Corrective Action Plans

Finding 369604 (2023-006)

Significant Deficiency 2023

AZ

Student Financial Aid Eligibility Significant Deficiency

Student Financial Assistance Cluster – Assistance Listing No. Various Recommendation: We recommend that the University review its procedures related to firsttime borrowers to ensure they are in compliance with the Department of Education's regulations. Explanation of disagreement with audit finding:...

Student Financial Assistance Cluster – Assistance Listing No. Various Recommendation: We recommend that the University review its procedures related to firsttime borrowers to ensure they are in compliance with the Department of Education's regulations. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: We hold all first-time freshman loan funds for 30 days after the start to ensure we are not paying anyone early. Additionally, we will run an entrance term report prior to the start of the semester/term. From this report we can identify all first-time borrowers and tag them in populi. Prior to batching federal funds, the financial aid office will pull a report by said tag and ensure disbursements dates are 30 days from the start of the term/semester. Name(s) of the contact person(s) responsible for corrective action: Lisa Stone, Joyce Hatch and Kelly Reyes Planned completion date for corrective action plan: November 2023

View Audit 290967

Finding 369599 (2023-005)

Significant Deficiency 2023

Arizona Christian University

AZ

Questioned Costs Student Financial Aid Significant Deficiency

Student Financial Assistance Cluster – Assistance Listing No. Various Recommendation: We recommend that the University review its procedures related to outstanding student refund checks to ensure they are being returned to the Department of Education after 240 days. Explanation of disagreement with ...

Student Financial Assistance Cluster – Assistance Listing No. Various Recommendation: We recommend that the University review its procedures related to outstanding student refund checks to ensure they are being returned to the Department of Education after 240 days. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: We have created a Stale check policy & procedure. The financial aid department will work in concert with student accounts and accounts payable to ensure compliance. The process has checkpoints starting at 30, 60 up to 180 days. 60 days before a check reaches 240 days. Name(s) of the contact person(s) responsible for corrective action: Lisa Stone, Joyce Hatch, Kelly Reyes, Michael Warner, Christy Krahn and Vikki Straw. Planned completion date for corrective action plan: November 2023

View Audit 290967 Questioned Costs: $1

Finding 369594 (2023-004)

Significant Deficiency 2023

Arizona Christian University

AZ

Questioned Costs Eligibility Significant Deficiency

tudent Financial Assistance Cluster – Assistance Listing No. Various Recommendation: We recommend the University implements policies to review all student award packages at the start of the academic year to ensure no over awards exist. Explanation of disagreement with audit finding: There is no disa...

tudent Financial Assistance Cluster – Assistance Listing No. Various Recommendation: We recommend the University implements policies to review all student award packages at the start of the academic year to ensure no over awards exist. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Financial Aid Department will review all student award packages at the midpoint of each semester to ensure no overawards exist. Name(s) of the contact person(s) responsible for corrective action: Lisa Stone, Joyce Hatch, and Kelly Reyes Planned completion date for corrective action plan: May 2024

View Audit 290967 Questioned Costs: $1

Finding 369589 (2023-003)

Significant Deficiency 2023

Arizona Christian University

AZ

Student Financial Aid Reporting Significant Deficiency

Student Financial Assistance Cluster – Assistance Listing No. Various Recommendation: We recommend the Institute review its reporting procedures to ensure that students’ statuses are timely reported to NSLDS as required by regulations. Explanation of disagreement with audit finding: There is no disa...

Student Financial Assistance Cluster – Assistance Listing No. Various Recommendation: We recommend the Institute review its reporting procedures to ensure that students’ statuses are timely reported to NSLDS as required by regulations. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: After an analysis of the auditor's finding, ACU's director of financial aid, AVP of institutional effectiveness, and associate director of institutional research concluded that a misunderstanding of the National Clearinghouse's process for summer enrollment reporting was the cause of the finding. During the summer months of June, July, and August, ACU has been submitting enrollment reports, including withdrawals, only for students enrolled in summer terms. Withdrawals of students enrolled in the spring term were not being reported until after the fall term commenced. To remedy this finding, the Department of Financial Aid (FA) and the Office of Institutional Effectiveness (OIE) has coordinated with the National Student Clearinghouse (NSC) to identify which reporting method would ensure that all withdrawn students are accounted for and reported between the spring and fall terms. It was determined we would send custom files that include all withdrawn students in early June and July. The report will be uploaded through the NSC's secure file upload system at least once between May 30th and August 30th, with no more than 60 days between any two enrollment file submissions. Name(s) of the contact person(s) responsible for corrective action: Lisa Stone, Jeff Phillips and Eric Tompkins Planned completion date for corrective action plan: May/June 2024

View Audit 290967

Finding 369584 (2023-002)

Significant Deficiency 2023

Arizona Christian University

AZ

Student Financial Aid Reporting Significant Deficiency

Student Financial Assistance Cluster – Assistance Listing No. Various Recommendation: We recommend the University evaluate its procedures and policies around reporting disbursements to COD to ensure that student information is reported accurately and timely. Explanation of disagreement with audit fi...

Student Financial Assistance Cluster – Assistance Listing No. Various Recommendation: We recommend the University evaluate its procedures and policies around reporting disbursements to COD to ensure that student information is reported accurately and timely. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The incorrect date was for a student who received the Pell Grant. When we batch Pell student awards in COD; and return funds at the same time, this will often cause a shortage in our Pell G5 account. This will delay the disbursement date on the school side. Although COD releases the disbursement, the funds are not available in G5 until days later and in some cases weeks later. The first step is to not process returns and draw downs at the same time. This will ensure the funds are in the Pell G5 acount so disbursment dates will match. The second piece is to audit the disbursement dates at the end of each semester to ensure we match. Name(s) of the contact person(s) responsible for corrective action: Lisa Stone, Joyce Hatch and Kelly Reyes Planned completion date for corrective action plan: November 2023

View Audit 290967

Finding 369581 (2023-001)

Significant Deficiency 2023

City of Columbia, Missouri

MO

Reporting Significant Deficiency Internal Control / Segregation of Duties

The Department of Public Health and Human Services (PHHS) will create the proper processes and procedures to track reporting requirement and document internal review and approvals prior to report submissions. The Grant Administrator will create the proper processes and procedures to track reporting ...

The Department of Public Health and Human Services (PHHS) will create the proper processes and procedures to track reporting requirement and document internal review and approvals prior to report submissions. The Grant Administrator will create the proper processes and procedures to track reporting requirements and notify departments of upcoming submission deadlines.

View Audit 290965

Finding 369567 (2023-003)

Significant Deficiency 2023

Idea Public Schools

TX

Questioned Costs Allowable Costs / Cost Principles Significant Deficiency

#2023-003 – Significant Deficiency and Other Non-Compliance. Condition and context: Sampling of internal controls over payroll revealed 7 of the 240 transactions did not have timesheets approved by the employee’s supervisor, and for 2 of the 240 transactions, the employee was paid the incorrect am...

#2023-003 – Significant Deficiency and Other Non-Compliance. Condition and context: Sampling of internal controls over payroll revealed 7 of the 240 transactions did not have timesheets approved by the employee’s supervisor, and for 2 of the 240 transactions, the employee was paid the incorrect amount.. Recommendation: Reemphasize current policies and procedures to review timesheets, and payroll transactions. Planned corrective action: Current policies and procedures will be reviewed, and alternative approval procedures will be identified for instances when the employee’s direct supervisor is unavailable for timely approval. Implement additional audits during rollover process to correct administrative gap, which resulted in 2 payment amount errors. Responsible officers: James Dworkin, Chief Financial Officer and Martin Winchester, Chief Human Assets Officer Estimated completion date: March 31, 2024

View Audit 290922 Questioned Costs: $1

Finding 369473 (2023-003)

Significant Deficiency 2023

Western Seminary

OR

Subrecipient Monitoring Significant Deficiency

Gramm-Leach-Bliley Act (GLBA) Compliance Planned Corrective Action We are updating our data security policies and procedures to correct the deficiencies that have been identified in our audit and to prevent their recurrence. We are also expanding our employee training in data security and are enhan...

Gramm-Leach-Bliley Act (GLBA) Compliance Planned Corrective Action We are updating our data security policies and procedures to correct the deficiencies that have been identified in our audit and to prevent their recurrence. We are also expanding our employee training in data security and are enhancing the documentation and reporting of our internal security audits. Person Responsible for Corrective Action Plan: Sean Gordon, Director of Information Technology Operations and Software Development Anticipated Date of Completion: June 30, 2024

View Audit 290692

Finding 369472 (2023-002)

Significant Deficiency 2023

Western Seminary

OR

Questioned Costs Student Financial Aid Reporting

Untimely Returns of Title IV Funds (R2T4) Planned Corrective Action: We agree with this recommendation. We continue strengthening the tracking system around the timely processing of R2T4 refunds. From the Fall 2023 semester, we developed a report within our Student Information System (SIS) to trac...

Untimely Returns of Title IV Funds (R2T4) Planned Corrective Action: We agree with this recommendation. We continue strengthening the tracking system around the timely processing of R2T4 refunds. From the Fall 2023 semester, we developed a report within our Student Information System (SIS) to track students who both received a loan and have dropped classes within Western Seminary’s SIS. From the Spring 2024 semester, we require attendance to be tracked in all classes, including in-person classes. We historically already track attendance of online courses. Financial Aid and the Business Office will have access to regularly scheduled reports to quickly identify when students stop attending class to determine whether an R2T4 form is required and should be processed. Person Responsible for Corrective Action Plan: Jonathan Gibson, CFO Anticipated Date of Completion: June 30, 2024

View Audit 290692 Questioned Costs: $1

Finding 369428 (2023-004)

Significant Deficiency 2023

Newberry College

SC

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

USDA Community Facilities Loan Reserve Accounts Planned Corrective Action: Reserve accounts to be funded per USDA requirements. Person Responsible for Corrective Action Plan: Jon Kokos, CFO Anticipated Date of Completion: June 30, 2024

View Audit 290607

Finding 369371 (2023-005)

Significant Deficiency 2023

Oklahoma Panhandle State University

OK

Questioned Costs Student Financial Aid Significant Deficiency § 200.303

Federal Supplemental Educational Opportunity Grant - Assistance List No. 84.007 Federal Work Study Program- Assistance Listing No. 84.033 Federal Pell Grant Program - Assistance Listing No. 84.063 Federal Direct Student Loans - Assistance Listing No. 84.268 Recommendation: We recommend the Universi...

Federal Supplemental Educational Opportunity Grant - Assistance List No. 84.007 Federal Work Study Program- Assistance Listing No. 84.033 Federal Pell Grant Program - Assistance Listing No. 84.063 Federal Direct Student Loans - Assistance Listing No. 84.268 Recommendation: We recommend the University document review of Return to Title IV calculations by an employee that did not prepare the calculations. We also recommend that the University review policies and procedures related to R2T4 calculations to ensure calculations are performed correctly and disbursed timely. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Financial aid personnel will implement Return to Title IV FSA calculation spreadsheet for additional backup support in determining if banner has calculated return amounts correctly. Additionally, financial aid will require all R2T4 calculations to be secondarily reviewed and confirmed in RHACOMM. The scheduled breaks for each semester will be determined by the Director of Financial Aid and given to the Registrar to be input into banner module SOATBRK. These breaks are what banner then uses for Return to Title IV purposes. Update procedures to reflect additional actions. Name(s) of the contact person(s) responsible for corrective action: Dasha Smith Planned completion date for corrective action plan: 4/1/24

View Audit 290586 Questioned Costs: $1

Finding 369367 (2023-004)

Significant Deficiency 2023

Oklahoma Panhandle State University

OK

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

Federal Supplemental Educational Opportunity Grant - Assistance List No. 84.007 Federal Work Study Program- Assistance Listing No. 84.033 Federal Pell Grant Program - Assistance Listing No. 84.063 Federal Direct Student Loans - Assistance Listing No. 84.268 Recommendation: We recommend the Univers...

Federal Supplemental Educational Opportunity Grant - Assistance List No. 84.007 Federal Work Study Program- Assistance Listing No. 84.033 Federal Pell Grant Program - Assistance Listing No. 84.063 Federal Direct Student Loans - Assistance Listing No. 84.268 Recommendation: We recommend the University review its current procedures for awarding Title IV funds and implement changes necessary to ensure federal funds are awarded and disbursed in accordance with federal regulations. We also recommend the University disburse the proper Pell award to these students. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Check Pell Calculation settings in banner and adjust, if needed, to achieve maximum accuracy based on student criteria (COA, EFC/SAI, Enrollment Status). Name(s) of the contact person(s) responsible for corrective action: Dasha Smith Planned completion date for corrective action plan: 4/1/24

View Audit 290586

Finding 369359 (2023-002)

Significant Deficiency 2023

Oklahoma Panhandle State University

OK

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

Federal Supplemental Educational Opportunity Grant - Assistance List No. 84.007 Federal Work Study Program- Assistance Listing No. 84.033 Federal Pell Grant Program - Assistance Listing No. 84.063 Federal Direct Student Loans - Assistance Listing No. 84.268 Recommendation: We recommend the Universi...

Federal Supplemental Educational Opportunity Grant - Assistance List No. 84.007 Federal Work Study Program- Assistance Listing No. 84.033 Federal Pell Grant Program - Assistance Listing No. 84.063 Federal Direct Student Loans - Assistance Listing No. 84.268 Recommendation: We recommend the University review reporting processes to ensure all students that require exit counseling receive it in a timely manner. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Request a formal count of all graduates from Registrar at the end of each semester and review the number of exit counseling notifications sent from financial aid to ensure notifications are sent to all appropriate graduating students. Update procedures to reflect additional review. Name(s) of the contact person(s) responsible for corrective action: Dasha Smith Planned completion date for corrective action plan: 4/1/24

View Audit 290586

Finding 369355 (2023-001)

Significant Deficiency 2023

Oklahoma Panhandle State University

OK

Subrecipient Monitoring Significant Deficiency Matching / Level of Effort / Earmarking § 200.303

Federal Supplemental Educational Opportunity Grant - Assistance List No. 84.007 Federal Work Study Program- Assistance Listing No. 84.033 Federal Pell Grant Program - Assistance Listing No. 84.063 Federal Direct Student Loans - Assistance Listing No. 84.268 Recommendation: We recommend that the Col...

Federal Supplemental Educational Opportunity Grant - Assistance List No. 84.007 Federal Work Study Program- Assistance Listing No. 84.033 Federal Pell Grant Program - Assistance Listing No. 84.063 Federal Direct Student Loans - Assistance Listing No. 84.268 Recommendation: We recommend that the College review the updated GLBA requirements and ensure their WISP includes all required elements Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: OPSU will communicate closely with OSU IT and the Office of Internal Audit regarding changes made at the system level to satisfy GLBA requirements. Name(s) of the contact person(s) responsible for corrective action: Elizabeth McMurphy and Dasha Smith Planned completion date for corrective action plan: May 2024

View Audit 290586

Finding 369351 (2023-001)

Significant Deficiency 2023

New Mexico Aging and Long-Term Services Department

NM

Cash Management Subrecipient Monitoring Significant Deficiency

Recommendation The Department should implement procedures to ensure compliance with the cost reimbursement nature of the grant and insure that all valid expenses have been incurred and supported for request for reimbursement. Management Response Corrective Action: Administrative Services Division...

Recommendation The Department should implement procedures to ensure compliance with the cost reimbursement nature of the grant and insure that all valid expenses have been incurred and supported for request for reimbursement. Management Response Corrective Action: Administrative Services Division (ASD) has processed the OPR for return of the $10,958 to the Department of Health. ALTSD will implement training for agency directors and other leaders who oversee and implement grant projects. This training will include the process for development of the initial budget allocations to appropriate categories grant procedures for requesting changes to the budget categories from the funder. The training will also include a process for streamlined communication between the director or manager and the ASD grant staff responsible for the financial controls. Timeline of Corrective Actions: Perform first training to any programmatic grant manager or involved staff by January 1, 2024. This will be ongoing any time a new grant award is received by the agency. Responsible Party(ies): Chief Financial Officer

View Audit 290577

Finding 369320 (2023-005)

Significant Deficiency 2023

Great Plains Food Bank

ND

Questioned Costs Internal Control / Segregation of Duties Subrecipient Monitoring

U.S. Department of Agriculture CFDA # 10.565, 10.568, 10.569 Food Distribution Cluster Finding Summary: As part of the audit done by Eide Bailly LLP, a lack of internal controls were identified in eligibility determinations for the CSFP and Emergency Food Assistance Programs. Responsible Individu...

U.S. Department of Agriculture CFDA # 10.565, 10.568, 10.569 Food Distribution Cluster Finding Summary: As part of the audit done by Eide Bailly LLP, a lack of internal controls were identified in eligibility determinations for the CSFP and Emergency Food Assistance Programs. Responsible Individuals: Melissa Sobolik, CEO and David Stachon, CFO Corrective Action Plan: The GPFB will ensure all documents for TEFAP and CSFP programs have proper signatures by necessary parties going forward. An electronic signature process has been implemented to make the dissemination, review and storage of this process easier. Anticipated Completion Date: Immediate

View Audit 290553 Questioned Costs: $1

Finding 369186 (2023-004)

Significant Deficiency 2023

Oklahoma State University

OK

Procurement, Suspension & Debarment Significant Deficiency § 200.303

US Department of Education: Education Stabilization Fund - Assistance Listing 84.425F Recommendation: We recommend the University review procedures to monitor and retain documentation for suspension and debarment verification. Explanation of disagreement with audit finding: There is no disagreement...

US Department of Education: Education Stabilization Fund - Assistance Listing 84.425F Recommendation: We recommend the University review procedures to monitor and retain documentation for suspension and debarment verification. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned/taken in response to finding: The University is already utilizing Visual Compliance to assess all vendors for suspension and debarment but will obtain and document the review of the SOC 2 report for Visual Compliance annually. Name(s) of the contact person(s) responsible for corrective action: Scott Schlotthauer, Chief Procurement Officer. Planned completion date for corrective action plan: Immediately.

View Audit 290482

Finding 369128 (2023-003)

Significant Deficiency 2023

Oklahoma State University

OK

Subrecipient Monitoring Significant Deficiency Matching / Level of Effort / Earmarking § 200.303

US Department of Education: Student Financial Assistance Cluster – Assistance Listing No. 84.007, 84.038, 84.063, 84.268, 84.379, 84.033 Recommendation: CLA recommends that the University review the updated GLBA requirements and ensure their WISP includes all required elements. Explanation of disag...

US Department of Education: Student Financial Assistance Cluster – Assistance Listing No. 84.007, 84.038, 84.063, 84.268, 84.379, 84.033 Recommendation: CLA recommends that the University review the updated GLBA requirements and ensure their WISP includes all required elements. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned/taken in response to finding: OSU is creating a GLBA management program to govern security of GLBA data and ensure compliance with associated requirements. Name(s) of the contact person(s) responsible for corrective action: Aaron Smith, Director of Information Security Services/Information Security Officer. Planned completion date for corrective action plan: March 31, 2024

View Audit 290482

Finding 369107 (2023-002)

Significant Deficiency 2023

Oklahoma State University

OK

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

US Department of Education: Student Financial Assistance Cluster – Assistance Listing No. 84.007, 84.063, 84.268, 84.033 Recommendation: CLA recommends OSU OKC and OSUIT review current processes for reporting to NSLDS and implement procedures to ensure submissions are reported timely and accurately...

US Department of Education: Student Financial Assistance Cluster – Assistance Listing No. 84.007, 84.063, 84.268, 84.033 Recommendation: CLA recommends OSU OKC and OSUIT review current processes for reporting to NSLDS and implement procedures to ensure submissions are reported timely and accurately Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned/taken in response to finding: OSU OKC: The Director of Financial Aid, Registrar, and Sr Director of Institutional Effectiveness developed a new process on reporting first of term, end of term, updates to enrollment, and processing errors in a timely manner. In addition, the Director of Financial Aid also added a step to the current OSU OKC R2T4 process. Financial Aid counselors will also be checking NSLDS on all students who populate on our R2T4 listing. Monthly, the Director of Financial Aid will select a small population to R2T4 and audit the information reported in NSLDS to ensure the new process is working correctly. OSUIT: OSUIT will shorten the dates for reporting to the NSLC to make sure the NSLC has sufficient time to report to NSLDS. Name(s) of the contact person(s) responsible for corrective action: OSU OKC: Elizabeth Lucas, Director of Financial Aid and Scholarships; Hank Lankford, Registrar; and Nick Irby, Senior Director of Institutional Effectiveness and Accreditation. OSUIT: Matt Short, Director of Financial Aid and Scholarships; and Crystal Palacioz, Registrar. Planned completion date for corrective action plan: OSU OKC: The completion date for the enrollment reporting has been implemented since the end of September 2023. The additional financial aid processes were implemented in October 2023 and will be fully completed by December 1, 2023. OSUIT: December 1, 2023.

View Audit 290482

Finding 369088 (2023-001)

Significant Deficiency 2023

Oklahoma State University

OK

Procurement, Suspension & Debarment Significant Deficiency § 200.303

US Department of Education: Student Financial Assistance Cluster – Assistance Listing No. 84.007, 84.063, 84.268, 84.033 Recommendation: CLA recommends OSU CHS and OSUIT evaluate its procedures around disbursements of loans and ensure documentation is properly retained. Explanation of disagreement ...

US Department of Education: Student Financial Assistance Cluster – Assistance Listing No. 84.007, 84.063, 84.268, 84.033 Recommendation: CLA recommends OSU CHS and OSUIT evaluate its procedures around disbursements of loans and ensure documentation is properly retained. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned/taken in response to finding: OSU CHS: Financial aid staff have added a process to Banner to automatically generate a notification e-mail to students when loans are disbursed. OSUIT: The query that OSUIT runs to send emails to the students and reports the results to OSUIT Financial Aid staff has been changed from reporting one term at a time to report disbursements from any term as long as the change in a prior term happens within the last 24 hours. In addition, staff will be retrained on how to review the reports and the reports will now go to all Financial Aid staff so that multiple staff may review reports. Name(s) of the contact person(s) responsible for corrective action: OSU CHS: Jeff Hackler, Associate Dean for Enrollment Management. OSUIT: Matt Short, Director of Financial Aid and Scholarships. Planned completion date for corrective action plan: OSU CHS: Already implemented. OSUIT: December 1, 2023.

View Audit 290482

Finding 369084 (2023-002)

Significant Deficiency 2023

Easter Seals Serving Dc/md/va

MD

Reporting Significant Deficiency Equipment & Real Property Management

The status of real property purchased, constructed, or subject to major renovations paid for in whole or in part with federal Head Start funds must be reported annually on standard forms (SF) Real Property Status Reports 429 and SF-429-A. Based on our grant agreement for our Early Head Start Program...

The status of real property purchased, constructed, or subject to major renovations paid for in whole or in part with federal Head Start funds must be reported annually on standard forms (SF) Real Property Status Reports 429 and SF-429-A. Based on our grant agreement for our Early Head Start Program in Washington, DC , as well as construction activities undertaken throughout Fiscal Year 2023 related to the facility located at 1151 Bladensburg Road, NE, Easter Seals DC | MD | VA is required to file the aforementioned forms no later than 90 days after the program year ends. As noted in the audit report, our organization did not file the required SF-429 Form for the latest program year (FY 2023) for our Washington DC EHS program. The director for the Head Start program was aware of the Real Property Status filing requirement, but apparently misunderstood that the deadline for the Year 2 (FY 2023) filing was September 30, 2023. We anticipate that the required reports will be submitted to the appropriate governing agency by March 31, 2024.

View Audit 290474

Finding 369077 (2022-007)

Significant Deficiency 2023

Wheeling Jesuit University INC

WV

Reporting Significant Deficiency Internal Control / Segregation of Duties

FINDING 2022 – 007 Repeat of Prior Year Finding 2021-011 Type of Finding: Significant Deficiency - Reporting Federal Award Program: COVID – 19 Higher Education Emergency Relief Fund (HEERF) Student Aid Portion and COVID – 19 HEERF Institutional Portion Federal Agency: U.S. Department of Education As...

FINDING 2022 – 007 Repeat of Prior Year Finding 2021-011 Type of Finding: Significant Deficiency - Reporting Federal Award Program: COVID – 19 Higher Education Emergency Relief Fund (HEERF) Student Aid Portion and COVID – 19 HEERF Institutional Portion Federal Agency: U.S. Department of Education Assistance Listing Number: 84.425E, 84.425F Federal Award Year: June 30, 2022 Name of responsible Individual: C.F.O., Gregory Bloomfield Criteria: Reporting: The University was required to submit to the Department of Education an annual report of its HEERF expenditures using the Annual Report Data Collection System by May 6, 2022. Additionally, the institution is required to post accurate and completed quarterly HEERF information to its primary website. Condition: The annual report was not completed or submitted. Additionally, certain amounts reported on submitted quarterly reports did not reconcile to underlying supporting documentation. Corrective Action: The University will formalize and document financial processes to establish internal controls in order to ensure accurate, timely and consistent reporting. In addition, this will create a reasonable transition plan during employee turnover, as well as ensure proper and timely filings. Anticipated Completion Date: Full implementation and documentation with current staffing is currently in process and estimate completion by March 31, 2024, however, HEERF has since ended so no further reporting is necessary.

View Audit 290469

Finding 369073 (2022-002)

Significant Deficiency 2023

Wheeling Jesuit University INC

WV

Student Financial Aid Reporting Significant Deficiency

FINDING 2022 – 002: Repeat of Prior Year Finding 2021-004 Name of Responsible Individual: Joyce Lubeck-Sonenberg, Acting Director of Financial Aid Type of Finding: Federal Award Findings and Questioned Costs Criteria: Recipients of federal awards are required to administer its federal programs with ...

FINDING 2022 – 002: Repeat of Prior Year Finding 2021-004 Name of Responsible Individual: Joyce Lubeck-Sonenberg, Acting Director of Financial Aid Type of Finding: Federal Award Findings and Questioned Costs Criteria: Recipients of federal awards are required to administer its federal programs with an adequate system of internal controls over applicable compliance requirements. Condition: The University did not reconcile its SAS data file to its financial records for all 12 months of the fiscal year. Corrective Action: Wheeling University has implemented several significant corrective actions towards improving the reconciliation requirements for the Pell and Direct Loan Programs. A highly administratively capable staff person has been promoted to Assistant Director and demonstrates a level of financial aid leadership that is appreciated throughout the campus community. This individual has received extensive regulatory and technical training regarding the federal requirements to monthly reconcile cash received from the G5 account with disbursements submitted to the COD System. In addition to confirming the accuracy of monthly reconciliation efforts, this approach allows the FA office to compare internal awarding databases against COD’s database for Pell and Direct Loan awards and identify discrepancies that require further attention. Also, this assists the University to be better prepared to perform efficient and accurate closeout activities at year-end. Previous audit findings showed little evidence of accurate reconciliation efforts. In working with the University IT Department, monthly reconciliation files are now housed in a shared electronic file system, easily retrieved for review, and are confirmed for accuracy by the acting Director of Financial Aide each month. Anticipated Completion Date: This process was completed in March of 2023 and is ongoing.

View Audit 290469

Finding 369072 (2022-006)

Significant Deficiency 2023

Wheeling Jesuit University INC

WV

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

FINDING 2022 – 006: Type of Finding: Significant Deficiency-Return of Title IV Funds Name of Responsible Individual: Joyce Lubeck-Sonenberg, Acting Director of Financial Aid Criteria: Title IV regulations (34 CFR 668.22) require the University to return the unearned portion of grants or loans to the...

FINDING 2022 – 006: Type of Finding: Significant Deficiency-Return of Title IV Funds Name of Responsible Individual: Joyce Lubeck-Sonenberg, Acting Director of Financial Aid Criteria: Title IV regulations (34 CFR 668.22) require the University to return the unearned portion of grants or loans to the student based the calculated percent completed by the student. Condition: Calculations of return of funds for certain students selected for testing were not completed and therefore refunds were not made. Corrective Action: Audit results identify several Wheeling University Financial Aid R2T4 calculations that were found to be incomplete, inaccurate, or not completed within an acceptable time frame as required by regulations. The apparent cause of these findings was a lack of administrative capability, staff turnover, and a general lack of a systematic process for completing accurate R2T4 calculations. Since these findings were first noted, the Wheeling University Financial Aid Office has added competent staff and has provided sufficient training and supervised experience to ensure R2T4 calculations are completed within the regulatory guidelines. The acting Director of Financial Aid has taken steps to ensure to inform the campus community of the Department’s philosophy of an “institutional responsibility” regarding regulatory compliance with Title IV programs, and this is particularly true in the matter of student FA eligibility with enrollment, attendance, and withdrawal. As such, the acting Director of Financial Aid has worked closely with the University Registrar to ensure there is a clear understanding that if a recipient of Title IV grant or loan funds withdraws from the University after beginning attendance, the FA Office must perform an R2T4 calculation to determine the amount of Title IV assistance earned by the student. Since withdrawal information is critical to R2T4 calculations, a Withdrawal Report has been developed to better capture withdrawal data. This report is updated and reviewed by the FA Director (three times per week) to confirm the accuracy of such data. In addition, all R2T4 calculations are completed on the University's internal software (Colleague) rather than DOE software and follow an updated, more clearly defined R2T4 policy. Anticipated Completion Date: This process was completed September of 2023 and is ongoing.

View Audit 290469

Finding 369066 (2023-002)

Significant Deficiency 2023

Moberly Area Community College

MO

Student Financial Aid Significant Deficiency Matching / Level of Effort / Earmarking § 200.303

2023-002 US Department of Education Student Financial Assistance Cluster - Assistance Listing No. 84.063, 84.268 Recommendation: We recommend the College review its current procedures for Title IV funds and implement additional procedures to ensure refunds are returned timely. Explanation of disa...

2023-002 US Department of Education Student Financial Assistance Cluster - Assistance Listing No. 84.063, 84.268 Recommendation: We recommend the College review its current procedures for Title IV funds and implement additional procedures to ensure refunds are returned timely. Explanation of disagreement with audit finding: MACC is an attendance taking institution and our regular practice requires review of attendance records two to three times per week. When the Financial Aid Office discovers students have withdrawn from classes, we review and calculate an R2T4 when required - usually within 1-5 days from the date it is discovered. This finding of a "late return" is due to a faculty member dropping a student outside of the dates required by our attendance policy. I would like to note that the R2T4 was performed timely and accurately as soon as the drop was identified. Action taken in response to finding: The issue was reported to the President, Vice Presidents, and Deans; as a result, the faculty were addressed and reminded of the importance to comply with the college's attendance policy. Name(s) of the contact person(s) responsible for corrective action: Amy Hager Planned completion date for corrective action plan: Our Vice President for Instruction will provide reminders of our policy with our faculty each semester. In the event that a faculty member does not comply with the attendance policy, their Dean will take disciplinary action.

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