Corrective Action Plans

Finding 525094 (2024-004)

None 2024

NY

Student Financial Aid Allowable Costs / Cost Principles Reporting

The University experienced significant staffing turnover in the financial aid department during the 2023-2024 aid year, resulting in certain established processes to go unfollowed. In June 2024, the University hired a full-time outsourced staffing solution, which has added headcount and stabilized t...

The University experienced significant staffing turnover in the financial aid department during the 2023-2024 aid year, resulting in certain established processes to go unfollowed. In June 2024, the University hired a full-time outsourced staffing solution, which has added headcount and stabilized the department staffing. The Director has established clear roles and responsibilities so that established processes are not missed going forward. Additionally, job duties have been reallocated to ensure calculations on official and unofficial withdrawals and exit counseling communications are done monthly going forward.

View Audit 344382

Finding 525093 (2024-006)

Material Weakness 2024

Union Theological Seminary in the City of New York

NY

Student Financial Aid Matching / Level of Effort / Earmarking Reporting

This Repeat Finding has been acknowledged. Union has taken several steps towards making the required changes to ensure compliance with our enrollment reporting responsibilities. This includes implementing process improvements related to our National Clearing House (NSC) submissions and reviewing ou...

This Repeat Finding has been acknowledged. Union has taken several steps towards making the required changes to ensure compliance with our enrollment reporting responsibilities. This includes implementing process improvements related to our National Clearing House (NSC) submissions and reviewing our academic policies related to academic leaves of absence and withdrawals. Timeliness of Enrollment Reporting Rosters: As of January 2024, Union completed the set-up and configuration of our enrollment reporting services with NSC as our third-party service provider. The new process is administered by the school Registrar, with back-up responsibilities handled by the Assistant Dean, Director of Financial Aid, and the Vice President of Admissions and Financial Aid. Since implementing the new system, Union has submitted our Enrollment Reporting Roster on a regular and timely basis. Under NSC, our submissions have occurred at least once per month and within the 15-day reporting requirement. As a result, we do not anticipate late reporting of Enrollment Reporting Rosters for FY25 or future periods.. Accuracy of Enrollment Status Changes: In order to further improve the timeliness and accuracy of our enrollment report submissions, we plan to make the following changes to our process with NSC. First, we will schedule additional submissions of our Enrollment Roster at key points during the academic year: (1) prior to the start of each semester, (2) immediately after the end of the drop-add period, and (3) during our non-required summer term. Second, we will work with NSC on our system configuration and error correction process, to ensure that enrollment status is accurately reported and that all status errors are resolved correctly and in a timely manner. Enrollment Roster transmissions will continue to take place according to a preset schedule. This process includes email communication from NSC the week prior to an enrollment submission, confirmation of a successful submission, and notification of potential errors. Union’s Registrar, who has 17 years of experience, is also working directly with NSLDS to address errors found in past submissions and working with internal stakeholders in the Academic Office, Financial Aid Office, Bursar’s Office, and IT Department to ensure that all student records accurately and correctly configured.

View Audit 344376

Finding 525030 (2024-002)

Material Weakness 2024

Colfax County, Nebraska

NE

Internal Control / Segregation of Duties Reporting

The County has discussed the finding but must consider the cost of adequate segregation of duties when determining the use of tax money.

View Audit 344341

Finding 525028 (2024-002)

Significant Deficiency 2024

Albright College

PA

Student Financial Aid Reporting Matching / Level of Effort / Earmarking

Finding 2024-002 Condition The change in student status for 12 of the 25 students tested was not reported to the National Student Loan Data Systems (NSLDS) within 30 days or included in a response to a roster file within 60 days. However, these students were ultimately reported to the NSLDS. Corr...

Finding 2024-002 Condition The change in student status for 12 of the 25 students tested was not reported to the National Student Loan Data Systems (NSLDS) within 30 days or included in a response to a roster file within 60 days. However, these students were ultimately reported to the NSLDS. Corrective Action Plan The Registrar’s Office remains committed to adhering to the College’s established reporting cadence. To ensure compliance with federal requirements, the College submits enrollment data to the National Student Clearinghouse at least every 30 days, maintaining timely and accurate reporting to the National Student Loan Data System. Name(s) of Contact Person(s) Responsible for Corrective Action: Michael Armato, Registrar James Palmer, Director of Institutional Research Anticipated Completion Date: FY2025

View Audit 344339

Finding 525017 (2024-001)

Significant Deficiency 2024

Brenda Thibeault

CT

Cash Management Reporting

After the former finance director completed the federal webinars on the guidelines for requesting funds through the Payment Management System and submitting Federal Financial Reports, it was identified and disclosed to the auditors that draw down procedures had not been in compliance. SAMHSA was no...

After the former finance director completed the federal webinars on the guidelines for requesting funds through the Payment Management System and submitting Federal Financial Reports, it was identified and disclosed to the auditors that draw down procedures had not been in compliance. SAMHSA was notified and accounts were reconciled with the return of unspent funds. All drawdowns are currently only occurring when funds are expended. Current finance personnel are trained and have extensive experience in federal reporting guidelines.

View Audit 344334

Finding 525012 (2024-002)

None 2024

Our Lady of the Lake University of San Antonio

TX

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

Finding: Special Tests and Provisions – Enrollment Reporting Student Financial Assistance Cluster, Assistance Listing Number 84.268 Federal Direct Student Loans, Assistance Listing Number 84.063 Federal Pell Grant Program U.S. Department of Education Program Year 2023–2024 Type of Finding: Other Ins...

Finding: Special Tests and Provisions – Enrollment Reporting Student Financial Assistance Cluster, Assistance Listing Number 84.268 Federal Direct Student Loans, Assistance Listing Number 84.063 Federal Pell Grant Program U.S. Department of Education Program Year 2023–2024 Type of Finding: Other Instance of Noncompliance and Deficiency Corrective Action: The failure to report certain enrollment status changes to the NSLDS on a timely basis during the fiscal year ending May 31, 2024, was an isolated instance due to turnover in the Registrar’s Office. The University has updated the process for reporting enrollment status changes to the NSLDS and has ensured there is adequate cross-training in the Registrar’s Office to prevent future instances of non-compliance with reporting deadlines. Status: Completed Person Responsible for Implementing: Melissa Delgado, Registrar Implementation Date: 01/01/2025

View Audit 344329

Finding 525011 (2024-001)

Significant Deficiency 2024

Holy Family University

PA

Student Financial Aid Reporting Significant Deficiency

Management Response: Holy Family University is dedicated to ensuring the accuracy of our reporting to the NSLDS. The following is how we plan to verify the integrity of our reports. The Registrar's Office will compare the list of students pulled in the monthly NSC process to a report showing all stu...

Management Response: Holy Family University is dedicated to ensuring the accuracy of our reporting to the NSLDS. The following is how we plan to verify the integrity of our reports. The Registrar's Office will compare the list of students pulled in the monthly NSC process to a report showing all students who withdrew that month. This will ensure that we are reporting all withdrawn/graduated students in a timely manner. In addition, the Registrar's Office will verify the potential graduation of students whose grades are changed after the end of the term. If the new grade completes their degree, the student will be reported as "graduated" when we process the next session's graduation applications. This will eliminate the reliance on an external database, as manual updates tend to lack consistency. Lastly, prior to submitting the Graduates Only file to the NSLDS, the Registrar will compare the entire list of graduates to the report showing all students who withdrew throughout the semester. This will be a double check since we will also be checking grade changes, as mentioned above.

View Audit 344324

Finding 524983 (2024-004)

Significant Deficiency 2024

Minneapolis College of Art and Design

MN

Student Financial Aid Reporting Significant Deficiency

Perkins Reconciliation Recommendation: It is recommended that the College review procedures in place to ensure accurate reporting of Perkins loan information to comply with Title IV regulations. Explanation of disagreement with audit finding: MCAD had undergone numerous staff transitions within The...

Perkins Reconciliation Recommendation: It is recommended that the College review procedures in place to ensure accurate reporting of Perkins loan information to comply with Title IV regulations. Explanation of disagreement with audit finding: MCAD had undergone numerous staff transitions within The Business Office. Its previous Perkins Loan Servicer, University Accounting Service (UAS), was derelict in its duty to fulfill the terms of the contract by failing to perform in managing all areas of MCAD’s Perkins Loan portfolio. UAS failed to keep current as well as accurate accounting and funds management records throughout its tenure as the servicer. Action taken in response to finding: ● Changing of Servicer: MCAD has removed UAS and completed the changeover to Heartland Educational Computer Systems Incorporated (ECSI) as its new Perkins servicer. ● Business Office (Student Accounts Manager) will provide close oversight to ensure accountability that ECSI will fulfill its duties and responsibilities as Perkins Loan Servicer ● The Financial Aid Office will partner with the Business Office as another layer of accountability and support to the Business Office as it supervises ECSI. ● Third-Party Assistance: The institution has engaged with CLA to assist with the reconciliation of the Perkins Loan accounts. It is expected that the work CLA has done to assist will come to full fruition and be fully reconciled sometime in 2025. Name(s) of the contact person(s) responsible for corrective action: Mary Alma Noonan, CFO, Brian Braden, Controller and Sherman Lee, Financial Aid Director Planned completion date for corrective action plan: June 30, 2025

View Audit 344312

Finding 524968 (2024-002)

Material Weakness 2024

National University

CA

Student Financial Aid Material Weakness Reporting

FINDING 2024-002 – Special Tests and Provisions – Enrollment Reporting: Material Weakness in Internal Control National University acknowledges the findings and the importance of accuracy and timeliness when completing enrollment reporting to NSLDS. The University has made significant efforts to impr...

FINDING 2024-002 – Special Tests and Provisions – Enrollment Reporting: Material Weakness in Internal Control National University acknowledges the findings and the importance of accuracy and timeliness when completing enrollment reporting to NSLDS. The University has made significant efforts to improve all areas of the enrollment reporting process, and the results of this audit do not reflect those efforts and improvements due to the timing of the FY 23 audit completion in February 2024 and CAP completion in June 2024. The institution has identified two items that have resulted in challenges to accurate and timely enrollment reporting during the audit year. Intent to return: The University has identified a need to improve the understanding and implementation of its intent to return (ITR) process. As a result, the University will conduct a holistic review, including assessment and clarification of the current policy, identification and implementation of technological controls, comprehensive training for ITR, and the development and implementation of a monthly ITR review. National Student Clearing House (NSC) reporting: On October 18, 2024, the institution was notified by NSC that its access to process enrollment reporting on behalf of NU was revoked during July 2024, resulting in a reporting gap. The institution is investigating the root cause of this and submitted a ticket to the FPS/SAIG help desk, but no root cause was able to be identified. The issue was immediately resolved upon notification; however, the reporting gap had a significant impact on the FY 24 enrollment reporting sample. In addition to the above, the institution will continue or take the following steps: • Continued monthly testing of enrollment reporting accuracy to NSLDS conducted by the quality assurance team. • Identification and timely delivery of training for areas of opportunity identified in the monthly reviews to the registrar and data operations teams. • Revise the internal documentation process between quality assurance, data operations, and the registrar teams to ensure clarity of policy and regulatory guidance in areas of identified risk/confusion during enrollment reporting processing. Contact Person Responsible for Corrective Action: • Rob Conlon, AVP Financial Aid Compliance • Sarah Massey, AVP of Operations Student Support and Registrar Operations • Gabrielle Witruke, Associate Director Data Analytics • Melissa Diaz, AVP Operations Advising Anticipated Completion Date: March 2025

View Audit 344308

Finding 524963 (2024-001)

Material Weakness 2024

National University

CA

Questioned Costs Special Tests & Provisions Student Financial Aid

Management’s Corrective Action Plan National University acknowledges the findings and the recommendations regarding improving procedures. FINDING 2024-001 – Special Tests and Provisions – Return of Title IV: Material Weakness in Internal Control National University acknowledges the finding and impo...

Management’s Corrective Action Plan National University acknowledges the findings and the recommendations regarding improving procedures. FINDING 2024-001 – Special Tests and Provisions – Return of Title IV: Material Weakness in Internal Control National University acknowledges the finding and importance of accurate identification and timely and accurate calculation of R2T4s. The University has made significant efforts to improve all areas of R2T4 processing, and the results of this audit show significant gains over the previous year. Given the timing of the FY 23 audit completion in February 2024 with CAP completion scheduled for June 2024, the benefits of the FY 23 corrective action plan have a limited impact on this audit period. This, coupled with the improved results the institution has seen in timeliness such as the late return error rate having decreased from 31% in FY 23 to 13% in the current audit, suggests that NU is pathing towards compliance with R2T4 requirements. Based on this assessment, NU will continue to take the following actions: • Continual assessment of staffing levels and hiring as needed to ensure timely identification and processing of R2T4s. Staffing ratios were established in FY24 and staffing increases were implemented to ensure accurate processing and timely completion. • Continual identification of risks with weekly testing and readouts from Quality Assurance to the financial aid processing team. • Re-training with the R2T4 processing team on the order of returns. • Identification and timely delivery of training for areas of risk identified in the weekly reviews. • Revise internal processes between the Quality Assurance and financial aid processing to better communicate policy and regulatory guidance in areas of identified risk/confusion during R2T4 processing. Contact Person Responsible for Corrective Action: • Rob Conlon, AVP Financial Aid Compliance • Alan Coddington, AVP Student Financial Services Anticipated Completion Date: January 2025

View Audit 344308 Questioned Costs: $1

Finding 524960 (2024-001)

Significant Deficiency 2024

Housing Authority of Cook County

IL

HUD Housing Programs Internal Control / Segregation of Duties Eligibility

Authority's Response and Planned Corrective Action: The Authority accepts the recommendation of the auditor. The Authority will increase oversight in the Housing Voucher Cluster to ensure that established internal control policies are being followed accurately and on a timely basis. Danita W. Childe...

Authority's Response and Planned Corrective Action: The Authority accepts the recommendation of the auditor. The Authority will increase oversight in the Housing Voucher Cluster to ensure that established internal control policies are being followed accurately and on a timely basis. Danita W. Childers, Executive Director, is responsible for implementing this corrective action by March 31, 2025.

View Audit 344304

Finding 524947 (2024-001)

Material Weakness 2024

The Thresholds and Affiliated Organizations

IL

Reporting

Condition: The Agency’s controls in place for financial reporting submissions did not identify that the SF-425 Federal Financial Report (“FFR”) submitted for the annual reporting period ending August 31, 2023, indicated that the report was prepared on the accrual basis of accounting when the report ...

Condition: The Agency’s controls in place for financial reporting submissions did not identify that the SF-425 Federal Financial Report (“FFR”) submitted for the annual reporting period ending August 31, 2023, indicated that the report was prepared on the accrual basis of accounting when the report was actually prepared on the cash basis of accounting. The report filed did not reflect the accrued expenditures for the program. Planned Corrective Action: Thresholds current policy is as follows. For purposes of financial reporting on federal awards, financial reports will be prepared by the grant accountant (or other appropriate party) and reviewed by the Senior Director of Grants Accounting (or their designee). Unfortunately, this policy did not identify this mistake, because these payments came from a construction escrow account and did not go through the normal accounts payable process. We will add additional requirements for any accounting entry resulting from construction escrow payments. Namely, we will scrutinize and verify the accrual period(s) for such escrow expenditures before posting the accounting entry. Contact person responsible for corrective action: Al Shoreibah, Chief Financial Officer Anticipated Completion Date: 03/01/2025

View Audit 344290

Finding 524943 (2024-002)

Material Weakness 2024

El Camino Community College District

CA

Student Financial Aid Reporting Material Weakness

Recommendation: We recommend the District review its reporting procedures to ensure that enrollment and program information is accurately reported to NSLDS as required by regulations. Action taken in response to finding: The District has taken the following actions to address this recommendation: As...

Recommendation: We recommend the District review its reporting procedures to ensure that enrollment and program information is accurately reported to NSLDS as required by regulations. Action taken in response to finding: The District has taken the following actions to address this recommendation: Assess Current Reporting Delays  Review the current submission schedule and identify specific time gaps between when Clearinghouse files are sent and when the data reaches NSLDS.  Work with the Clearinghouse to confirm file submission dates and compare them with NSLDS report uploads.  Document delays and establish a baseline for necessary improvements. Action 1.2: Communicate with NSLDS and Clearinghouse  Contact NSLDS and Clearinghouse support teams to communicate the delays and request any assistance or expedited processes.  Set clear expectations with these parties on how to resolve the reporting issue and prevent future delayed submissions. Establish Clear Reporting Timelines  Work with Clearinghouse to establish a clear, consistent timeline for file submission and confirm the timing of data submission to NSLDS.  Ensure reporting timelines align with NSLDS deadlines to ensure timely reporting.  Update internal policies and procedures to reflect the new reporting timeline and expectations. Staff Training and Awareness  Conduct training sessions for staff involved in the Clearinghouse file preparation and submission process, emphasizing the importance of timely submissions.  Provide regular updates and reminders about deadlines and processes. Automate or Enhance File Submission Process  Implement any necessary technology upgrades to streamline the data submission process.  Explore the possibility of setting up automatic file uploads directly to NSLDS to minimize delays. Implement Monitoring and Reporting System  Set up a monitoring system to track Clearinghouse file submissions to NSLDS, including confirmation that files have been successfully submitted and processed.  After implementing process changes, conduct monthly reviews to verify that student data is being submitted to NSLDS on time.  Track and report submission times Continuous Communication with NSLDS and Clearinghouse  Establish a point of contact at both NSLDS and the Clearinghouse to improve communication regarding file submission issues. Conduct regular reviews to ensure that the institutions’ reporting process aligns with NSLDS requirements. Name of the contact person responsible for corrective action: Dr. Kristina Martinez, Acting Dean of Enrollment Services Planned completion date for corrective action plan: June 30, 2025

View Audit 344288

Finding 524920 (2024-002)

Significant Deficiency 2024

Howard Community College

MD

Special Tests & Provisions Student Financial Aid Reporting § 200.303

2024‐002: Special Tests and Provisions – NSLDS Enrollment Reporting Student Financial Aid Cluster – Assistance Listing No. 84.063, 84.268 Condition: During testing of the enrollment status reporting, we noted that the incorrect enrollment status and effective date was included in NSLDS. Recommenda...

2024‐002: Special Tests and Provisions – NSLDS Enrollment Reporting Student Financial Aid Cluster – Assistance Listing No. 84.063, 84.268 Condition: During testing of the enrollment status reporting, we noted that the incorrect enrollment status and effective date was included in NSLDS. Recommendation: The institution should evaluate their procedures and policies related to reporting status changes and effective dates to NSLDS and enhance as deemed necessary to ensure that accurate information is reported to NSLDS. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Howard Community College will work with Records, Registration and Veterans Affairs (RRVA) to conduct a thorough review of the current policies and procedures for reporting student enrollment status changes and effective dates to NSLDS and then subsequently implement process improvements to ensure that our process aligns with federal regulations. Name(s) of the contact person(s) responsible for corrective action: Jessica Peterson, Registrar Planned completion date for corrective action plan: June 30, 2026

View Audit 344285

Finding 524915 (2024-004)

Significant Deficiency 2024

Howard Community College

MD

Student Financial Aid Reporting Significant Deficiency § 200.303

2024 – 004: Fiscal Operations Report and Application to Participate (FISAP) Reporting Student Financial Aid Cluster – Assistance Listing No. 84.063, 84.268, 84.007, 84.033 Condition: The documents retained by the University to support amounts included in the FISAP did not agree to the FISAP. Recom...

2024 – 004: Fiscal Operations Report and Application to Participate (FISAP) Reporting Student Financial Aid Cluster – Assistance Listing No. 84.063, 84.268, 84.007, 84.033 Condition: The documents retained by the University to support amounts included in the FISAP did not agree to the FISAP. Recommendation: It is recommended that the College strengthens its internal controls and verification processes to ensure the accuracy of data reported in the FISAP. This may include creating a formalized review process for the FISAP and ensuring all supporting schedules used to populate the form are centrally stored. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Financial Aid Services has created a formalized review process for FISAP and created a central location to store data. This review process includes multiple staff members and internal controls for future review. Name(s) of the contact person(s) responsible for corrective action: Detra Hooper, Financial Aid Services Director Planned completion date for corrective action plan: June 30, 2025

View Audit 344285

Finding 524897 (2024-002)

Significant Deficiency 2024

Town of Coventry, Connecticut

CT

Internal Control / Segregation of Duties Allowable Costs / Cost Principles Reporting

UNITED STATES DEPARTMENT OF THE TREASURY 2024-002 COVID-19 – American Rescue Plan Act – Assistance Listing No. 21.027 Recommendation: We recommend that the Town review its procedures over grant reporting requirements to ensure all reports are reviewed and documentation of that review is retained. ...

UNITED STATES DEPARTMENT OF THE TREASURY 2024-002 COVID-19 – American Rescue Plan Act – Assistance Listing No. 21.027 Recommendation: We recommend that the Town review its procedures over grant reporting requirements to ensure all reports are reviewed and documentation of that review is retained. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Although there were no errors in the reporting, to ensure efficiencies, staff other than the Finance Director will review grant reporting and sign off before it is submitted. Name(s) of the contact person(s) responsible for corrective action: Julie Chapman Planned completion date for corrective action plan: February 1, 2025

View Audit 344253

Finding 524886 (2024-001)

Significant Deficiency 2024

Eastern Michigan University

MI

Student Financial Aid Matching / Level of Effort / Earmarking Reporting

Condition: Of the 40 students selected for enrollment reporting testing, 5 students did not have their status updated appropriately. Planned Corrective Action: The Office of Financial Aid has implemented a process to communicate and confirm with the office responsible for enrollment reporting to ver...

Condition: Of the 40 students selected for enrollment reporting testing, 5 students did not have their status updated appropriately. Planned Corrective Action: The Office of Financial Aid has implemented a process to communicate and confirm with the office responsible for enrollment reporting to verify that enrollment rosters will not be/have not been sent after a semester has officially ended. Contact person responsible for corrective action: Jennifer Tremewan, Asst. Director Office of Financial Aid Anticipated Completion Date: December 31, 2024

View Audit 344249

Finding 524876 (2024-001)

None 2024

East Windsor Regional School District

NJ

Reporting Internal Control / Segregation of Duties

Cross training will occur between the BA, Assistant BA and the Senior Accountant. In the event of extended vacancies or absences, multiple staff members will be trained on filing correct final reports.

View Audit 344245

Finding 524872 (2024-001)

Significant Deficiency 2024

Cumberland University

TN

Reporting Student Financial Aid Matching / Level of Effort / Earmarking

Finding Summary: When a recipient of a Title IV grant or loan assistance withdraws from an institution during a payment period or period of enrollment in which the recipient began attendance, the institution must determine the amount of Title IV grant or loan assistance the student earned as of the...

Finding Summary: When a recipient of a Title IV grant or loan assistance withdraws from an institution during a payment period or period of enrollment in which the recipient began attendance, the institution must determine the amount of Title IV grant or loan assistance the student earned as of the student’s withdrawal date and must return the amount of Title IV funds for which it was responsible as soon as possible but no later than 45 days after the date of the institution’s determination that the student withdrew (34 CFR 668.22(j)(1)). Annual Single Audit review of Return to Title IV (R2T4) funds found that the return of federal funds was outside the required window. All necessary funds were returned during the 23-24 funding period. While R2T4 calculations were performed within the required time limit, there were three total students with returns that were outside the return window for the 23-24 Academic Year. Corrective Action Plan (CAP): The Associate Director of Financial Aid will be the primary staff member responsible for the R2T4 calculations and returns. If they are unavailable in a given week, the Executive Director will perform the weekly calculations needed. To ensure that the calculations and returns are completed within federal guidelines, the Associate Director will block 2-4 hours at the beginning of each week of the semester to review the prior week’s withdrawals and perform all necessary calculations and returns. At the end of each week, the Associate Director and the Executive Director will meet to review the prior week’s calculations and returns to ensure all returns have been processed through the Department of Education Common Origination and Disbursement (COD) website. A checklist has been created with all the necessary steps for each return, with a sign-off and documentation required to be attached as proof of completion. Anticipated Completion Date: The procedures will be implemented for the 2024-2025 Financial Aid Year. Responsible Parties: Beatrice LaChance

View Audit 344243

Finding 524867 (2024-001)

Significant Deficiency 2024

John A Logan College, Community College District #530

IL

Special Tests & Provisions Student Financial Aid Reporting

Finding No. 2024-001: Controls Over Student Financial Assistance Special Tests and Provisions – Enrollment Reporting (Repeated from Finding No. 2022-001 and 2023-001) Condition: During the compliance testing of “Special Tests and Provisions” requirements related to Enrollment Reporting, we noted ...

Finding No. 2024-001: Controls Over Student Financial Assistance Special Tests and Provisions – Enrollment Reporting (Repeated from Finding No. 2022-001 and 2023-001) Condition: During the compliance testing of “Special Tests and Provisions” requirements related to Enrollment Reporting, we noted the following exceptions: • Two (2) students were not reported to the Clearinghouse after withdrawing from the institution. Plan: After contacting Jenzabar One, the College has determined it cannot alter the pre-made Clearinghouse report; however, the College can alter its withdrawal process to ensure accurate withdrawal dates are reported in the correct area within the SIS. Admissions and Records will modify withdrawal and school determination dates, so the SIS gathers the correct information to be reported for future reporting. The Registrar will also work with and crosscheck students with Financial Aid to ensure all students who attended, but dropped before census, will be reported to the Clearinghouse. Anticipated Date of Completion: January 2025 Name of Contact Person: Dr. Stephanie Hartford, Provost

View Audit 344230

Finding 524822 (2024-001)

Significant Deficiency 2024

The College of New Jersey

NJ

Subrecipient Monitoring Reporting Internal Control / Segregation of Duties § 200.403 § 200.430

Corrective Action Plan for Current Year Findings June 30, 2024 Finding 2024-001: Activities Allowed or Unallowed Research and Development Cluster Award Period: July 1, 2023 – June 30, 2024 Responsible Person: Karen Miller, Controller 609-771-2203 Jeanette Vega, Director of Grant Financial Administra...

Corrective Action Plan for Current Year Findings June 30, 2024 Finding 2024-001: Activities Allowed or Unallowed Research and Development Cluster Award Period: July 1, 2023 – June 30, 2024 Responsible Person: Karen Miller, Controller 609-771-2203 Jeanette Vega, Director of Grant Financial Administration 609-771-2847 Corrective Action Plan: For the fiscal year ending June 30, 2024, the College had 7 employees with a combined total of 10 payroll instances with no effort verification form certified for any of the transactions from July 1, 2023, to December 31, 2023, in the fiscal year being audited. The effort was certified after the fiscal year, as part of the year-end process which was not in line with the semi-annually time frames as historically done with guidance in our Effort Verification Operating Policy. The College recognizes the importance of ensuring that labor costs charged to federal awards are based on accurate and timely records and certifications, as required under 2 CFR 200.430(g). The timing delays occurred due to staffing vacancies and knowledge transfer of current staff as well as misalignment of staffing. Once the staffing was realigned, trained, and vacant positions filled, the time and effort certification for the fiscal year labor costs were completed. This task occurred during the months between August 2024 and November 2024 which was outside the policy time frames. The College is committed to improving its internal controls over time and effort reporting for research and development grants to ensure compliance by taking corrective action steps to improve monitoring and oversight, strengthen training and communications, and develop an action plan for corrective timing. The College implemented part of the corrective action on August 01, 2024, retroactive to July 1, 2023, and will complete the remaining items by the end of the next fiscal year. Anticipated Completion Date: June 30, 2025

View Audit 344210

Finding 524819 (2024-002)

Significant Deficiency 2024

Octorara Area School District

PA

Reporting Significant Deficiency

During the audit of the 2023-2024 school year, it was determined that the expenditures reported for the 2022-2023 fiscal year did not align with the expenses recorded and reported on the Schedule of Expenditures of Federal Awards (SEFA). Cause: The discrepancy appears to be a result of coding err...

During the audit of the 2023-2024 school year, it was determined that the expenditures reported for the 2022-2023 fiscal year did not align with the expenses recorded and reported on the Schedule of Expenditures of Federal Awards (SEFA). Cause: The discrepancy appears to be a result of coding errors or weaknesses in internal controls over the financial reporting process. Corrective Action Plan: 1. Review and Reconciliation Process Improvement - Implement a standardized reconciliation process to ensure that all expenditures reported in federal grant filings match the SEFA and general ledger records. - The reconciliation process will be conducted monthly to ensure expenditures are accurately recorded and categorized. 2. Independent Review of Reports - Assign an independent reviewer, separate from the preparer, to verify the accuracy of all grant-related reports before submission. - This reviewer will cross-check expenditures with SEFA, general ledger records, and supporting documentation to ensure consistency and compliance. 3. Enhanced Internal Controls - Develop and document a formalized grant reporting procedure that includes clear steps for expenditure tracking, coding, and verification. - Require dual sign-off on all grant expenditure reports before submission to the Pennsylvania Department of Education. 4. Staff Training and Accountability - Provide targeted training to finance and grants management personnel on proper coding procedures and federal grant compliance requirements. - Conduct annual refresher training to reinforce best practices in financial reporting and compliance. 5. Regular Monitoring and Audits - Conduct quarterly internal audits of grant expenditures to proactively identify and correct any discrepancies before external audits. - Establish a compliance checklist to ensure all reporting aligns with federal and state requirements. 6. Follow-Up and Monitoring: - A follow-up review will be conducted after the next reporting cycle to assess the effectiveness of corrective actions and ensure compliance. By implementing these corrective measures, the District aims to strengthen internal controls, improve reporting accuracy, and ensure compliance with federal grant requirements.

View Audit 344208

Finding 524811 (2024-003)

None 2024

Corban University

OR

Student Financial Aid Reporting

FISAP Reporting Planned Corrective Action: Independent of the individual who prepares the FISAP, Corban will assign another team member to review the completed FISAP for quality assurance (QA). We have retained all FISAP related records for the current year and are in the process of better organizin...

FISAP Reporting Planned Corrective Action: Independent of the individual who prepares the FISAP, Corban will assign another team member to review the completed FISAP for quality assurance (QA). We have retained all FISAP related records for the current year and are in the process of better organizing our FISAP files. Financial Aid professionals have also been added to internal meetings where decisions on programs, academic calendars, and other significant timing decisions are made to better enhance our ability to comply. Person Responsible for Corrective Action Plan: Jordan Lindsey, Vice President for Enrollment Management and Marketing Anticipated Date of Completion: 2/1/25

View Audit 344190

Finding 524810 (2024-002)

None 2024

Corban University

OR

Student Financial Aid Matching / Level of Effort / Earmarking Reporting

Common Origination and Disbursement (COD) Reporting Planned Corrective Action: The Financial Aid Office will conduct monthly reconciliations between student accounts and COD to identify mismatched disbursement dates and correct them. Person Responsible for Corrective Action Plan: Jordan Lindsey, Vic...

Common Origination and Disbursement (COD) Reporting Planned Corrective Action: The Financial Aid Office will conduct monthly reconciliations between student accounts and COD to identify mismatched disbursement dates and correct them. Person Responsible for Corrective Action Plan: Jordan Lindsey, Vice President for Enrollment Management and Marketing Anticipated Date of Completion: 2/1/25

View Audit 344190

Finding 524790 (2024-002)

Significant Deficiency 2024

University of Dubuque

IA

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

Finding: The University’s R2T4 calculation was improper for one student, as the student had not signed a promissory note for the direct loans and the direct loans should have not been included in the calculation. Corrective Actions Taken or Planned: The Director of Financial Aid reviews and process...

Finding: The University’s R2T4 calculation was improper for one student, as the student had not signed a promissory note for the direct loans and the direct loans should have not been included in the calculation. Corrective Actions Taken or Planned: The Director of Financial Aid reviews and processes the R2T4 calculations. The Director will reassess R2T4 calculations and verify that only aid with signed promissory notes are being included in R2T4 calculations. Internal policies and procedures have been updated to ensure accurate calculations. Person Responsible: Teresa Brahm, TBrahm@dbq.edu Anticipated completion date: 09/25/2024

View Audit 344180 Questioned Costs: $1

Corrective Action Plans

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