Corrective Action Plan (CAP) Institution: Westchester Community College New York Program Audited: Assistance Listing Number & Title: 84.063 – Federal Pell Grant Prepared for: Submission to Single Audit reporting package through the Federal Audit Clearinghouse (FAC) and Aid, Director, Financial Manag...
Corrective Action Plan (CAP) Institution: Westchester Community College New York Program Audited: Assistance Listing Number & Title: 84.063 – Federal Pell Grant Prepared for: Submission to Single Audit reporting package through the Federal Audit Clearinghouse (FAC) and Aid, Director, Financial Management Group – Federal Student Aid Date: August 27, 2025 1. Finding Reference • Audit Report Section: [Insert Finding Number/Reference] Finding 2024-001: Refunds of Title IV Funds Calculation and Disbursement Errors (Significant Deficiency - Special Tests and Provisions) • Description of Finding: Summarize the audit finding clearly as stated in the audit report. During the Fall 2023-2024 semester, 125 Pell Grant refund checks totaling $144,576 were issued incorrectly due to failures in the newly implemented student financial aid reporting system. • Errors Identified: 1. 10 checks totaling $11,087 were cashed, with only $1,233 returned to the college. The remaining $9,854 is considered questioned costs. 2. 51 checks totaling $56,263 were cashed, and accounts were later adjusted with student cooperation. 3. 64 checks totaling $77,226 were stopped before payment. 2. Root Cause Analysis • Cause of Noncompliance: Explain why the issue occurred (e.g., lack of internal controls, insufficient training, system error). System and operational failures due to inadequacy of the new student financial aid reporting system. • Contributing Factors: List any secondary factors (e.g., staff turnover, policy misinterpretation). 1. Data integrity issues – Automatic updates resulted in unauthorized entries and inaccurate data. 2. Communication failures – Early reports by staff of system errors were not addressed in a timely manner, resulting in delayed communication. 3. Disbursement errors – Scheduled disbursement dates canceled and rescheduled as a result of system’s inability to package students correctly. 4. SFP processing was inconsistent with US DOE COD system data. 5. Compliance date reporting errors due to SFP processing. 6. Training on the new SFP system was insufficiently provided by the vendor. In-person and self-paced training modules also not provided by the vendor. 7. SFP system contributed to incorrect financial aid packaging, requiring manual reprocessing 8. The SFP system was not aligned with unique community college scheduling features (e.g. parts of term such as winter session, 8-week semesters). 3. Corrective Action Plan Planned Corrective Measures: Detail the specific steps WCC management will take to correct the deficiency. To mitigate further damage, WCC reinstated the prior software system in April 2024, however, since the ISIRs were already determined, manual adjustments were made to students. This required additional corrective action steps: • Manual Data Corrections – Financial aid counselors manually reviewed data on approximately 6400 students and made corrections, student by student. • Reconciliation with G5 Data – Financial aid data had to be manually reconciled with G5, the federal payment system. • Compliance Adjustments – Transaction dates for compliance reporting were corrected. • Award Authorization – Student award amounts required manual verification, authorization, and approval. • Bursar’s Office Delays – Due to system errors, Bursar’s Office delayed processing refunds to prevent further financial discrepancies. • Parallel setup of on-prem financial aid system in March 2024 to prepare for the 2024-25 academic year. • Extraction of 2023-24 academic year financial aid data from SFP system and import into on-prem financial aid system. • Discontinue use of SFP on approximately 7/1/2025. • Responsible Party: Name/Title of the person(s) responsible for implementing corrective action. Garrett McAlister, Vice President of Information Technology; Dawn Gillins, Acting Vice President of Administrative Services/CFO; Dr. Erik Fortune, Assistant Vice President of Administration; Dr. Sandra Ramsey, Director of Enrollment Services; Nicola Howard-Brown, Acting Director of Financial Aid; Richard Cruz, Manager of Fiscal Operations; Garth Walcott, Program Administrator- Bursar Operations; Brian Murphy, former VP of Administrative Services/CFO; Dante Cantu, VP of Student Affairs; Anita Cook, former Director of Financial Aid. • Resources Required: Identify resources such as additional staff, training, IT system upgrades. Additional financial aid professional staff, IT/SFP system consultants. • Timeline: Expected completion date(s) for each corrective measure. Financial aid system remediation and awarding is complete. 2023-24 student financial aid data extraction/import for future reference in process. 4. Monitoring & Follow-Up • Ongoing Oversight - Describe how WCC will monitor to ensure corrective actions remain effective: WCC has a fully documented academic year financial aid project plan that is followed to ensure the timely implementation of tasks. • Internal Review Mechanisms: WCC will include periodic reviews aligned with standard DOE reporting timelines. Increase reconciliation frequency between G5 and COD. Increase periodic reviews, reports to leadership, and internal audit spot checks. 5. Evidence of Implementation • Documentation: List the types of evidence that will be maintained (e.g., revised policies, training logs, updated system reports). Project plan to revert back to previous system, training schedules, policy updates as they occur, and relevant updated system reports. • Retention: Confirm that documentation will be retained in accordance with federal regulations. WCC confirms that documentation will be retained in accordance with federal regulations. 6. Management Certification I certify that the corrective actions described above will be implemented as stated and monitored to ensure full compliance with federal requirements. Signed: Belinda S. Miles Name: Belinda S. Miles, Ed. D. Title: President Date: August 29, 2025