Corrective Action Plans

Finding 539474 (2024-007)

Significant Deficiency 2024

Urshan College

MO

Questioned Costs Student Financial Aid Matching / Level of Effort / Earmarking § 200.303

Eligibility – Assistance Listing No. 84.063, 84.268 Recommendation: We recommend the College design controls to ensure an adequate review process is in place to ensure compliance with reporting requirements. Explanation of disagreement with audit finding: There is no disagreement with the audit fin...

Eligibility – Assistance Listing No. 84.063, 84.268 Recommendation: We recommend the College design controls to ensure an adequate review process is in place to ensure compliance with reporting requirements. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Financial Aid office will be implementing an SOP which will document a review process of work done by the third-party processor, to include COD reporting, and Verification procedures. We will also be implementing a process to review students who need to complete their exit counseling. Name(s) of the contact person(s) responsible for corrective action: Levi Powell, Student Financial Aid Director Planned completion date for corrective action plan: 6/30/2025

View Audit 350009 Questioned Costs: $1

Finding 539472 (2024-006)

Significant Deficiency 2024

Urshan College

MO

Questioned Costs Subrecipient Monitoring Reporting § 200.303

Special Tests and Provisions Gramm-Leach-Bliley Act– Assistance Listing No. 84.063, 84.268 Recommendation: We recommend the College design controls to ensure an adequate review process is in place to ensure compliance with reporting requirements. Explanation of disagreement with audit finding: Ther...

Special Tests and Provisions Gramm-Leach-Bliley Act– Assistance Listing No. 84.063, 84.268 Recommendation: We recommend the College design controls to ensure an adequate review process is in place to ensure compliance with reporting requirements. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The IT department continues to improve its processes; an annual review of the WISP has been started and will continue. The Financial Aid Office will work with IT to make sure that the WISP is improved to include and provide secure disposal of customer information and make sure the review is documented. Name(s) of the contact person(s) responsible for corrective action: Levi Powell, Student Financial Aid Director Planned completion date for corrective action plan: 6/30/2025

View Audit 350009 Questioned Costs: $1

Finding 539470 (2024-005)

Material Weakness 2024

Urshan College

MO

Questioned Costs Student Financial Aid Material Weakness § 200.303

Special Tests and Provisions R2T4 – Assistance Listing No. 84.063, 84.268 Recommendation: We recommend the College design controls to ensure an adequate review process is in place to ensure compliance with reporting requirements. Explanation of disagreement with audit finding: There is no disagreeme...

Special Tests and Provisions R2T4 – Assistance Listing No. 84.063, 84.268 Recommendation: We recommend the College design controls to ensure an adequate review process is in place to ensure compliance with reporting requirements. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Financial Aid office will be crafting a new SOP to address R2T4 audit findings. The team will work more closely with the Registrar and Academic Deans when determining the withdrawal status of a student and make sure that the R2T4 documentation is accurately completed, a review of completed R2T4s will also be conducted. Name(s) of the contact person(s) responsible for corrective action: Levi Powell, Student Financial Aid Director Planned completion date for corrective action plan: 6/30/2025

View Audit 350009 Questioned Costs: $1

Finding 539468 (2024-004)

Significant Deficiency 2024

Urshan College

MO

Student Financial Aid Matching / Level of Effort / Earmarking Reporting § 200.303

Special Tests and Provisions Enrollment Reporting – Assistance Listing No. 84.063, 84.268 Recommendation: We recommend the College provide additional resources to ensure all compliance requirements are met. Explanation of disagreement with audit finding: There is no disagreement with the audit find...

Special Tests and Provisions Enrollment Reporting – Assistance Listing No. 84.063, 84.268 Recommendation: We recommend the College provide additional resources to ensure all compliance requirements are met. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: A new Standard Operating Procedure (SOP) is being created, which will address enrollment reporting concerns. The Financial Aid office will work with the Registrar to increase communication between offices and eliminate enrollment reporting errors. The Financial Aid office will also improve reporting to the third-party processor, so that timely and accurate information is uploaded to NSLDS. Furthermore, a recurring review of the third-party’s reporting to NSLDS will be instituted. Name(s) of the contact person(s) responsible for corrective action: Levi Powell, Director of Financial Aid Planned completion date for corrective action plan: 6/30/2025

View Audit 350009

Finding 539414 (2024-003)

Significant Deficiency 2024

Siena Heights University

MI

Student Financial Aid Reporting Significant Deficiency

Condition: Of the 40 students selected for enrollment reporting testing, 1 student did not have their program-level status change updated appropriately and another student was not updated from less than half time to withdrawn by the University's third party administrator. Planned Corrective Action: ...

Condition: Of the 40 students selected for enrollment reporting testing, 1 student did not have their program-level status change updated appropriately and another student was not updated from less than half time to withdrawn by the University's third party administrator. Planned Corrective Action: Clearinghouse reporting process has been reassessed, and error reporting will be completed weekly. Training will be done for registrar staff on process, and how to verify information has successfully been accepted by NSLDS. The Registrar's office will work closely with Financial Aid to verify enrollment updates and complete error resolution. Contact person responsible for corrective action: Callie Zake, Senior Director Student Financial Services Anticipated Completion Date: June 30, 2025

View Audit 349964

Finding 539412 (2024-002)

Significant Deficiency 2024

Siena Heights University

MI

Questioned Costs Student Financial Aid Internal Control / Segregation of Duties § 200.303

Condition: There was a lack of internal controls in place related to the return of Title IV funds. Planned Corrective Action: Director will update academic calendar on COD R2TIV calculator yearly and verify dates and length of breaks are correct. The University will continue to have the Senior Fina...

Condition: There was a lack of internal controls in place related to the return of Title IV funds. Planned Corrective Action: Director will update academic calendar on COD R2TIV calculator yearly and verify dates and length of breaks are correct. The University will continue to have the Senior Financial Aid Advisor complete R2TIV and the Director will sign off on calculations. Contact person responsible for corrective action: Callie Zake, Senior Director Student Financial Services Anticipated Completion Date: June 30, 2025

View Audit 349964 Questioned Costs: $1

Finding 539401 (2024-001)

Significant Deficiency 2024

University of St. Thomas

MN

Student Financial Aid Reporting Significant Deficiency

Recommendation: CLA recommends the University review its reporting procedures to ensure the students' statuses are accurately reported to NSLDS as required by regulations. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to fin...

Recommendation: CLA recommends the University review its reporting procedures to ensure the students' statuses are accurately reported to NSLDS as required by regulations. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: By reviewing the ordering of internal processes and procedures St. Thomas determined two internal processes ran out of order causing incorrect reporting. Procedural documentation has been updated and training provided to ensure this error is not repeated. Name(s) of the contact person(s) responsible for corrective action: Yuko Kachinsky: yuko.kachinsky@stthomas.edu Planned completion date for corrective action plan: A process error was identified and corrected in August 2024.

View Audit 349948

Finding 539390 (2024-001)

Significant Deficiency 2024

Local Area of the Workforce Development in the Northwest

PR

Matching / Level of Effort / Earmarking

VIEWS OF RESPONSIBLE OFFICIALS The youth committee attached to the Norwest Local Board will compromise a representative from finance, budget and planning staff (youth program and executive) who will measure the achievement of the 20% benchmark on a quarterly basis. This committee will take appropr...

VIEWS OF RESPONSIBLE OFFICIALS The youth committee attached to the Norwest Local Board will compromise a representative from finance, budget and planning staff (youth program and executive) who will measure the achievement of the 20% benchmark on a quarterly basis. This committee will take appropriate actions in order to verify the correctness of the expenditures according to the 20% expense requirement mentioned above. This committee will provide to the Executive Director, recommendations to the operational areas in order to comply to the goal of expenditures required under sections 20 CFR 681.590, 681.00(a)(3) and 681.600 of WIOA. A report will be issue to the operational levels in accordance to the recommendations adopted by the Executive Director. The public policy for the implementation of the work experience element of the youth program gave the opportunity to increase youth service. The Northwest Local Area has established strategies for the dissemination of services for the youth program. This is done through the integration of social networks (fakebook, TikTok, Instagram) radio, signs press, television and official internet page. Employment and Educational Fairs for the Youth Program are being developed to recruit out of school Youth and promote work experience activity. We will continue to join efforts through mass campaigns with an effective strategic plan to outreach the youth program. IMPLEMENTATION DATE Immediately RESPONSIBLE PERSONS Executive Director, Area Executive, Finance Director

View Audit 349939

Finding 539387 (2024-006)

Significant Deficiency 2024

City of Norfolk

VA

Matching / Level of Effort / Earmarking

Internal controls will be established over reporting to the Virginia Department of Education to ensure accuracy of data, to include: · Student enrollment and membership data will be verified by the Department of Assessment, Research and Accountability. · Cost data and other financial information wil...

Internal controls will be established over reporting to the Virginia Department of Education to ensure accuracy of data, to include: · Student enrollment and membership data will be verified by the Department of Assessment, Research and Accountability. · Cost data and other financial information will be verified by the Accounting Department. · Information regarding children with disabilities will be verified by the Department of Learning Support.

View Audit 349937

Finding 539386 (2024-005)

Significant Deficiency 2024

City of Norfolk

VA

Questioned Costs Matching / Level of Effort / Earmarking Internal Control / Segregation of Duties § 200.326

The Department of Public Works, will incorporate the Federal Statement of Compliance form (C-56) within the Technical Specifications section of all federally-funded VDOT project contracts.

View Audit 349937 Questioned Costs: $1

Finding 539374 (2024-002)

Significant Deficiency 2024

Greensboro College, Inc. and Affiliates

NC

Student Financial Aid Reporting Matching / Level of Effort / Earmarking

Contact Person: Travis Mickey, Registrar Views of Responsible Officials and Planned Corrective Action: There is no disagreement with the audit finding. The College will collaborate with NSC to evaluate the errors in the file transmissions and to develop procedures to minimize further errors in ...

Contact Person: Travis Mickey, Registrar Views of Responsible Officials and Planned Corrective Action: There is no disagreement with the audit finding. The College will collaborate with NSC to evaluate the errors in the file transmissions and to develop procedures to minimize further errors in the future. More specifically, the College will review the reporting procedures for withdrawn and graduating students to ensure the correct information is transmitted to NSLDS. Anticipated Completion Date: 6/30/2025

View Audit 349911

Finding 539372 (2024-003)

Material Weakness 2024

Argos Community Schools

IN

Special Tests & Provisions Subrecipient Monitoring Material Weakness § 200.303

Description of Corrective Action Plan: Argos Community Schools will ensure that going forward any construction we have done, funded with federal dollars will be compliant with Davis-Bacon Act Reporting laws and ensure we receive required documentation, as required by Federal Law.

View Audit 349901

Finding 539368 (2024-002)

None 2024

Eastern University

PA

Questioned Costs Student Financial Aid Matching / Level of Effort / Earmarking

Verification Planned Corrective Action: We will periodically review students selected for verification with a status of verification not completed to ensure they did not receive need based federal aid. Person Responsible for Corrective Action Plan: Andrea Ruth, Director of Financial Aid Anticipated...

Verification Planned Corrective Action: We will periodically review students selected for verification with a status of verification not completed to ensure they did not receive need based federal aid. Person Responsible for Corrective Action Plan: Andrea Ruth, Director of Financial Aid Anticipated Date of Completion: 3/22/2025

View Audit 349900 Questioned Costs: $1

Finding 539367 (2024-001)

Significant Deficiency 2024

Eastern University

PA

Questioned Costs Student Financial Aid Matching / Level of Effort / Earmarking

Incorrect Return of Title IV (R2T4) Funds Calculations and Untimely Returns Planned Corrective Action: When this was identified last year, the Director of Financial Aid Office spent the next year working with the Department of Education as they conducted two separate reviews. The first review was c...

Incorrect Return of Title IV (R2T4) Funds Calculations and Untimely Returns Planned Corrective Action: When this was identified last year, the Director of Financial Aid Office spent the next year working with the Department of Education as they conducted two separate reviews. The first review was completed and we were notified that everything was good. The second review recently concluded via an exit interview where we were notified that a final report would be sent to us within the next two months. Additionally, the Director of Financial Aid has been working with the IT department, the Registrar’s Office, and our Academic Technology department to streamline the identification of students who need a R2T4 completed. This has been an ongoing process in the midst of the program reviews and getting clarification and guidance from the Department of Education, coupled with the FAFSA issues, continued to cause further delays with R2T4 calculations. Person Responsible for Corrective Action Plan: Andrea Ruth, Director of Financial Aid Anticipated Date of Completion: 3/22/2025

View Audit 349900 Questioned Costs: $1

Finding 539365 (2024-002)

Significant Deficiency 2024

Portland State University

OR

Student Financial Aid Reporting Matching / Level of Effort / Earmarking

Recommendation: We recommend that the University strengthen its internal controls over reporting student enrollment changes to NSLDS to ensure that enrollment effective dates are reported to NSLDS within 60 days of an enrollment status change and that enrollment is being properly certified every 60 ...

Recommendation: We recommend that the University strengthen its internal controls over reporting student enrollment changes to NSLDS to ensure that enrollment effective dates are reported to NSLDS within 60 days of an enrollment status change and that enrollment is being properly certified every 60 days. Explanation of Disagreement with Audit Finding: There is no disagreement with the audit finding. Action in Response to Finding: Portland State University relies on a third party, National Student Clearinghouse, to report student enrollment status changes to the NSLDS. Fall 2023 and Winter 2024 enrollment certification files were provided to NSC for relay to NSLDS. Despite this, these enrollment files were never provided to NSLDS and as such the students status change, effective September 26, 2023, was not certified within the NSLDS until May 3, 2024. We are researching why these enrollment certification files were never provided to the NSLDS. Name of the Contact Person Responsible for Corrective Action: Nicolle DuPont, Associate Registrar Planned Completion Date for Corrective Action Plan: April 2025

View Audit 349899

Finding 539258 (2024-710)

Significant Deficiency 2024

State of Wisconsin

WI

Student Financial Aid Reporting Subrecipient Monitoring

Planned Corrective Action: The financial aid office will report enrollment of unofficial withdrawals/last date of attendance on NSLDS upon completion of the Return to Title IV calculations and when unofficial withdrawals are reviewed at the end of each term. The Registrar's Office will review NSC G ...

Planned Corrective Action: The financial aid office will report enrollment of unofficial withdrawals/last date of attendance on NSLDS upon completion of the Return to Title IV calculations and when unofficial withdrawals are reviewed at the end of each term. The Registrar's Office will review NSC G (graduated) not applied reports after submitting degree verify files and corrections will be made, if needed, within 30 day period after submission. Anticipated completion date: financial aid has already acted on this beginning Fall 2024. Registrar's office will begin review of "G Not Applied" reportsbeginning Spring 2025. Person responsiblef or correctiveaction: Financial aid MIchelle Lamb, lamb@uwosh.edu, Alison Casady, casadya@uwosh.edu, Julia Bodette, bodettej@uwosh.edu

View Audit 349896

Finding 539257 (2024-709)

Significant Deficiency 2024

State of Wisconsin

WI

Student Financial Aid Reporting Special Tests & Provisions

Planned Corrective Action: As soon as UW-Milwaukee was notified during the LAB review process that enrollment status effective dates were being reported incorrectly, we took action to correct this issue. While a permanent fix to the extract process from PeopleSoft is dependent on Oracle providing a ...

Planned Corrective Action: As soon as UW-Milwaukee was notified during the LAB review process that enrollment status effective dates were being reported incorrectly, we took action to correct this issue. While a permanent fix to the extract process from PeopleSoft is dependent on Oracle providing a reliable solution to the issue or UW-Milwaukee Information Technology rewriting a custom process and therefore outside of the immediate control of the Registrar’s Office, the Registrar’s Office did immediately start using the “mass correction” feature for the 1800 series warnings provided by the NSC. This will result in enrollment status effective dates which fulfil the Department of Education’s requirements. Since utilizing the “mass correction” option increases the amount of time needed to work through NSC error and warning reports, the Registrar’s Office is hopeful that a more permanent reliable solution on the SIS level will be coming in the future. In the meantime, we will continue to utilize the mass correction option to ensure that enrollment status effective dates are only changed if a student’s enrollment status changes, per the Department of Education’s requirements. UW-Milwaukee Registrar’s Office staff reviewed the records of the five individuals that LAB indicated did not have accurate data reported to the NSLDS. We discovered that the data was reported accurately for enrollment status changes, which would result in a change in effective date. However, it appears that the NSLDS roster request schedule differs from UW-Milwaukee’s enrollment reporting schedule to the NSC. UWMilwaukee reports enrollment information to the NSC on the third Tuesday of each month. It looks like the NSLDS does a roster request at the beginning of the third week of each month. We will investigate if it is possible to adjust our NSC submission schedule to move up by one week, so new data should be available for the mid-month NSLDS roster request. Anticipated Completion Date: May 1, 2025 Person responsible for corrective action: Emily Bach, Records Coordinator UW-Milwaukee Registrar’s Office ecbach@uwm.edu

View Audit 349896

Finding 539256 (2024-708)

Significant Deficiency 2024

State of Wisconsin

WI

Student Financial Aid Reporting Subrecipient Monitoring

Planned Corrective Action: UW-Madison’s Office of Student Financial Aid (OSFA) and Registrar’s Office (RO) reviewed the enrollment reporting recommendations cited in Finding 2024-708 and corrected error reports as appropriate. UW-Madison will review procedures to report all changes in student enroll...

Planned Corrective Action: UW-Madison’s Office of Student Financial Aid (OSFA) and Registrar’s Office (RO) reviewed the enrollment reporting recommendations cited in Finding 2024-708 and corrected error reports as appropriate. UW-Madison will review procedures to report all changes in student enrollment accurately, completely, and in a timely manner for all instances that require reporting. OSFA and RO will review and update internal procedures to ensure that the date that a student is unofficially withdrawn is communicated and reported consistently between the National Student Loan Data System (NSLDS) and the National Student Clearinghouse (NSC) as appropriate. Prior to the LAB’s review, UW-Madison discovered and corrected issues relating to program enrollment status in NSC and NSLDS. As of November 2024, updates were made for all retroactive instances using appropriate conferral dates and accurate “G - Graduated” statuses. The long-term solution includes the creation of a “Graduates Only Enrollment” file which includes all students who have been reported as enrolled, not withdrawn in a given term and who have earned their degree in each of UW-Madison’s three degree conferral dates. This enrollment file will trigger an enrollment status update that occurs outside of the automatic NSC process. UW-Madison has updated procedures and now uses the NSC extract process to comply with the NSLDS and NSC reporting procedures for program-level enrollment status effective dates. For the beginning of the Fall 2025 term, UW-Madison will update procedures and extract logic from the student information system to ensure accuracy in the reporting of program begin dates. In the meantime, the RO team has reviewed, tested, and updated the process to ensure previously inaccurate program begin dates are corrected. Anticipated Completion Date: September 30, 2025 Person responsible for corrective action: Beth Warner Registrar Office – Division of Enrollment Mangement beth.warner@wisc.edu

View Audit 349896

Finding 539255 (2024-707)

None 2024

State of Wisconsin

WI

Questioned Costs Subrecipient Monitoring Matching / Level of Effort / Earmarking

Planned Corrective Action: We agree with the finding as to the handling of an inadvertent overpayment, defined as a disbursement inadvertently made to a student after the student ceased attendance but prior to the date of the institution’s determination that the student withdrew, and the requirement...

Planned Corrective Action: We agree with the finding as to the handling of an inadvertent overpayment, defined as a disbursement inadvertently made to a student after the student ceased attendance but prior to the date of the institution’s determination that the student withdrew, and the requirement that they be included in a Return of Title IV Aid calculation as aid that could have been disbursed rather than aid that was disbursed. Furthermore if the inadvertent overpayment could not have been made as a late disbursement under federal regulations, the entire amount of the overpayment must be returned. As of the date below and moving forward when a Title IV aid recipient officially withdraws and when a Title IV aid recipient withdraws without notification (an unofficial withdrawal as was the case with the finding), the date of disbursement for each aid type will be reviewed in relation to the date of the student’s ceasing attendance. This will determine how each aid type is treated within the calculation in line with policy addressed in the paragraph above. Appropriate action as to each aid type will be taken at the time of processing the Return of Title IV Aid calculation. Anticipated Completion Date: March 15, 2025 Person responsible for corrective action: Name, Title: William Trippett, Financial Aid Director Email address: trippetw@uww.edu

View Audit 349896 Questioned Costs: $1

Finding 539254 (2024-706)

Significant Deficiency 2024

State of Wisconsin

WI

Questioned Costs Subrecipient Monitoring Significant Deficiency

Item One: Establishing Attendance 1. The Registrar’s Office will inform the Financial Aid and Scholarships Office of approved retroactive withdrawals. 2. Financial Aid and Scholarships office staff have been added to the academic calendar group, so we are aware of changes as they are made. 3. Provos...

Item One: Establishing Attendance 1. The Registrar’s Office will inform the Financial Aid and Scholarships Office of approved retroactive withdrawals. 2. Financial Aid and Scholarships office staff have been added to the academic calendar group, so we are aware of changes as they are made. 3. Provost and College Deans are now ensuring 100% completion of attendance rosters from faculty. 4. We will look more closely at students with withdrawal dates in the first week of the term to ensure they established attendance. 5. We will investigate more automated ways to monitor both establishing attendance as well as retroactive changes. Item Two: Calculation of Days in the Term We have implemented a semesterly meeting, including multiple people, to review the calendar together to determine the number of days in the term. Anticipated Completion Date: Item One: Establishing Attendance 1. Completed February 2025 2. Completed February 2025 3. Completed September 2024 4. In Progress a. Written policies completed February 2025. b. The next time this practice will be done is June 2025. 5. In Progress a. Determine current options and implement if there are automated ways to monitor by September 2025. Item Two: Calculation of Days in the Term Complete. First meeting held 2/12/2025 Person responsible for corrective action: Melissa Haberman Director, Financial Aid and Scholarships University of Wisconsin - Platteville Platteville, Wisconsin habermanm@uwplatt.edu

View Audit 349896 Questioned Costs: $1

Finding 539253 (2024-705)

Significant Deficiency 2024

State of Wisconsin

WI

Questioned Costs Subrecipient Monitoring Significant Deficiency

Planned Corrective Action: Module R2T4 date determination corrective action: Updated module R2T4 procedures to assist in determination of dates to be included in the R2T4 calculation. Complete recalculation for impacted 23-24 audit students, and review others in similar programs for updates by Revie...

Planned Corrective Action: Module R2T4 date determination corrective action: Updated module R2T4 procedures to assist in determination of dates to be included in the R2T4 calculation. Complete recalculation for impacted 23-24 audit students, and review others in similar programs for updates by Review withdrawals in terms/programs taught in modules for 24-25 for accuracy in determining correct end dates and charges used in determining withdrawal. Withdrawal Timing Updated R2T4 procedures to include quick review of timing of the disbursement of funds versus the students recorded withdrawal date. Anticipated Completion Date: March 2025 Person responsible for corrective action: Kristina Klemens Director of Scholarships and Financial Aid Name Title Jamie Thomas Financial Aid Business Analyst-Operations and Compliance Name Title Financial Aid/Enrollment Management Division or Unit (if applicable) Kristina Klemens: klemens@uwp.edu Email address Jamie Thomas: thomsonj@uwp.edu Email address

View Audit 349896 Questioned Costs: $1

Finding 539252 (2024-704)

Significant Deficiency 2024

State of Wisconsin

WI

Questioned Costs Student Financial Aid Subrecipient Monitoring

Interim corrective actions: These cases involved situations where students dropped courses before withdrawing (officially or unofficially) from all courses. UW-River Falls did not have a system in place to review course participation for courses which students dropped prior to withdrawal, although i...

Interim corrective actions: These cases involved situations where students dropped courses before withdrawing (officially or unofficially) from all courses. UW-River Falls did not have a system in place to review course participation for courses which students dropped prior to withdrawal, although it has procedures in place to review course participation for enrolled courses at the time of withdrawal and when students are assigned failing grades. For Fall Semester 2024: Existing procedures: 1. Official withdrawals: Students officially withdrawing from the University must complete an electronic form which collects instructor verification of course participation. The Financial Aid office receives this form once it has been processed by the Registrar’s office. Students reported as not having participated in courses have their financial aid adjusted prior to calculating a return to Title IV funds. 2. Unofficial withdrawals: Instructors assigning failing grades to students must report student’s course participation or non-participation and, if available, a last date of course participation. Following the grading deadline, a report listing all students who never participated in classes is run and students found to have failed courses due to non-participation have their financial aid adjusted prior to calculating a return to Title IV funds. Additional procedure instituted: 3. Learning management system review: Students who withdraw (officially or unofficially) and who dropped courses prior to withdrawing had their dropped courses reviewed in the Learning Management System (LMS). Students who submitted assignments as recorded in the system were determined to have begun participation in the course. Students who submitted no assignments were determined to not have participated in the course and financial aid was adjusted prior to calculating a return to Title IV funds. For Spring Semester 2025: Existing procedures: 1. Procedures 1,2, and 3 from Fall Semester 2024 continue to be employed for Spring semester 2025. Additional procedures: 2. Expanding the LMS review to Pell grant students with dropped courses: Students with disbursed Pell Grants who drop courses after the Pell grant census date now have these courses reviewed to determine if the student began attendance before dropping the course, using the same procedure as #3 above.Instructor course participation verification: After the 3rd week of classes for Spring 2025, UWRiver Fall requested that instructors report students who had not begun participation in their courses. This report is currently being reviewed and students with Pell grants will be evaluated to determine if an adjustment to the student’s enrollment intensity is needed to ensure that the disbursed Pell grant is accurate. Student who have begun participation in no enrolled courses will be reviewed for possible return of all Title IV funds. Future additional corrective actions: 1. UW-River Falls will pursue making course participation verification by instructors during the first month of the semester an administrative policy and develop formal procedures for surveying instructors and reporting students found to not have begun participation in a course or courses to the Financial Aid office for adjustments to their disbursed Title IV aid. 2. UW-River Falls will pursue adding an instructor course participation step to the course drop form currently in use by the Registrar’s office. Anticipated Completion Date: Interim actions were implemented in September 2024 and February 2025. Permanent action expected by Spring 2026. Person(s) responsible for corrective action: Cindy Holbrook, Executive Director of Enrollment Management Cindy.Holbrook@uwrf.edu 715-425-3500 Robert Bode, Director of Financial Aid and Military/Veterans Resource Center Robert.Bode@uwrf.edu 715-425-3141 Kelly Browning, University Registrar Kelly.Browning@uwrf.edu 715-425-3342 Responsible Unit Division of Enrollment Mangagement

View Audit 349896 Questioned Costs: $1

Finding 539251 (2024-703)

Significant Deficiency 2024

State of Wisconsin

WI

Questioned Costs Subrecipient Monitoring Significant Deficiency

Planned Corrective Action: UW-Madison’s Office of Student Financial Aid (OSFA) reviewed the return of fund calculations cited in Finding 2024-703 and returned funds as appropriate. OSFA will review internal procedures to ensure accuracy and timely completion of the return of funds process. As a proa...

Planned Corrective Action: UW-Madison’s Office of Student Financial Aid (OSFA) reviewed the return of fund calculations cited in Finding 2024-703 and returned funds as appropriate. OSFA will review internal procedures to ensure accuracy and timely completion of the return of funds process. As a proactive measure, UW-Madison is establishing a new position focused on compliance and training within OSFA. This individual will oversee key compliance areas in Title IV administration, including R2T4 calculations and the unofficial withdrawal process. The new position will conduct quality assurance reviews at the end of each term to identify and address any weaknesses in the R2T4 and other administrative processes. Any concerns will be remedied within the required timeframe, and staff will receive training on the relevant policies and procedures. Additionally, two OSFA team members are registered to attend National Association of Student Financial Aid Administrators’ (NASFAA) online Return of Title IV Funds five-week course in April 2025. This training will inform any necessary updates to OSFA’s policies and procedures related to official and unofficial withdrawals. Anticipated Completion Date: June 30, 2025 Person responsible for corrective action: Shane Maloney, Associate Director of Financial Aid Office of Student Financial Aid - Division of Enrollment Mangement shane.maloney@wisc.edu

View Audit 349896 Questioned Costs: $1

Finding 539250 (2024-700)

Significant Deficiency 2024

State of Wisconsin

WI

Student Financial Aid Reporting Significant Deficiency

Planned Corrective Action: Financial Aid will continue to reconcile Direct Loans and the Federal Pell Grant programs with the Department of Education through the Common Origination and Disbursement system. The loan coordinator and Pell Grant manager will confirm SIS amounts reconcile with WISER mont...

Planned Corrective Action: Financial Aid will continue to reconcile Direct Loans and the Federal Pell Grant programs with the Department of Education through the Common Origination and Disbursement system. The loan coordinator and Pell Grant manager will confirm SIS amounts reconcile with WISER monthly, at minimum. If there are any discrepancies, the Controller will be contacted to assist with internal reconciliation of funds. Anticipated Completion Date: Will begin corrective action Spring 2025 Person responsible for corrective action: Alison Casady, Director of Financial Aid; casadya@uwosh.edu In conjunction with Direct Loan coordinator: Ashley Hass; hassa@uwosh.edu Pell Grant program manager: Elizabeth Bloedow; bloedowe@uwosh.edu Controller: Mai Lee; Financial Services; leemai@uwosh.edu

View Audit 349896

Finding 539204 (2024-101)

Significant Deficiency 2024

State of Wisconsin

WI

Subrecipient Monitoring Reporting Significant Deficiency

Planned Corrective Action: The Wisconsin Department of Administration (DOA) is committed to accountability and transparency in federal award administration, as is the objective of Federal Funding Accountability and Transparency Act (FFATA) reporting under 2 CFR s. 170. Accordingly, in March 2024, in...

Planned Corrective Action: The Wisconsin Department of Administration (DOA) is committed to accountability and transparency in federal award administration, as is the objective of Federal Funding Accountability and Transparency Act (FFATA) reporting under 2 CFR s. 170. Accordingly, in March 2024, in response to the auditor’s finding and recommendations, DOA inquired to the Office of Management and Budget (OMB) for clarification on the requirements for reporting subaward modifications in the FFATA Subaward Reporting System (FSRS). OMB’s response indicated that DOA should “use the total amount after adjusted,” which was DOA’s practice at the time and thus, was maintained. In February 2025, DOA became aware of U. S. General Services Administration (GSA) knowledge base article titled, “Five tips for accurate FFATA* subaward reporting”, published at the Federal Service Desk (fsd.gov). The article states, “When you modify a subaward, update the original report with the new information. If you modify the amount, replace the original amount with the new amount.” In response to that guidance, DOA updated its guidance to state agencies effective March 2025. DOA’s updated guidance also incorporated changes resulting from GSA’s February 27, 2025, announcement that FSRS.gov would be retired on March 6, 2025, and subaward reporting transitioned to SAM.gov effective March 8, 2025. State agencies were provided training regarding the updated guidance on March 6, 2025. Anticipated Completion Date: March 31, 2025 Person responsible for corrective action: Dustin Trickle, Executive Policy & Budget Manager State Budget Office Division of Executive Budget & Finance dustin.trickle1@wisconsin.gov

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