Corrective Action Plans

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Description of Finding: From the testing sample, six instances were found where credit balances from Title IV balances were not properly refunded to students based on the disbursement dates. Statement of Concurrence or Nonconcurrence: With staff turnover, offices were incurring a longer time to bala...
Description of Finding: From the testing sample, six instances were found where credit balances from Title IV balances were not properly refunded to students based on the disbursement dates. Statement of Concurrence or Nonconcurrence: With staff turnover, offices were incurring a longer time to balance COD approved disbursements to actual disbursements to student accounts. Once the loan disbursements were balanced and confirmed to students, the loan refunds were immediately released to students. CMU is aware of, and normally follows the 14 day policy, but it was determined to hold loan refunds until the loans posted to CMU accounts were correct with COD to avoid incorrect disbursements. Corrective Action: The office of Financial Assistance has identified balancing COD disbursements and internal loan disbursement as a mandatory priority each week. A macro report has been developed to help identify differences with COD and allow corrections and COD draws in a timely fashion. Name of Contact Person: Dyllon Harper, Director of Financial Assistance, Projected Completion Date: Fall 2024
Finding 525598 (2024-001)
Significant Deficiency 2024
Criteria, Condition, Cause: We concur that our timely reporting of academically dismissed students during the non-required summer term is an issue and will be vigilant to prevent this delayed reporting in the fun1re. It should be noted that this small cohort was all deemed ineligible to return for ...
Criteria, Condition, Cause: We concur that our timely reporting of academically dismissed students during the non-required summer term is an issue and will be vigilant to prevent this delayed reporting in the fun1re. It should be noted that this small cohort was all deemed ineligible to return for the upcoming semester on the same day, and so that singular days' enrollment status changes were the only updates that were untimely in the submission to the National Student Loan Data System (NSLDS). We will be modifying and monitoring our process to accurately capture and report to the NSLDS sh1dents determined to be ineligible to return in the fall semester even during a tenn of non-required enrollment. Effect, Questioned costs, Context: Enrollment rosters and updated enrollment statuses are reported regularly with NSLDS to ensure current enrollment status that can impact loan repayment dates and in-school deferments are accurately on record with the Department of Education. For the summer enrollment roster, although Allegheny's summer term is a non-required tern1, students that are not enrolled in the summer tern1, but Allegheny is aware that they will not be enrolled in the upcoming required fall tem1 must be reported as withdrawn through the summer enrollment roster. Recommendation The College will continue to confom1 to the NSLDS reporting process and timeline, and with the collaboration of the Financial Aid's, Registrar's, and Provost's Offices, will fully bring the non-required term enrollment reporting into alignment. For the next non-required summer tern1 enrollment report in 2025, Allegheny will be incorporating the shtdents determined to be academically dismissed from the spring tenn on the initial summer enrollment roster with the updated withdrawn stah1s. The initial summer enrollment roster will be submitted within 60 days.
Auditor Description of Condition and Effect. The College does not have a negotiated rate, however, they used a rate other than the de minimis rate of 10% in their calculation of indirect costs. The College also did not use the modified total direct costs “MTDC” for purposes of this calculation, but...
Auditor Description of Condition and Effect. The College does not have a negotiated rate, however, they used a rate other than the de minimis rate of 10% in their calculation of indirect costs. The College also did not use the modified total direct costs “MTDC” for purposes of this calculation, but instead used the budgeted indirect cost total for the program. As a result of this condition, the College over-charged the grant by $21,765 during the fiscal year ended June 30, 2024. Auditor Recommendation. We recommend that the College implement a review process to ensure that the indirect costs charged to the grant are in accordance with the grant award letter. Corrective Action. The College will implement a review process to ensure that the indirect costs charged to the grant are in accordance with the grant award letter. Responsible Persons. Tom Zeidel, Vice President of Finance and Facilities and Troy Slater, Director of Business Office. Anticipated Completion Date. March 31, 2025.
View Audit 344645 Questioned Costs: $1
Finding 525563 (2024-005)
Significant Deficiency 2024
Corrective Action Plan 2024-005: The College has provided to the USDA the required documentation that had been identified as not sufficiently provided and has established controls to ensure that the requirements listed in the Letter of Conditions will be met each year going forward. Completion Date...
Corrective Action Plan 2024-005: The College has provided to the USDA the required documentation that had been identified as not sufficiently provided and has established controls to ensure that the requirements listed in the Letter of Conditions will be met each year going forward. Completion Date: December 2024 Contact Person: Steven W. Eckman, President
Finding 525559 (2024-004)
Significant Deficiency 2024
Corrective Action Plan 2024-004: The College concurs with the finding and has taken corrective action by submitting a corrected FISAP with the accurate date prior to the FISAP corrections due date of December 13, 2024. Additionally, the College has established controls to ensure review of the Perkin...
Corrective Action Plan 2024-004: The College concurs with the finding and has taken corrective action by submitting a corrected FISAP with the accurate date prior to the FISAP corrections due date of December 13, 2024. Additionally, the College has established controls to ensure review of the Perkins section of the FISAP for the next reporting year. Completion Date: December 2024 Contact Person: Steven W. Eckman, President
Finding 525556 (2024-003)
Significant Deficiency 2024
Corrective Action Plan 2024-003: The College concurs with the finding and has reviewed and where appropriate made updates to the processes used to report disbursement dates to COD and has corrected the disbursement date in COD for the student discrepancy noted. Completion Date: February 2024 Conta...
Corrective Action Plan 2024-003: The College concurs with the finding and has reviewed and where appropriate made updates to the processes used to report disbursement dates to COD and has corrected the disbursement date in COD for the student discrepancy noted. Completion Date: February 2024 Contact Person: Steven W. Eckman, President
Finding 525554 (2024-001)
Significant Deficiency 2024
Corrective Action Plan 2024-001: The College concurs with the finding and has adjusted its processes and controls beginning with the Spring 2024 semester to conduct a review of students for which refund payments need to be made prior to drawing down funds from G5. Anticipated Completion Date: Febru...
Corrective Action Plan 2024-001: The College concurs with the finding and has adjusted its processes and controls beginning with the Spring 2024 semester to conduct a review of students for which refund payments need to be made prior to drawing down funds from G5. Anticipated Completion Date: February 2024 Contact Person: Steven W. Eckman, President
Finding 525553 (2024-002)
Significant Deficiency 2024
Corrective Action Plan 2024-002: The College concurs with the finding and will formalize its written Information Security Program. Anticipated Completion Date: Spring 2025 Contact Person: Joshua Bieber, Director of Information Technology
Corrective Action Plan 2024-002: The College concurs with the finding and will formalize its written Information Security Program. Anticipated Completion Date: Spring 2025 Contact Person: Joshua Bieber, Director of Information Technology
Finding 525538 (2024-001)
Significant Deficiency 2024
Return of Title IV (R2T4) Planned Corrective Action: The College will continue to ensure that the Financial Aid staff is properly and regularly trained on all aspects of Return of Title IV Funds. The staff will participate in any webinars or conferences available. Weekly reports will be produced ...
Return of Title IV (R2T4) Planned Corrective Action: The College will continue to ensure that the Financial Aid staff is properly and regularly trained on all aspects of Return of Title IV Funds. The staff will participate in any webinars or conferences available. Weekly reports will be produced to ensure that all calculations are completed within the 45-day regulation. The Director of Financial Aid will regularly review calculations for accuracy, completeness, and timely return of funds. Person Responsible for Corrective Action Plan: Monique Rickenbaker, Director of Financial Aid and Scholarships Anticipated Date of Completion: July 1, 2025
Finding Number: 2024‐001 Program Name/Assistance Listing Titles: Emergency Connectivity Fund; Education Stabilization Fund Assistance Listing Numbers: 32.009; 84.425 Contact Person: Jackie Mattinen, Director of Finance Anticipated Completion Date: February 28, 2025 Planned Corrective Action: The Gil...
Finding Number: 2024‐001 Program Name/Assistance Listing Titles: Emergency Connectivity Fund; Education Stabilization Fund Assistance Listing Numbers: 32.009; 84.425 Contact Person: Jackie Mattinen, Director of Finance Anticipated Completion Date: February 28, 2025 Planned Corrective Action: The Gilbert Public Schools Finance Department will provide financial oversight of all State and Federal fund applications and will require finance approval prior to submittal of all State and Federal fund applications initiated by all District departments and schools.
View Audit 344525 Questioned Costs: $1
Official Responsible for Ensuring CAP Dani Haman, Head Start business manager, will be responsible to ensure that the appropriate measures are taken. Correcting Plan The District will provide Dani Haman, Head Start business manager, necessary training. The Planned Completion Date of CAP Immediately
Official Responsible for Ensuring CAP Dani Haman, Head Start business manager, will be responsible to ensure that the appropriate measures are taken. Correcting Plan The District will provide Dani Haman, Head Start business manager, necessary training. The Planned Completion Date of CAP Immediately
Supportive Housing for Persons with Disabilities – Assistance Listing No. 14.181 Recommendation: Perform training regarding HUD requirements surrounding Residual Receipts Provisions and introduce policies and procedures to prevent oversight of deposit changes. Explanation of disagreement with audit ...
Supportive Housing for Persons with Disabilities – Assistance Listing No. 14.181 Recommendation: Perform training regarding HUD requirements surrounding Residual Receipts Provisions and introduce policies and procedures to prevent oversight of deposit changes. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned in response to finding: Management with conduct training and introduce new policies and procedures to prevent noncompliance. Management will make the required deposit immediately. Name(s) of the contact person(s) responsible for corrective action: Cheryl Wilson, Executive Director Planned completion date for corrective action plan: June 30, 2025
Supportive Housing for Persons with Disabilities – Assistance Listing No. 14.181 Recommendation: Perform training regarding HUD requirements surrounding Residual Receipts Provisions and introduce policies and procedures to prevent oversight of surplus cash deposits. Explanation of disagreement with ...
Supportive Housing for Persons with Disabilities – Assistance Listing No. 14.181 Recommendation: Perform training regarding HUD requirements surrounding Residual Receipts Provisions and introduce policies and procedures to prevent oversight of surplus cash deposits. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned in response to finding: Management with conduct training and introduce new policies and procedures to prevent noncompliance. Name(s) of the contact person(s) responsible for corrective action: Cheryl Wilson, Executive Director
Supportive Housing for Persons with Disabilities – Assistance Listing No. 14.181 Recommendation: Perform training regarding HUD requirements surrounding Residual Receipts Provisions and introduce policies and procedures to prevent oversight of surplus cash deposits. Explanation of disagreement with ...
Supportive Housing for Persons with Disabilities – Assistance Listing No. 14.181 Recommendation: Perform training regarding HUD requirements surrounding Residual Receipts Provisions and introduce policies and procedures to prevent oversight of surplus cash deposits. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned in response to finding: Management with conduct training and introduce new policies and procedures to prevent noncompliance. Name(s) of the contact person(s) responsible for corrective action: Cheryl Wilson, Executive Director
Student Financial Assistance Cluster – Assistance Listing No. 84.007 (Federal Supplemental Educational Opportunity Grants Program), 84.033 (Federal Work Study Program), 84.038 (Federal Perkins Loan Program), 84.063 (Federal Pell Grant Program), 84.268 (Federal Direct Student Loans Program), 93.364 (...
Student Financial Assistance Cluster – Assistance Listing No. 84.007 (Federal Supplemental Educational Opportunity Grants Program), 84.033 (Federal Work Study Program), 84.038 (Federal Perkins Loan Program), 84.063 (Federal Pell Grant Program), 84.268 (Federal Direct Student Loans Program), 93.364 (Nursing Student Loans) Recommendation: We recommend the University work to update the written security program to ensure compliance with all the standards. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Illinois Wesleyan University will designate an individual to be the Information Security Officer. The information security policy will be updated as applicable for GLBA standards. Name(s) of the contact person(s) responsible for corrective action: David Myron, Vice President of Business and Finance Planned completion date for corrective action plan: Updates for the information security policy will be made on an as-needed basis for applicable changes. The Information Security Officer was named in Spring 2024 and has continued progress forward for GLBA compliance.
Student Financial Assistance Cluster – Assistance Listing No. 84.007 (Federal Supplemental Educational Opportunity Grants Program), 84.033 (Federal Work Study Program), 84.038 (Federal Perkins Loan Program), 84.063 (Federal Pell Grant Program), 84.268 (Federal Direct Student Loans Program), 93.364 (...
Student Financial Assistance Cluster – Assistance Listing No. 84.007 (Federal Supplemental Educational Opportunity Grants Program), 84.033 (Federal Work Study Program), 84.038 (Federal Perkins Loan Program), 84.063 (Federal Pell Grant Program), 84.268 (Federal Direct Student Loans Program), 93.364 (Nursing Student Loans) Recommendation: We recommend the University review its reporting procedures to ensure that students’ statuses are accurately and 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: When a graduation has been confirmed outside of the normal timeframe due to later grade reporting, the Assistant Registrar will include the Director of Financial Aid and the Associate Director of Financial Aid in an email along with the standard process of notifying the Associate Registrar. The Associate Director of Financial Aid will go directly to NSLDS and enter the graduation date in NSLDS. The Associate Registrar will continue the normal reporting process with the Clearinghouse but this will alleviate challenges that come when the Associate Registrar is resolving discrepancies and can’t report the graduation immediately. Name(s) of the contact person(s) responsible for corrective action: Scott Seibring, Director of Financial Aid Planned completion date for corrective action plan: This process will be implemented starting with the Spring 2025 semester.
Finding 2024-005 Recommendation: The University should implement a monthly review process to ensure all student enrollment status changes are captured when certifying enrollment data. View of Responsible Officials and Planned Corrective Actions: During fiscal year 2024, there was a one-time error re...
Finding 2024-005 Recommendation: The University should implement a monthly review process to ensure all student enrollment status changes are captured when certifying enrollment data. View of Responsible Officials and Planned Corrective Actions: During fiscal year 2024, there was a one-time error resulting in manual enrollment statuses not being captured by the National Student Clearinghouse (NSC). Degree and enrollment files were sent timely, however, manual updates of student statuses on the NSC website were not processed successfully leading to inconsistencies. Going forward, enrollment files will be reviewed regularly against the NSLDS website to ensure that all student enrollment statuses are accurate. Individual Responsible for Corrective Action: Deanna Carroll, University Registrar, 610-660-1000, ddaly@sju.edu Anticipated Completion Date for Corrective Action: The Planned Corrective Actions will be immediately implemented.
Finding 2024-004 Recommendation: The University should evaluate all program lengths per the website and ensure that program lengths are accurate and that there are no discrepancies when comparing the website to NSLDS. View of Responsible Officials and Planned Corrective Actions: The University will ...
Finding 2024-004 Recommendation: The University should evaluate all program lengths per the website and ensure that program lengths are accurate and that there are no discrepancies when comparing the website to NSLDS. View of Responsible Officials and Planned Corrective Actions: The University will immediately review all program lengths and update the website as well as Banner. Moving forward, Banner will be the system of record for program lengths and basis for reporting to the NSLDS. Any updates or changes to the website will require approval from the Registrar and Financial Aid Offices to ensure that all records are consistent and accurate. Individual Responsible for Corrective Action: Deanna Carroll, University Registrar, 610-660-1000, ddaly@sju.edu Anticipated Completion Date for Corrective Action: The Planned Corrective Actions will be immediately implemented.
Finding 2024-003 Recommendation: The University should implement a control within the Financial Aid department that requires another individual within the department to review the Pell funds awarded by student for accuracy. For the 13 students with inaccurate Pell awards, these were corrected immedi...
Finding 2024-003 Recommendation: The University should implement a control within the Financial Aid department that requires another individual within the department to review the Pell funds awarded by student for accuracy. For the 13 students with inaccurate Pell awards, these were corrected immediately when brought to management’s attention. View of Responsible Officials and Planned Corrective Actions: This issue was unique to the 2023 summer term as a result of the University changing the header semester to the summer term for the 23/24 award year. The University has changed the fund award and disbursement schedule rules in Banner to correctly calculate the Pell Grant awards for summer terms. This eliminates the need for Financial Aid staff to manually update awards on an individual student basis. In addition to the aforementioned change in the Banner rules, the University will have an individual in the Financial Aid Office run a report to audit summer term awards to ensure the Pell Grant is being calculated correctly. Individual Responsible for Corrective Action: Caroline Baker, Senior Director of Financial Aid, 610-660-1000, cbaker01@sju.edu Anticipated Completion Date for Corrective Action: The Planned Corrective Actions will be immediately implemented.
Management Response: Holy Family University is dedicated to ensuring the accuracy of our reporting to the NSLDS. The following is how we plan to verify the integrity of our reports. The Registrar's Office will compare the list of students pulled in the monthly NSC process to a report showing all stu...
Management Response: Holy Family University is dedicated to ensuring the accuracy of our reporting to the NSLDS. The following is how we plan to verify the integrity of our reports. The Registrar's Office will compare the list of students pulled in the monthly NSC process to a report showing all students who withdrew that month. This will ensure that we are reporting all withdrawn/graduated students in a timely manner. In addition, the Registrar's Office will verify the potential graduation of students whose grades are changed after the end of the term. If the new grade completes their degree, the student will be reported as "graduated" when we process the next session's graduation applications. This will eliminate the reliance on an external database, as manual updates tend to lack consistency. Lastly, prior to submitting the Graduates Only file to the NSLDS, the Registrar will compare the entire list of graduates to the report showing all students who withdrew throughout the semester. This will be a double check since we will also be checking grade changes, as mentioned above.
Notifications of Disbursements Recommendation: We recommend the College review and strengthen its procedures for notifying students of their Direct Loan disbursements within the required time frame and that documentation of the letters sent is maintained. Explanation of disagreement with audit findi...
Notifications of Disbursements Recommendation: We recommend the College review and strengthen its procedures for notifying students of their Direct Loan disbursements within the required time frame and that documentation of the letters sent is maintained. Explanation of disagreement with audit finding: The Financial Aid Office already has set procedures pertaining to the sending of mass communications to our students whenever Direct Loan disburses. There was an oversight only for the term of Fall 2023 where MCAD failed to launch the communication in a timely manner to disbursement receiving students. Action taken in response to finding: ● The Financial Aid Operations Calendar - will include updated entries concerning the generation of communication for Disbursement Notification. ● Process Update - the sending of the communication will be incorporated into the mass disbursement process at the end of Add/Drop periods during the Fall and Spring terms. Name(s) of the contact person(s) responsible for corrective action: Sherman Lee, Financial Aid Director Planned completion date for corrective action plan: Mar 1, 2025
Awarding of Direct Loans Recommendation: We recommend the College evaluate its procedures and a policy around how level of education is determined and verified when packaging and awarding students. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Actio...
Awarding of Direct Loans Recommendation: We recommend the College evaluate its procedures and a policy around how level of education is determined and verified when packaging and awarding students. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: ● Updating the current policy: Financial Aid Office will outline a more thorough policy pertaining to its awarding of additional unsubsidized loan amounts to dependent students. ● Proper documentation concerning the reason for the additional award amount will be required in the specific student’s file in Powerfaids. ● Training sessions will be conducted to assure all members of the Financial Aid Office understands the conditions and expectations from the Department of Education regarding the awarding of additional unsubsidized loans. Name(s) of the contact person(s) responsible for corrective action: Sherman Lee, Financial Aid Director Planned completion date for corrective action plan: May 1, 2025
View Audit 344312 Questioned Costs: $1
Perkins Reconciliation Recommendation: It is recommended that the College review procedures in place to ensure accurate reporting of Perkins loan information to comply with Title IV regulations. Explanation of disagreement with audit finding: MCAD had undergone numerous staff transitions within The...
Perkins Reconciliation Recommendation: It is recommended that the College review procedures in place to ensure accurate reporting of Perkins loan information to comply with Title IV regulations. Explanation of disagreement with audit finding: MCAD had undergone numerous staff transitions within The Business Office. Its previous Perkins Loan Servicer, University Accounting Service (UAS), was derelict in its duty to fulfill the terms of the contract by failing to perform in managing all areas of MCAD’s Perkins Loan portfolio. UAS failed to keep current as well as accurate accounting and funds management records throughout its tenure as the servicer. Action taken in response to finding: ● Changing of Servicer: MCAD has removed UAS and completed the changeover to Heartland Educational Computer Systems Incorporated (ECSI) as its new Perkins servicer. ● Business Office (Student Accounts Manager) will provide close oversight to ensure accountability that ECSI will fulfill its duties and responsibilities as Perkins Loan Servicer ● The Financial Aid Office will partner with the Business Office as another layer of accountability and support to the Business Office as it supervises ECSI. ● Third-Party Assistance: The institution has engaged with CLA to assist with the reconciliation of the Perkins Loan accounts. It is expected that the work CLA has done to assist will come to full fruition and be fully reconciled sometime in 2025. Name(s) of the contact person(s) responsible for corrective action: Mary Alma Noonan, CFO, Brian Braden, Controller and Sherman Lee, Financial Aid Director Planned completion date for corrective action plan: June 30, 2025
Documentation of Review Recommendation: We recommend the College reevaluate its procedures and review policies surrounding controls implemented for Title IV Aid. Explanation of disagreement with audit finding: MCAD Financial Aid already has sound procedures in place that outlines the process for ou...
Documentation of Review Recommendation: We recommend the College reevaluate its procedures and review policies surrounding controls implemented for Title IV Aid. Explanation of disagreement with audit finding: MCAD Financial Aid already has sound procedures in place that outlines the process for our internal review and audit processes in all areas (ex. Awarding, Reconciliation, and R2T4). Action taken in response to finding: ● The Director of Financial Aid will ensure regular internal review audits will take place throughout the fiscal year. ● Review results will be documented for recordkeeping and to track whether processes and procedures are followed. ● The Financial Aid Operations Calendar will include dates of when internal reviews will take place over the different areas of the department ● The Business Office will be involved for all reconciliation related internal review processes as a third party reviewer to ensure the disbursed amounts on Powerfaids, COD, and G5 are synchronized. Name(s) of the contact person(s) responsible for corrective action: Sherman Lee, Financial Aid Director Planned completion date for corrective action plan: May 1, 2025
Gramm-Leach Bliley Act (GLBA) Recommendation: We recommend 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 taken in response to findi...
Gramm-Leach Bliley Act (GLBA) Recommendation: We recommend 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 taken in response to finding: MCAD’s IT department has been working to finalize its WISP protocols to comply with the updated GLBA requirements and ensure the safety and security of data held by MCAD. As we implement the necessary changes required for compliance, our intention is to have these documented and adopted by the end of our fiscal year. Name(s) of the contact person(s) responsible for corrective action: Mary Alma Noonan, CFO and Matthew Hoban, AVP Technology Planned completion date for corrective action plan: May 31, 2025
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