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Saint Mary's University of Minnesota Corrective Action Plan For the Year Ended May 31, 2025 Finding 2025-001 Criteria: Title IV regulations (34 CFR 668.22) require the University to return the unearned portion of grants or loans to the Title IV program within 45 days after a student withdraws. Addit...
Saint Mary's University of Minnesota Corrective Action Plan For the Year Ended May 31, 2025 Finding 2025-001 Criteria: Title IV regulations (34 CFR 668.22) require the University to return the unearned portion of grants or loans to the Title IV program within 45 days after a student withdraws. Additionally, The U.S. Department of Education (ED) requires that an institution must ensure that its administrative procedures for the FSA programs include an adequate system of internal controls or checks and balances to ensure compliance with FSA laws and regulations including the return of Title IV funds. Condition/Context: The federal aid refunds for 1 out of 8 of the students tested was not calculated correctly and subsequently, not returned within 45 days from the withdrawal date. The sample was not statistically valid. Also, the auditor noted that the University did not have evidence or documentation available to support the control/review process for return of Title IV calculations. Cause: The University's review procedures for the return of Title IV funds were not followed and the system was not programmed to ensure the correct withdrawal date was used in the calculation of the return of Title IV funds. Effect: The University was in possession of funds belonging to the federal government longer than allowed and could have incorrect return of Title IV calculations and return incorrect amounts to students and/or the ED. Questioned Costs: Not applicable. Recommendation: The University should adhere to its procedures for refunding awards and implement a more formal documented review process/control to ensure refunds are calculated correctly and timely and any returns are made within the required timeframe. Management Response: The University agrees with this finding. The JFA R2T4 calculation incorrectly populated the wrong date used to perform the calculation, thus causing the error. The error was corrected and the director performs the R2T4 and is working to have a back-up employee trained. Staffing levels will have to be brought up to allow for new financial aid staff to complete this task. Corrective Action Plan Corrective Action Planned: To ensure accuracy, the withdrawal date generated in the JFA calculation will be cross-referenced against the J1 SIS record. Once verified, this date will be documented alongside the R2T4 calculation. This process guarantees that the student's period of attendance is calculated using the correct data. Name(s) of Contact Person(s) Responsible for Corrective Action: Holly Weberg, Director of Financial Aid and new hire designee. Anticipated Completion Date: The director is still fulfilling the R2T4 duties until a new hire candidate is hired and trained.
Finding 2025-001: U.S. Department of Health and Human Service, National Institutes for Health Research and Development Cluster, Cancer Control, Assistance Listing #93.399; Lack of Required Written Policies Corrective Action: We agree with the recommendation. We do currently require complete supporti...
Finding 2025-001: U.S. Department of Health and Human Service, National Institutes for Health Research and Development Cluster, Cancer Control, Assistance Listing #93.399; Lack of Required Written Policies Corrective Action: We agree with the recommendation. We do currently require complete supporting documentation for all expenditures. Montana Cancer Consortium (MCC) has updated the Financial Process Procedure to include language related to receipt management, allowable and disallowed grant expenses, and timing of payment requests. Timeline: This was implemented on December 1, 2025. Responsible Parties: MCC Director, Principal Investigators
Student Financial Aid Cluster – Assistance Listing Numbers 84.007, 84.033, 84.038, 84.063, and 84.268 Recommendation: We recommend the University review its return of Title IV fund procedures to ensure that calculations are performed with correct inputs as required by regulations. Explanation of dis...
Student Financial Aid Cluster – Assistance Listing Numbers 84.007, 84.033, 84.038, 84.063, and 84.268 Recommendation: We recommend the University review its return of Title IV fund procedures to ensure that calculations are performed with correct inputs as required by regulations. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: This finding was driven by incorrect MSMS program start and end dates configured in the University’s new Student Information System (Workday). When processing Return of Title IV (R2T4) calculations, Workday relies on the program start and end dates stored in the system. Due to these dates being incorrect, the R2T4 process calculated an inaccurate number of days enrolled, which resulted in an incorrect earned percentage of Title IV aid and, consequently, an incorrect amount of aid the student was eligible to retain. To address this issue, the University has implemented internal controls to review and verify the start and end dates of each academic year in Workday prior to the start of each semester. In addition, an internal control has been added to ensure the start and end dates of each academic year are reviewed and validated as part of the Return of Title IV processing. Name(s) of the contact person(s) responsible for corrective action: Jacob Witt, AVP of Financial Aid, 703-284-1532 Courtney Carey, University Registrar, 703-284-1523 Planned completion date for corrective action plan: Completed December 2025.
Recommendation: We recommend the University review the R2T4 requirements and implement adequate procedures to make sure that students that withdrew have a calculation performed. We also recommend the University to evaluate the R2T4 review process to ensure Title IV funds are returned timely. Explana...
Recommendation: We recommend the University review the R2T4 requirements and implement adequate procedures to make sure that students that withdrew have a calculation performed. We also recommend the University to evaluate the R2T4 review process to ensure Title IV funds are returned timely. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The University agrees with the importance of ensuring that the return of Title IV funds (R2T4) calculation is performed both timely and accurately. The University has taken significant steps to improve its compliance with R2T4 requirements. These efforts have yielded improved results with the late return error rate decreasing year over year from 13% to 7%. The University will continue to monitor staffing levels and workload to ensure that staffing aligns with timeline requirements. The University’s Processing team will lead focused R2T4 training on topics related to areas of noncompliance. Additional topics will be identified throughout the year as trends are identified in the Quality Assurance Audit process. The following steps will be taken immediately to address finding 2025-001. - The Processing team will continue to conduct subject matter training monthly, prioritized as follows: o Post Withdrawal Disbursements (PWD) identification o Post Withdrawal Disbursement timeline requirements - A new weekly review will be implemented by quality assurance outside of the review completed by R2T4 leadership to test if processing specialists are accurately determining if an R2T4 is required and if a refund is needed for a withdrawn student. Results will be used to coach staff members as needed. The University’s Quality Assurance team will continue to conduct weekly R2T4 reviews to test the R2T4 calculation for accuracy, timeliness of funds returned, and verifying that all internal and external system inputs are completed correctly. Findings from the internal audits will inform ongoing training and remediation steps throughout the year. Name(s) of the contact person(s) responsible for corrective action: - Rob Conlon, AVP Financial Aid Compliance - Alan Coddington, AVP Student Financial Services - John Okel, Director of Operations, Financial Aid Processing Planned completion date for corrective action plan: January 2026
Student Financial Assistance Cluster – Assistance Listing No. 84.063, 84.268 Recommendation: We recommend the University evaluate its policies and procedures around reporting student status changes to the NSLDS to ensure that all relevant information is being captured and reported timely in accordan...
Student Financial Assistance Cluster – Assistance Listing No. 84.063, 84.268 Recommendation: We recommend the University evaluate its policies and procedures around reporting student status changes to the NSLDS to ensure that all relevant information is being captured and reported timely in accordance with applicable regulations. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: La Salle contractually relies on the National Student Clearinghouse (NSC) to conduct its enrollment reporting to NSLDS. While there has been closer adherence to the overall transmission schedule established with the NSC, and this covers enrollment reporting for the vast majority of our registered students, such was not always the case in prior semesters, and selected exceptional registration transactions are not directly reported when they actually occur, resulting in delays, until the next regularly scheduled transmission. Going forward, upon encountering these exceptional transactions, we will take steps to ensure reporting of individual enrollments to the NSC within 1-2 business days following the transaction’s occurrence. Name(s) of the contact person(s) responsible for corrective action: Gerard Donahue, Registrar Planned completion date for corrective action plan: Corrected as of Spring 2026 (Fall 2025 is already complete as of this writing)
Student Financial Assistance Cluster – Assistance Listing No. 84.063 Recommendation: We recommend the University evaluate its procedures and review policies in overseeing COD reporting to ensure timely reporting. Explanation of disagreement with audit finding: There is no disagreement with the audit...
Student Financial Assistance Cluster – Assistance Listing No. 84.063 Recommendation: We recommend the University evaluate its procedures and review policies in overseeing COD reporting to ensure timely reporting. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: La Salle University has developed a report that enables weekly auditing of the Pell-eligible student population to ensure accurate identification and timely submission for evaluation. This report will be monitored on an ongoing weekly basis to promptly detect and address any errors related to Pell eligibility. Name(s) of the contact person(s) responsible for corrective action: Michele McDevitt, Assistant Vice President for Student Financial Services Planned completion date for corrective action plan: Corrected as of Spring 2026 (Fall 2025 is already complete as of this writing)
Management acknowledges that the Agency did not meet the required 20 percent non-federal share for the budget period ended May 31, 2025, and that the waiver request was submitted after the close of the budget period. While allowable in-kind contributions were tracked throughout the year, communicati...
Management acknowledges that the Agency did not meet the required 20 percent non-federal share for the budget period ended May 31, 2025, and that the waiver request was submitted after the close of the budget period. While allowable in-kind contributions were tracked throughout the year, communication from OHS provided differing guidance regarding the timing of submission for a Non-Federal Share waiver, which contributed to the delay. To address this matter, the Agency has implemented the following corrective actions: 1. A formal monthly Non-Federal Share Monitoring Report has been implemented and is reviewed by the Director and CFO. This report calculates the required match based on cumulative federal expenditures and compares it to documented in-kind contributions to ensure ongoing compliance. 2. Quarterly match projections are now prepared to identify potential shortfalls in advance of the budget period end. If projections indicate a deficit, corrective measures will be initiated immediately, including intensified in-kind collection efforts or submission of a waiver request prior to the end of the budget period. 3. The Governing Board and Policy Council will receive quarterly updates on non-federal share status to strengthen governance oversight and ensure transparency. 4. Written internal procedures for in-kind documentation, valuation, and monitoring have been formalized and incorporated into the Agency's fiscal policies and procedures manual. 5. The CFO has received additional training regarding federal matching requirements under 45 CFR §75 and Head Start Program Performance Standards to reinforce compliance expectations and ensure timely action in future budget periods. Management believes these corrective actions will strengthen internal controls, improve monitoring, and prevent recurrence in future budget periods.
Student Financial Aid Corrective Action Plan Institution Name: Southwestern University Audit/Review Period: FY 2024-2025 Date of Plan: Feb 4, 2026 Finding: 2025-001 Effect: The University did not report withdraw changes to the NSLDS timely. Recommendation: The University should put in place a proces...
Student Financial Aid Corrective Action Plan Institution Name: Southwestern University Audit/Review Period: FY 2024-2025 Date of Plan: Feb 4, 2026 Finding: 2025-001 Effect: The University did not report withdraw changes to the NSLDS timely. Recommendation: The University should put in place a process to timely capture student status changes so that they can be reported to the NSLDS. Management Response: The University concurs with this finding. University Corrective Action Plan: Every 30 days, the University reports updated student enrollment activity, encompassing attendance levels, graduation status, withdrawals, dropouts, and enrollment changes, to the National Student Loan Database System via the National Student Clearinghouse. Regrettably, during the 2024-25 academic year, an unforeseen error from the Clearinghouse resulted in the dissemination of incorrect enrollment statuses for a subset of our students. This oversight was beyond the Registrar's Office's knowledge, leading to an unintended delay in rectifying the reported statuses. We believe this Clearinghouse error was an isolated incident, having never occurred in any preceding academic year. The issue has been effectively resolved and should not recur in the future. Nevertheless, as a proactive measure, commencing with the 2025-26 academic year, the Financial Aid Office will collaborate with the Registrar's Office to review a representative sample of at least 10% of student records transmitted to the Clearinghouse. This review process will serve as an additional safeguard, ensuring the accuracy and timeliness of our reporting requirements.
Material weakness in internal control over compliance - Lack of control over monitoring of maintenance of effort Planned Corrective Action: The District is developing procedures to adequately monitor the calculation of maintenance of effort during the year. Program staff and business office personne...
Material weakness in internal control over compliance - Lack of control over monitoring of maintenance of effort Planned Corrective Action: The District is developing procedures to adequately monitor the calculation of maintenance of effort during the year. Program staff and business office personnel will meet regularly to identify any potential issues for noncompliance with maintenance of effort and develop a plan accordingly to ensure compliance is met. Staff training and utilization of the calculation tools provided by TEA will be provided to ensure all involved gain the necessary understanding. Responsible Contact Person: Farrah Jernigan, Chief Financial Officer Anticipated Completion Date: June 30, 2026
Material weakness in internal control over compliance - Lack of control over monitoring of maintenance of effort Planned Corrective Action: The District is developing procedures to adequately monitor the calculation of maintenance of effort during the year. Program staff and business office personne...
Material weakness in internal control over compliance - Lack of control over monitoring of maintenance of effort Planned Corrective Action: The District is developing procedures to adequately monitor the calculation of maintenance of effort during the year. Program staff and business office personnel will meet regularly to identify any potential issues for noncompliance with maintenance of effort and develop a plan accordingly to ensure compliance is met. Staff training and utilization of the calculation tools provided by TEA will be provided to ensure all involved gain the necessary understanding. Responsible Contact Person: Farrah Jernigan, Chief Financial Officer Anticipated Completion Date: June 30, 2026
2025-003 EARMARKING U.S. Department of Labor Assistance Listing Number 17.258/17.259/17.278 Condition: During our testing of Earmarking requirements for Youth Activities, we noted that approximately 13 percent of Youth activity finds allocated to the local area, except for the local area expenditure...
2025-003 EARMARKING U.S. Department of Labor Assistance Listing Number 17.258/17.259/17.278 Condition: During our testing of Earmarking requirements for Youth Activities, we noted that approximately 13 percent of Youth activity finds allocated to the local area, except for the local area expenditures for administration, was used to provide paid and unpaid work experience, which is not in compliance with the provisions stated in the Uniform Grant Guidance under the WIOA Cluster for Youth Activities. Recommendation: We recommend that the Board regularly review the grant expenditures for each of its programs and activities to ensure that all requirements for earmarking within the Uniform Grant Guidance are met. Region 3 Action: the Board will conduct formal monthly reviews of all WIOA grant expenditures by program and funding stream. These reviews will compare actual expenditure to budget allocations and earmarking requirements to ensure compliance with Uniform Grant Guidance and WIOA statutory requirements. Financial staff will prepare monthly expenditure reports, which will then be reviewed and approved by the Executive Director and presented quarterly to the Finance Committee of the Board. The Finance Committee will document its review in meeting minutes. The Board believes these corrective measures strengthen internal controls and ensure ongoing compliance with federal grant requirements. We are committed to maintaining sound fiscal oversight and full adherence to all applicable WIOA and Uniform Grant Guidance requirements.
2025-002 Eligibility- WIOA intake applications were not signed properly U.S. Department of Labor Assistance Listing Number 17.258/17.259/17.278 Condition: During our testing of WIOA participants, it was noted that for one of the six youth participants selected for testing the WIOA intake application...
2025-002 Eligibility- WIOA intake applications were not signed properly U.S. Department of Labor Assistance Listing Number 17.258/17.259/17.278 Condition: During our testing of WIOA participants, it was noted that for one of the six youth participants selected for testing the WIOA intake application was not signed by the case manager. Recommendation: We recommend that the Board thoroughly review all applications for Youth Activities to ensure that all required eligibility documentation is completed and properly approved. Region 3 Action:ln direct response to this finding, the Board developed and implemented a comprehensive Youth Eligibility Policy, effective February 25, 2025. This policy establishes clear and enforceable procedures to ensure that all youth participants are properly vetted prior to receiving WIDA-funded services.Specifically, the policy includes a dedicated "Eligibility Verification" and "Documents for Verifying WIOA Eligibility" section which requires that service providers confirm each individual meets all applicable WIOA eligibility requirements including age, selective service registration and citizenship status at the time of registration. The policy further requires that each participant file contain a completed application along with supporting documentation confirming general WIOA eligibility and all applicable Youth eligibility data elements. Additionally, all questions on the intake form must be fully answered and both the applicant and the intake staff member are required to sign the intake forms prior to the delivery of services. Primary Eligibility Review is the Local Board's program staff's responsibility to ensure all registration paperwork is complete and accurate before WIOA enrollment.The Board is confident that these policy requirements provide the necessary framework and controls to ensure consistent, documented eligibility verification across all service providers administering youth activities under WIOA. The Board will continue to monitor compliance with this policy through its oversight activities to ensure the controls remain effective on an ongoing basis.
2025-001 REPORTING-MACC reports did not contain evidence of supervisory approval Condition: For all MACC reports selected for testing, management was unable to provide adequate support that the reports were properly reviewed and approved prior to being submitted. Recommendation: We recommend that th...
2025-001 REPORTING-MACC reports did not contain evidence of supervisory approval Condition: For all MACC reports selected for testing, management was unable to provide adequate support that the reports were properly reviewed and approved prior to being submitted. Recommendation: We recommend that the Board design and implement controls to ensure that all required reporting is submitted accurately in a timely fashion, with proper review and approval prior to submission. Region 3 action: Although Region 3 has established a monthly checklist that is reviewed and signed off by Brenda Hunt CPA, it is a work in progress and ad ustments will be made to reflect an additional review and approval prior to submission.
Finding 1175480 (2025-003)
Material Weakness 2025
Identifying Number: 2025-003 Finding: Graham Leach Bliley Act – Student Information Security The College’s written information security program did not include the following elements required by regulation as agreed to in the PPA: • The College has performed a risk assessment utilizing internal reso...
Identifying Number: 2025-003 Finding: Graham Leach Bliley Act – Student Information Security The College’s written information security program did not include the following elements required by regulation as agreed to in the PPA: • The College has performed a risk assessment utilizing internal resources but has not fully integrated the information security program on the results of this assessment, nor has the College included all required elements of internal and external risks to the security, confidentiality or integrity of customer information. The College’s risk assessment is in the process of implementing an inventory of IT systems that process and store customer information and the compliance with information security elements related to multifactor authentication, access control, change management, logging and alerting and encryption. • The College has not identified, designed or implemented safeguards for all of the risks identified in the risk assessment. The safeguards do not include the identification of security events the detection and response capabilities to support incident response is still being developed. • The College has not been able to test safeguards because safeguards have not been fully designed or implemented in response to the risk assessment. • The College has not developed written policies and procedures to ensure that personnel are able to enact the information security program. There is a lack of evidence of leadership being required to report to the board or an appropriate supervisory council to ensure those charged with governance are informed on the current state of the information security program. Corrective Actions Taken or Planned: 1. Integration of Risk Assessment Results • Corrective Actions Taken or Planned: Complete a new risk assessment for our new information systems and fully integrate the results including safeguards into the College’s information security program. • Person Responsible: James Stevens, Chief Information Officer, jstevens@knox.edu • Anticipated Completion Date: June 30, 2026 2. Provide Training for Written Policies and Procedures • Corrective Actions Taken or Planned: Distribute written policies and procedures to ensure personnel can enact the information security program. Provide training to all relevant staff. • Person Responsible: James Stevens, Chief Information Officer, jstevens@knox.edu • Anticipated Completion Date: June 30, 2026 3. Testing of Safeguards • Corrective Actions Taken or Planned: Conduct regular testing of implemented safeguards to ensure effectiveness. Document results and make improvements as needed. • Person Responsible: James Stevens, Chief Information Officer, jstevens@knox.edu • Anticipated Completion Date: June 30, 2026 4. Comprehensive Inventory of IT Systems • Corrective Actions Taken or Planned: Update and maintain our inventory of all IT systems that process and store customer information. Ensure compliance with multifactor authentication, access control, change management, logging, alerting, and encryption requirements. • Person Responsible: James Stevens, Chief Information Officer, jstevens@knox.edu • Anticipated Completion Date: June 30, 2026 5. Governance and Reporting • Corrective Actions Taken or Planned: Establish a formal process requiring leadership to report on the state of the information security program to the Board of Trustees and include in our security policies. • Person Responsible: James Stevens, Chief Information Officer, jstevens@knox.edu • Anticipated Completion Date: 6/30/2026 6. GLBA Policy Enhancement • Corrective Actions Taken or Planned: Review and revise the information security policy to ensure all GLBA-required elements are included, referencing current regulatory guidance. • Person Responsible: James Stevens, Chief Information Officer, jstevens@knox.edu • Anticipated Completion Date: 6/30/2026
Finding 1175470 (2025-001)
Material Weakness 2025
Identifying Number: 2025-001 Finding: Error in Reporting for National Student Loan Data System (NSLDS) The College did not properly report the student enrollment change for students who received federal student aid to the NSLDS. The College did not timely report three students’ Program-Level or Camp...
Identifying Number: 2025-001 Finding: Error in Reporting for National Student Loan Data System (NSLDS) The College did not properly report the student enrollment change for students who received federal student aid to the NSLDS. The College did not timely report three students’ Program-Level or Campus-Level enrollment status change to NSLDS. Out of the 25 students tested, we noted 3 students (12%) whose status change at the Program-Level and Campus-Level was not timely reported to NSLDS. The College did not have adequate controls related to the process of enrollment reporting, which is required under Uniform Grant Guidance. Corrective Actions Taken or Planned: Knox College will add a third report submission to the end of the term. This will ensure that we report any students that made end of term withdrawals within the time window we are required to report. Any students who withdraw between terms will be captured in the first report submitted after our two week census. Person Responsible: Patrick Hathaway, Registrar, phathaway@knox.edu Anticipated Completion Date: December 31, 2025
Finding 2025-003: Late Student Status Change Reporting Federal Agency: U.S. Department of Education Program: Student Financial Assistance Cluster Criteria: 34 CFR 668.32 requires that an organization reports student status changes within 60 days of graduation, withdrawal, or other roster status chan...
Finding 2025-003: Late Student Status Change Reporting Federal Agency: U.S. Department of Education Program: Student Financial Assistance Cluster Criteria: 34 CFR 668.32 requires that an organization reports student status changes within 60 days of graduation, withdrawal, or other roster status changes. Condition: The change in status for 4 of 40 students tested was not reported to the National Student Loan Data System (NSLDS) within 60 days of the change. Cause: Staffing changes during the year impacting the College’s internal control structure resulted in an administrative delay in reporting the changes to NSLDS. Effect: The effect of the condition described above was that the College was not in compliance with NSLDS reporting requirements. Repeat Finding: This is not a repeat finding. Questioned costs: There are no known questioned costs to report. Recommendation: We recommend that the College ensures sufficient staffing is available to report NSLDS requirements timely. View of Responsible Officials and Planned Corrective Action Corrective Action Plan: There is no disagreement with this audit finding. During the fall of 2024 the Registrar’s Office was downsized. This resulted in the delayed processing of the error report following the 10.25.2024 report. This resolution required contacting NSC for assistance in clearing two of the errors, which increased the processing time. Moving forward, the Registrar’s Office will continue to report to NSC on the predetermined schedule, process errors timely, and additionally, a quality control check will be implemented for the Financial Aid Office to compare NSLDS records following the NSC transmissions. Name(s) of the contact person(s) responsible for corrective action: Dr. Melissa Wisniewski, Dean of Enrollment Services at 717-391-7234. Planned completion date for corrective action plan: February 2026 If the Department of Education has questions regarding this plan, please call the Vice President of Finance and Administration, Mr. George Longridge at 717-391-6947.
Finding 2025-002: Student Financial Aid Cluster – Allowable Costs and Allowable Activities and Eligibility Federal Agency: U.S. Department of Education Program: Student Financial Assistance Cluster Criteria: The College is required to have controls in place to ensure students receive the proper amou...
Finding 2025-002: Student Financial Aid Cluster – Allowable Costs and Allowable Activities and Eligibility Federal Agency: U.S. Department of Education Program: Student Financial Assistance Cluster Criteria: The College is required to have controls in place to ensure students receive the proper amount of student financial assistance they are entitled to based on financial need. Condition: Our financial aid sample of 40 items tested yielded 31 students who received Direct Loan Funding. Of the 31 students who received Direct loan funding, we noted 1 instance where the student received the incorrect amount of Unsubsidized funding. Based on the students Student Aid Index, the student should have received $1,750 in Unsubsidized funding; however, they received $2,227 in Unsubsidized Direct Loan funding, resulting in an overpayment of Direct Loan funding of $477. Cause: The controls in place did not detect that the student had incorrectly been awarded assistance based on more than 30 credits when they actually had 25 credits. The additional 5 credits needed for the amount of the award were not earned until the following semester. Effect: Internal controls related to student financial assistance were not operating properly. Repeat Finding: This is not a repeat finding. Questioned costs: $477 Recommendation: We recommend Thaddeus develop systems that would detect credits posted but not earned to ensure proper student assistance is awarded. View of Responsible Officials and Planned Corrective Action: Management agrees. See separate Corrective Action Plan. Corrective Action Plan: There is no disagreement with the audit finding. After reviewing the policy for Grade-Level Advancement for Direct Loan Consideration, it was determined that the student referenced in the funding did not meet the qualifications needed to be considered a sophomore level student for the Fall 2024 semester. The student became eligible for the increased loan amount in the Spring 2025 semester. The $500 that was incorrectly awarded to the student for the Fall 2024 semester has been corrected and reallocated to Spring 2025. The Office of Financial Aid has created a procedure to check student loan amounts during fall and spring semester to ensure accuracy. Additionally, an Assistant Director of Financial Aid was hired in February 2025 to strengthen financial aid administration within the department. Name(s) of the contact person(s) responsible for corrective action: Melissa Wisniewski, Dean of Enrollment Services at 717-391-7234. Planned completion date for corrective action plan: January 2026. If the Department of Education has questions regarding this plan, please call the Vice President of Finance and Administration, George Longridge at 717-391-6947.
Finding 2025-001 Condition Management implemented controls that specifically addressed some of the circumstances surrounding prior year finding 2024-001. Management's review of the enrollment reporting did not timely report certain student Campus-Level and Program-Level data elements. Student record...
Finding 2025-001 Condition Management implemented controls that specifically addressed some of the circumstances surrounding prior year finding 2024-001. Management's review of the enrollment reporting did not timely report certain student Campus-Level and Program-Level data elements. Student records within the NSLDS was identified with non-timely Campus-Level and Program-Level data elements. Corrective Action Plan Corrective Action Planned: Management agrees with the finding. To resolve this issue, when a student formally withdraws or is academically dismissed in summer, the student information will be manually added to the next National Student Clearinghouse (NSC) upload file, submitted once a month, and marked as “Withdrawn” with an effective status date of the withdrawn date of determination. This complies with NSC processes detailed here: https://help.studentclearinghouse.org/compliancecentral/knowledge-base/enrollment-reporting-for-summer-and-other-non-required-terms/. Name of Contact Person Responsible for Corrective Action: Mark Fetherston, Vice President for Enrollment Management Anticipated Completion Date: Process and procedures will be updated in February 2026, with first implementation in May 2026 (as part of the Summer 2026 submission process).
Condition: There was an incorrect cost of attendance amount used to calculate a parent PLUS loan for 1 out 40 students tested. Criteria: According to the U.S. Department of Education, an institution must use cost of attendance minus other financial aid received to calculate the amount of PLUS loans ...
Condition: There was an incorrect cost of attendance amount used to calculate a parent PLUS loan for 1 out 40 students tested. Criteria: According to the U.S. Department of Education, an institution must use cost of attendance minus other financial aid received to calculate the amount of PLUS loans that students are eligible to receive. Cause: The University utilizes a paper worksheet to manually calculate a student’s eligibility for PLUS loans. Due to a manual entry error, the cost of attendance was recorded as $1,000 less than the correct amount. As a result, the student was eligible to borrow more funds than initially indicated. Effect: As a result of the manual calculation error on the loan worksheet, the student was informed of a lower borrowing limit than they were actually eligible for. This discrepancy contributed to the student receiving less financial aid than anticipated. Additionally, the error highlights a risk in the manual calculation process, which could result in similar miscalculations for other students if not addressed. Context: The University determines PLUS loan eligibility using a manually prepared worksheet rather than an automated system calculation. Financial aid staff record the cost of attendance and other aid amounts on this form to compute the eligible PLUS loan amount. During audit testing, it was noted that an error occurred in recording the cost of attendance, resulting in an incorrect calculation of the student’s PLUS loan eligibility. Recommendation: The University should implement controls to prevent, or detect and correct, manual calculation errors in determining PLUS loan eligibility. This may include transitioning to an automated system-based calculation, improving the secondary review process for all manually prepared worksheets, or incorporating validation checks for key data. Implementing these controls will help ensure accuracy in loan determinations and compliance with federal awarding requirements. View of Responsible Officials and Planned Corrective Action: Thank you for the opportunity to report on enhancements the University has made to resource our students and maintain the highest standards of accounting. While we are pleased that the audit indicated significant progress, the following are additional steps we are taking to ensure even greater accuracy and compliance: 1. An improved review process for all manually calculated loan worksheets to verify the accuracy of key inputs, including the cost of attendance and other aid amounts and 2. The University is also exploring options to automate the loan calculation process within its financial aid management system to reduce the risk of manual errors.
Management Response: The University agrees with this recommendation and will modify the procedures associated with the review of subsequent payroll and fringe adjustments to ensure that in addition to reversing in total that the adjustments also reverse at the index-account level. These new procedur...
Management Response: The University agrees with this recommendation and will modify the procedures associated with the review of subsequent payroll and fringe adjustments to ensure that in addition to reversing in total that the adjustments also reverse at the index-account level. These new procedures will be implemented by February 27, 2026, and will be overseen by the Deputy Controller.
Criteria Institutions are required to report enrollment information under the Pell grant and the Direct and FFEL loan programs via the NSLDS. The administration of the Title IV programs depends heavily on the accuracy and timeliness of the enrollment information reported by institutions. Institution...
Criteria Institutions are required to report enrollment information under the Pell grant and the Direct and FFEL loan programs via the NSLDS. The administration of the Title IV programs depends heavily on the accuracy and timeliness of the enrollment information reported by institutions. Institutions must review, update, and certify student enrollment statuses, program information, and effective dates that appear on the Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS Professional Access (NSDLSFAP) website. There are two categories of enrollment information, “Campus Level” and “Program Level,” both of which need to be reported accurately and have separate record types. Title 2 U.S. Code of Federal Regulations Part 200 (2CFR 200) Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, section 303(a) states, the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statues, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition In testing the Program-Level enrollment reporting data elements as reported to NSLDS, key items to test are: OPEID Number, CIP Code, CIP Year, Credential Level, Published Program Length Measurement, Published Program Length, Program Begin Date, Program Enrollment Status, and Program Enrollment Effective Date. During the performance of our test work, the College identified that 31 of the 409 students who graduated during the year had enrollment statuses that did not agree between campus-level and program-level NSLDS data. Specifically, these 31 students’ enrollment statuses were correctly reported as graduated in the campus-level NSLDS data but were inaccurately reported as withdrawn in the program-level NSLDS data. The exception described above did not result in changes to the amounts awarded or disbursed to students by the College for the current fiscal year. Cause The condition resulted from a gap in the College’s internal control processes. Specifically, the College did not implement a control to ensure that all changes in enrollment information were submitted accurately to NSLDS. Possible Asserted Effect Inaccurate submission of student enrollment status information and related program information affects the determinations that lenders and servicers of students’ loans make related to in-school status, deferments, grace periods, and repayment schedules, as well as the federal government’s payment of interest subsidies. Questioned Costs None. Statistical Sampling The sample was not intended to be, and was not, a statistically valid sample. Identification of Whether the Audit Finding was a Repeat Finding This is not a repeat finding. Recommendation We recommend the College review and enhance its process related to enrollment reporting to ensure that all key data elements are reported accurately to the NSLDS. Views of Responsible Officials Responsible Individual: Joan Romano, Registrar, Enrollment Strategy and Operations Contact Information: jromano2@berklee.edu , 617-747-2475 In response to the condition identified, the College has strengthened its internal controls over enrollment reporting to ensure alignment between campus-level and program-level data submitted to NSLDS. Automated validation control implemented: Crossfield validation added to the student information system to ensure campus and program-level enrollment statuses align prior to NSLDS submission at graduation closure. Graduation records with misaligned statuses will be blocked from transmission, and discrepancies generate exception alerts that must be corrected before file submission. Monthly reconciliation and documented exception tracking established: After each NSLDS submission and graduation file transmission, reconciliation reports will compare campus and program-level data. Any discrepancies identified are resolved through a formal exception tracking process before certifying subsequent submissions. Standard operating procedures will be updated to document these enhancements to enrollment data reporting. Enhanced monitoring and supervisory oversight: Enhanced controls will ensure enrollment data reported to NSLDS is accurate, complete, and compliant preventing future reporting misalignment. The Registrar/Associate Registrar will perform review and sign-off to confirm procedures are consistently followed to remediate the risk of any future findings. Expected Implementation Completed: May 31, 2026 Status of Completion: In Process
Criteria Institutions submit Direct Loan, Pell Grant, TEACH Grant, and IASG origination records and disbursement records to the Common Origination and Disbursement (COD) system. Origination records can be sent well in advance of any disbursements, as early as the institution chooses to submit them f...
Criteria Institutions submit Direct Loan, Pell Grant, TEACH Grant, and IASG origination records and disbursement records to the Common Origination and Disbursement (COD) system. Origination records can be sent well in advance of any disbursements, as early as the institution chooses to submit them for any student the institution reasonably believes will be eligible for a payment. The disbursement record reports the actual disbursement date and the amount of the disbursement. ED processes origination and/or disbursement records and returns acknowledgments to the institution. The acknowledgments identify the processing status of each record: Rejected, Accepted with Corrections, or Accepted. Title 2 U.S. Code of Federal Regulations Part 200 (2CFR 200) Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, section 303(a) states, the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statues, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition In testing the origination and disbursement data, key items to test on origination records, if applicable, are: Social Security number, award amount, enrollment date, verification status code, transaction number, cost of attendance, and academic calendar. During our test work over the key items on origination records as reported on COD, KPMG identified the following: • 6 of the 40 students selected for test work had incorrect academic start or end dates that did not agree to the College’s records. None of the items that were exceptions described above resulted in the College over awarding students for the current fiscal year. Cause The condition resulted from the College Student Financial Aid Operations Department not reporting updated information to the COD System when changes were made to enrollment dates of the students identified due to the College not having an adequate internal control process. Questioned Costs None. Statistical Sampling The sample was not intended to be, and was not, a statistically valid sample. Identification of Whether the Audit Finding was a Repeat Finding This is not a repeat finding. Recommendation We recommend the College review and enhance its process related to reporting key items to the COD System and update key fields as information may change during the awarding process to ensure that they agree to the College’s records. Views of Responsible Officials Responsible Individual: Russell Romandini, Director of Student Financial Aid Services, Student Financial Services Contact Information: rromandini@berklee.edu , 617-747-2505 Management concurs with the recommendation. Berklee will enhance internal controls over the reporting of key data to the COD system. Designated staff in the Student Financial Aid Operations Department and Office of the Registrar has developed reports and implemented a recurring review process comparing enrollment and academic year dates in PowerFAIDS to Berklee’s registration records. This review will be performed at relevant intervals to be sure data mismatches are resolved by the end of the academic year processing cycle. These intervals occur towards the end of academic year processing (summer semester for campus; spring and summer terms for the online program) as these are the academic periods that generate the most enrollment changes, and with it, academic year date fluctuations. Any differences identified will be updated in PowerFAIDS and COD as necessary and in a timely manner to ensure ongoing data alignment and accuracy between the COD system and institutional records. Supervisory oversight by the Director of Student Aid Operations will include review and sign off to ensure the enhanced procedures are consistently followed by the Operations team to remediate the risk of any future findings. Expected Implementation Completed: May 31, 2026 Status of Completion: In Process
January 27, 2026 Aldrich CPAs + Advisors LLP 7676 Hazard Center Drive, Suite 550 San Diego, CA 92108 RE: Corrective Action Plan Dear Aldrich, The following are responses to the finding identified in Union of Pan Asian Communities (UPAC) audit for the year ended June 30, 2025: 1) Finding 2025-001 a. ...
January 27, 2026 Aldrich CPAs + Advisors LLP 7676 Hazard Center Drive, Suite 550 San Diego, CA 92108 RE: Corrective Action Plan Dear Aldrich, The following are responses to the finding identified in Union of Pan Asian Communities (UPAC) audit for the year ended June 30, 2025: 1) Finding 2025-001 a. Program Information: 93.778 Medicaid Cluster – Medical Assistance Program, Pass-Through Award #567787 b. Criteria: In accordance with 2 CFR 200.329, non-Federal entities must submit performance reports at the interval required by the Federal awarding agency or pass-through entity no later than the specified due date. If a justified request is submitted by a non-Federal entity, the Federal agency may extend the due date for any performance report. c. Condition: During our audit, we identified one quarterly status report that was submitted to the Contracting Officer’s Representative (COR) after the stated due date. Response: UPAC has put in place a system of reminders and deadline review with program managers and administrative staff to ensure deadlines for contract reporting due dates are calendared and scheduled in advance. Contact persons responsible for corrective action: 1) Sarah Ferry, Chief Financial Officer 2) Courtney Boatman, Vice President of Addiction Treatment and Recovery Services Completion date: Additional internal control procedure noted above will be effective immediately. Sincerely, Wendy Urushima-Conn Chief Executive Officer Union of Pan Asian Communities
Student Financial Assistance Cluster – Assistance Listing No. 84.268 Recommendation: We recommend the College evaluate its procedures and a policy around how Subsidized Stafford loans are calculated, awarded, and packaged. Explanation of disagreement with audit finding: There is no disagreement with...
Student Financial Assistance Cluster – Assistance Listing No. 84.268 Recommendation: We recommend the College evaluate its procedures and a policy around how Subsidized Stafford loans are calculated, awarded, and packaged. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The long-established process for prorating direct student loans for students entering their last term of study and scheduled to attend less than a full year relies on a loan proration chart kept by the financial aid office. This situation affects very few students each year. A minor error was made on one student’s award due to using an outdated proration chart. As soon as the error was discovered, the chart was updated and its accuracy will be confirmed annually.
Management acknowledges that certain internal controls did not operate effectively during the year ended June 30, 2025. Management is in the process of implementing additional controls to ensure a stable control environment that complies with procurement requirements.
Management acknowledges that certain internal controls did not operate effectively during the year ended June 30, 2025. Management is in the process of implementing additional controls to ensure a stable control environment that complies with procurement requirements.
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