in place, the Information Security Policy does not specifically address Gramm-Leach-Bliley Act (GLBA) security criteria. It is now understood that the defined processes that address and support GLBA security criteria need to be put into a format that is published for access by the UCM community. UCM has commenced the process to create and publish the written information security program that addresses all required elements of the GLBA.
Cause and potential effect as presented in the Summary of Findings and Questioned Costs: The University's internal controls for determining that a loan disbursement notification was sent for each disbursement made was not operating effectively. Accordingly, the University did not send a loan notific...
Cause and potential effect as presented in the Summary of Findings and Questioned Costs: The University's internal controls for determining that a loan disbursement notification was sent for each disbursement made was not operating effectively. Accordingly, the University did not send a loan notification for disbursements within the required timeframe nor with the required information. Narrative Explanation: The general Financial Aid Award letter-directing the student to view their Loan Disbursement information was insufficient to meet the requirement. While the students have direct access to their student accounts that show disbursement activity and the institution has posted to their website the required terms of loan disbursements, the federal direct loan disbursement notification was not sent to the student or parent within the required 30 days before or 30 days after the disbursement was credited to the student's account and did not include the necessary information regarding the student's right or parent's right to cancel per 34 CFR section 668.165. Corrective action: The Student Financial Aid office reached out to our software vendor Ellucian Colleague and similar peer institutions to create a Loan Disbursement Notification notice. Effective immediately, all term disbursements will receive Loan Disbursement Notification notices. The Financial Aid Transmittal process (FATR) is run each week on Tuesday morning. The notices will be emailed weekly using a date range from the last financial aid transmittal date to the current date. Should more than one FATR be run in a week’s time, the notices would increase in frequency and intensity. The documents will be archived in batches within our current Document Imaging System by date. Additionally, a section on the Student Financial Aid website will be dedicated to the Disbursement Information, including Loan Notifications and Right to Cancel Loan procedures. MUSC is currently in the process of implementing a new Student Information System with a go live date scheduled for February 2025. During implementation we will configure the new SIS to automatically send the Loan Disbursement notifications to the students when their funds have been credited to the student’s accounts. You may direct questions to me at freelan@musc.edu or by telephone at 843-792-4364.
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