Corrective Action Plans

Finding 524713 (2024-001)

Significant Deficiency 2024

VT

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

Recommendation: We recommend the University review current processes for reporting to NSLDS and implement procedures to ensure submissions are reported timely and accurately. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response t...

Recommendation: We recommend the University review current processes for reporting to NSLDS and implement procedures to ensure submissions are reported timely and accurately. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The errors noted in the finding resulted from a missing step in the reconciliation process. Until recently the Registrar’s office relied on an error report from NSC to help identify any issues that might be noted in the student files. The findings noted, reenforced that this process alone was not sufficient to capture all errors. To ensure that these types of errors do not reoccur, subsequently, the registrars office team has initiated an additional monthly reconciliation between the NSLDS and internal student management system. This reconciliation will show any status variance or date mismatches. Any variances noted will be updated in the NSC/NSLDS system. Name(s) of the contact person(s) responsible for corrective action: Sarah Harris, Director, Office of Financial Aid Planned completion date for corrective action plan: December 2024

View Audit 344144

Finding 524695 (2024-001)

None 2024

Wilkes University

PA

Student Financial Aid Special Tests & Provisions Matching / Level of Effort / Earmarking

Management agrees with the finding and recommendation. The University will implement a process that ensures notification from the Registrar when a student drops from any course or from the University. A review of R2T4 will be completed at that time if deemed necessary. The process will be reviewed a...

Management agrees with the finding and recommendation. The University will implement a process that ensures notification from the Registrar when a student drops from any course or from the University. A review of R2T4 will be completed at that time if deemed necessary. The process will be reviewed annually by the University to ensure compliance.

View Audit 344126

Finding 524678 (2024-003)

Significant Deficiency 2024

La Salle University

PA

Student Financial Aid Significant Deficiency Matching / Level of Effort / Earmarking

Student Financial Assistance Cluster - Assistance Listing No. 84.038 Recommendation: We recommend the University evaluate its procedures and policies around recordkeeping and record retention. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action tak...

Student Financial Assistance Cluster - Assistance Listing No. 84.038 Recommendation: We recommend the University evaluate its procedures and policies around recordkeeping and record retention. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: We have contracted with RPK, a leading higher educating consulting firm who has been assisting us with examining our systems, practices, policies, and procedures. We have reorganized the student accounts receivable functions into a seamless student financial service and created a student financial operations backend where all database maintenance, automation, processing, and audits are being coordinated by a team separate from those servicing students directly. We have replaced all ineffective staff members including those who oversaw the record keeping process based on the support and recommendations of RPK, and are completing audits of all files, current and past, in a manual review of all cabinets to correctly alphabetize and organize. Name(s) of the contact person(s) responsible for corrective action: Michele McDevitt, Assistant Vice President, Student Financial Services Planned completion date for corrective action plan: Summer 2025

View Audit 344109

Finding 524677 (2024-002)

Significant Deficiency 2024

La Salle University

PA

Reporting Student Financial Aid Significant Deficiency

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 : Like many US institutions, La Salle contractually relies on the National Student Clearinghouse (NSC) to conduct its enrollment reporting to NSLDS. In order to comply with established regulations, we set up an Enrollment Reporting Submission Schedule with the NSC. La Salle's schedule for 2025 is below: Term Begin Date Term End Date Transmission Type : Schedule Transmission Date Received Date Transmission Status 1/ 13/ 2025 5/ 9/ 2025 F rst of Term 1/ 31/ 2025 1/ 31 /2 25 Edtts Comp eted 1/13/ 2025 5/9/2025 Subsequent of - erm 2/ 17/ 2025 Not Yet Rece ed 1/ 13/ 2025 5/ 9/ 2025 Subsequent of Term 3/ 17/ 2025 Not Yet Rece'ved 1/ 13/ 2025 5/ 9/ 2 25 Subsequent of-erm t./ 15/ 2025 Not Yet Rece'ved 1/ 13/ 2025 5_/9/ 2025 Subsequent of -e,m 5/ 20/ 2025 Not Yet Rece v ed 5/ 19/ 2025 8/ 22/ 2025 Sumr,er F,r;.: 6/ 3/ 2025 Not Yet Rece ved 5/ 19/ 2025 8/ 22/2025 Summer Subsequent 7/ 9/ 2025 Not Yet Recewed 5/ 19/ 2025 8/ 22/ 2025 Sumr,er Subsequent 8/ 13/ 2025 Not Yet Recev ed 8/ 25/ 2025 12/ 13/2025 F rst of Terr, 9/ 23/ 2025 Not Yet Rece'ved 8/ 25/ 2025 12/13/ 2025 Subsequent of Term 10/ 28/ 2025 Not Yet ReceiVed 8/ 25 / 2025 12/ 13/ 2::>25 Subsequent of-erm 11/ 15/ 2025 Not Yet Rece·ved 8/ 25/ 2025 12/ 13/ 2025 Subsequent of-erM 12/16/ 2025 Not vet Receved Adherence to this reporting schedule would ensure timely reporting, as the NSC subsequently transmits data monthly to NSLDS, throughout the academic year, well within the requirement to report student enrollment status at least every 60 days. Our Associate Registrar for Academic Information Systems is specifically charged with maintaining, executing, and adhering to this schedule, as part of the routine duties assigned to that position in our office. Regarding accuracy, data structures are defined in our BANNER database to classify a given student's enrollment status in a given semester as full, three-quarter, half, or less-than-half time, and withdrawn. Those structures are long-established by student level (graduate, undergrad, doctoral), and do not change from semester to semester. BANNER processes extract the registration data and its timing, in light of those definitions and the data is formatted for transmission to the NSC as prescribed. Sound data entry practices have been established to make certain dates associated with those statuses, and the transition of a student within them, are accurately recorded. Consequently, we rely on the BANNER NSC extract, and the NSC's reporting relationship with NSLDS to accurately transmit that data accordingly. The NSC does work with us to rectify or resolve any seemingly inconsistent or incorrect data, based on prior transmissions and current regulations, prior to committing the given enrollment extract to the NSC database for our institution. They help us stay in compliance and consistent on both the campus-level and program-level basis upon which we're required to report. Name(s) of the contact person(s) responsible for corrective action: Gerard Donahue, Registrar Planned completion date for corrective action plan: Corrected as of Fall 2024

View Audit 344109

Finding 524659 (2024-001)

Material Weakness 2024

University of Southern Indiana

IN

Student Financial Aid Internal Control / Segregation of Duties Matching / Level of Effort / Earmarking § 200.303

FINDING 2024-001 Finding Subject: Student Financial Assistance Cluster - Special Tests and Provisions - Verification Summary of Finding: The University had designed a key control that one employee would perform the required verifications, and a second employee would then review a sample of those ver...

FINDING 2024-001 Finding Subject: Student Financial Assistance Cluster - Special Tests and Provisions - Verification Summary of Finding: The University had designed a key control that one employee would perform the required verifications, and a second employee would then review a sample of those verifications. However, the control was not properly implemented or operating effectively as the University had not established proper segregation of duties. The same employee was responsible for performing and reviewing verifications during the audit period without an independent oversight, review, or approval process involving a second employee. Contact Person Responsible for Corrective Action: Joanna Riney, Director of Student Financial Assistance Contact Phone Number and Email Address: 812-465-7049; jriney@usi.edu Views of Responsible Officials: We concur with the finding. While the University of Southern Indiana had internal controls in place to prevent aid from disbursing before verification was marked complete and assigned responsibility for verification processing to a well-trained employee with 20 years of verification processing experience, staff vacancies in the department in addition to training and preparation for vast changes in application, award calculation, and system controls for the 2024-2025 aid year limited the ability to conduct an independent review on a sample of students for which verification had been performed. Given the fact that there were very minimal changes to the verification process from the verification process performed in the last several years, in lieu of an independent review, management determined that for the 2023-2024 aid year, utilizing an after-the-fact review on a sample of completed verifications by the employee performing the verification, to review/double-check the verification procedures, provided reasonable assurance that compliance would be achieved. No instances of non-compliance in verification procedures were detected in the audit. Description of Corrective Action Plan: Staffing levels are returning to normal and new staff have a more complete understanding of overall financial aid including the verification process. Also, the Department of Education has provided additional clarification and guidance for all 2024-2025 processing and reduced the number of students selected for verification, allowing management the ability to resume the performance of an independent review on a sample of students for which verification had been performed. Anticipated Completion Date: The independent review was reinstated effective for verifications performed in Fall 2024 and going forward.Per Uniform Guidance: 2 CFR § 200.511(a) – “The auditee is responsible for follow-up and corrective action on all audit findings. . .The auditee must also prepare a corrective action plan for current year audit findings. . .􀀃The corrective action plan and summary schedule of prior audit findings must include findings relating to the financial statements which are required to be reported in accordance with GAGAS. ” 2 CFR § 200.511(c) – “At the completion of the audit, the auditee must prepare, in a document separate from the auditor's findings described in § 200.516, a corrective action plan to address each audit finding included in the current year auditor's reports. The corrective action plan must provide the name(s) of the contact person(s) responsible for corrective action, the corrective action planned, and the anticipated completion date. If the auditee does not agree with the audit findings or believes corrective action is not required, then the corrective action plan must include an explanation and specific reasons.”

View Audit 344100

Finding 524649 (2024-007)

Significant Deficiency 2024

Eureka College

IL

Student Financial Aid Special Tests & Provisions Significant Deficiency

2024-007 - Student Financial Aid Cluster - (a) Federal Pell Grant (b) Federal Supplemental Educational Opportunity Grant (c) Federal Work Study Grant (d) Federal Perkins Loan Program (e) Federal Direct Student Loans (f) Teacher education Assistance for College and Higher Education ALN No. (a) 84.063...

2024-007 - Student Financial Aid Cluster - (a) Federal Pell Grant (b) Federal Supplemental Educational Opportunity Grant (c) Federal Work Study Grant (d) Federal Perkins Loan Program (e) Federal Direct Student Loans (f) Teacher education Assistance for College and Higher Education ALN No. (a) 84.063 (b) 84.007 (c) 84.033 (d) 84.038 (e) 84.268 (f) 84.379 - Year Ended June 30, 2024. Condition: The College did not complete monthly reconciliations for Direct Loan funds. We consider this condition to be a significant deficiency in internal control over compliance relating to the Special Tests and Provisions compliance requirement. Management Response: Management agrees with the finding Corrective Action Plan: JFA deletes prior reconciliation reports. Separate file location on the cloud has been created to hold these monthly reconciliation files. Corresponding reconciliation within Sonis (see above corrective action plan for excess cash) will also occur. Responsible Person: Tim Marten and Beth Collingwood Implementation Date: 7/01/2024

View Audit 344088

Finding 524647 (2024-006)

Significant Deficiency 2024

Eureka College

IL

Questioned Costs Student Financial Aid Special Tests & Provisions

2024-006 - Student Financial Aid Cluster - (a) Federal Pell Grant (b) Federal Supplemental Educational Opportunity Grant (c) Federal Work Study Grant (d) Federal Perkins Loan Program (e) Federal Direct Student Loans (f) Teacher education Assistance for College and Higher Education ALN No. (a) 84.063...

2024-006 - Student Financial Aid Cluster - (a) Federal Pell Grant (b) Federal Supplemental Educational Opportunity Grant (c) Federal Work Study Grant (d) Federal Perkins Loan Program (e) Federal Direct Student Loans (f) Teacher education Assistance for College and Higher Education ALN No. (a) 84.063 (b) 84.007 (c) 84.033 (d) 84.038 (e) 84.268 (f) 84.379 - Year Ended June 30, 2024. Condition: The College did not timely and accurately complete refund calculations in the Spring. In review of the Spring 2024 calculations the number of days in the break was not calculated correctly, resulting in the incorrect days in all Spring 2024 return of Title IV funds calculations. As a result of the incorrect number of days, the amounts of Title IV amounts returned for all withdrawn students were incorrectly calculated for 4 out of the population of 6 (67%) Spring withdrawal calculations as two students had attended over 60% of the semester for bot the original and updated calculations and as such, no return was required. A sample of Fall withdrawal calculations identified no errors. We consider this finding to be a significant deficiency in relation to Special Tests and Provisions. Statistical sampling was not used in making sample selections. Management Response: Management agrees with the finding Corrective Action Plan: JFA did not accurately include days of breaks for Spring Break. A manual R2T4 calculation is in place to catch errors in the days in a semester. Responsible Person: Tim Marten Implementation Date: 7/01/2024

View Audit 344088 Questioned Costs: $1

Finding 524641 (2024-005)

None 2024

Eureka College

IL

Student Financial Aid Reporting Matching / Level of Effort / Earmarking

2024-005 - Student Financial Aid Cluster - (a) Federal Pell Grant (b) Federal Supplemental Educational Opportunity Grant (c) Federal Work Study Grant (d) Federal Perkins Loan Program (e) Federal Direct Student Loans (f) Teacher education Assistance for College and Higher Education ALN No. (a) 84.063...

2024-005 - Student Financial Aid Cluster - (a) Federal Pell Grant (b) Federal Supplemental Educational Opportunity Grant (c) Federal Work Study Grant (d) Federal Perkins Loan Program (e) Federal Direct Student Loans (f) Teacher education Assistance for College and Higher Education ALN No. (a) 84.063 (b) 84.007 (c) 84.033 (d) 84.038 (e) 84.268 (f) 84.379 - Year Ended June 30, 2024. Condition: The College did not submit the Fiscal Operations Report (FISAP) on or before the specified deadline of September 30, 2023. We consider this condition to be an instance of noncompliance relating to the Reporting compliance requirement. Management Response: Management agrees with the finding Corrective Action Plan: FISAP will be completed by September 15th each year. Plan is in place to ensure access to a wet signature. Prior late submission was due to staffing change and rejected application. Responsible Person: Tim Marten and Michael Bauman Implementation Date: 7/01/2024

View Audit 344088

Finding 524640 (2024-004)

None 2024

Eureka College

IL

Student Financial Aid Eligibility Matching / Level of Effort / Earmarking

2024-004 - Student Financial Aid Cluster - (a) Federal Pell Grant (b) Federal Supplemental Educational Opportunity Grant (c) Federal Work Study Grant (d) Federal Perkins Loan Program (e) Federal Direct Student Loans (f) Teacher education Assistance for College and Higher Education ALN No. (a) 84.063...

2024-004 - Student Financial Aid Cluster - (a) Federal Pell Grant (b) Federal Supplemental Educational Opportunity Grant (c) Federal Work Study Grant (d) Federal Perkins Loan Program (e) Federal Direct Student Loans (f) Teacher education Assistance for College and Higher Education ALN No. (a) 84.063 (b) 84.007 (c) 84.033 (d) 84.038 (e) 84.268 (f) 84.379 - Year Ended June 30, 2024. Condition: One of the 40 student files (2.5%) we examined, we noted the students were not properly awarded Pell grants. Management Response: Management agrees with the finding Corrective Action Plan: Pell calculations are automatic as part of JFA. Any manual changes to Pell grant amounts will be documented on the student file to justify differing amounts. The only way an amount should differ is if a student is close to their SULA and/or less than full time. Responsible Person: Tim Marten Implementation Date: 7/01/2024

View Audit 344088

Finding 524639 (2024-003)

None 2024

Eureka College

IL

Questioned Costs Student Financial Aid Cash Management

2024-003 - Student Financial Aid Cluster - (a) Federal Pell Grant (b) Federal Supplemental Educational Opportunity Grant (c) Federal Work Study Grant (d) Federal Perkins Loan Program (e) Federal Direct Student Loans (f) Teacher education Assistance for College and Higher Education ALN No. (a) 84.063...

2024-003 - Student Financial Aid Cluster - (a) Federal Pell Grant (b) Federal Supplemental Educational Opportunity Grant (c) Federal Work Study Grant (d) Federal Perkins Loan Program (e) Federal Direct Student Loans (f) Teacher education Assistance for College and Higher Education ALN No. (a) 84.063 (b) 84.007 (c) 84.033 (d) 84.038 (e) 84.268 (f) 84.379 - Year Ended June 30, 2024. Condition: Three of the 40 student files (7.5%) we examined, we noted the students were not properly awarded Direct loans. We consider this condition to be an instance of noncompliance relating to the Eligibility compliance and is part a repeat finding shown in Section IV of this report as prior year finding 2023-003. Management Response: Management agrees with the finding Corrective Action Plan: Loan calculations are automatic as part of JFA. Any manual changes to these loan amounts will be documented on the student file to justify differing amounts. Responsible Person: Tim Marten Implementation Date: 7/01/2024

View Audit 344088 Questioned Costs: $1

Finding 524638 (2024-002)

Significant Deficiency 2024

Eureka College

IL

Student Financial Aid Special Tests & Provisions Significant Deficiency

2024-002 - Student Financial Aid Cluster - (a) Federal Pell Grant (b) Federal Supplemental Educational Opportunity Grant (c) Federal Work Study Grant (d) Federal Perkins Loan Program (e) Federal Direct Student Loans (f) Teacher education Assistance for College and Higher Education ALN No. (a) 84.063...

2024-002 - Student Financial Aid Cluster - (a) Federal Pell Grant (b) Federal Supplemental Educational Opportunity Grant (c) Federal Work Study Grant (d) Federal Perkins Loan Program (e) Federal Direct Student Loans (f) Teacher education Assistance for College and Higher Education ALN No. (a) 84.063 (b) 84.007 (c) 84.033 (d) 84.038 (e) 84.268 (f) 84.379 - Year Ended June 30, 2024. Condition: The College did not report actual loan disbursement dates to the COD system for 4 of 40 students in the sample (10%). We consider this condition to be a significant deficiency of internal control over compliance relating to the Special Tests and Provisions compliance and is part a repeat finding shown in Section IV of this report as prior year finding 2023-003. Statistical sampling was not used in making sample selections. Management Response: Management agrees with the finding Corrective Action Plan: Implementation of a newer process based on the system and program defaults in Jenzabar Financial Aid. Will use posted dates in Sonis to ensure they match COD within the 3-day regulatory requirement. New reporting usages of SAS loan files will be checked in Sonis to ensure matching disbursement dates. Responsible Person: Tim Marten and Beth Collingwood Implementation Date: 7/01/2024

View Audit 344088

Finding 524632 (2024-001)

None 2024

Bellarmine University

KY

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

Bellarmine University agrees with the auditors’ finding and recommendations. The following corrective action will be taken: The University will return $1,779 in federal student financial aid to the United States Department of Education (USED) which represents the updated R2T4 accounting for the corr...

Bellarmine University agrees with the auditors’ finding and recommendations. The following corrective action will be taken: The University will return $1,779 in federal student financial aid to the United States Department of Education (USED) which represents the updated R2T4 accounting for the correct withdrawal dates in the Spring 2024 semester. There will be an additional review process that will include validation from financial and student accounts to verify calculations before finalizing returns of funds. Financial Aid will provide an additional R2T4 form that has date of determination and LDA. Financial Aid will review that all dates and calculations match after the R2T4 has been completed and before handing off to student accounts. Student accounts will then review to confirm all dates and amounts match before processing the return of funds. April Tretter, Director of Financial Aid, expected implementation date 2.26.25.

View Audit 344071 Questioned Costs: $1

Finding 524630 (2024-004)

Significant Deficiency 2024

Keystone College

PA

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

Management will implement a thorough review process of calculations to ensure proper dates are being used. Additionally, management will review update routines and communication of student enrollment status to ensure timely cacluation and return of any unearned portion of grant or loan funds to the...

Management will implement a thorough review process of calculations to ensure proper dates are being used. Additionally, management will review update routines and communication of student enrollment status to ensure timely cacluation and return of any unearned portion of grant or loan funds to the appropriate Title IV program in accordance with federal regulations.

View Audit 344059 Questioned Costs: $1

Finding 524609 (2024-003)

Significant Deficiency 2024

Marymount University

VA

Student Financial Aid Matching / Level of Effort / Earmarking Internal Control / Segregation of Duties

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 reporting procedures to ensure that enrollment and program information is accurately reported to NSLDS as required by regulations. Explanatio...

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 reporting procedures to ensure that enrollment and program information is 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: The findings stemmed from how the Student Information System (SIS) transmitted graduation dates and the accuracy of submission files. Our previous SIS was unable to determine the correct graduation dates, leading to incorrect data uploads to the National Student Clearinghouse (NSC). We reviewed the NSC error report and made individual corrections. Unfortunately, we missed the data transmission at the beginning of the month and had to wait for the corrections to be sent to the National Student Loan Data System (NSLDS) the following month. Additionally, we did not conduct a comprehensive review of the file to ensure that all data matched after the upload. Marymount has transitioned to a new SIS starting in Fall 2024. We are working closely with the NSC during this transition to provide more timely and accurate data. We have also improved our processes by having multiple staff members review data files before posting them to the NSC, ensuring that every data point is correct. Furthermore, we have joined user groups related to our SIS and NSC reports to stay informed about changes made by the SIS vendor and to be aware of potential complications faced by other universities. Any errors identified during the data upload to the NSC will be corrected within 2-3 business days. This process will ensure that the enrollment status is certified within 60 days and that all dates match. If we are unable to update the NSC before the file is submitted to the NSLDS, we will collaborate with our Financial Aid department to manually update the NSLDS. Name(s) of the contact person(s) responsible for corrective action: Courtney Carey, University Registrar, 703-284-1523 Planned completion date for corrective action plan: March 2025

View Audit 344056

Finding 524605 (2024-001)

Significant Deficiency 2024

Local Area of the Workforce Development in the Northeast

PR

Matching / Level of Effort / Earmarking Subrecipient Monitoring Period of Performance

Our Agency has included activities as a joint force’s initiative with other agencies and entities in an outreach task. We have been authorized to use the distribution waiver of percentages to have a better or bigger span for our youth populations. We also signed a memorandum of understanding with at...

Our Agency has included activities as a joint force’s initiative with other agencies and entities in an outreach task. We have been authorized to use the distribution waiver of percentages to have a better or bigger span for our youth populations. We also signed a memorandum of understanding with attractive entities like the PR National Guard and have planned activities reaching youth from school programs to communities without school youths. Our alliances with DDEC, Azore and the Department of Education will contribute to an increase in youth program expenses. We have strategically created an initiative that targets in-school youths where we’ll provide workshops focused on elevating their skills and creating real-time experiences. The memorandum we have with the Department of Education has facilitated this strategy. The Individual Training account (ITA) program will also be promoted in our school district to identify candidates with barriers that can be served through our program. As part of our outreach strategy, we plan to visit foster homes alongside the Department of the Family, which we have signed a memorandum to target this group of disadvantaged youths, as well as projects we have signed with the vocational schools in our district providing real time and paid work experience. With the nine municipalities comprising our area will develop summer work experience targeting our in-and-out school youth (TSY, OSY) populations. The estimated expenses for these initiatives, based on last year's outcome, will reach the goal parameters of programs under WIOA Act. IMPLEMENTATION DATE June 2025 RESPONSIBLE PERSONS Budget Director, Executive Director, Directors of Programmatic and Operations

View Audit 344044

Finding 524579 (2024-002)

Significant Deficiency 2024

Saint Mary's University of Minnesota

MN

Student Financial Aid Reporting Significant Deficiency

Student Status Changes Condition The change in student status for 8 of 25 students tested was not reported to the National Student Loan Data System (NSLDS) within 30 days or included in a response to a roster file within 60 days. However, the students were ultimately reported to the NSLDS. Correc...

Student Status Changes Condition The change in student status for 8 of 25 students tested was not reported to the National Student Loan Data System (NSLDS) within 30 days or included in a response to a roster file within 60 days. However, the students were ultimately reported to the NSLDS. Corrective Action Plan: The institution launched the Jenzabar student information system in July 2023. As part of this transition, institution discontinued our branch with the National Student Clearinghouse (NSC). This closure led to recurring reporting errors each month as the NSC worked to correct the branch closure data. Currently, one person is responsible for submitting the university's monthly enrollment and degree verification reports. There has been a significant learning curve as the instruction worked to address NSC errors, Jenzabar implementation errors, Jenzabar processes, and our own SMU practices. The learning was complemented by the work to file the FVT/GE reporting in fall 2024. Starting January 1, 2025, the institution has updated processes to minimize the need for secondary reviews of reported graduations at NSC. The institution implemented a tracking system to identify situations that consistently lead to errors in the graduation reporting process. The financial aid department has been provided access to NSC to review and address errors needing to be fixed directly in NSLDS. The financial aid department will audit reports of graduates in NSLDS against those submitted through NSC. The financial aid team will partner with registrar on corrections and evaluate if access to NSLDS for members of the registrar team would also make sense.

View Audit 344025

Finding 524574 (2024-001)

None 2024

Saint Mary's University of Minnesota

MN

Student Financial Aid Matching / Level of Effort / Earmarking HUD Housing Programs

Return of Title IV Funds Condition The federal aid refunds for one of the students tested was not returned within 45 days from the withdrawal date. Corrective Action Plan: The intuition has since resolved these issues and have reports and practices in place to monitor and preform R2T4s. The fin...

Return of Title IV Funds Condition The federal aid refunds for one of the students tested was not returned within 45 days from the withdrawal date. Corrective Action Plan: The intuition has since resolved these issues and have reports and practices in place to monitor and preform R2T4s. The financial aid office is now staffed with a qualified director that is able to monitor and preform R2T4s in a timely manner. There was also a deficiency with getting accurate information from the new student information system, Jenzabar that did cause issues with identifying student drops. The director has worked with the IT department in developing a report that is ran on a weekly basis to catch all changes to enrollment. More staff in the coming year will be trained on how to preform R2T4s so that there will be more than one person qualified to preform R2T4s for the institution.

View Audit 344025

Finding 524571 (2024-102)

Significant Deficiency 2024

Aroostook Area Agency on Aging INC

ME

Student Financial Aid Reporting Matching / Level of Effort / Earmarking

The Agency will implement appropriate processes and controls to ensure the Schedule of Federal Awards contains complete and accurate data.

View Audit 344021

Finding 524567 (2024-002)

None 2024

Oregon College of Oriental Medicine

OR

Student Financial Aid Reporting Matching / Level of Effort / Earmarking

Finding: 2024-002 Reporting Department’s Response: We concur Corrective Action: Since the closure of the College will result in no further student loan activity, no immediate corrective action is considered necessary. Contact: Phil Lundberg Anticipated Completion Date: Immediately

View Audit 344009

Finding 524564 (2024-001)

Significant Deficiency 2024

The Chicago School-Cal INC Dba the Chicago Sch of Pro Psychology

IL

Student Financial Aid Cash Management Matching / Level of Effort / Earmarking § 200.303

Corrective Action Plan – The Chicago School Identifying Number: 2024-001 Finding: Excess Cash – Student Financial Aid Applicable Regulation: According to Uniform Grant Guidance (34 CFR 668.166), the Secretary considers excess cash to be any amount of Title IV, HEA program funds, other than Federa...

Corrective Action Plan – The Chicago School Identifying Number: 2024-001 Finding: Excess Cash – Student Financial Aid Applicable Regulation: According to Uniform Grant Guidance (34 CFR 668.166), the Secretary considers excess cash to be any amount of Title IV, HEA program funds, other than Federal Perkins Loan program funds, that an institution does not disburse to students within the required timeframe. Institutions must return any amount of excess cash over the one-percent tolerance and any remaining cash after the seven-day tolerance period. Finding: The College had excess cash for the Federal Direct Student Loan program, ranging from $528,450 to $1,238,306, from November 13, 2023, to December 18, 2023. While the excess cash did not exceed the one-percent tolerance of prior year drawdowns, the amounts were not returned within the seven-day period as required. Summary: The College draws a portion of funds for student stipends while award reconciliation is in progress to ensure timely disbursement. An administrative oversight led to excess cash being held longer than allowed. Specifically, the prior stipend drawdown was not netted out when calculating subsequent fund requests, resulting in excess cash being held for 24 business days. Corrective Action Planned or Taken: 1. Procedure Update: The College has updated its cash management procedures to ensure compliance with the seven-day return requirement. 2. Process Change: Going forward, the College will refrain from drawing funds for student stipends until reconciliations have been fully completed. This will ensure that funds are drawn in alignment with actual disbursement needs, reducing the risk of excess cash. 3. Internal Control Strengthening: The College will enhance internal controls around cash management to ensure that excess cash instances are identified and corrected promptly. 4. Staff Training: All relevant staff will undergo training on revised cash management procedures and the importance of timely reconciliation and returns. 5. Improved Monitoring: The College will implement a more robust monitoring process to track excess cash and ensure compliance with Federal regulations, including daily checks during peak disbursement periods. Contact Person: Theresa Cowan, Associate Vice President, Compliance and Student Finance tcowan@tcsedsystem.edu Anticipated Completion Date: December 16, 2024

View Audit 343996

Finding 524562 (2024-001)

Significant Deficiency 2024

Pacific Oaks Education Corporation

CA

Student Financial Aid Cash Management Matching / Level of Effort / Earmarking § 200.303

Corrective Action Plan – Pacific Oaks Education Corporation Identifying Number: 2024-001 Finding: Excess Cash – Student Financial Aid Applicable Regulation: According to Uniform Guidance of the Department of Education (34 CFR 668.166), the Secretary considers excess cash to be any amount of Title...

Corrective Action Plan – Pacific Oaks Education Corporation Identifying Number: 2024-001 Finding: Excess Cash – Student Financial Aid Applicable Regulation: According to Uniform Guidance of the Department of Education (34 CFR 668.166), the Secretary considers excess cash to be any amount of Title IV, HEA program funds, other than Federal Perkins Loan program funds, that an institution does not disburse to students within the required timeframe. Institutions must return any amount of excess cash over the one-percent tolerance and any remaining cash after the seven-day tolerance period. Finding: The College had excess cash for the Federal Direct Student Loan program, ranging from $1,335,590 to $4,774,182, from September 6, 2023, to September 13, 2023. The excess cash exceeded the one-percent tolerance of prior year drawdowns, and the funds were not posted to students' ledgers within the three-business-day period as required. Summary: The College draws a portion of funds early to ensure the timely disbursement of stipends to students, while the reconciliation process is still underway. However, the funds were not posted to students’ ledgers within the required three days, leading to a violation of the federal cash management requirements. The issue was related to administrative oversight in the processing of the drawn funds. Corrective Action Planned or Taken: 1. Procedure Update: The College has updated its cash management procedures to ensure funds are posted to students’ ledgers within the three-business-day requirement. 2. Process Change: The College will refrain from drawing funds early to cover stipends until all necessary reconciliations are completed, ensuring compliance with the required disbursement timeline. 3. Internal Control Strengthening: The College will strengthen internal controls by implementing more rigorous checks to ensure timely posting of funds to students' accounts after drawdowns. 4. Staff Training: Relevant staff members will undergo training on the updated procedures and the importance of timely posting of funds to student ledgers. 5. Improved Monitoring: The College will institute enhanced monitoring and tracking of funds after drawdowns to ensure that the required posting timeframe is consistently met. Contact Person: Theresa Cowan, Associate Vice President, Compliance and Student Finance tcowan@tcsedsystem.edu Anticipated Completion Date: December 16, 2024

View Audit 343993

Finding 524554 (2024-001)

Significant Deficiency 2024

University of Miami

FL

Student Financial Aid Reporting Matching / Level of Effort / Earmarking

UM management acknowledges that the status changes for 5 out of 40 students selected were not reported to NSLDS within the required 60-day timeframe. This delay was caused by unexpected technical issues during the submission process to the National Student Clearinghouse. Corrective Action Plan UM ...

UM management acknowledges that the status changes for 5 out of 40 students selected were not reported to NSLDS within the required 60-day timeframe. This delay was caused by unexpected technical issues during the submission process to the National Student Clearinghouse. Corrective Action Plan UM management has since implemented a new process for reporting submission to bypass the technical issues. Timeline for Action Plan The new process was implemented in March 2024. Responsible JndjviduaJs Allen Augustin, Associate Registrar

View Audit 343977

Finding 524548 (2024-005)

Significant Deficiency 2024

Gibraltar Area School District

WI

Procurement, Suspension & Debarment Matching / Level of Effort / Earmarking Significant Deficiency § 200.214

Suspension and Debarment Federal Assistance Listing Number: Special Education Cluster (84.027 and 84.173) Procedures will be updated to include documentation of verification that a vendor has not been suspended or debarred. A record of this verification will be retained. Responsible official: Mark ...

Suspension and Debarment Federal Assistance Listing Number: Special Education Cluster (84.027 and 84.173) Procedures will be updated to include documentation of verification that a vendor has not been suspended or debarred. A record of this verification will be retained. Responsible official: Mark Lindem, Business Manager, mark.lindem@gibraltar.k12.wi.us Anticipated Completion Date: June 30, 2025

View Audit 343957

Finding 524542 (2024-003)

Significant Deficiency 2024

Donnelly College

KS

Student Financial Aid Matching / Level of Effort / Earmarking

Contact Person: Ron Dempsey, Controller Views of Responsible Officials and Planned Corrective Action: The College has procedures in place that are supposed to prevent the awarding of students in verification. The Student Information System (Empower) has a feature for tracking students in verificati...

Contact Person: Ron Dempsey, Controller Views of Responsible Officials and Planned Corrective Action: The College has procedures in place that are supposed to prevent the awarding of students in verification. The Student Information System (Empower) has a feature for tracking students in verification. That tracking system did not prevent the awarding of Title IV aid. Therefore, the college will implement a backup tracking system to help track students in verification. Anticipated Completion Date: March 31, 2025

View Audit 343943

Finding 524514 (2024-002)

Significant Deficiency 2024

Cornish College of the Arts and Cornish Foundation

WA

Student Financial Aid Significant Deficiency Matching / Level of Effort / Earmarking

Student Financial Assistance Cluster – Assistance Listing No. Various Recommendation: We recommend that the College review their records to locate the missing promissory notes. If the signed promissory notes can’t be located, the College should assess if there is sufficient documentation to support...

Student Financial Assistance Cluster – Assistance Listing No. Various Recommendation: We recommend that the College review their records to locate the missing promissory notes. If the signed promissory notes can’t be located, the College should assess if there is sufficient documentation to support the loan such as repayment history, documentation showing the original payment was accepted by the student, etc. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Subsequent to the audit testing, all Perkins loan MPNs were located and the College is finalizing its assignment of the loans to the Department of Education. Name(s) of the contact person(s) responsible for corrective action: Cheryl Wynne, Interim CFO and Grant Drinnen, Cash and Accounts Receivable Specialist Planned completion date for corrective action plan: January 31, 2025

View Audit 343891

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