Corrective Action Plans

Finding 374513 (2023-001)

Significant Deficiency 2023

CA

Student Financial Aid Eligibility Reporting

Management’s Corrective Action Plan Soka University acknowledges the finding and the recommendation regarding improving procedures. Finding 2023-001 - Special Tests and Provisions – Enrollment Reporting: Significant Deficiency in Internal Control over Compliance After addressing the identified defic...

Management’s Corrective Action Plan Soka University acknowledges the finding and the recommendation regarding improving procedures. Finding 2023-001 - Special Tests and Provisions – Enrollment Reporting: Significant Deficiency in Internal Control over Compliance After addressing the identified deficiency in our enrollment reporting process, a thorough evaluation was conducted to rectify the issue and prevent its recurrence. We recognized that alterations in students' academic plans, prompted by the COVID-19 pandemic, led to delays in fulfilling mandatory graduation requirements such as study abroad requirements, resulting in delays in posting study abroad grades to the Soka transcript. Consequently, during end-of-term degree audits by the Office of the Registrar, students with pending study abroad grades or incomplete grades in their final term were inadvertently not updated to a withdrawn status, thereby failing to trigger updates to the National Student Clearinghouse and subsequently National Student Loan Data System (NSLDS). In collaboration with the Office of the Registrar, robust internal controls have been implemented to mitigate this issue going forward. Following the conclusion of each term, the Registrar will generate a comprehensive report listing all students who have applied for degree completion. This report will be annotated to identify students who have fulfilled all degree requirements, enabling their degrees to be conferred promptly. Additionally, students with incomplete grades will be flagged, and their status will be promptly changed to withdrawn. In both scenarios, enrollment status updates will be transmitted to the clearinghouse and subsequently NSLDS. The Registrar will inform the Office of Financial Aid of graduates and students with updated statuses for NSLDS reporting, and Financial Aid will request an ad hoc enrollment request on NSLDS. To ensure accuracy, a manual spot-checking process will be conducted in NSLDS on 20% of the updated student records in NSLDS. Upon notification of completed incomplete grades, the Registrar will promptly update transcripts, review degree requirements, and confer degrees where applicable. Following this update, the Registrar will manually update the clearinghouse and ask the Office of Financial Aid to request an Ad hoc enrollment report on NSLDS, ensuring timely and accurate reporting. This manual request will be verified on NSLDS after the ad hoc report has been run. Students failing to meet degree requirements due to failed coursework and are enrolled to return in subsequent terms will not be updated to withdrawn status unless they fail to return as scheduled. These measures aim to enhance the integrity and accuracy of our enrollment reporting process, ensuring compliance with regulatory requirements and minimizing the risk of future deficiencies. Anticipated Completion Date: February 2024 Scott Brandos Director of Financial Aid Soka University of America 949-480-4048

View Audit 294224

Finding 374493 (2023-003)

Significant Deficiency 2023

Lighthouse Community Public Schools

CA

Procurement, Suspension & Debarment Subrecipient Monitoring School Nutrition Programs § 200.320

Views of responsible officials and Corrective Action Plan: Management of the School has noted the 2 CFR Section 200.320 to ensure that the procurement requirements are met.

View Audit 294202

Finding 374492 (2023-001)

Significant Deficiency 2023

Lighthouse Community Public Schools

CA

Reporting Significant Deficiency Internal Control / Segregation of Duties

Views of responsible officials and Corrective Action Plan: Controls will be implemented for future reporting and the School will correct the reporting errors in the following period.

View Audit 294202

Finding 374491 (2023-001)

Significant Deficiency 2023

Cairn University

PA

Reporting Student Financial Aid Significant Deficiency

Views of Responsible Officials and Planned Corrective Actions: The University agrees with this recommendation and will ensure that staff with reporting compliance responsibilities are appropriately trained during periods of transition.

View Audit 294192

Finding 374479 (2023-001)

Significant Deficiency 2023

Brattleboro Development Credit Corporation

VT

Reporting Subrecipient Monitoring Significant Deficiency

Audit Finding Reference: 2023-001 Improve Controls and Timing of Reporting Planned Corrective Action: The Organization currently has written Grant Management Policies, and Management agrees with this finding, that these policies do not adequately address the Federal Funding Accountability and Tran...

Audit Finding Reference: 2023-001 Improve Controls and Timing of Reporting Planned Corrective Action: The Organization currently has written Grant Management Policies, and Management agrees with this finding, that these policies do not adequately address the Federal Funding Accountability and Transparency Act (Pub. L. No. 109-282), as amended by Section 6202 of Public Law 110-252 which requires recipients (i.e., direct recipients) of grants or cooperative agreements to report first-tier subawards of $30,000 or more to the Federal Funding Accountability and Transparency Act Subaward Reporting System. The Organization will update its Grant Management Policies to address the requirements of the Federal Funding Accountability and Transparency Act, and once formally adopted, the Organization will distribute the new policies and procedures to necessary staff, as well as advise and train its staff on following such policies and procedures. Planned Implementation Date of Corrective Action: June 30, 2024 Person Responsible for Corrective Action: Director of Finance & Grant Management

View Audit 294142

Finding 374472 (2023-002)

Significant Deficiency 2023

Bay De Noc Community College

MI

Subrecipient Monitoring Special Tests & Provisions Allowable Costs / Cost Principles

Auditor Description of Condition and Effect. The most recent Gramm Leach Bliley Policy fails to address the implementation of safeguards to control the risks the institution identifies through its risk assessment, the testing or monitoring the effectiveness of the safeguards implemented, and the eva...

Auditor Description of Condition and Effect. The most recent Gramm Leach Bliley Policy fails to address the implementation of safeguards to control the risks the institution identifies through its risk assessment, the testing or monitoring the effectiveness of the safeguards implemented, and the evaluation and adjustment of its information security program in light of the results of the required testing and monitoring. As a result of this condition, the College is not meeting the safeguard requirements necessary to comply with the FTC. In addition, the lack of safeguard controls creates an increased risk to highly sensitive data that is possessed by the College. Auditor Recommendation. We recommend that the College implement procedures to ensure that all Gramm Leach Bliley Policies are met and verified by a second individual. Corrective Action. Currently, the College is reviewing the compliance requirements for the Gramm Leach Bliley Act and will amend the current policy to ensure that each safeguard is being addressed within the policy. Responsible Person. Jonathan Lane, Director of IT. Anticipated Completion Date. June 30, 2024

View Audit 294140

Finding 374465 (2023-001)

Significant Deficiency 2023

Bay De Noc Community College

MI

Special Tests & Provisions Student Financial Aid Allowable Costs / Cost Principles

Auditor Description of Condition and Effect. A break of at least five consecutive days was not excluded from the reported enrollment period for the Fall 2022 semester, which resulted in the calculation being incorrect for all students who had returns in the Fall 2022 semester. As a result of this co...

Auditor Description of Condition and Effect. A break of at least five consecutive days was not excluded from the reported enrollment period for the Fall 2022 semester, which resulted in the calculation being incorrect for all students who had returns in the Fall 2022 semester. As a result of this condition, Return of Title IV calculations were incorrect for 60 students for the Fall 2022 semester, resulting in $10,459 less funds returned to the U.S. Department of Education. It is our understanding that on July 24, 2023, the College repaid the 60 students affected by this calculation error. Auditor Recommendation. We recommend that the College implement a review process to ensure the number of enrollment days used in the Return of Title IV calculations is accurate and that the R2T4 calculation is reviewed by a second individual. Corrective Action. Upon discovery of the Return of Title IV Calculation error, the College went through and made corrections to all student accounts affected. To prevent a similar problem arising in the future, the College has developed a review process that will require an additional sign‐off for the total days to be used in the calculation. Responsible Person. Ruth Carlson, Director of Financial Aid. Anticipated Completion Date. July 24, 2023.

View Audit 294140

Finding 374462 (2023-002)

Significant Deficiency 2023

Latino Network

OR

Allowable Costs / Cost Principles Internal Control / Segregation of Duties Subrecipient Monitoring

2023-002 Finding – Federal Award – Significant Deficiency in Internal Control over Compliance - Allowable Costs Context: Expenditures should be charged to the proper programs and allocated in accordance with the cost allocation plan and documentation of approval of any subsequent change to the alloc...

2023-002 Finding – Federal Award – Significant Deficiency in Internal Control over Compliance - Allowable Costs Context: Expenditures should be charged to the proper programs and allocated in accordance with the cost allocation plan and documentation of approval of any subsequent change to the allocation plan should be maintained. Recommendation: We recommend management implement procedures to ensure that costs charged to the grant follow the approved cost allocation and documentation of approved changes to allocations be maintained. Action Taken: Management concurs with the auditor’s finding and will enhance documentation protocols, standardize the approval process, and have regular reviewing and monitoring.

View Audit 294126

Finding 374446 (2023-001)

Significant Deficiency 2023

Young Harris College

GA

Student Financial Aid Matching / Level of Effort / Earmarking Special Tests & Provisions § 200.303

Finding 2023-001: Special Test and Provisions: Enrollment Reporting Context/Condition: Of the 37 students selected for enrollment reporting testing, 5 students within the sample were reported to NSLDS outside the maximum 60-day window. Recommendation: The auditor recommended that the College revie...

Finding 2023-001: Special Test and Provisions: Enrollment Reporting Context/Condition: Of the 37 students selected for enrollment reporting testing, 5 students within the sample were reported to NSLDS outside the maximum 60-day window. Recommendation: The auditor recommended that the College review and update internal controls to ensure student enrollment status in the National Student Loan Data System (NSLDS) is updated in a timely manner to ensure compliance with Federal Requirements. Persons Responsible for Corrective Action: Tammy Gibson, Registrar Planned Corrective Action: Additional dates will be added to the National Student Clearinghouse submission schedule to capture December graduates. In addition, Registrar's Office staff will be instructed to update individual student records, as needed, to account for changes outside of the submission schedule to avoid reporting outside of the maximum 60-day window. Anticipated Completion Date: December 8, 2023

View Audit 294103

Finding 374445 (2023-003)

Significant Deficiency 2023

West Lyon Community School District

IA

Internal Control / Segregation of Duties Significant Deficiency Matching / Level of Effort / Earmarking

Finding 2023‐003 Special Tests – Wage Rate Requirement Significant Deficiency Finding Summary: The District did not sure proper and timely inclusion of prevailing wage clauses in one construction contract issued in the prior year and still in effect this year. Responsible Individuals: Shawn Kreman, ...

Finding 2023‐003 Special Tests – Wage Rate Requirement Significant Deficiency Finding Summary: The District did not sure proper and timely inclusion of prevailing wage clauses in one construction contract issued in the prior year and still in effect this year. Responsible Individuals: Shawn Kreman, Superintendent Corrective Action Plan: The District will include prevailing requirements in contracts utilizing federal dollars. Anticipated Completion Date: Ongoing

View Audit 294102

Finding 374389 (2023-005)

Significant Deficiency 2023

Bethany College

KS

Subrecipient Monitoring Special Tests & Provisions Significant Deficiency

Corrective Action Plan 2023-005: The College concurs with the finding and will formalize its written Information Security Program. Completion Date: Spring 2024 Contact Person: Joshua Bieber, Director of Information Technology

View Audit 293985

Finding 374388 (2023-004)

Significant Deficiency 2023

Bethany College

KS

Questioned Costs Student Financial Aid Eligibility

Corrective Action Plan 2023-004: The College concurs with the finding and has reviewed and where appropriate made updates to the processes used to package loans when there is an annual or aggregate loan limit reached. Completion Date: August 2023 Contact Person: Haley Wesley, Vice President of Enr...

Corrective Action Plan 2023-004: The College concurs with the finding and has reviewed and where appropriate made updates to the processes used to package loans when there is an annual or aggregate loan limit reached. Completion Date: August 2023 Contact Person: Haley Wesley, Vice President of Enrollment Management & Marketing

View Audit 293985 Questioned Costs: $1

Finding 374382 (2023-003)

Significant Deficiency 2023

Bethany College

KS

Special Tests & Provisions Subrecipient Monitoring Significant Deficiency

Corrective Action Plan 2023-003: The College has obtained the required letter of credit from a local bank and will comply with federal heightened cash monitoring requirements. The College continues to work to positively align revenues and expenses. The College regularly monitors its cash flows and e...

Corrective Action Plan 2023-003: The College has obtained the required letter of credit from a local bank and will comply with federal heightened cash monitoring requirements. The College continues to work to positively align revenues and expenses. The College regularly monitors its cash flows and expense budgets both for timing and savings. Efforts continue to increase net student revenues to reduce the need for current-year contributions and other income for operating expenses. The College will continue to carefully plan and manage institutional financial aid to yield stronger net student revenues to support operations. Anticipated Completion Date: August 2024 Contact Person: Steven W. Eckman, President

View Audit 293985

Finding 374345 (2023-002)

Significant Deficiency 2023

Town of Bridgwater, Vermont

VT

Subrecipient Monitoring Significant Deficiency Matching / Level of Effort / Earmarking § 200.302

Update grant spreadsheet monthly

View Audit 293943

Finding 374344 (2023-001)

Significant Deficiency 2023

Town of Bridgwater, Vermont

VT

Subrecipient Monitoring Allowable Costs / Cost Principles Significant Deficiency § 200.302

Adopt suggested policies as outlined by auditor

View Audit 293943

Finding 374343 (2023-001)

Significant Deficiency 2023

Lexington-Fayette Urban County Housing Authority

KY

HUD Housing Programs Subrecipient Monitoring Eligibility

Re: 2023-01 Audit Finding/Plan of Action The Lexington Housing Authority (LHA) proposes this corrective plan of action to address the late recertifications (13) and annual recertification (1) from the audit conducted by Rector, Reeder & Lofton PC, onsite at LHA September 25-29, 2023. ADDRESSING S...

Re: 2023-01 Audit Finding/Plan of Action The Lexington Housing Authority (LHA) proposes this corrective plan of action to address the late recertifications (13) and annual recertification (1) from the audit conducted by Rector, Reeder & Lofton PC, onsite at LHA September 25-29, 2023. ADDRESSING STAFFING Securing qualified candidates to fill Housing Management Specialist (HMS) positions throughout 2020, 2021 and 2022 was challenging for LHA. In some instances, positions were vacant for up to 12 months before they were filled. LHA will do the following to address staffing: • Seek to fill HMS positions within forty-five (45) days of the position going vacant. • Advertise to hire two full-time HMS positions for the two management teams with the most units in their management portfolio. • Continue to advertise open positions online, on social media and in the local newspaper. • Offer incentive bonus up to $1,500 to newly hired HMS, paying $750 to new hires after six month of employment and an additional $750 after 12 months of employment. • Over-time will be allowed on an as-needed basis to complete and process certifications. CERTIFICATION PROCEDURES Further, LHA housing management staff will adhere to the following procedures to facilitate timely completion of annual certifications. - HMS staff will continue utilize in-person interviews and mail (via USPS and email) to complete needed documentation for annual certifications. - All housing management staff may utilize electronic signature to attain required signatures when necessary. - The first day of each month housing managers will run the certification audit report to be shared with the Chief Operating Officer to monitor the status of in-progress and upcoming certifications. - July 1, 2023, LHA implemented quality control (QC) of public housing files to be conducted by a newly created compliance position. LHA' s compliance coordinator will complete 229 (25%) QC reviews of public housing files during FY2024 (July 1, 2023 - June 30, 2024). - At least once monthly on a rotating basis housing management staff from all offices will convene at a selected housing management office to complete and process certifications. This schedule will continue until all offices are up to date on certifications. LHA staff will apply these procedures as outlined to mitigate this finding to ensure compliance and proper documentation of future certifications. Contact Person: Andrea Wilson, Chief Operating Officer Anticipated Completion Date: June 30, 2024

View Audit 293932

Finding 372650 (2023-001)

Significant Deficiency 2023

Pendergast Elementary School District No. 92

AZ

Cash Management Reporting School Nutrition Programs

Findings and Questioned Costs Related to Federal Awards Finding Number: 2023‐001 Program Name/Assistance Listing Title: Child Nutrition Cluster Assistance Listing Numbers: 10.553, 10.555, 10.559 Contact Person: Krystal Burnham, Food Service Compliance Coordinator/ Danny Robbins, Interim Director of ...

Findings and Questioned Costs Related to Federal Awards Finding Number: 2023‐001 Program Name/Assistance Listing Title: Child Nutrition Cluster Assistance Listing Numbers: 10.553, 10.555, 10.559 Contact Person: Krystal Burnham, Food Service Compliance Coordinator/ Danny Robbins, Interim Director of Budget and Finance Anticipated Completion Date: July 31, 2023 Planned Corrective Action: The District will ensure that monthly counts are supported by documentation and verified by a second staff member and agree to the accuracy of the reimbursement claims prior to submission to the Arizona Department of Education. The District will also ensure that reimbursement claims are submitted within the required time period after month end and any identified issues with measures that prevent their recurrence.

View Audit 293730

Finding 372633 (2023-005)

Significant Deficiency 2023

Autonomous Municipality of Ponce

PR

HUD Housing Programs Subrecipient Monitoring Eligibility

The Section 8 Program will improve its internal controls and monitoring procedures to assure the correction of income included in the 50058-Family Report. Implementation Date: During the fiscal year 2023-2024 Responsible Persons: Mr. Job Bonilla Federal Program Director

View Audit 293712

Finding 372621 (2023-006)

Significant Deficiency 2023

Agate Housing and Services, Inc.

MN

Special Tests & Provisions Eligibility HUD Housing Programs

2023-006 Reasonable Rents Documentation Name of contact person – Laura Straw, Finance Director and/or Elizabeth Machart, Director of Contracts, Compliance, & Special Initiatives Corrective action – Management has reviewed the current practice and has implemented a new form and procedures for do...

2023-006 Reasonable Rents Documentation Name of contact person – Laura Straw, Finance Director and/or Elizabeth Machart, Director of Contracts, Compliance, & Special Initiatives Corrective action – Management has reviewed the current practice and has implemented a new form and procedures for documenting the determination and approvals in the case files. Completion date – Management and the Board of Directors implemented the above as of 2/28/2024

View Audit 293672

Finding 372600 (2023-003)

Significant Deficiency 2023

Agate Housing and Services, Inc.

MN

Cash Management Significant Deficiency Internal Control / Segregation of Duties

2023-003 Lack of Support for Credit Card Charges for Former Employees Name of contact person – Laura Straw, Director of Finance Corrective action – Agate has re-instated the credit card receipt policy and has begun to enforce this policy. We are also taking action to review current policies and ...

2023-003 Lack of Support for Credit Card Charges for Former Employees Name of contact person – Laura Straw, Director of Finance Corrective action – Agate has re-instated the credit card receipt policy and has begun to enforce this policy. We are also taking action to review current policies and procedures surrounding employee credit cards and reimbursements. Completion date – Management and the Board of Directors implemented the above as of January 1, 2024.

View Audit 293672

Finding 372592 (2023-002)

Significant Deficiency 2023

Agate Housing and Services, Inc.

MN

Internal Control / Segregation of Duties Significant Deficiency

2023-002 Lack of Review on Payroll Transactions/Payroll Files Name of contact person – Laura Straw, Director of Finance Corrective action – Management is reviewing and assessing all of the payroll and human resource functions related to payroll and benefits to ensure that the correct department ...

2023-002 Lack of Review on Payroll Transactions/Payroll Files Name of contact person – Laura Straw, Director of Finance Corrective action – Management is reviewing and assessing all of the payroll and human resource functions related to payroll and benefits to ensure that the correct department and qualified employee is performing the various functions that include the payroll and benefits of an employee. HR will be hiring a Human Resource Generalist to monitor benefits and work with the payroll accountant reconcile benefits and benefit plans. Completion date – Management and the Board of Directors implemented the above January, 2024. We are implementing a new HRIS/Payroll system and making a final decision on the final by mid-February. We are anticipating a start date of 7/1/24. In the interim, a manual process had been put in place where in Payroll and HR meets bi-weekly to review all payroll changes.

View Audit 293672

Finding 372381 (2023-004)

Significant Deficiency 2023

Point University, Inc. and Subsidiaries

GA

Student Financial Aid Subrecipient Monitoring Significant Deficiency

GLBA non-compliance Finding: The University does not meet the compliance requirements outlined in the GLBA Safeguards Rule. Discrepancies were identified in requirement B.6 which addresses how the institution how the institution will oversee its information system service providers. The University ...

GLBA non-compliance Finding: The University does not meet the compliance requirements outlined in the GLBA Safeguards Rule. Discrepancies were identified in requirement B.6 which addresses how the institution how the institution will oversee its information system service providers. The University did not have a Vendor Management Program with standards in place to oversee critical system service providers regarding due diligence, risk assessments, and annual reviews as related to 3rd party service providers. Auditors' Recommendation: The University needs to review the updated GLBA requirements and ensure their WISP includes all required elements. School Response: The school agrees with this finding. Corrective Action Plan: The school's director of IT is reviewing the school's Written Information Security Plan (WISP) to ensure GLBA Compliance. A vendor management plan has been added to the WISP which specifies that any information technology vendors and products will be subjected to an IT Acquisition Process prior to use by the University. In the IT Acquisition Process, the vendors and products will be evaluated by the Information Technology Advisory Committee and the Office of Information Technology to determine impact on the current infrastructure and data systems as well as any security concerns that should be addressed prior to implementation. Name(s) of the contact person{s) responsible for corrective action: Point University Director of IT, Bill Dorminy Planned completion date for corrective action plan: • WISP and review of GLBA requirements is ongoing with completion of the current review expected by June 1, 2024.

View Audit 293636

Finding 372380 (2023-003)

Significant Deficiency 2023

Point University, Inc. and Subsidiaries

GA

Questioned Costs Student Financial Aid Eligibility

Pell Award Errors Finding: As noted in the audit report, there were 5 instances out of 60 students with Pell award errors. Auditors' Recommendation: The University should have appropriate policies and procedure, as well as safeguards in place to ensure Pell eligibility and awarding is correctly de...

Pell Award Errors Finding: As noted in the audit report, there were 5 instances out of 60 students with Pell award errors. Auditors' Recommendation: The University should have appropriate policies and procedure, as well as safeguards in place to ensure Pell eligibility and awarding is correctly determined. School Response: The school agrees with this finding and has initiated corrective action. Corrective Action Plan: For student #5, there was a Pell awarding error where the student was under awarded Pell by $172. The school made the correction to the award and disbursed the additional Pell. For student #16, student was over awarded Pell Grant for $1723 due to incorrect refunds made while adjusting for changes in the student's schedule. The school has refunded the $1723 over award back to the fund source. For student #24, the student was initially awarded correctly, but withdrew during their 2nd term. Due to incorrect Pell Recalculation on the R2T4, the school refunded too much Pell grant, and the student was under awarded by $458. The school has disbursed the additional Pell so the student is now paid correctly. For student #27, the student was over awarded Pell by $350 due to in error in Pell Recalculation based on the student's schedule. The school has refunded the over award to the fund source. For student #43, the student was under awarded by $22 due to an error in Pell Recalculation based on the student's schedule. The school has disbursed the additional Pell grant funds to correct the error. Starting with the Fall 2023 semester the school has implemented a new student information system (SIS), Colleague. The school has also partnered with a third-party servicer, Financial Aid Services (FAS), to assist with packaging. The new SIS automatically adjusts Pell grant whenever there is a change to a student's schedule during the term through the school's census date for each term and module. The system will schedule a refund for any over awards and increase the Pell award for any that may have been under awarded. Since this is no longer reviewed solely by the financial aid office, this is expected to reduce the number of errors in Pell awarding. In addition to the system adjustments, the school's third-party servicer, FAS, will review packaging for any students with changes to the number of registered credits during the term to ensure the system is making adjustments properly and the students are correctly packaged. Name(s) of the contact person{s) responsible for corrective action: Financial Aid Director, Holly Hardnett and third-party servicer, FAS, representative Planned completion date for corrective action plan: • New Colleague SIS implemented live beginning in the Fall semester 2023. • Training for Pell Recalculations in Colleague July 2023. • Registration/schedule changes for term reviewed by FAS at least weekly.

View Audit 293636 Questioned Costs: $1

Finding 372379 (2023-002)

Significant Deficiency 2023

Point University, Inc. and Subsidiaries

GA

Student Financial Aid Reporting Significant Deficiency

NSLDS Enrollment Reporting (repeat) Finding: As noted in the audit report, there were 4 discrepancies found in 17 files in which student information reported to NSLDS was incorrect or untimely. • 2 students' status was incorrectly reported to NSLDS. • 1 student's enrollment effective date was not r...

NSLDS Enrollment Reporting (repeat) Finding: As noted in the audit report, there were 4 discrepancies found in 17 files in which student information reported to NSLDS was incorrect or untimely. • 2 students' status was incorrectly reported to NSLDS. • 1 student's enrollment effective date was not reported correctly to NSLDS. • 1 student's enrollment status change was not reported to NSLDS within 60 days. Auditors' Recommendation: The University should review their enrollment reporting policies and procedures to ensure accurate reporting. School Response: The school agrees with this finding and has initiated corrective action. Corrective Action Plan: There were two files in which NSLDS reporting errors were found. Student #12 was withdrawn per their school transcript effective 5/14/2023, however, the enrollment status was reported at NSLDS as Less Than Half Time as of 5/8/2023. Student #14 was in a Graduate status on their transcript but was reported as Withdrawn on NSLDS. Also, the student's status was reported 134 days after the status change event. Status changes must be reported to NSLDS within 60 days. The instances for this finding occurred during a time when there was a staffing change in the registrar's office and a new registrar had not yet transitioned into the position. Since this time, a new registrar, Natalie Brown-Motes, was hired, and the process has been reviewed with Assistant Registrar, Lara Ellison, to ensure that there is a back up plan if the registrar is unavailable to complete this process. Additionally, the school switched to a new Student Information System (SIS), Colleague, which was implemented beginning with the Fall semester 2023. The new SIS works with the National Student Clearinghouse enrollment reporting service. In order to ensure timely reporting, the registrar's office creates an enrollment report in Colleague each month. That report is transmitted to Clearinghouse which uses the information to update the enrollment data in NSLDS. If there are any possible errors that need to be reviewed, the registrar receives a report on Clearinghouse of any errors so they can be reviewed and approved or corrected. The error report must be completed within two weeks of receipt. Colleague only reports to Clearinghouse students who have actually registered for classes. Previously, enrolled students who had not registered were included in the report. This inclusion regularly generated additional errors. Since the new system improves the reporting process so only registered students are reported, there is less opportunity for error. Name(s) of the contact person(s) responsible for corrective action: University Registrar, Natalie BrownMotes and Assistant Registrar, Lara Ellison Planned completion date for corrective action plan: • New Colleague SIS implemented live beginning in the Fall semester 2023. • Training on National Student Clearinghouse process with Colleague completed September 23. • Began using Colleague system to report enrollment data to NSLDS through National Student Clearinghouse in September 2023.

View Audit 293636

Finding 372378 (2023-001)

Significant Deficiency 2023

Point University, Inc. and Subsidiaries

GA

Student Financial Aid Reporting Significant Deficiency

Disbursement Dates (repeat) Finding: As noted in the audit report, there were three instances in 60 files in which there were discrepancies in disbursement dates. Disbursement dates recorded on student accounts for Direct Loan and Pell disbursements did not agree to the disbursement date reported t...

Disbursement Dates (repeat) Finding: As noted in the audit report, there were three instances in 60 files in which there were discrepancies in disbursement dates. Disbursement dates recorded on student accounts for Direct Loan and Pell disbursements did not agree to the disbursement date reported to Common Origination and Disbursement (COD). Auditors' Recommendation: The University should review their policies and procedures to ensure accurate reporting to COD. School Response: The University agrees with this finding and has initiated corrective action. Corrective Action Plan: Title IV disbursements must be posted to student accounts within 15 days of the funds drawdown. Also, the disbursement date per COD must match the disbursement date on the student account. There was one instance in which the Disbursement date for a Pell Grant was 10/10/2022 per COD and 10/19/2022 on the student's account. One instance had a disbursement date at COD as 2/16/2023 and at 2/15/2023 on the student's account. The third instance had a disbursement date of 1/25/23 at COD and 1/26/23 on the student's account. Each of these disbursements were posted in the old Student Information System (SIS), Anthology. The posting process that the school used under the previous system relied primarily on manual checks by employees in various departments in which reports could be sent to COD in which the posting dates did not match the COD dates. In order to avoid this finding in the future, the University has sought out and implemented a new Student Information System (SIS), Colleague, beginning with the 2023-24 award year. The school has also contracted with a third-party servicer, Financial Aid Services (FAS}, to assist with packaging students and completing the disbursement process. To disburse funds, the Director of Financial Aid Quality and Compliance or the representative from FAS runs a report in Colleague which pulls scheduled and approved financial aid disbursements for students who have met the enrollment criteria to receive those disbursements. The report goes to the student accounts office where the financial aid is posted to the student ledgers. Then it is transmitted to COD with the posted dates so that the dates reported to COD match the dates in the SIS. If there are any errors in the transmission, the Director of Financial Aid Quality and Compliance or the representative from FAS will review the rejected disbursements and make corrections to get them processed as quickly as possible. The accounting office submits the drawdown request to G-5 for the amount of the approved and posted financial aid. The new process in which the disbursement amounts and dates transmitted to COD match the disbursement amounts and dates posted to the students' ledgers is expected to ensure compliance in the future. Name(s) of the contact person(s) responsible for corrective action: Director of Financial Aid Quality and Compliance, Rachal Wortham Planned completion date for corrective action plan: • New Colleague SIS implemented live beginning in the Fall semester 2023. • Training on new disbursement process completed August 2023. • First disbursements approved using the new SIS done by Director of Financial Aid Quality and Compliance August 2023. • Review of disbursement process with FAS October 2023. • Follow up with Colleague team to review the process and work out any flaws February 2024.

View Audit 293636

Corrective Action Plans

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