Corrective Action Plans

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2023-001: Internal Controls over Federal Award – Reporting (VMS) - Significant Deficiency in Internal controls over compliance over reporting Recommendation: The Authority should establish a clearly documented review process wherein someone other than the preparer reviews the VMS report prior to sub...
2023-001: Internal Controls over Federal Award – Reporting (VMS) - Significant Deficiency in Internal controls over compliance over reporting Recommendation: The Authority should establish a clearly documented review process wherein someone other than the preparer reviews the VMS report prior to submission. Action Taken: The Authority will have a member of management review VMS submissions prior to submission. Due Date of Completion: February 2024 Responsible Official: Chris Herbert, Executive Director, Irene Murillo, Deputy Director, Carol Hensley, Assistant Deputy Director
Corrective Action Plan: The University has implemented a correction to the reporting logic that caused the inaccurate reporting of program begin date for some students. This implementation was effective for enrollment reporting beginning with the Fall 2023 semester. In addition, the University is ut...
Corrective Action Plan: The University has implemented a correction to the reporting logic that caused the inaccurate reporting of program begin date for some students. This implementation was effective for enrollment reporting beginning with the Fall 2023 semester. In addition, the University is utilizing available error reports via the National Student Clearinghouse to ensure program begin dates and other program-level data reported is accurate. Implementation Date: August 2023 Responsible Persons: Ashley Wheelis, Deputy Registrar Molly Collins, Associate Registrar Zach Yeager, Assistant Director
Corrective Action Plan: The University will implement additional controls to check internal disbursement dates against disbursement dates reported in COD in instances where manual reporting is required. Implementation Date: May 2024 Responsible Persons: Kimberley Wells, Director of Financial Aid & S...
Corrective Action Plan: The University will implement additional controls to check internal disbursement dates against disbursement dates reported in COD in instances where manual reporting is required. Implementation Date: May 2024 Responsible Persons: Kimberley Wells, Director of Financial Aid & Scholarships John Robert, Associate Director of Financial Aid & Scholarships Beth Tolan, Associate Vice President of Financial Aid & Scholarships
Corrective Action Plan: The Office of the Registrar and the Office of Scholarships and Financial Aid will collaborate to identify the root cause of why some student data is not being reported in a timely manner. The Office of the Registrar will also institute monthly validation into their business p...
Corrective Action Plan: The Office of the Registrar and the Office of Scholarships and Financial Aid will collaborate to identify the root cause of why some student data is not being reported in a timely manner. The Office of the Registrar will also institute monthly validation into their business processes in alignment with the NSC and NSLDS submission schedule. Implementation Date: February 2025 Responsible Persons: Rachel Honora, Senior Associate Registrar Reggie Brazzle, Director of Operations, SFA
Corrective Action Plan: To strengthen its controls and ensure that program-level data elements are reported to NSLDS accurately, the University will implement business procedures to prevent inaccurate reporting of effective dates. These procedures will be modified to align campus-level and program-l...
Corrective Action Plan: To strengthen its controls and ensure that program-level data elements are reported to NSLDS accurately, the University will implement business procedures to prevent inaccurate reporting of effective dates. These procedures will be modified to align campus-level and program-level effective dates. Specifically, a review process will be added to ensure effective dates are reported accurately to NSLDS. Implementation Date: January 2025 Responsible Persons: Sofia Almeda, University Registrar Esteban Martin, Associate Registrar
Corrective Action Plan: For students that are considered an unofficial withdraw from the university, the Financial Aid Counselor processing the unofficial withdraw will update NSLDS with the unofficial withdraw date at the end of each semester. To address the incorrect enrollment status change and t...
Corrective Action Plan: For students that are considered an unofficial withdraw from the university, the Financial Aid Counselor processing the unofficial withdraw will update NSLDS with the unofficial withdraw date at the end of each semester. To address the incorrect enrollment status change and the incorrect program level errors noted by the auditors, the University is currently working on updating the query output that is used to report to the National Student Clearinghouse to ensure that the data is correct. Implementation Dates: 01/2024 for Unofficial Withdraw 05/2024 for National Student Clearinghouse reporting Responsible Persons: Scott Lapinski, Assistant Vice President for Enrollment Management/Director of Financial Aid Joe Sanders Assistant Vice President for Enrollment Management/Registrar
Corrective Action Plan: The University has implemented significant process and validation enhancements in this area. The operational manual was revised to include detailed procedures. Management manually reviewed CIP codes for all programs and updated system records as appropriate on October 12, 202...
Corrective Action Plan: The University has implemented significant process and validation enhancements in this area. The operational manual was revised to include detailed procedures. Management manually reviewed CIP codes for all programs and updated system records as appropriate on October 12, 2023. Management conducted two subsequent reviews on January 3, 2024, and January 5, 2024, to ensure compliance with the requirements. Implementation Dates: Revisions to operational manual, October 12, 2023. Updates to system records, October 12, 2023. Management review for continued compliance, January 3, 2024 and January 5, 2024. Responsible Persons: Blanca E. Guerra, Ph.D., University Registrar Brandy Simpkins Piner, M.P.A., Senior Associate Registrar
Corrective Action Plan: Through analysis of the exceptions identified in the audit, the University is working to implement corrective action that will consistently report the OPEID of the location where students are taking the majority of their coursework. Implementation Date: March 2025 Responsible...
Corrective Action Plan: Through analysis of the exceptions identified in the audit, the University is working to implement corrective action that will consistently report the OPEID of the location where students are taking the majority of their coursework. Implementation Date: March 2025 Responsible Person: Tiffany Robinson, AVP and University Registrar
Corrective Action Plan: The University has already established a campus-wide working group to provide additional modifications to the current procedures for Enrollment Reporting. Through this collaboration, the Institution is implementing changes to the spring 2024 semester that will provide the Uni...
Corrective Action Plan: The University has already established a campus-wide working group to provide additional modifications to the current procedures for Enrollment Reporting. Through this collaboration, the Institution is implementing changes to the spring 2024 semester that will provide the University with the necessary tools to comply with the Federal Enrollment Reporting regulations. Implementation Date: May 2024 Responsible Person: Nohemi Gallarzo, Registrar & AVP for Enrollment Operations
Corrective Action Plan: The University has implemented process enhancements in this area. While the audit identified inaccurate Program Enrollment Effective Dates, the corresponding Campus Enrollment Effective Dates were accurate. To address this inconsistency, coding modifications have been created...
Corrective Action Plan: The University has implemented process enhancements in this area. While the audit identified inaccurate Program Enrollment Effective Dates, the corresponding Campus Enrollment Effective Dates were accurate. To address this inconsistency, coding modifications have been created, tested, and applied to ensure our enrollment reporting files are accurate and match on Program Enrollment Effective Date and Campus Enrollment Effective Date. Beginning with our fall 2023 subsequent of term enrollment file received by the National Student Clearinghouse (NSC) on 12/18/23, the students’ Program Enrollment Effective Dates are accurate and match the associated Campus Enrollment Effective Dates. Our documentation will be revised to include these changes. Management will conduct a second level review to ensure that the University is in compliance with the requirements. Implementation Date: December 2023 Responsible Person: Eric Poch, Associate Registrar
Corrective Action Plan: The Office of the Registrar is working with the Office of Information Technology (OIT) to review the current NSC Enrollment Reporting logic within our student information system to identify the root cause of the data inconsistencies between campus- and program-level data, and...
Corrective Action Plan: The Office of the Registrar is working with the Office of Information Technology (OIT) to review the current NSC Enrollment Reporting logic within our student information system to identify the root cause of the data inconsistencies between campus- and program-level data, and subsequently update the associated logic for future term reporting. The Office of the Registrar has also implemented monthly data validation into our business processes (as of Fall 2023), in alignment with the NSC file submission schedules, which allows for further management oversight of deadline compliance and additional data validation. Implementation Date: August 1, 2024 Responsible Persons: Kimberly Tate, University Registrar Deepika Chalemela, Chief Information Officer
Corrective Action Plan: The University has implemented significant process enhancements in this area. The policy manual has been revised to include detailed procedures. Management will conduct a second level review to ensure that the University is following the requirements. After the aid year activ...
Corrective Action Plan: The University has implemented significant process enhancements in this area. The policy manual has been revised to include detailed procedures. Management will conduct a second level review to ensure that the University is following the requirements. After the aid year activation for calendars is posted by the Office of Registrar, management will review calendar dates and other components reported to COD on a monthly schedule to ensure accuracy. COD reports are sent twice a week to ensure calendar and cost of attendance is updated correctly for all federal programs. Implementation Date: March 2024 Responsible Persons: Leanne Sikora, Associate Director Laurie Rosenkrantz, Associate Director
Corrective Action Plan: We will work to reestablish access with NSLDS to ensure that all student statuses are reported correctly from NSC. We will also incorporate procedures to ensure we are capturing and reporting all students’ status changes accurately through Cognos reports and a newly developed...
Corrective Action Plan: We will work to reestablish access with NSLDS to ensure that all student statuses are reported correctly from NSC. We will also incorporate procedures to ensure we are capturing and reporting all students’ status changes accurately through Cognos reports and a newly developed enrollment reporting dashboard. Implementation Date: Summer 2024 Responsible Person: Amanda McSween, TTUHSC Registrar
Corrective Action Plan: • The University has already implemented significant process enhancements in this area. • Additional checks are now in place to ensure that campus-level and program level reporting is accurate moving forward. • Additional checks have also been put in place to ensure that dual...
Corrective Action Plan: • The University has already implemented significant process enhancements in this area. • Additional checks are now in place to ensure that campus-level and program level reporting is accurate moving forward. • Additional checks have also been put in place to ensure that dual-majors graduation statuses are reporting accurately and in a more timely manner moving forward. Implementation Date: January 2024 Responsible Persons: Kyle Phillips and Bobbie Brown
Corrective Action Plan: Texas Southern University agrees with the information that states the student’s program length was incorrectly reported to NSLDS for 10 of 60 students tested. To further enhance reporting accurate information, the Office of Student Records (formerly the Registrar’s Office) ha...
Corrective Action Plan: Texas Southern University agrees with the information that states the student’s program length was incorrectly reported to NSLDS for 10 of 60 students tested. To further enhance reporting accurate information, the Office of Student Records (formerly the Registrar’s Office) has updated our business practice regarding this matter in the following way. First, the Office of Student Records reached out to the Interim Dean of the Graduate School to provide the correct program length for Graduate Programs at TSU. Second, we gathered information regarding the total number of hours of each program offered and the total number of hours required to be considered a fulltime student at TSU. We then utilized this information to calculate the program length in years. (For example, the eMPA program at TSU is 36 hours and a full-time course load for a graduate student is 9 hours. We then divided the total hours of the program (36 hours) by the full-time load (9). This provided us with how many semesters a full-time student would take to complete the program. To finish the calculation and get the program length, we divided it into 2 to get the number of years required to complete the program. Implementation Date: January 2024 Responsible Person: Dr. Nickolaus Cioci, Dean of Student Records Corrective Action Plan: Texas Southern University also agrees with the information stating 17 of 38 student’s tested enrollment status was not reported to NSLDS in a timely manner. We agree with this information that states 13 of the students tested did not have their graduation effective date accurately reported to NSLDS in a timely manner. To combat this issue, the Office of Student Records has created a new business process to report these students to NSLDS in a timelier manner. First, the graduation coordinator has requested academic units to provide her with information regarding students whose degrees are 100% complete earlier to allow her to confer these degrees quicker. Second, the Office of Student Records has also changed their business practice and informed both the Graduation Coordinator and the Law School Registrar’s representative that all degrees must be conferred no later than 45 days after the semester ends. This will allow other staff time to turn in the graduation report to NSC in a timelier manner and review the rejected records/correct the rejected records before the 60-day deadline to help keep us in compliance. Implementation Date: January 2024 Responsible Person: Dr. Nickolaus Cioci, Dean of Student Records Corrective Action Plan: Texas Southern University also agrees with the information stating 4 students that did not have their withdrawal status or effective date of status change reported in a timely manner to NSLDS. In reviewing these records, it appears accurate attendance was not taken causing Texas Southern University to be out of compliance for reporting practices. To further enhance reporting capabilities, the Office of Student Records has created a new business process to correct this error. First, TSU no longer allows advisors to register students and students must register themselves and sign a financial acknowledgement form. Also, the Office of Student Records has collaborated with the Office of the Provost to effectively communicate with faculty the ramifications of inaccurate attendance reporting. In these communications, the faculty are also provided instructions on how to accurately report attendance using their MyTSU attendance portal. Also, the Office of Student Records worked in conjunction with the Office of Information Technology, to automate the process of dropping students for nonattendance as reported by their faculty. Furthermore, we are continuing to update our business processes, so these students are reported to NSC/NSLDS in a timely manner. Another issue involved students being reported as nonattending but attending the course. TSU’s Office of Student Records and Office of the Provost have also worked in conjunction to fix this issue as well. Several faculty members would not mark attendance causing their whole class to get dropped. We have worked in our process to inform instructors they must mark attendance for students to not create this issue in the future. Implementation Date: January 2024 Responsible Person: Dr. Nickolaus Cioci, Dean of Student Records
Corrective Action Plan: The University, with the National Student Clearinghouse (NSC), has developed an expanded enrollment reporting schedule for reporting graduated students on special “Graduates Only” files after subsequent semester enrollment reporting has begun. Previously, we relied on the Deg...
Corrective Action Plan: The University, with the National Student Clearinghouse (NSC), has developed an expanded enrollment reporting schedule for reporting graduated students on special “Graduates Only” files after subsequent semester enrollment reporting has begun. Previously, we relied on the DegreeVerify file to report Graduated status. The Graduates Only files, which will include only students with an awarded credential for the semester and are a supplement to the regular Enrollment files sent during the semester, will ensure that Graduated statuses for Doctor of Veterinary Medicine students are reported accurately and in a timely manner. The use of a supplemental Graduates Only enrollment file will also eliminate warning files that currently result from the DegreeVerify reporting process. Should there be an issue with the Graduates Only file, an enrollment reporting warning/error file will be received and processed in a timely manner, as they are during the semester when an Enrollment file generates a warning/error report. The new process will be more consistent, efficient, and complete. The Graduates Only file transmission schedule for the current semester has been updated and procedures for setting the enrollment reporting schedule each year have been updated to include the expanded Graduates Only file transmission schedule. Discussion with the NSC resulted in a clear understanding of how the Graduates Only files should be processed to ensure accurate and complete reporting of Graduated statuses. All staff members responsible for processing of the Graduates Only files have been trained in this procedure, and additional information has been included in written procedures for processing the files. Implementation Date: November 2023 Responsible Person: Venesa Heidick, Registrar
Corrective Action Plan: The Office of the Registrar will develop an action plan to evaluate the internal process changes which must occur considering the following implications: • There will be significant process changes of the reporting parameters that are run for the National Student Clearinghous...
Corrective Action Plan: The Office of the Registrar will develop an action plan to evaluate the internal process changes which must occur considering the following implications: • There will be significant process changes of the reporting parameters that are run for the National Student Clearinghouse jobs in Banner to ensure that the proper branch code is identified for each student; • Further research will be required to identify other areas which will be impacted by this change, including but not limited to IPEDS data submissions, CBM Reporting, SACSCOC notifications, etc.; • Will collaborate with College of Graduate Studies to remove degree plans that are listed as sought and are not actively being pursued by the student. This will ensure that correct degree sequencing is accounted for and reported on correctly each month to the National Student Clearinghouse; • Strengthen internal controls and communication channels to ensure consistent and accurate reporting of student statuses across all levels. Implementing additional validation checks in our reporting systems will ensure the accuracy of program begin dates before submission; • Update our standard operating procedures to indicate review of the National Student Clearinghouse EDI Rejection File to ensure all students are accurately being pulled into NSLDS; • Conduct a comprehensive review of our reporting procedures to identify the specific breakdown in the process that led to the failure to report enrollment status to NSLD; • Implement enhanced internal controls and validation checks to ensure that enrollment statuses are accurately reported to both NSC and NSLDS in a timely manner; and • The policies and procedures will be revised to include these updated procedures. Implementation Date: January 2024 Responsible Person: Erika Graham, University Registrar
Corrective Action Plan: The University has formally documented the procedures that have been put in place. The University will address issues with National Student Clearinghouse (NSC) reporting and will attempt to fix each issue before sending to NSC, including Social Security Number, Name, and othe...
Corrective Action Plan: The University has formally documented the procedures that have been put in place. The University will address issues with National Student Clearinghouse (NSC) reporting and will attempt to fix each issue before sending to NSC, including Social Security Number, Name, and other miscellaneous issues. The procedures include three DegreeVerify files being sent that report graduates and the University will be adding three more DegreeVerify files to be sent two to three weeks after the end of the semester, part of term and end of mini to pick up remaining graduates for the term. The University will have the Information and Analysis team create a report each term of students that were enrolled in the previous semester but are not enrolled in the current semester so that they can be reported as withdrawn to NSC correctly. Implementation Date: February 2024 Responsible Person: Cheri Lewis, Enrollment Management Analyst
Corrective Action Plan: The University has implemented significant enhancements- in its process to grant user access. In addition, to address the specific exceptions noted by the State Auditor’s Office, access for all staff within the SIS has been restricted from disbursing aid. Access is now only g...
Corrective Action Plan: The University has implemented significant enhancements- in its process to grant user access. In addition, to address the specific exceptions noted by the State Auditor’s Office, access for all staff within the SIS has been restricted from disbursing aid. Access is now only granted to the batch user account. Implementation Date: 11/2023 Responsible Person: Scott Lapinski, Assistant Vice President for Enrollment Management/Director of Financial Aid
Corrective Action Plan: In the event that an employee transitions to another University department but needs to retain access for a period of time to facilitate knowledge transfer or to provide backstop support during the transition period, a date will be set for removing that access by setting an e...
Corrective Action Plan: In the event that an employee transitions to another University department but needs to retain access for a period of time to facilitate knowledge transfer or to provide backstop support during the transition period, a date will be set for removing that access by setting an expiration date on the authorization, when feasible. If an automated access expiration date is not available, a calendar meeting will be scheduled for at least 2 people authorized to remove that access to remind them to remove the access. Implementation Date: January 2024 Responsible Person: Diane Todd Sprague, Assistant Vice Provost for Scholarships and Financial Aid Corrective Action Plan: The University is currently in the process of replacing its current custom-developed, mainframe-based financial aid management system with a vendor-provided, cloud-based system. The current issue with the mainframe programming library not being under change control will be resolved with the implementation of the new financial aid management system. Implementation Dates: Rolling implementation starting February 2024 through August 2024 Responsible Person: Graham Chapman, Assistant Vice Provost and Director of Academic Information Systems
Corrective Action Plan: In response to the current finding of temporary access monitoring, the frequency of reviews for people that have temporary Financial Aid role assignments will be increased from an annual review to quarterly, for a period of two years. Staff training for access control and bus...
Corrective Action Plan: In response to the current finding of temporary access monitoring, the frequency of reviews for people that have temporary Financial Aid role assignments will be increased from an annual review to quarterly, for a period of two years. Staff training for access control and business owner training has taken place, to increase awareness that roles need timely removal when maintenance tasks are completed. Implementation Date: 1/29/24 Responsible Persons: Karen Krause, Office of Financial Aid Doug Bergere, Office of Information Technology
Corrective Action Plan: • The University has already implemented significant process enhancements in this area. • The University immediately reviewed all Financial Aid security access and removed any access not deemed immediately necessary to the employee’s job duties. • The University has developed...
Corrective Action Plan: • The University has already implemented significant process enhancements in this area. • The University immediately reviewed all Financial Aid security access and removed any access not deemed immediately necessary to the employee’s job duties. • The University has developed Financial Aid security classes based on employee positions. This will allow us to more easily monitor what access an employee has and ensure that it is appropriate to their job responsibilities. Implementation Date: September 2023 Responsible Persons: Kyle Phillips and Robert Hamilton
Corrective Action Plan: Through analysis of the exceptions identified in the audit, the University has developed a standard operating procedure to assign employee access based on the principle of least privilege as determined by individual roles. The university is engaged with a third-party vendor t...
Corrective Action Plan: Through analysis of the exceptions identified in the audit, the University has developed a standard operating procedure to assign employee access based on the principle of least privilege as determined by individual roles. The university is engaged with a third-party vendor to procure and implement an automated role-based access assignment process, to ensure that the University complies with this audit findings requirements. Implementation Date: June 2024 Responsible Person: Mr. Matthew Steimel, Director of Enterprise Applications
Corrective Action Plan: The user access has been limited to their specific job function. The university will verify user access was appropriately updated/removed. Access review procedures will be reviewed to ensure access is appropriately assigned in the future. To streamline and assure a consistent...
Corrective Action Plan: The user access has been limited to their specific job function. The university will verify user access was appropriately updated/removed. Access review procedures will be reviewed to ensure access is appropriately assigned in the future. To streamline and assure a consistent outcome regarding the approvals for security patches to be introduced to the production environment, the University will convert these normal changes to standard changes. A standard change is “A pre-authorized change that is low risk, relatively common and follows a procedure or work instruction. (ITIL v4 definition.)” Software patching and updates are standard change candidates. Not applying security patches in a timely manner introduces a greater risk to the University than processing these requests as a normal change. A standard change is pre-authorized and will address how IT is testing and/or validating whether the OS patches were successful in an available test environment prior to deployment to production. Test procedures will be documented as a requirement of the Standard Change Model. IT will document that outcome of the testing and/or validating of the OS patch as a Journal entry on the Standard Change prior to implementation. The Change Advisory Board (CAB) will review these changes/procedures on a regular basis to ensure we are in compliance. Policies, Standards and Procedures will be updated to meet any required changes. Implementation Date: January, 2025 Responsible Persons: Michael Dewey, Chief Technology Officer Amy Wilson, Director of Financial Aid and Scholarships
Corrective Action Plan: When the office of Student Aid began work on the Fiscal Operations Report and Application to Participate (FISAP), a discrepancy in the PELL amount was identified. The SAO team requested the FISAP in October 2023, which notated that the PELL amount would need to be submitted b...
Corrective Action Plan: When the office of Student Aid began work on the Fiscal Operations Report and Application to Participate (FISAP), a discrepancy in the PELL amount was identified. The SAO team requested the FISAP in October 2023, which notated that the PELL amount would need to be submitted by the December 15th deadline. The corrections to PELL were not resolved by the December 15th deadline, so a request for extension was requested on December 15, 2023, and granted on December 20, 2023, with an updated due date of January 3, 2024.  Part II, Section E was completed with the corrected PELL amount on final submission.  FSEOG Expenditures Reporting is being reviewed by Student Aid and Student Business Services to identify the error in reporting discrepancies. Implementation Date: February 2024 Responsible Persons: Megan Begnaud, Director of Student Aid
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