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Finding 369428 (2023-004)
Significant Deficiency 2023
USDA Community Facilities Loan Reserve Accounts Planned Corrective Action: Reserve accounts to be funded per USDA requirements. Person Responsible for Corrective Action Plan: Jon Kokos, CFO Anticipated Date of Completion: June 30, 2024
USDA Community Facilities Loan Reserve Accounts Planned Corrective Action: Reserve accounts to be funded per USDA requirements. Person Responsible for Corrective Action Plan: Jon Kokos, CFO Anticipated Date of Completion: June 30, 2024
Inaccurate Return of Title IV Funds (R2T4) Planned Corrective Action: The director is performing the R2T4 calculation, returning funds (if necessary), adjusting the student’s awards and bill in the appropriate software. The senior associate director is reviewing each student to be certain the cor...
Inaccurate Return of Title IV Funds (R2T4) Planned Corrective Action: The director is performing the R2T4 calculation, returning funds (if necessary), adjusting the student’s awards and bill in the appropriate software. The senior associate director is reviewing each student to be certain the correct funds are being reduced and/ or returned based on the calculation. Person Responsible for Corrective Action Plan: Karen Benfield, Director of Financial Aid Anticipated Date of Completion: This process is being implemented for the 2023-24 academic year.
Federal Supplemental Educational Opportunity Grant - Assistance List No. 84.007 Federal Work Study Program- Assistance Listing No. 84.033 Federal Pell Grant Program - Assistance Listing No. 84.063 Federal Direct Student Loans - Assistance Listing No. 84.268 Recommendation: We recommend the Universi...
Federal Supplemental Educational Opportunity Grant - Assistance List No. 84.007 Federal Work Study Program- Assistance Listing No. 84.033 Federal Pell Grant Program - Assistance Listing No. 84.063 Federal Direct Student Loans - Assistance Listing No. 84.268 Recommendation: We recommend the University document review of Return to Title IV calculations by an employee that did not prepare the calculations. We also recommend that the University review policies and procedures related to R2T4 calculations to ensure calculations are performed correctly and disbursed timely. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Financial aid personnel will implement Return to Title IV FSA calculation spreadsheet for additional backup support in determining if banner has calculated return amounts correctly. Additionally, financial aid will require all R2T4 calculations to be secondarily reviewed and confirmed in RHACOMM. The scheduled breaks for each semester will be determined by the Director of Financial Aid and given to the Registrar to be input into banner module SOATBRK. These breaks are what banner then uses for Return to Title IV purposes. Update procedures to reflect additional actions. Name(s) of the contact person(s) responsible for corrective action: Dasha Smith Planned completion date for corrective action plan: 4/1/24
View Audit 290586 Questioned Costs: $1
Federal Supplemental Educational Opportunity Grant - Assistance List No. 84.007 Federal Work Study Program- Assistance Listing No. 84.033 Federal Pell Grant Program - Assistance Listing No. 84.063 Federal Direct Student Loans - Assistance Listing No. 84.268 Recommendation: We recommend the Univers...
Federal Supplemental Educational Opportunity Grant - Assistance List No. 84.007 Federal Work Study Program- Assistance Listing No. 84.033 Federal Pell Grant Program - Assistance Listing No. 84.063 Federal Direct Student Loans - Assistance Listing No. 84.268 Recommendation: We recommend the University review its current procedures for awarding Title IV funds and implement changes necessary to ensure federal funds are awarded and disbursed in accordance with federal regulations. We also recommend the University disburse the proper Pell award to these students. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Check Pell Calculation settings in banner and adjust, if needed, to achieve maximum accuracy based on student criteria (COA, EFC/SAI, Enrollment Status). Name(s) of the contact person(s) responsible for corrective action: Dasha Smith Planned completion date for corrective action plan: 4/1/24
Federal Supplemental Educational Opportunity Grant - Assistance List No. 84.007 Federal Work Study Program- Assistance Listing No. 84.033 Federal Pell Grant Program - Assistance Listing No. 84.063 Federal Direct Student Loans - Assistance Listing No. 84.268 Recommendation: We recommend the Universi...
Federal Supplemental Educational Opportunity Grant - Assistance List No. 84.007 Federal Work Study Program- Assistance Listing No. 84.033 Federal Pell Grant Program - Assistance Listing No. 84.063 Federal Direct Student Loans - Assistance Listing No. 84.268 Recommendation: We recommend the University review current processes for reporting to NSLDS and implement procedures to ensure submissions are reported timely and accurately. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Ellucian, the producer of Banner, had a known defect that caused incorrect status change dates to be inserted in the Banner program which processes student enrollments. This defect was not known to me at the time, therefore, it was not something I was aware to be looking for when completing enrollment reporting. There were no errors which would have alerted me to the issue. See case PB006205. Known defect now seems to be corrected. Will review current processes in order to ensure the continuance of timely and accurate reporting, and to eliminate the possibility of future errors being at the fault of the University. Name(s) of the contact person(s) responsible for corrective action: Erin Moore and Dasha Smith Planned completion date for corrective action plan: 4/1/24
Federal Supplemental Educational Opportunity Grant - Assistance List No. 84.007 Federal Work Study Program- Assistance Listing No. 84.033 Federal Pell Grant Program - Assistance Listing No. 84.063 Federal Direct Student Loans - Assistance Listing No. 84.268 Recommendation: We recommend the Universi...
Federal Supplemental Educational Opportunity Grant - Assistance List No. 84.007 Federal Work Study Program- Assistance Listing No. 84.033 Federal Pell Grant Program - Assistance Listing No. 84.063 Federal Direct Student Loans - Assistance Listing No. 84.268 Recommendation: We recommend the University review reporting processes to ensure all students that require exit counseling receive it in a timely manner. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Request a formal count of all graduates from Registrar at the end of each semester and review the number of exit counseling notifications sent from financial aid to ensure notifications are sent to all appropriate graduating students. Update procedures to reflect additional review. Name(s) of the contact person(s) responsible for corrective action: Dasha Smith Planned completion date for corrective action plan: 4/1/24
Federal Supplemental Educational Opportunity Grant - Assistance List No. 84.007 Federal Work Study Program- Assistance Listing No. 84.033 Federal Pell Grant Program - Assistance Listing No. 84.063 Federal Direct Student Loans - Assistance Listing No. 84.268 Recommendation: We recommend that the Col...
Federal Supplemental Educational Opportunity Grant - Assistance List No. 84.007 Federal Work Study Program- Assistance Listing No. 84.033 Federal Pell Grant Program - Assistance Listing No. 84.063 Federal Direct Student Loans - Assistance Listing No. 84.268 Recommendation: We recommend that the College review the updated GLBA requirements and ensure their WISP includes all required elements Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: OPSU will communicate closely with OSU IT and the Office of Internal Audit regarding changes made at the system level to satisfy GLBA requirements. Name(s) of the contact person(s) responsible for corrective action: Elizabeth McMurphy and Dasha Smith Planned completion date for corrective action plan: May 2024
Education Stabilization Fund – Special Tests and Provisions - Wage Rate Requirements Contact Person Responsible for Corrective Action: Jim Holifield Contact Phone Number: 219-531-3007 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: Davis-Bacon...
Education Stabilization Fund – Special Tests and Provisions - Wage Rate Requirements Contact Person Responsible for Corrective Action: Jim Holifield Contact Phone Number: 219-531-3007 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: Davis-Bacon wage rate requirement language has been added to all bid packets and quote solicitations. The Educational Support Coordinator and Deputy Treasurer will work with VCS Department Directors to monitor all federally-funded construction projects for compliance with said language. Anticipated Completion Date: February 1, 2024
Rules set up within the system to generate a list of students who disbursed Title IV funds during each term failed when new academic year field was not updated for the new year. The Student Financial Planning Office identified the error on October 6, 2022 – six days over the 15 – day reporting requ...
Rules set up within the system to generate a list of students who disbursed Title IV funds during each term failed when new academic year field was not updated for the new year. The Student Financial Planning Office identified the error on October 6, 2022 – six days over the 15 – day reporting requirement. Error was identified and updated the system by creating new rule criteria. Management has updated the opening of a new federal year standard operating procedure (SOP). The updated SOP now has the running of the registered student credits process for the opening of each new academic year added to the annual calendar. In addition, management enhanced the eligibility rule criteria from one rule to two rules. By separating out the loan origination and acceptance rule into two separate rules an extra barrier of prevention has been added to help ensure only loans originated and accepted are disbursed to the student’s account. The College has complied since October 6, 2022, and no further findings were found after that date. Responsible Party: Jeanine Gemmell, Director of Student Financial Planning Completion Date: October 6, 2022
Matching Calculation Condition: During review of yearly match calculation report, It was noted the match was not correctly reported. Recommendation: We recommend documenting via an approval form with written or electronic signatures designating who is preparing and who is reviewing match form. Expla...
Matching Calculation Condition: During review of yearly match calculation report, It was noted the match was not correctly reported. Recommendation: We recommend documenting via an approval form with written or electronic signatures designating who is preparing and who is reviewing match form. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned/taken in response to finding: Match reports are input into a data document that includes providers in 14 counties. For this reason, our managing entity was requested to send our version without the other counties. The wrong version was sent (quarter 3 instead of final year end version) therefore from this date forward we will keep each quarterly version in our database with added line items that list the preparer and tile approval w/date. Name(s) of the contact person(s) responsible for corrective action: Angie Ellison Immediate: Staff will go back to quarter 1 of 23/24 year and make these changes with copies in database as well as preparer and approval lines w/date. These documents will be prepared in this fashion from this date forward.
Finding Number: 2023-001 Planned Corrective Action: See Below Anticipated Completion Date: 01/22/2024 Responsible Contact Person: Patricia Eddy, Treasurer The District is aware of the requirement in Federal Program legislation to ensure the inclusion of the prevailing wage rate provision in ag...
Finding Number: 2023-001 Planned Corrective Action: See Below Anticipated Completion Date: 01/22/2024 Responsible Contact Person: Patricia Eddy, Treasurer The District is aware of the requirement in Federal Program legislation to ensure the inclusion of the prevailing wage rate provision in agreements, as well as to obtain certified payroll reports to verify prevailing wages were paid. At the time the District entered into the agreement with West Roofing to install and renovate the HVAC system at Columbia High School, which was January 7, 2021, ESSER funds were not awarded to the District. The District planned on using its Permanent Improvement funds (a non -federal program sourced fund) to pay West Roofing. The District initially paid West Roofing from the Permanent Improvement fund for the installation/renovation of the HYAC at Columbia High School as per the initial contract. Once the ESSER funds were awarded, they allowed for previous expenses related to improving air quality to be included as part of reimbursement through ESSER funds. The prevailing wage was not met under the existing contract. The District has implemented the following Action Plan for Correction: 1. The Treasurer will ensure that all agreements intended to be sourced through Federal Funds will contain prevailing wage rate provisions prior to signing such agreements. 2. The Treasurer will ensure that invoices from contractors contain the necessary prevailing wage certified payroll reports prior to approving such invoices for payment from Federal Funds, 3. The Treasurer will educate all responsible parties in the District regarding prevailing wage documentation to ensure appropriate documentation is obtained prior to payment to the contractors and prior to requesting Federal Funds.
Incorrect and Untimely Return of Title IV Funds Calculation (R2T4) Planned Corrective Action: The University understands and concurs with the incorrect and untimely return of some Title IV funds. In response, the University has taken three (3) immediate steps to address this deficiency in the futu...
Incorrect and Untimely Return of Title IV Funds Calculation (R2T4) Planned Corrective Action: The University understands and concurs with the incorrect and untimely return of some Title IV funds. In response, the University has taken three (3) immediate steps to address this deficiency in the future. First, the institution has added financial aid staff with significant expertise and experience in the administration of the R2T4 process to periodically review standard and modular students R2T4 to ensure accurate, timely and compliant returns and reporting. Second, the University has identified policy and procedure improvements that align with best practice approaches to R2T4 administration in support of Pell recalculations and accurate return of funds. Finally, the institution has identified professional development opportunities for all financial aid, and associated personnel, to improve theoretical and practical awareness and implementation of the return process i.e., conference/webinar participation, in-house training workshops and discussions, identified liaison/unit champion roles, etc. Person Responsible for Corrective Action Plan: Michael Mathis, Director of Financial Aid Anticipated Date of Completion: January 2024
View Audit 290552 Questioned Costs: $1
Recommendation: We recommend the Organization implement a documented review process for reimbursement requests before submitting the requests monthly. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: CommUnity has p...
Recommendation: We recommend the Organization implement a documented review process for reimbursement requests before submitting the requests monthly. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: CommUnity has put into place an added month end process that includes verification that all billing has been reviewed. Name(s) of the contact person(s) responsible for corrective action: Angie Meiers Planned completion date for corrective action plan: February 2024
Recommendation: We recommend the Organization documents review of all payroll reports. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: CommUnity has put into place an added payroll process that includes monthly ver...
Recommendation: We recommend the Organization documents review of all payroll reports. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: CommUnity has put into place an added payroll process that includes monthly verification that all reports have been reviewed. Name(s) of the contact person(s) responsible for corrective action: Angie Meiers Planned completion date for corrective action plan: February 2024
US Department of Education: Student Financial Assistance Cluster – Assistance Listing No. 84.007, 84.038, 84.063, 84.268, 84.379, 84.033 Recommendation: CLA recommends that the University review the updated GLBA requirements and ensure their WISP includes all required elements. Explanation of disag...
US Department of Education: Student Financial Assistance Cluster – Assistance Listing No. 84.007, 84.038, 84.063, 84.268, 84.379, 84.033 Recommendation: CLA recommends that the University review the updated GLBA requirements and ensure their WISP includes all required elements. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned/taken in response to finding: OSU is creating a GLBA management program to govern security of GLBA data and ensure compliance with associated requirements. Name(s) of the contact person(s) responsible for corrective action: Aaron Smith, Director of Information Security Services/Information Security Officer. Planned completion date for corrective action plan: March 31, 2024
US Department of Education: Student Financial Assistance Cluster – Assistance Listing No. 84.007, 84.063, 84.268, 84.033 Recommendation: CLA recommends OSU OKC and OSUIT review current processes for reporting to NSLDS and implement procedures to ensure submissions are reported timely and accurately...
US Department of Education: Student Financial Assistance Cluster – Assistance Listing No. 84.007, 84.063, 84.268, 84.033 Recommendation: CLA recommends OSU OKC and OSUIT review current processes for reporting to NSLDS and implement procedures to ensure submissions are reported timely and accurately Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned/taken in response to finding: OSU OKC: The Director of Financial Aid, Registrar, and Sr Director of Institutional Effectiveness developed a new process on reporting first of term, end of term, updates to enrollment, and processing errors in a timely manner. In addition, the Director of Financial Aid also added a step to the current OSU OKC R2T4 process. Financial Aid counselors will also be checking NSLDS on all students who populate on our R2T4 listing. Monthly, the Director of Financial Aid will select a small population to R2T4 and audit the information reported in NSLDS to ensure the new process is working correctly. OSUIT: OSUIT will shorten the dates for reporting to the NSLC to make sure the NSLC has sufficient time to report to NSLDS. Name(s) of the contact person(s) responsible for corrective action: OSU OKC: Elizabeth Lucas, Director of Financial Aid and Scholarships; Hank Lankford, Registrar; and Nick Irby, Senior Director of Institutional Effectiveness and Accreditation. OSUIT: Matt Short, Director of Financial Aid and Scholarships; and Crystal Palacioz, Registrar. Planned completion date for corrective action plan: OSU OKC: The completion date for the enrollment reporting has been implemented since the end of September 2023. The additional financial aid processes were implemented in October 2023 and will be fully completed by December 1, 2023. OSUIT: December 1, 2023.
Based on our grant agreement with Head Start, Easter Seals DC | MD | VA is required to provide a 20% contribution of total project costs for each annual budget period, unless a waiver has been requested and approved; any combination of actual cash expended, or in-kind contributions, may be used to m...
Based on our grant agreement with Head Start, Easter Seals DC | MD | VA is required to provide a 20% contribution of total project costs for each annual budget period, unless a waiver has been requested and approved; any combination of actual cash expended, or in-kind contributions, may be used to meet the matching requirement. Our organization met the 20% non-federal match requirement for the latest program year (Year 2) for our Early Head Start Program in Washington DC. However, we did not meet the match requirement for Year 5 of our Prince George County program. The mandatory annual waivers associated with our organization’s 20% non-federal share matching contribution requirement for the first four years (2019 - 2022) of the individual award periods ended July 31 of our Prince George’s County Head Start Program grant agreement have been submitted. Likewise, the waiver request for the first year (2022) of the individual award period ended June 30, 2022, for our Washington, DC Head Start Program grant agreement has also been submitted. Per Section 640(b)(1)(5) of the Head Start Act, a waiver request for Year 5 (2023) was submitted alongside the original budget narrative. While the budget was approved, we were notified after the program year ended that a standalone/separate waiver request for Year 5 was required. The outstanding waiver requests remain under review by representatives of The Administration of Families and Children, the agency that oversees the Office of Head Start program. We have maintained a constant dialogue with the Office of Head Start, which administers grant funding and oversight, but have yet to receive formal approval for any of the outstanding waiver submissions. However, we believe that amended waiver requests will be required for some of the program years in which we did not meet our 20% non-federal contribution match in Prince George’s County. In December 2023, we provided the Office of Head Start with additional details related to the organization’s annual expenditures, cash receipts, and non-federal share obligations for the first five years of the Prince George’s County grants. We anticipate that final responses to all five required waiver requests our Prince George’s County Program will be obtained no later than the end of the current grant year (July 31, 2024). We expect the outstanding waiver request for Year 1 of our Washington DC program will be considered and approved by the end of the current grant year (July 31, 2024).
FINDING 2022 – 004: Name of Responsible Individual: Tracy Jenkins, Student Accounts Type of Finding: Authorization for Retaining Credit Balance Criteria: Title IV regulations (34 CFR 668.165(b)) states that an institution must obtain written authorization from a student or parent in order to hold an...
FINDING 2022 – 004: Name of Responsible Individual: Tracy Jenkins, Student Accounts Type of Finding: Authorization for Retaining Credit Balance Criteria: Title IV regulations (34 CFR 668.165(b)) states that an institution must obtain written authorization from a student or parent in order to hold any Title IV program funds that would otherwise be paid directly to the student or parent as a credit balance. Condition: During testing auditors noted one student had a credit balance that was held beyond the end of the loan period without authorization from the student or parent to hold the funds. Corrective Action: During the testing, the audit report noted one student who had a credit balance that was held beyond the end of the loan period without authorization from the student or parent to hold the funds. In response to this finding, 2022-004 Wheeling University Student Accounts Office has added competent staff. Student Accounts has a set calendar for refund dates to coincide with each semester. The first refund distribution happens during the second week of classes for the semester. The exact process is followed for weeks three and four of the semesters. Week seven of the semester is the fourth distribution of refunds, and week nine is the fifth distribution of refund checks. The refund process is completed within seven days of disbursement notification. Anticipated Completion Date: This process was completed in August of 2023 and is an ongoing process.
FINDING 2022 – 003: Repeat of Prior Year Finding 2021-008 Name of Responsible Individual: Joyce Lubeck-Sonenberg, Acting Director of Financial Aid Type of Finding: Overaward of Title IV Funds Criteria: Title IV regulations (34 CFR 685.203) states in no case may Direct Subsidized, Direct Unsubsidized...
FINDING 2022 – 003: Repeat of Prior Year Finding 2021-008 Name of Responsible Individual: Joyce Lubeck-Sonenberg, Acting Director of Financial Aid Type of Finding: Overaward of Title IV Funds Criteria: Title IV regulations (34 CFR 685.203) states in no case may Direct Subsidized, Direct Unsubsidized, or Direct PLUS Loan amount exceed the student’s estimated cost of attendance for the period of enrollment for which the loans were intended, less (1) the student’s estimated financial assistance for that period and (2) the borrower’s expected family contribution for that period. Condition: During testing the auditors noted two instances where the University awarded a Direct Unsubsidized loan to a student that caused the student’s financial assistance received to be greater than the student’s cost of attendance. Corrective Action: At the time of these findings, all Wheeling University Financial Aid processing operations were being conducted manually. The high level of complexity commonly associated with financial aid processing creates an environment, especially when conducted in a manual format, that is error-intrinsic. Packaging and awarding for each of the federal student aid programs are currently conducted by using the student information system, Colleague, which allows the FA office to perform these processing operations in a fully automated manner. Proper use of the “auto-packaging” feature provides significant assurance that student awards will not exceed financial need based on Cost of Attendance (COA) and Estimated Family Contribution (EFC). Previous audit findings have noted a general lack of accuracy, organization, and documentation regarding the final figure for the COA, which can result in packaging and over-award errors. As such, the Acting Director of Financial Aid has completely extensively researched and input data into the system with an accurate, fair, and equitable formula for arriving at a COA while meeting student need and, consequently, reducing or eliminating the potential for over-awards. This data was obtained from state and local cost of living figures, input from other similar state schools, and by use of the higher education organization, the College Board. This data is available as a reference for future documentation and review in a shared electronic file. Anticipated Completion Date: This process was completed in March of 2023 and is ongoing.
View Audit 290469 Questioned Costs: $1
FINDING 2022 – 002: Repeat of Prior Year Finding 2021-004 Name of Responsible Individual: Joyce Lubeck-Sonenberg, Acting Director of Financial Aid Type of Finding: Federal Award Findings and Questioned Costs Criteria: Recipients of federal awards are required to administer its federal programs with ...
FINDING 2022 – 002: Repeat of Prior Year Finding 2021-004 Name of Responsible Individual: Joyce Lubeck-Sonenberg, Acting Director of Financial Aid Type of Finding: Federal Award Findings and Questioned Costs Criteria: Recipients of federal awards are required to administer its federal programs with an adequate system of internal controls over applicable compliance requirements. Condition: The University did not reconcile its SAS data file to its financial records for all 12 months of the fiscal year. Corrective Action: Wheeling University has implemented several significant corrective actions towards improving the reconciliation requirements for the Pell and Direct Loan Programs. A highly administratively capable staff person has been promoted to Assistant Director and demonstrates a level of financial aid leadership that is appreciated throughout the campus community. This individual has received extensive regulatory and technical training regarding the federal requirements to monthly reconcile cash received from the G5 account with disbursements submitted to the COD System. In addition to confirming the accuracy of monthly reconciliation efforts, this approach allows the FA office to compare internal awarding databases against COD’s database for Pell and Direct Loan awards and identify discrepancies that require further attention. Also, this assists the University to be better prepared to perform efficient and accurate closeout activities at year-end. Previous audit findings showed little evidence of accurate reconciliation efforts. In working with the University IT Department, monthly reconciliation files are now housed in a shared electronic file system, easily retrieved for review, and are confirmed for accuracy by the acting Director of Financial Aide each month. Anticipated Completion Date: This process was completed in March of 2023 and is ongoing.
FINDING 2022 – 006: Type of Finding: Significant Deficiency-Return of Title IV Funds Name of Responsible Individual: Joyce Lubeck-Sonenberg, Acting Director of Financial Aid Criteria: Title IV regulations (34 CFR 668.22) require the University to return the unearned portion of grants or loans to the...
FINDING 2022 – 006: Type of Finding: Significant Deficiency-Return of Title IV Funds Name of Responsible Individual: Joyce Lubeck-Sonenberg, Acting Director of Financial Aid Criteria: Title IV regulations (34 CFR 668.22) require the University to return the unearned portion of grants or loans to the student based the calculated percent completed by the student. Condition: Calculations of return of funds for certain students selected for testing were not completed and therefore refunds were not made. Corrective Action: Audit results identify several Wheeling University Financial Aid R2T4 calculations that were found to be incomplete, inaccurate, or not completed within an acceptable time frame as required by regulations. The apparent cause of these findings was a lack of administrative capability, staff turnover, and a general lack of a systematic process for completing accurate R2T4 calculations. Since these findings were first noted, the Wheeling University Financial Aid Office has added competent staff and has provided sufficient training and supervised experience to ensure R2T4 calculations are completed within the regulatory guidelines. The acting Director of Financial Aid has taken steps to ensure to inform the campus community of the Department’s philosophy of an “institutional responsibility” regarding regulatory compliance with Title IV programs, and this is particularly true in the matter of student FA eligibility with enrollment, attendance, and withdrawal. As such, the acting Director of Financial Aid has worked closely with the University Registrar to ensure there is a clear understanding that if a recipient of Title IV grant or loan funds withdraws from the University after beginning attendance, the FA Office must perform an R2T4 calculation to determine the amount of Title IV assistance earned by the student. Since withdrawal information is critical to R2T4 calculations, a Withdrawal Report has been developed to better capture withdrawal data. This report is updated and reviewed by the FA Director (three times per week) to confirm the accuracy of such data. In addition, all R2T4 calculations are completed on the University's internal software (Colleague) rather than DOE software and follow an updated, more clearly defined R2T4 policy. Anticipated Completion Date: This process was completed September of 2023 and is ongoing.
FINDING 2022 – 005: Repeat of Prior Year Finding 2021-003 Type of Finding: Material Weakness-Enrollment Reporting Name of Responsible Individual: Joyce Lubeck-Sonenberg, Acting Director of Financial Aid Criteria: An institution is required to update students’ changes in status on the National Studen...
FINDING 2022 – 005: Repeat of Prior Year Finding 2021-003 Type of Finding: Material Weakness-Enrollment Reporting Name of Responsible Individual: Joyce Lubeck-Sonenberg, Acting Director of Financial Aid Criteria: An institution is required to update students’ changes in status on the National Student Loans Data System (NSLDS) website within 30 days of the date the institution becomes aware of the change in enrollment status for students that graduate, withdraw, or have an increase or decrease in attendance during the fiscal year (34 CFR 685.309). Condition: For certain students selected for testing who graduated or withdrew during the year, the University did not submit an appropriate and/or timely status change notification to the NSLDS website. A group of graduated students were erroneously reported as ‘withdrawn’ from the University. Corrective Action: Audit results identify several Wheeling University Enrollment Reports that were found to be incomplete, inaccurate, or not completed within an acceptable time frame as required by regulations. In response to finding 2022-005, Wheeling University has implemented several significant corrective actions towards improving Enrollment Reporting. The apparent cause of these findings was a lack of administrative capability, staff turnover, and a general lack of a systematic process for completing accurate Enrollment Reports to the National Student Clearing House (NSC) and National Student Loan Data System (NSLDS). Since these findings were first noted, the Wheeling University Registration Office and Financial Aid Office have added competent staff and have provided sufficient training and experience to ensure Enrollment Reports are completed within the regulatory guidelines. The Vice President of Enrollment has worked closely with the Financial Aid Office and the Registration Office to ensure there is a clear understanding of who reports to the National Student Clearing House and who is responsible for monitoring NSLDS. There are also weekly meetings between the Business Office, Registration, and Financial Aid to ensure all reporting is correct and completed in a timely manner. Anticipated Completion Date: A new process has been in place Since October 2023 and is ongoing.
2023-002 US Department of Education Student Financial Assistance Cluster - Assistance Listing No. 84.063, 84.268 Recommendation: We recommend the College review its current procedures for Title IV funds and implement additional procedures to ensure refunds are returned timely. Explanation of disa...
2023-002 US Department of Education Student Financial Assistance Cluster - Assistance Listing No. 84.063, 84.268 Recommendation: We recommend the College review its current procedures for Title IV funds and implement additional procedures to ensure refunds are returned timely. Explanation of disagreement with audit finding: MACC is an attendance taking institution and our regular practice requires review of attendance records two to three times per week. When the Financial Aid Office discovers students have withdrawn from classes, we review and calculate an R2T4 when required - usually within 1-5 days from the date it is discovered. This finding of a "late return" is due to a faculty member dropping a student outside of the dates required by our attendance policy. I would like to note that the R2T4 was performed timely and accurately as soon as the drop was identified. Action taken in response to finding: The issue was reported to the President, Vice Presidents, and Deans; as a result, the faculty were addressed and reminded of the importance to comply with the college's attendance policy. Name(s) of the contact person(s) responsible for corrective action: Amy Hager Planned completion date for corrective action plan: Our Vice President for Instruction will provide reminders of our policy with our faculty each semester. In the event that a faculty member does not comply with the attendance policy, their Dean will take disciplinary action.
2023-001 US Department of Education Student Financial Assistance Cluster - Assistance Listing No. 84.063 Recommendation: We recommend that the student financial aid department work to ensure disbursements are reported to COD within 15 days of the disbursement date. Explanation of disagreement with...
2023-001 US Department of Education Student Financial Assistance Cluster - Assistance Listing No. 84.063 Recommendation: We recommend that the student financial aid department work to ensure disbursements are reported to COD within 15 days of the disbursement date. Explanation of disagreement with audit finding: As a standard, regular practice, communicates disbursement information for Federal Pell and Federal loans to COD no less than once per week; therefore, we believe we have an adequate way to report disbursements to COD within 15 days of the disbursement date. MACC transitioned to new financial aid processing software (Jenzabar Financial Aid - JFA) in summer 2022 while other areas of the college were still using the "old" system (Jenzabar CX). We experienced a glitch during the transition in which the files did not update as expected, we worked with our software vendor to correct the issue. Below is the timeline of action taken:This finding pertains to one student with Sub and Unsub Loans. We posted aid and sent the original batch on Friday, 07/15/2022; we discovered the issue on Wednesday, 07/20/2022, and reached out to Jenzabar immediately; we followed up with Jenzabar on Thursday, 07/28/2022 because the records were not updated; the records were updated on Monday, August 1. Action taken in response to finding: MACC continues to submit disbursement information at least once per week and review student details for posting accuracy. We took the necessary steps to fix the issue. Name(s) of the contact person(s) responsible for corrective action: Amy Hager Planned completion date for corrective action plan: We believe this finding was an anomaly due to the system conversion. We have no evidence of this happening since.
2023-003 US Department of Education Student Financial Assistance Cluster - Assistance Listing No. 84.007, 84.033, 84.063, 84.268 Recommendation: We recommend the College review current processes for reporting to NSLDS and implement procedures to ensure submissions are reported timely and accuratel...
2023-003 US Department of Education Student Financial Assistance Cluster - Assistance Listing No. 84.007, 84.033, 84.063, 84.268 Recommendation: We recommend the College review current processes for reporting to NSLDS and implement procedures to ensure submissions are reported timely and accurately. Explanation of disagreement with audit finding: There is no disagreement with the audit finding, but we offer the following explanation: Identification of Errors and Corrections to New SIS: • Conversion to a new SIS (Jenzabar - Jl) was effective November 2022, and forced subsequent Fall 2022 NSC Enrollment Transmittal Files to be created in the new system mid-term. The concern of enrollment report timing was brought to the vendor multiple times before the transition. However, due to scheduling limitations on the vendor's end, the transition to the new system had to be completed mid-term. • In late May/early June we began end of term processing and reconciliations, and we identified that student status changes were not properly pulling the correct enrollment status information through the vendor's enrollment report creation process. • Support tickets were sent to the vendor immediately to address the problems with the system process that creates NSC Transmittal Files. • System configuration changes were made as recommended by the vendor to properly update enrollment status changes. • Through the investigation of these configuration changes, additional system errors were identified that were not allowing some enrolled students to be properly pulled to the enrollment files. • Support engagements continued with the vendor throughout July and August to identify and correct the system configuration to correctly pull enrolled students into the NSC Transmittal File. This was completed by the end of summer term, and the final summer enrollment file contained the correct number of students enrolled with the correct final enrollment status. • Internal validation reports were created and executed to ensure that correct student data was transmitted on the Fall first of Term reports. We believe this transmission contained the correct number of students and the correct status. These internal validation reports will be conducted prior to all NSC submissions. Creation of new/additional reports will be conducted as necessary. • We have been able to verify that the Fall 2023 subsequent term enrollment file did contain accurate status change information, and this issue is now resolved. • By correcting status change configurations, we have also identified that program begin dates converted from the old SIS to the new SIS were incorrectly mapped. • We are currently in the process of identifying the ID#s with incorrect program begin dates and making manual updates to the students' record in the new SIS environment. The vendor has not provided a clear path to programmatically correct this in bulk, so this record validation is being completed one-by-one manually. We project to have this completed for currently enrolled students by the final fall 2023 enrollment submission. Correcting previously submitted data: • We reached out to our Data Analyst, Elizabeth Fennessy, with the National Student Clearinghouse, to begin working on a corrective action for the missing status change data. • Elizabeth consulted with the NSC Audit Resource Team, and the following plan was recommended to MACC: • For students Less Than Half Time Spring 2023 or Withdrawn Spring 2023 that re-enrolled Summer 2023, these would be a manual update in NSLDS for Title IV students in these scenarios using NSLDS site 'Enrollment History Update.' • Later in Clearinghouse, the same update can be reflected using Clearinghouse site 'Student Look-Up' to bring the record current with updated enrollment reflected Spring 2023. By updating NSLDS first, that will avoid an NSLDS error "certification date out of sync" (error code 32). • MACC prepared reports to retrieve students meeting the criteria identified above. • These students' enrollment statuses for Spring 2023 and Summer 2023 have been manually updated in NSLDS Enrollment History Update and in NSC Student Look-up to bring these enrollment statuses up to date; this has been a long and time-consuming process. • We are also currently working on reports to identify students that were enrolled in spring 2023 but missed when the NSC Enrollment Transmittal File was created. We believe that students missed in Summer 2023 have been brought up to date through the submission of the corrected final Summer 2023 Enrollment File (to include students that were also enrolled in Spring 2023). Any student that was inadvertently excluded from the Spring 2023 and has not been brought up to date through subsequent corrected submissions, will be manually corrected through NSC Student Look-Up, and NSLDS Enrollment History Update if necessary. • We also reached out to l<athy Feith, Branch Chief, l<C School Participation Division, Federal Student Aid, U.S. Department of Education; she is aware of our issues. She recommended making enrollment changes directly in NSLDS for students who withdrew. Action taken in response to finding: The following is our Corrective Action Plan. • The Registrar will review data in J1 and submit enrollment records to NSC each month. o The Registrar will also work with the Director of Administrative Computing to ensure program information and other vital data are reported correctly. o MACC will continue to work with Jenzabar for a solution for reporting last dates of attendance for students who are withdrawn from all classes. • After the enrollment file is accepted by NSC, 20 randomly selected students will be verified for accuracy. • The selection will be made by the Director of FA and/or Registrar. • The selection will include students who have withdrawn from all classes and had an R2T4 calculation performed. • The Registrar, or designee, will review the data in NSC. • The Associate Director of Financial Aid, or designee, will review the data in NSLDS. • Discrepancies will be addressed between the Registrar and Financial Aid Offices immediately; and will utilize the Director of Administrative Computing to assist with configuration changes and data clean-up. • The records will be maintained in a designated Teams folder. Name(s) of the contact person(s) responsible for corrective action: Amy Hager and Amy See (Registrar). Planned completion date for corrective action plan: We expect the plan will be an ongoing effort to ensure compliance.
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