Corrective Action Plans

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Management concurs with the finding and notes that the Town is actively working to complete the integration of the payroll module within the new accounting platform. Management has arranged system training to ensure staff understand the payroll and reconciliation functions and can effectively utiliz...
Management concurs with the finding and notes that the Town is actively working to complete the integration of the payroll module within the new accounting platform. Management has arranged system training to ensure staff understand the payroll and reconciliation functions and can effectively utilize the module once configuration is complete. In the interim, the Town will continue to prepare timely reconciliations and record necessary adjusting entries to ensure accurate financial reporting.
2025-002. Payroll (Allowable Costs/Cost Principles) United States Department of Education, Passed-through New York State Department of Education: Education Stabilization Funds COVID 19: American Rescue Plan – Elementary and Secondary School Emergency Relief ALN: 84.425U Condition: Subpart I, 2 CFR §...
2025-002. Payroll (Allowable Costs/Cost Principles) United States Department of Education, Passed-through New York State Department of Education: Education Stabilization Funds COVID 19: American Rescue Plan – Elementary and Secondary School Emergency Relief ALN: 84.425U Condition: Subpart I, 2 CFR §200.430 of the Uniform Guidance requires that charges to “Federal awards for salaries and wages must be based on records that accurately reflect the work performed.” The documentation should support the distribution of the employee’s compensation among specific activities if the employees work on more than one Federal award, or a Federal award and non-Federal award. The preparation of payroll verification forms, or periodic certifications or the equivalent is the most effective way to comply with this requirement. During the current year, it was noted that in one instance, the District’s payroll verification form was not reviewed or signed by either the supervisor or employee that was chargedto the grant in order to comply with Subpart I, 2 CFR §200.430. Planned Corrective Action: The District acknowledges the finding and will thoroughly review and maintain the payroll verification forms to ensure each employee’s salary, or other forms of compensation, are properly approved and signed off by the employer and employee. Anticipated Completion Date: June 30, 2026
In December 2026, managemetn worked with SBA representatives to transfer excess reserves from other SBA Loan Loss Reserve Fund (LLRF) balances to the fund with the deficiency. The matter has been resolved.
In December 2026, managemetn worked with SBA representatives to transfer excess reserves from other SBA Loan Loss Reserve Fund (LLRF) balances to the fund with the deficiency. The matter has been resolved.
Estacada School District submits this Corrective Action Plan in response to audit finding SA-2025-02, included in the District’s audit report for the fiscal year ended June 30, 2025, related to the Child Nutrition Cluster federal programs. Finding SA-2025-02 – Significant Deficiency Federal Program:...
Estacada School District submits this Corrective Action Plan in response to audit finding SA-2025-02, included in the District’s audit report for the fiscal year ended June 30, 2025, related to the Child Nutrition Cluster federal programs. Finding SA-2025-02 – Significant Deficiency Federal Program: 10.553, 10.555, 10.559 Child Nutrition Cluster Condition: NSLP reimbursement claims were submitted without consistent evidence of independent review and documentation prior to submission. Cause: Staffing turnover and workload demands contributed to inconsistent review practices. Recommendation: Assign an individual other than the preparer to review NSLP reimbursement claims prior to submission and retain documentation of the review. Corrective Action Plan The District has implemented procedures requiring all NSLP reimbursement claims to be reviewed and approved by an individual independent of the preparer prior to submission. A standardized review and documentation process has been implemented to ensure review is consistently completed and retained with claim submission records. Written procedures and cross-training will continue to support consistency and continuity. Implementation Date Corrective actions were implemented during in July 2025 and are currently in place as of February 2026.
The Department agrees with the recommendation. The Department will review, assess, and, where necessary, update existing procedures for FFATA reporting relating to the requirement that state subawards for $30,000+ be submitted within 30 days of committed budget. This will include ensuring that the c...
The Department agrees with the recommendation. The Department will review, assess, and, where necessary, update existing procedures for FFATA reporting relating to the requirement that state subawards for $30,000+ be submitted within 30 days of committed budget. This will include ensuring that the confirmation date is documented. This process will be a coordinated effort between the Office Transportation Safety (OTS) and the Center for Accounting. This will include updating our reconciliation process to include additional data, reviewing and updating reconciliation and review procedures as needed, and reconciling Grants awarded in prior fiscal years that are still active and ensuring they have been appropriately reported. The findings related to this recommendation are in part the result of a federal reporting system limitation, and a federal system conversion. The legacy reporting system, FSRS, had a system limitation, which prevented the full amount of the award being reported in the case of three awards. Additionally, this conversion resulted in some data conversion issues impacting one additional award.
The Department agrees with this finding and will provide any training needed to staff members to ensure that all components of the FFATA are completed accurately, timely and with proper reviews. This training will include leadership reviewing NHTSA/Federal guidelines and SAM.Gov training on FFATA re...
The Department agrees with this finding and will provide any training needed to staff members to ensure that all components of the FFATA are completed accurately, timely and with proper reviews. This training will include leadership reviewing NHTSA/Federal guidelines and SAM.Gov training on FFATA reporting and requirements, documenting controls and ensuring the approvers have access to all supporting schedules, forms and systems and that they understand the subawards, and process for late submissions if needed.
The Department agrees with the finding and will ensure that staff follow all internal policies and procedures to maintain accurate and complete FFATA reporting. To achieve this, staff will review existing procedures and make any necessary updates regarding report compilation. Additionally, we will r...
The Department agrees with the finding and will ensure that staff follow all internal policies and procedures to maintain accurate and complete FFATA reporting. To achieve this, staff will review existing procedures and make any necessary updates regarding report compilation. Additionally, we will review control points to ensure they are consistently followed and approved by the team supervisor and team manager.
Management has put procedures in place in the current year to ensure timely submission.
Management has put procedures in place in the current year to ensure timely submission.
The Medical Center will create calendar appointments prior to required deadline for submission of the audited financial statements and annual budget for the responsible personnel including the chief financial officer.
The Medical Center will create calendar appointments prior to required deadline for submission of the audited financial statements and annual budget for the responsible personnel including the chief financial officer.
2025-001. Matching, Level of Effort, Earmarking United States Department of Education, Passed-through New York State Department of Education: Special Education Cluster Special Education Grants to StatesALN: 84.027 Special Education Preschool GrantsALN: 84.173 Condition: Upon review of the MOE, compl...
2025-001. Matching, Level of Effort, Earmarking United States Department of Education, Passed-through New York State Department of Education: Special Education Cluster Special Education Grants to StatesALN: 84.027 Special Education Preschool GrantsALN: 84.173 Condition: Upon review of the MOE, completed by the District to demonstrate the compliance requirement for the 2023-2024 grant program, it was noted that certain expenditures used in the MOE did not agree with the audited expenditure amounts. This resulted in an erroneous calculation indicating that the District had met the maintenance of effort requirement; however, the MOE completed using audited amounts would have indicated the District would not have met the MOE requirement without the District identifying allowable exceptions. Planned Corrective Action: The District concurs with the finding and has already provided additional training to the individuals responsible for preparing the MOE. Additionally, the District worked with its outside consultant to ensure the revised MOE was accurately completed. The revised MOE was subsequently transmitted to the New York State Education Department. Responsible Contact Person: Timothy Laube, Assistant Superintendent for Business & Operations. Eastport-South Manor Central School District 149 Dayton Avenue Manorville, New York 11949 laubet@esmonline.org 631-801-3001 Anticipated Completion Date: Corrective action completed.
FINDING 2025-003 Finding Subject: Child Nutrition Cluster - Eligibility Contact Person Responsible for Corrective Action: Katie Elliott Contact Phone Number and Email Address: 812-847-6020 ext. 1007 katieelliott@lssc.k12.in.us Views of Responsible Officials: We concur with the finding. Description o...
FINDING 2025-003 Finding Subject: Child Nutrition Cluster - Eligibility Contact Person Responsible for Corrective Action: Katie Elliott Contact Phone Number and Email Address: 812-847-6020 ext. 1007 katieelliott@lssc.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: Eligibility - Income guidelines will be entered by the Director of Food Services and reviewed by the Director of School Finance to ensure accuracy. Review by the Director of School Finance will be noted on the July monthly checklist completed by the Director of School Finance. Direct certification - The direct certification process will be completed on a weekly basis by the Director of Food Services and will be reviewed and signed off via email by the Director of School Finance. Review of Applications - The Food Service Management provider reviews and approves or denies online applications. The applications are printed monthly and maintained in the office of the Director of Food Service. The Director of Food Service will review a sample of applications each month to verify proper approvals and denials. The Director of Food Service will provide verified applications to the Director of School Finance for review. Anticipated Completion Date: This Corrective Action Plan will be put in effect February 2026.
Reference Number: 2025-001 Finding: Other Instance of Noncompliance and Deficiency Status: In-Progress Corrective Action: An instance was found where the R2T4 calculation for one student had a typo of the incorrect date. This was subsequently corrected. We reviewed this student record and concluded ...
Reference Number: 2025-001 Finding: Other Instance of Noncompliance and Deficiency Status: In-Progress Corrective Action: An instance was found where the R2T4 calculation for one student had a typo of the incorrect date. This was subsequently corrected. We reviewed this student record and concluded that it was a human error made. There is no pattern of incorrect information being used. To avoid future errors, the Assistant Director will meet with the Dean monthly and we will review completed R2T4's during that period. We believe having another pair of eyes to review the work completed will be sufficient to correct any inconsistencies. Person(s) Responsible for Implementing: Lynda McKendree, Dean of Scholarships and Financial Aid and Thuylieu Aligo, Assistant Director of Scholarships and Financial Aid. Implementation Date: 1/27/2026
USDA Community Facilities Loan Reserve Accounts Planned Corrective Action: Since the USDA loans were settled on December 10, 2020, Presbyterian College has held the required restricted reserves within its investment accounts. The College has confirmed with its USDA loan representative that a fully f...
USDA Community Facilities Loan Reserve Accounts Planned Corrective Action: Since the USDA loans were settled on December 10, 2020, Presbyterian College has held the required restricted reserves within its investment accounts. The College has confirmed with its USDA loan representative that a fully funded reserve is equal to the total annual payment for each loan. At all times, sufficient assets were maintained to meet the required reserve levels; however, the accounts were not separately titled or formally documented in accordance with the specific administrative requirements of the loan agreements. As soon as is practical, and following guidance regarding timing, the College will work with its investment advisors to make the administrative change to transfer the required balances into separately titled accounts designated “USDA Reserve Account.” The clear account description will ensure proper segregation and documentation of required reserves and prevent these funds from being commingled with other institutional funds in the future. In addition, the Finance Office will document reserve calculations and maintain supporting documentation to ensure ongoing compliance with USDA reserve requirements. Person Responsible for Corrective Action Plan: Elizabeth Oswald-Sease, Vice President of Finance and Administration and Elizabeth Shull, Controller Anticipated Date of Completion: As soon as is practical, but no later than July 1, 2026
Finding number: 2025-001 Federal agency: U.S. Department of Education Programs: Student Financial Assistance Cluster Assistance Listing #: 84.063 Award year: 2025 Corrective Action Plan Contact Person: Sabina Yesman, Director of Financial Aid A PELL Grant was awarded and disbursed for one ineligible...
Finding number: 2025-001 Federal agency: U.S. Department of Education Programs: Student Financial Assistance Cluster Assistance Listing #: 84.063 Award year: 2025 Corrective Action Plan Contact Person: Sabina Yesman, Director of Financial Aid A PELL Grant was awarded and disbursed for one ineligible student during the 2024-2025 Academic Year at Benjamin Franklin Cummings Institute of Technology (FC Tech). The error resulted from incomplete synchronization between enrollment and financial aid systems during the system transition period. Specifically, enrollment status and census-date verification were not fully integrated into the automated disbursement workflow, allowing aid to disburse before final eligibility confirmation. FC Tech has taken corrective measures and implemented monitoring and system controls to prevent future errors from occurring. Corrective Action Taken  FC Tech reviewed the student’s record and confirmed the ineligibility.  The PELL Grant award was adjusted to $0, and the disbursement was reversed.  The student account was corrected, and all required accounting and G5 drawdown adjustments were completed. The amount of $3,697 was returned on 12/18/2025  The case was documented internally for training purposes. Preventive Measures Implemented (February 2026) To prevent recurrence, FC Tech has implemented the following controls:  Enrollment Verification Prior to Disbursement All PELL-eligible students must be actively enrolled and confirmed in the Student Information System (Jenzabar) prior to disbursement.  Census-Date Verification Through Multiple Systems Enrollment status at census date is now validated through an integrated, multi-system verification process involving the Jenzabar, our Financial Aid System (PowerFAIDS), and Registrarconfirmed Enrollment Reports.  Delayed Disbursement Timeline Federal Aid disbursements are scheduled to occur no earlier than one week after census date to allow sufficient time for enrollment stabilization, drops, corrections and reconciliation  System Edit/Control Automated system edits have been implemented to prevent a PELL disbursement if census-date enrollment status is missing, unconfirmed, or inconsistent across systems.
Contact Person – Cassandra Heide, City Administrator Corrective Action Plan – Will establish a procedure to review certified payrolls. Completion Date – March 2026
Contact Person – Cassandra Heide, City Administrator Corrective Action Plan – Will establish a procedure to review certified payrolls. Completion Date – March 2026
FINDING 2025-004 Subject: COVID -19 - Education Stabilization Fund - Cash Management Contact Person Responsible for Corrective Action: Allison Vanover, Corporation Treasurer. Contact Phone Number 812-246-3375 Email Address: avanover@scsc.school Views of Responsible Officials: We concur with the find...
FINDING 2025-004 Subject: COVID -19 - Education Stabilization Fund - Cash Management Contact Person Responsible for Corrective Action: Allison Vanover, Corporation Treasurer. Contact Phone Number 812-246-3375 Email Address: avanover@scsc.school Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The Corporation will implement and consistently apply a standardized two-level review and approval process for all grant reimbursements to ensure proper accounting, documentation, and compliance. The grants administrator (or designee) will prepare and conduct the initial review of each grant reimbursement to verify that all expenses and receipts contain the correct accounting information, are properly documented, and are recorded in the appropriate accounts within the Financial Management System (FMS). The Corporation Treasurer (or designee) will perform an independent secondary review of all grant reimbursements, including a review of supporting documentation and account coding, and will provide final approval and signature as evidence of authorization. On a monthly basis, grant accounts will be reviewed by the grants administrator for accuracy and completeness, with the Corporation Treasurer (or designee) conducting a secondary monthly review to confirm accuracy and compliance. This two-level review process ensures adequate segregation of duties, strengthens internal controls, and provides documented oversight of all grant reimbursement activity. Anticipated Completion Date: The ESSER grant is finished. If we were to receive this grant in the future, Silver Creek School Corporation would apply the procedures in the corrective action plan.
FINDING 2025-003 Subject: COVID -19 - Education Stabilization Fund – Activities Allowed and Unallowed, Allowable Costs/Cost Principles Contact Person Responsible for Corrective Action: Allison Vanover, Corporation Treasurer. Contact Phone Number 812-246-3375 Email Address: avanover@scsc.school Views...
FINDING 2025-003 Subject: COVID -19 - Education Stabilization Fund – Activities Allowed and Unallowed, Allowable Costs/Cost Principles Contact Person Responsible for Corrective Action: Allison Vanover, Corporation Treasurer. Contact Phone Number 812-246-3375 Email Address: avanover@scsc.school Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The Corporation will implement and consistently apply a standardized two-level review and approval process for all grant reimbursements to ensure proper accounting, documentation, and compliance. The grants administrator (or designee) will prepare and conduct the initial review of each grant reimbursement to verify that all expenses and receipts contain the correct accounting information, are properly documented, and are recorded in the appropriate accounts within the Financial Management System (FMS). The Corporation Treasurer (or designee) will perform an independent secondary review of all grant reimbursements, including a review of supporting documentation and account coding, and will provide final approval and signature as evidence of authorization. On a monthly basis, grant accounts will be reviewed by the grants administrator for accuracy and completeness, with the Corporation Treasurer (or designee) conducting a secondary monthly review to confirm accuracy and compliance. This two-level review process ensures adequate segregation of duties, strengthens internal controls, and provides documented oversight of all grant reimbursement activity. Anticipated Completion Date: The ESSER grant is finished. If we were to receive this grant in the future, Silver Creek School Corporation would apply the procedures in the corrective action plan.
FINDING 2025-004 Finding Subject: COVID-19 - Education Stabilization Fund - Earmarking Audit Findings: Material Weakness, Modified Opinion Contact Person Responsible for Corrective Action: Ellen Prince and Chrystal Street Contact Phone Number and Email Address: ellenprince@crothersville.k12.in.us; c...
FINDING 2025-004 Finding Subject: COVID-19 - Education Stabilization Fund - Earmarking Audit Findings: Material Weakness, Modified Opinion Contact Person Responsible for Corrective Action: Ellen Prince and Chrystal Street Contact Phone Number and Email Address: ellenprince@crothersville.k12.in.us; cstreet@crothersville.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The district has implemented enhanced documentation procedures requiring written justification for all future ESSER-funded purchases, including identification of the program purpose and connection to learning loss when applicable. The district’s centralized grant binder will serve as the official tracking document for federal programs. The binder includes grant identification details, funding source, compliance requirements, and expenditure documentation. Anticipated Completion Date: January 2026
Findings Reported by Uniform Guidance – The following steps have been taken or will be taken to address Finding 2025-001: • Aspire Indiana Health continues to focus on reviews of the rental assistance calculation forms to make sure future issues are caught before submission • Aspire Indiana Health u...
Findings Reported by Uniform Guidance – The following steps have been taken or will be taken to address Finding 2025-001: • Aspire Indiana Health continues to focus on reviews of the rental assistance calculation forms to make sure future issues are caught before submission • Aspire Indiana Health upon discovery of the errors corrected within the system and plan to reverse out the dollars received in future drawdowns for this program
Federal Program: Department of Homeland Security Assistance Listing: 97.036 Federal Agency: COVID-19 Disaster Grants – Public Assistance (Presidentially Declared Disasters) (FEMA) Pass-Through Entity: State of Tennessee Grant Award Number: All FEMA Projects (Projects 435263,550461, 684580) Award Per...
Federal Program: Department of Homeland Security Assistance Listing: 97.036 Federal Agency: COVID-19 Disaster Grants – Public Assistance (Presidentially Declared Disasters) (FEMA) Pass-Through Entity: State of Tennessee Grant Award Number: All FEMA Projects (Projects 435263,550461, 684580) Award Period: Project 435263: 1/1/2020-7/31/2021 Project 550461: 1/1/2020-7/31/2021 Project 684580: 8/1/2020-6/30/2022 Management understands that additional audit evidence must be retained at a detailed enough level to allow the auditor to meet their reperformance standard. All expenses claimed were eligible and were reviewed by management prior to the submission. The control issue identified is due to the lack of evidence to support approval. Should management have a future FEMA claim we will retain additional audit evidence to enable auditor reperformance of the controls regarding approval of expenditures. Paula Yarbrough, VUMC Director – Grants and Contracts will be responsible for the implementation by fiscal year-end 2026.
The agency has verified and concurs with the finding as the payroll expense was inadvertently posted to the incorrect Chartfield. The agency failed to complete the requested journal entry, which was a communication failure within the ASD division. The ASD division has corrected this issue with added...
The agency has verified and concurs with the finding as the payroll expense was inadvertently posted to the incorrect Chartfield. The agency failed to complete the requested journal entry, which was a communication failure within the ASD division. The ASD division has corrected this issue with added communication levels to ensure that more than one person received communication between ASD and agency divisions. The ASD division has implemented better communication lines between the ASD division and the agency divisions which will resolve this issue. With more than one person receiving the information and additional training on ensuring that all reconciling items are addressed timely the agency general ledger will remain clean and in balance with allowable expended posted to the correct Chatfield’s.
Finding 2025-002: Internal Controls over Compliance Responsible Individuals: Mark Miller, Accounting Manager Corrective Action Plan: Management is currently implementing review procedures and proper oversight of compliance. Anticipated Completion Date: 2026
Finding 2025-002: Internal Controls over Compliance Responsible Individuals: Mark Miller, Accounting Manager Corrective Action Plan: Management is currently implementing review procedures and proper oversight of compliance. Anticipated Completion Date: 2026
Corrective Action Plan: The University is committed to ensuring compliance with all federal, institutional, and program regulations. The University continues to enhance its internal controls, policies, and procedures to ensure the appropriate documentation to support is maintained, and to ensure tha...
Corrective Action Plan: The University is committed to ensuring compliance with all federal, institutional, and program regulations. The University continues to enhance its internal controls, policies, and procedures to ensure the appropriate documentation to support is maintained, and to ensure that level of effort is appropriately documented and reported. To this end the University enlisted the support of Moore & Van Allen and associates law firm to support in developing enhanced policies, procedures, and training modules to support an increased level of compliance support. Moore & Van Allen is a wellrespected international law firm that specializes in reporting compliance and compliance training.To address the specific audit concerns Moore & Van Allen in conjunction with the JCSU executive cabinet, Government Sponsored Programs, the President and Board of Trustees to develop these policies, supporting procedures and training modules. These policies have been approved as of the January 15, 2026 Board of Trustees meeting: Time and Effort Reporting Policy, Government- Sponsored Equipment and Property Management Policy, Post-Award Management Policy, Grant Records Management Policy and Revised Extra Compensation for Faculty and Staff Policy. The level of effort reporting process has been modified to a consistent reporting for all campus awards. Level of effort reports are done by academic term, and the reports are due within 60 days following the end of the term. The Office of Government Sponsored Programs (“GSPAR”) has implemented monitoring and tracking measures to all reports are captured and completed according to federal guidelines. A system of multiple reviews has been implemented to help in reducing errors in reporting and increase efficiency in timeliness of the reports. Additionally, GSPAR intends to work closely with the Human Resources division to ensure accurate and efficient Time and Effort reporting. To address this concern, the Payroll unit has been reorganized into the Business and Finance Office to streamline communication and time and effort report fidelity between Payroll and GSPAR. In addition, the University mandated participation in compliance training for all faculty and staff; participants are required to submit an acknowledgment that they participated in the training and are aware of the compliance requirements. The mandatory training will occur annually for the university and all new grant award recipients will receive this training as part of their grant startup process. All GSPAR employees will also participate in training related to time and effort and allowable costs compliance, annually. Specific to the TRIO programs, as the result of a re-organization in February 2025 the University created a new position: Assistant Vice President (AVP) for Student Affairs, TRIO, and Well-being. This role will oversee Time and Effort Reporting, Annual Performance Report submissions, and financial transactions, ensuring accuracy and adherence to all relevant policies, regulations, and procedures. Additionally, this position will support professional development initiatives to enhance grant management and compliance. The AVP will also support university efforts to conduct regular program reviews to ensure proper documentation supporting TRIO eligibility and adherence to program requirements. To improve program knowledge and standardize practices, TRIO personnel will continue engaging in professional development offered locally and nationally. Internally, the TRIO Leadership Team (TRIO Project Directors and SVP of Student Enrollment & Retention Management) established TRIO Professional Development Day, a two-day training designed specifically for JCSU TRIO staff. These sessions provide guidance on university policies, financial compliance, Time and Effort reporting, effective record-keeping, and data management. The event also includes a roundtable discussion to promote collaboration and shared learning across programs. In addition, the TRIO Leadership Team will continue to explore best practices from high-functioning TRIO programs. To enhance communication and strengthen internal controls, the TRIO Leadership Team implemented monthly TRIO Program meetings. These meetings, involving TRIO Project Directors and the Senior Vice President of Strategic Enrollment and Retention Management, facilitate discussions on compliance, streamline processes, and support policy development. Additionally, the TRIO Leadership Team established monthly interdepartmental meetings among TRIO programs, the Division of Government Sponsored Programs and Research, and the Division of Business and Finance to further ensure alignment with institutional and federal requirements. Human Resources will also participate in future meetings to review Time and Effort Reporting procedures. TRIO Project Directors maintain ongoing communication with the Department of Education Program Officer, seeking written guidance on allowable costs, staffing adjustments, and fund reallocations, when necessary. Continuous monitoring and evaluation will ensure the effectiveness of these corrective actions, allowing the university to identify areas for ongoing improvement and maintain full compliance with all regulatory requirements Anticipated Completion Date: December 2026
Corrective Action Plan: To address the deficiencies identified in Finding 2025-004, the University has implemented and continues to enhance corrective actions focused on automating loan disbursement notifications, standardizing notification content and timing, strengthening documentation and audit t...
Corrective Action Plan: To address the deficiencies identified in Finding 2025-004, the University has implemented and continues to enhance corrective actions focused on automating loan disbursement notifications, standardizing notification content and timing, strengthening documentation and audit trails, and institutionalizing quality assurance oversight to ensure sustained compliance with federal notification requirements. Primary Control Enhancements. Loan disbursement notifications to the student for Subsidized, Unsubsidized, and Graduate PLUS Loans are now system-generated through Ellucian Colleague, providing automated delivery and a documented audit trail. Notifications are issued upon disbursement processing and delivered through system-supported modalities, including electronic communication and student portal updates. Ellucian Colleague retains a system-generated audit trail documenting the timing and content of each notification, strengthening the University’s ability to demonstrate compliance with federal requirements. This system-based approach eliminates reliance on third-party notification tools previously used and brings direct control of notification sequencing, content, and documentation within the University’s financial aid infrastructure. Supporting Controls and Training. The University has revised the Parent PLUS Loan notification process to ensure that required disbursement information—including the date, amount, and type of loan—is provided directly within the notification communication. While Parent PLUS notifications currently require initiation through a controlled manual process, procedures have been amended to ensure timely issuance, content accuracy, and supervisory oversight during this interim period. The University is actively working with the Ellucian Colleague implementation team to further automate Parent PLUS Loan disbursement notifications and eliminate manual triggering. Until full automation is achieved, documented procedures and quality assurance reviews will serve as compensating controls to ensure compliance with notification timing and content requirements. Monitoring and Quality Assurance. The University established and maintains a formal quality assurance framework to monitor loan disbursement notifications. A quality assurance calendar requires reviews at least twice per semester to confirm that notifications are issued within required regulatory timeframes, include all required elements, and are sent to the appropriate recipient (student or parent). As part of ongoing monitoring, the University has conducted multiple quality assurance reviews of loan disbursement notifications. These reviews have demonstrated improved compliance with notification timing and content requirements while also identifying isolated system sequencing issues that were promptly addressed through configuration updates and enhanced scheduling controls within Ellucian Colleague. Sustained Oversight. Any discrepancies identified through quality assurance reviews are documented, corrected, and evaluated to inform process refinement, system configuration, and staff training. Anticipated Completion Date: September 2026
Corrective Action Plan: To address the deficiencies identified in Finding 2025-001, the University has undertaken and continues to implement a comprehensive corrective action strategy focused on strengthening financial aid systems, standardizing processes, enhancing staff capacity, and institutional...
Corrective Action Plan: To address the deficiencies identified in Finding 2025-001, the University has undertaken and continues to implement a comprehensive corrective action strategy focused on strengthening financial aid systems, standardizing processes, enhancing staff capacity, and institutionalizing quality assurance and oversight mechanisms. Primary Control Enhancements. The University transitioned from PowerFAIDS to Ellucian Colleague as the system of record for financial aid awarding, enabling automated enforcement of packaging, eligibility, and fund-specific awarding rules. System configuration enhancements now support accurate cost of attendance calculations, enforcement of loan limits, and eligibility sequencing based on updated ISIR data, reducing reliance on manual intervention. Supporting Controls and Training. To support the implementation and stabilization of these controls, the University partnered with Financial Aid Services (FAS) in February 2025 to conduct a comprehensive review of financial aid systems, processes, and internal controls. Through this partnership, FAS has provided experienced Colleague specialists to support annual system setup, troubleshooting, validation of awarding rules, and targeted staff training. In addition, Financial Aid staff participate in ongoing professional development through the National Association of Student Financial Aid Administrators (NASFAA) and Federal Student Aid (FSA) to ensure continued proficiency and regulatory awareness. Monitoring and Quality Assurance. A formal quality assurance framework has been institutionalized, requiring eligibility and award accuracy reviews at least twice per semester. Reviews validate FSEOG prioritization by Student Aid Index (SAI), resolution of ISIR comment codes prior to disbursement, compliance with annual and lifetime loan limits, and alignment between cost-of-attendance values maintained in Ellucian Colleague and those reported to COD. Since the implementation of enhanced system controls and QA procedures, the University has conducted multiple eligibility and award accuracy reviews across Title IV programs, including Direct Loans, Pell Grants, and cost-ofattendance reconciliation. These reviews have demonstrated improved accuracy and control effectiveness, while also identifying isolated issues that were addressed through system updates or corrective adjustments. Sustained Oversight. Results of quality assurance reviews are documented, corrected, and analyzed to inform system configuration, staff training, and supervisory oversight. These controls ensure that improvements supported through the FAS partnership are institutionalized within university operations and sustained beyond the initial remediation period. Anticipated Completion Date: June 2026
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