Corrective Action Plans

Finding 1206468 (2025-002)

Material Weakness 2025

FL

Student Financial Aid

We acknowledge the auditors’ recommendation regarding the implementation of a more formalized and documented review process for the FISAP prior to submission. While no errors or compliance findings were identified as a result of the current process, we understand the value of enhancing documentation...

We acknowledge the auditors’ recommendation regarding the implementation of a more formalized and documented review process for the FISAP prior to submission. While no errors or compliance findings were identified as a result of the current process, we understand the value of enhancing documentation to further evidence existing internal controls. It is important to note that, based on guidance and industry practice—including input from the U.S. Department of Education’s Regional Office of Participation (Southeast Region), the National Association of Student Financial Aid Administrators, and the Florida Association of Student Financial Aid Administrators—there is no regulatory requirement mandating an independent, formally documented review of the FISAP to demonstrate compliance with internal control standards. That said, in the spirit of continuous improvement and to address the auditors’ recommendation, management will enhance its existing review procedures as follows: • The Director of Financial Aid will continue to prepare and submit the FISAP in accordance with federal requirements. • As part of the established process, the Financial Aid Business Systems Analyst and Assistant Director of Financial Aid will continue to support the review by validating data accuracy, report outputs, and proper classification within the application. • To further strengthen documentation, a standardized review checklist will be implemented and retained to evidence the review process prior to submission. These enhancements are intended to formalize and document controls already in place, while aligning with the auditors’

View Audit 398469

Finding 1206465 (2025-001)

Material Weakness 2025

Adventhealth University

FL

Student Financial Aid Cash Management Reporting

The finding was in the No Passing Grade selection. Due to the way the institution tracks attendance, the student was listed as having earned an F instead of being administratively withdrawn. The institution will now start using a new report. This report will track: o Any student with a no passing gr...

The finding was in the No Passing Grade selection. Due to the way the institution tracks attendance, the student was listed as having earned an F instead of being administratively withdrawn. The institution will now start using a new report. This report will track: o Any student with a no passing grade o Any student in this category who received financial aid. IT has developed this report and the report is identified as the No passing Grades report. This will allow the institution to review and determine if the student needs to be considered as an unofficial withdrawal and whether or not an R2T4 is needed. The FA Business Systems analyst will run this report at the end of each term when grades have been issued. The institution will also meet with the Faculty Senate to put a process in place which will determine whether the student who earned a no passing grade participated in the course or should have been administratively withdrawn at the time grades are issued. This will help the institution to determine if an R2T4 calculation was needed and allow for a timely return of funds.

View Audit 398469

Finding 1206261 (2025-001)

Material Weakness 2025

Sonoran University of Health Sciences

AZ

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

Student Financial Aid Cluster – Assistance Listing No. Various Recommendation: We recommend the University review its controls around exit counseling procedures to ensure that all students who withdrew or graduated with a Stafford or PLUS loan had exit counseling performed for them and appropriate d...

Student Financial Aid Cluster – Assistance Listing No. Various Recommendation: We recommend the University review its controls around exit counseling procedures to ensure that all students who withdrew or graduated with a Stafford or PLUS loan had exit counseling performed for them and appropriate documentation is retained. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Financial Aid staff are working with the Registrar and Advising staff on the implementation of a tracking sheet to ensure outreach is provided to all students who withdraw or graduate from the University. The Financial Aid staff will meet with students in person or virtually and provide students with a follow-up email communicating exit counseling information. The Financial Aid staff will update the tracking sheet with confirmed notes and dates, and the Registrar and Advising teams will review to ensure students have received the necessary information from all offices prior to exiting the University. Name(s) of the contact person(s) responsible for corrective action: Ana Borjas, Financial Aid Director Planned completion date for corrective action plan: 03/06/2026

View Audit 398239

Finding 1206256 (2025-004)

Material Weakness 2025

Livingstone College

NC

Student Financial Aid

Finding 2025-0004 - U.S. Department of Education (ED) Student Financial Assistance Programs – Untimely Release of Title IV Funds – (significant deficiency): Information on the federal program – Federal Direct Student Loans, FAL No. 84.268, June 30, 2025; Federal Pell Grant Program, FAL No. 84. 063, ...

Finding 2025-0004 - U.S. Department of Education (ED) Student Financial Assistance Programs – Untimely Release of Title IV Funds – (significant deficiency): Information on the federal program – Federal Direct Student Loans, FAL No. 84.268, June 30, 2025; Federal Pell Grant Program, FAL No. 84. 063, June 30, 2025; Federal Supplemental Educational Opportunity Grant, FAL No. 84.007, June 30, 2025; Federal Work-Study Program, FAL No. 84.033, June 30, 2025. Condition – During our review of the Return of Title IV Funds (R2T4) calculations, we identified one (1) student for whom the institution did not return unearned Title IV funds within the required 45-day timeframe. The funds were not returned until 102 days after the institution’s date of determination (ED), exceeding the regulatory deadline. Management’s Position and Perspective – One student was deemed out of compliance with the 45-day return of funds to the federal government. There was a communication gap between the Registrar and Financial Aid which resulted in the return of funds to exceed the allowed time limit of 45 days. Responsible Party – Assistant Vice President of Financial Aid and the Registrar are responsible for ensuring the funds are returned to the federal government in a timely fashion. Corrective Action Description – Going forward, the Registrar will complete a notice that a student withdrawal with a clear date when the student leaves the college. This notice will be forwarded to Financial Aid and responsibility shift to this department to ensure that the funds are returned within the allowed time limit. Timeline – Completion effective June 30, 2026.

View Audit 398235

Finding 1206252 (2025-003)

Material Weakness 2025

Livingstone College

NC

Student Financial Aid Subrecipient Monitoring Reporting

Finding 2025-003 – U.S. Department of Education (ED) Student Financial Assistance Programs – Untimely Release of Title IV Credit Balances – (significant deficiency): Information on the federal program – Federal Direct Student Loans, FAL No. 84.268, June 30, 2025; Federal Pell Grant Program, FAL No. ...

Finding 2025-003 – U.S. Department of Education (ED) Student Financial Assistance Programs – Untimely Release of Title IV Credit Balances – (significant deficiency): Information on the federal program – Federal Direct Student Loans, FAL No. 84.268, June 30, 2025; Federal Pell Grant Program, FAL No. 84. 063, June 30, 2025; Federal Supplemental Educational Opportunity Grant, FAL No. 84.007, June 30, 2025; Federal Work-Study Program, FAL No. 84.033, June 30, 2025. Condition – During testing of student account activity, we identified that three (3) out of sixty (60) sampled students had Title IV created credit balances that remained on their accounts for more than 14 days without being released to the student or parent. Management’s Position and Perspective – Three students received refunds outside the 14-day requirement. The College will introduce a process to ensure there will be a meeting between Students Accounts and Financial Aid to determine the student refunds prior to start of the semester. Both departments will determine the target dates based on the estimated timing of financial aid, as well as completion of college charges to student accounts. Included in this period is time to review the refunds and adjust. These deadlines will be outlined in the department calendar to ensure the student refunds within 14 days from posting awards and charges. Responsible Party – Assistant Vice President of Business Operations and the Director of Students Accounts are responsible for scheduling the refunds, managing workflows to ensure the 14-day time limit is achieved, and student refunds are delivered on time. Corrective Action Description – Procedures will be developed to document the new process and delivery of refunds within the guidelines. The College will introduce a process to ensure there will be a meeting between Students Accounts and Financial Aid to determine the student refunds prior to start of the semester. Both departments will determine the target dates based on the estimated timing of financial aid, as well as completion of college charges to student accounts. Included in this period is time to review the refunds and adjust. Timeline – Completion effective June 30, 2026.

View Audit 398235

Finding 1205832 (2025-011)

Material Weakness 2025

Dillard University

LA

Internal Control / Segregation of Duties Student Financial Aid Subrecipient Monitoring § 200.512

The University acknowledges the auditor’s finding regarding the late submission of the June 30, 2025, Single Audit reporting package. Although the submission exceeded the required federal deadline by only one day, management recognizes that any delay constitutes noncompliance with 2 CFR 200.512(a), ...

The University acknowledges the auditor’s finding regarding the late submission of the June 30, 2025, Single Audit reporting package. Although the submission exceeded the required federal deadline by only one day, management recognizes that any delay constitutes noncompliance with 2 CFR 200.512(a), and we take full responsibility for this timing exception. Over the past six months, the University has undertaken significant steps to strengthen its financial, accounting, and compliance infrastructure. As part of this effort, the University has hired several key leaders and staff members, including a new Vice President & Chief Financial Officer, a Controller, and a Director of Financial Aid, among other critical staff additions. These new appointments have already begun enhancing oversight, accountability, and operational capacity within the Financial Affairs and Student Financial Aid functions. The slight delay in the FY 2025 submission occurred during a period of substantial organizational transition, when newly onboarded leadership was assessing existing workflows and implementing corrective improvements. To ensure that no future deadlines are missed—and to fully eliminate repeat findings—the University has established enhanced internal controls and strengthened reporting processes, including: • Implementing a detailed Single Audit reporting calendar with accelerated internal milestones. • Assigning clear roles, responsibilities, and escalation procedures across all involved departments. • Deploying an automated tracking and reminder system for federal reporting deadlines. • Conducting quarterly compliance and readiness reviews to ensure alignment with Uniform Guidance requirements. Management is committed to ensuring timely and accurate compliance with all federal reporting obligations. With the addition of new, experienced leadership and the implementation of strengthened processes, the University is confident that this issue has been addressed and will not recur.

View Audit 397569

Finding 1205822 (2025-006)

Material Weakness 2025

Dillard University

LA

Student Financial Aid Subrecipient Monitoring Internal Control / Segregation of Duties

Return of Title IV Funds (R2T4) Calculation The University acknowledges the finding related to errors and missing documentation in the Return of Title IV Funds (R2T4) process. We recognize the importance of accurate withdrawal date determination, proper calculation of earned versus unearned aid, and...

Return of Title IV Funds (R2T4) Calculation The University acknowledges the finding related to errors and missing documentation in the Return of Title IV Funds (R2T4) process. We recognize the importance of accurate withdrawal date determination, proper calculation of earned versus unearned aid, and timely retention of supporting documentation in accordance with federal requirements. Corrective Actions 1. Immediate Corrections and Reconciliation: The University has reviewed the identified cases and will recalculate the R2T4 amounts where required, and process the return of the $18,016 owed to the U.S. Department of Education. Additional reviews are underway to identify any other students who may have been affected. 2. Strengthened Documentation and Record Retention: Procedures have been updated to ensure that withdrawal dates, last dates of attendance, and all supporting documentation are retained and readily available for audit and compliance review. 3. Revised R2T4 Calculation and Review Process: A standardized calculation template and checklist have been implemented to ensure consistency in determining payment period days, institutional charges, and earned aid. All R2T4 calculations will undergo a secondary review prior to processing. 4. Improved Coordination Between Offices: The University has enhanced communication procedures between Financial Aid, the Registrar, and Student Accounts to ensure timely access to enrollment, grade, and withdrawal information necessary for accurate R2T4 processing. 5. Staff Training and Compliance Oversight: Financial Aid staff have received updated training on R2T4 regulatory requirements, documentation standards, and calculation procedures. Periodic internal monitoring will be conducted to validate continued compliance. The University believes these corrective actions will address the root causes identified and strengthen overall compliance with federal R2T4 regulations going forward.

View Audit 397569

Finding 1205821 (2025-005)

Material Weakness 2025

Dillard University

LA

Student Financial Aid Subrecipient Monitoring

Pell Grant Calculations The University acknowledges the finding regarding errors in Pell Grant calculations for Summer 2025. We acknowledge the importance of ensuring that Pell Grant awards are calculated accurately in accordance with federal regulations. Corrective Actions 1. Immediate Corrections:...

Pell Grant Calculations The University acknowledges the finding regarding errors in Pell Grant calculations for Summer 2025. We acknowledge the importance of ensuring that Pell Grant awards are calculated accurately in accordance with federal regulations. Corrective Actions 1. Immediate Corrections: The University has reviewed the affected student accounts and has processed the remaining Pell funds owed to each student. 2. Strengthened Review Controls: A secondary review process has been implemented to verify Pell Grant calculations prior to disbursement, including confirmation of enrollment status, cost of attendance, and formula application. 3. Staff Training: Financial Aid staff are receiving additional training on Pell awarding requirements and payment schedule usage to ensure the correct application of formulas. 4. Broader File Review: The University is conducting a wider review of Pell disbursements outside the audit sample to identify and correct any similar errors. The University believes these actions will prevent future calculation errors and ensure ongoing compliance with federal regulations.

View Audit 397569

Finding 1205820 (2025-004)

Material Weakness 2025

Dillard University

LA

Student Financial Aid

FISAP Reporting The University acknowledges the finding related to the FISAP report. During the reporting period, newly hired Financial Aid staff had limited access to required U.S. Department of Education systems. Because these employees had not yet been fully authorized by the Department of Educat...

FISAP Reporting The University acknowledges the finding related to the FISAP report. During the reporting period, newly hired Financial Aid staff had limited access to required U.S. Department of Education systems. Because these employees had not yet been fully authorized by the Department of Education, they were unable to enter FISAP data or view the system-generated error notifications that are normally used to validate and finalize the report. This contributed to delays in completing the FISAP and in maintaining the supporting documentation needed for audit review. Corrective Actions 1. Resolution of System Access Issues: The University is working with the Department of Education to ensure all relevant staff will soon have full and active system credentials, allowing timely FISAP data entry and error review. 2. Strengthened Reporting Procedures: Internal processes have been updated to ensure supporting documentation for the FISAP is compiled, retained, and stored in a centralized digital repository. 3. Staffing and Oversight Improvements: Responsibilities for FISAP preparation have been reassigned and supplemented with supervisory review to prevent delays during staffing transitions or access lapses. 4. Accounting Entries: The accounting office will continue to update the general ledger to agree with the activities generated from the ECSI report and be prepared to provide the relevant data to the auditors upon request. 5. Earlier Internal Deadlines: The University has established internal timelines ahead of the federal deadline to allow adequate time for review, corrections, and document retention. The University believes these measures will prevent future access related delays and ensure timely, accurate, and fully documented FISAP submissions in compliance with federal requirements.

View Audit 397569

Finding 1205819 (2025-003)

Material Weakness 2025

Dillard University

LA

Student Financial Aid Subrecipient Monitoring Eligibility

Annual and Aggregate Loan Limits The University acknowledges the finding regarding the awarding of unsubsidized loan funds in excess of annual limits without adequate supporting documentation. We recognize that federal regulations require either a valid PLUS denial or fully documented professional j...

Annual and Aggregate Loan Limits The University acknowledges the finding regarding the awarding of unsubsidized loan funds in excess of annual limits without adequate supporting documentation. We recognize that federal regulations require either a valid PLUS denial or fully documented professional judgment to support additional unsubsidized eligibility. Corrective Actions 1. Strengthened Documentation Requirements: Effective immediately, financial aid staff will maintain complete professional judgment documentation, including the rationale, supporting evidence, and approval, in the student’s file before any additional unsubsidized loan is awarded. 2. Verification Controls: A mandatory checklist has been implemented to ensure that a PLUS denial or documented professional judgment is obtained and reviewed prior to disbursement of any loan amount exceeding standard limits. 3. Staff Training: The Office of Financial Aid will conduct targeted training to reinforce Title IV loan limit rules and proper documentation standards. 4. Ongoing Monitoring: Supervisory review will be performed on all professional judgment decisions and on any loan increases exceeding the standard $2,000 annual limit. The University believes these corrective measures will address the root cause of the finding and ensure full compliance with federal loan regulations going forward.

View Audit 397569

Finding 1205818 (2025-002)

Material Weakness 2025

Dillard University

LA

Subrecipient Monitoring Student Financial Aid Reporting

Student Status Confirmation Report The University acknowledges the finding regarding the timeliness of providing required reports to support audit testing of student enrollment status. We recognize the importance of accurate and timely reporting to the student status confirmation process and regret ...

Student Status Confirmation Report The University acknowledges the finding regarding the timeliness of providing required reports to support audit testing of student enrollment status. We recognize the importance of accurate and timely reporting to the student status confirmation process and regret that the requested documentation was not supplied within the audit timeframe. Corrective Actions Taken / Planned 1. Process Redesign and Timeliness Controls The University has implemented revised internal procedures to ensure that all requested enrollment reports are generated promptly. This includes establishing defined timelines for responding to audit requests and assigning responsibility to specific staff members to track and manage reporting obligations. 2. System and Reporting Enhancements We are reviewing and updating our reporting workflow within our student information system to strengthen data retrieval capabilities and reduce delays in report generation. Additional user training will be provided to ensure staff can efficiently extract the required information. 3. Improved Communication With the Guaranty Agency The University will review past enrollment status submissions and implement additional checks to ensure that future enrollment reporting to the guaranty agency is complete, accurate, and timely. A 45-day reconciliation process has been added to verify that all required status updates have been transmitted. 4. Ongoing Monitoring The University has established ongoing oversight to ensure consistent compliance with reporting requirements. Internal reviews will be performed periodically to confirm that corrective actions remain effective. Management Conclusion We believe these measures will address the root causes identified in the finding and will ensure the timely delivery of required information for future audits. The University is committed to maintaining full compliance with federal and state reporting standards.

View Audit 397569

Finding 1205770 (2025-004)

Material Weakness 2025

Hampton University

VA

Student Financial Aid Special Tests & Provisions

Corrective Action: The University agrees with the findings. Management will perform a review of Title IV refunds to ensure credit balances are refunded to students within the required 14-day timeframe. In addition, management will review the existing system of controls related to the timely refund o...

Corrective Action: The University agrees with the findings. Management will perform a review of Title IV refunds to ensure credit balances are refunded to students within the required 14-day timeframe. In addition, management will review the existing system of controls related to the timely refund of credit balances. Further, management will reinforce control ownership and provide targeted training to individuals responsible for compliance. The actions will help to ensure that appropriate controls are in place and responsibilities are clearly defined, and instances of noncompliance are mitigated to support controls. Contact Person: Terry Nixon, Assistant Comptroller, Student Business Services Anticipated Completion Date: June 15, 2026

View Audit 397505

Finding 1205768 (2025-002)

Material Weakness 2025

Hampton University

VA

Student Financial Aid

Corrective Action : The U niversity agrees with the find ings. We will update our interna l review repoti so that we wi ll meet the enrollment status changes withi n the 60 day period. . The Program Level is updated by the SHRDEGV report and is al ready submitted in a timely manner. The time status ...

Corrective Action : The U niversity agrees with the find ings. We will update our interna l review repoti so that we wi ll meet the enrollment status changes withi n the 60 day period. . The Program Level is updated by the SHRDEGV report and is al ready submitted in a timely manner. The time status issues were addressed and updated during the Fall 2025 term merge project. We will work with IT to enhance the information included in the Comprehensive Graduation Report (CRT) to ensure complete, accurate and timely repmiing.Contact Person: Regina Cotter, University Registrar Anticipated Completion Date: June 15, 2026

View Audit 397505

Finding 1205764 (2025-001)

Material Weakness 2025

Richmont Graduate University

TN

Student Financial Aid Reporting Material Weakness

Richmont Graduate University has updated their policy for the Registrar to communicate to the Financial Aid Office AND the Administration Office when a student as fallen below half-time or has withdrawn/dropped all their coursework for the semester. The Registrar has updated the Add/Drop/Withdrawn f...

Richmont Graduate University has updated their policy for the Registrar to communicate to the Financial Aid Office AND the Administration Office when a student as fallen below half-time or has withdrawn/dropped all their coursework for the semester. The Registrar has updated the Add/Drop/Withdrawn form that requires her to sign that she has communicated to both offices. Hear is the updated for: Add/Drop/Withdrawn Form

View Audit 397502

Finding 1205711 (2025-007)

Material Weakness 2025

Paine College

GA

Student Financial Aid Internal Control / Segregation of Duties

Uniform Guidance Financial and Compliance Audit-June 30, 2025, Ending Fiscal Year Paine College has developed a structured corrective action plan to address findings (2025- 001, 2025-002, 2025-003, 2025-004, and 2025-005) identified in the Uniform Guidance Financial and Compliance Audit. The institu...

Uniform Guidance Financial and Compliance Audit-June 30, 2025, Ending Fiscal Year Paine College has developed a structured corrective action plan to address findings (2025- 001, 2025-002, 2025-003, 2025-004, and 2025-005) identified in the Uniform Guidance Financial and Compliance Audit. The institution is prioritizing the strengthening of internal controls, the improvement of financial oversight, and the enhancement of compliance monitoring to ensure responsible stewardship offederal funds and long-term institutional stability. The corrective action outlines each audit finding and the steps the College is taking to resolve the identified concerns.

View Audit 397416

Finding 1205707 (2025-006)

Material Weakness 2025

Paine College

GA

Student Financial Aid Internal Control / Segregation of Duties Subrecipient Monitoring

Uniform Guidance Financial and Compliance Audit-June 30, 2025, Ending Fiscal Year Paine College has developed a structured corrective action plan to address findings (2025- 001, 2025-002, 2025-003, 2025-004, and 2025-005) identified in the Uniform Guidance Financial and Compliance Audit. The institu...

Uniform Guidance Financial and Compliance Audit-June 30, 2025, Ending Fiscal Year Paine College has developed a structured corrective action plan to address findings (2025- 001, 2025-002, 2025-003, 2025-004, and 2025-005) identified in the Uniform Guidance Financial and Compliance Audit. The institution is prioritizing the strengthening of internal controls, the improvement of financial oversight, and the enhancement of compliance monitoring to ensure responsible stewardship offederal funds and long-term institutional stability. The corrective action outlines each audit finding and the steps the College is taking to resolve the identified concerns.

View Audit 397416

Finding 1205703 (2025-005)

Material Weakness 2025

Paine College

GA

Student Financial Aid Subrecipient Monitoring Eligibility

Uniform Guidance Financial and Compliance Audit-June 30, 2025, Ending Fiscal Year Paine College has developed a structured corrective action plan to address findings (2025- 001, 2025-002, 2025-003, 2025-004, and 2025-005) identified in the Uniform Guidance Financial and Compliance Audit. The institu...

Uniform Guidance Financial and Compliance Audit-June 30, 2025, Ending Fiscal Year Paine College has developed a structured corrective action plan to address findings (2025- 001, 2025-002, 2025-003, 2025-004, and 2025-005) identified in the Uniform Guidance Financial and Compliance Audit. The institution is prioritizing the strengthening of internal controls, the improvement of financial oversight, and the enhancement of compliance monitoring to ensure responsible stewardship offederal funds and long-term institutional stability. The corrective action outlines each audit finding and the steps the College is taking to resolve the identified concerns. Corrective Action 2025-005: Administrative and Fiscal Affairs 1235 Fifteenth Street, Augusta, GA 30901 Implement the Return to Title IV monitoring system, weekly credit balance tracking, counseling verification procedures, and strengthen coordination between Financial Aid, Registrar, and Business Office Target resolution: Spring-Summer 2026

View Audit 397416

Finding 1205695 (2025-002)

Material Weakness 2025

Miles College

AL

Student Financial Aid Cash Management Allowable Costs / Cost Principles § 200.305

Finding 2025-002 - U.S. Department of Education (USO}, Title IV Student Financial Aid Programs (significant deficiency): Information on the federal program - Federal Pell Grant Program, FAL No. 84.063, June 30,2025; Federal Work-Study Program, FAL No. 84.033, June 30, 2025; Federal Supplemental Oppo...

Finding 2025-002 - U.S. Department of Education (USO}, Title IV Student Financial Aid Programs (significant deficiency): Information on the federal program - Federal Pell Grant Program, FAL No. 84.063, June 30,2025; Federal Work-Study Program, FAL No. 84.033, June 30, 2025; Federal Supplemental Opportunity Grant Program, FAL No. 84.007, June 30, 2025; Federal Direct Student Loan Program, FAL No. 84.268, June 30, 2025; Teachers Education Assistance for College(TEACH),FAL No. 84.379, June 30, 2025. Under 2 CFR 200.305 and the U.S. Department of Education's cash management requirements at 34 CFR 668.162, institutions must draw down Title IV funds only for expenditures 1. Corrective Action Description The College now requires all drawdowns to include supporting documentation of the funds requested from GS, along with sign-offs on preparation and approval. Supporting documents are stored securely on the College's accounting drive for easy access. 2. Person Responsible and Department Diana Knighton Senior Vice President, Finance and Business Administration Miles College 5500 Myron Massey Boulevard Fairfield, AL 3506 (205) 929-1442 dknighton@miles.edu a. Implementation Timeline This procedure took effect as of July 31, 2025. b. Planned Preventive Measures Following the policy and procedures to support all drawdowns with proper documentation. c. Disagreement with the Finding None

View Audit 397405

Finding 1205691 (2025-001)

Material Weakness 2025

Miles College

AL

Student Financial Aid Matching / Level of Effort / Earmarking Subrecipient Monitoring

Finding 2025 - 001 - U.S. Department of Education (USD), Title IV Student Financial Aid Programs (material weakness): Information on the federal program - (Federal Award Identification): - Federal Pell Grant Program, FAL No. 84.063, June 30, 2025; Federal Supplemental Opportunity Grant Program, FAL ...

Finding 2025 - 001 - U.S. Department of Education (USD), Title IV Student Financial Aid Programs (material weakness): Information on the federal program - (Federal Award Identification): - Federal Pell Grant Program, FAL No. 84.063, June 30, 2025; Federal Supplemental Opportunity Grant Program, FAL No. 84.007, June 30, 2025; Federal Work-Study Program, FAL No. 84.033, June 30, 2025; Federal Direct Student Loan Program, FAL No. 84.268, June 30, 2025; Federal Teacher Education Assistance for College (TEACH), FAL No. 84.379, June 30, 2025. Institutions must determine a student's financial need by subtracting the expected family contribution and estimated financial assistance from the cost of attendance. 34 CFR 668.2 and 34 CFR 637.S(a). 1. Corrective Action Description The College has engaged a financial aid consultant to support the development of cost-of-attendance budgets and ensure they align with industry best practices, thereby making improvements to the College's financial aid operating system. After evaluating the auditors' sample of forty students, the College confirmed that no instances of over/under awarding occurred. There were clarifications and changes made to the initial cost of attendance budgets provided to the auditors that led to the questioned cost. The College will implement ongoing monitoring each semester to further enhance operational efficiency and effectiveness. The cost of attendance budgets has been uploaded into the College's financial aid system to prevent the recurrence of this issue for the current and future years. a. Responsible Person and Department Diana Knighton Senior Vice President, Finance and Business Administration Miles College 5500 Myron Massey Boulevard Fairfield, AL 3506 (205) 929-1442 dknighton@miles.edu b. Implementation Timeline January 18, 2026, for the spring semester c. Planned Preventive Measures The College hired a financial aid consultant to assist the financial aid Director with best practices and to make modifications to the ERP system to provide better operating efficiency and effectiveness. d. Disagreement with the Finding None

View Audit 397405

Finding 1205680 (2025-001)

Material Weakness 2025

East-West University

IL

Student Financial Aid Eligibility Matching / Level of Effort / Earmarking

2025-001: Incorrect Direct Loans Disbursement Amount - Student Financial Aid Cluster Assistance Listing Number 84.007, 84.033, 84.038, 84.063, 84.268, Grant Period - Year Ended August 31, 2025 Condition Found During our student file testing we noted two students out of forty were disbursed the incor...

2025-001: Incorrect Direct Loans Disbursement Amount - Student Financial Aid Cluster Assistance Listing Number 84.007, 84.033, 84.038, 84.063, 84.268, Grant Period - Year Ended August 31, 2025 Condition Found During our student file testing we noted two students out of forty were disbursed the incorrect Direct Loan amount. Based on the student’s enrollment status and need, the University over awarded the students by $1,229. We consider this error in awarding to be an instance of noncompliance of the Eligibility Compliance Requirement. Corrective Action Plan Financial Aid office will make sure the correct amount is awarded based on the student enrollment status and need of the student. EWU will make the proper adjustments to the Direct Subsidized Loan to reflect the correct amount for the two students. Responsible Person for Corrective Action Plan Director of Financial Aid Cesar Campos Implementation Date of Corrective Action Plan March 06, 2026

View Audit 397395

Finding 1205644 (2025-008)

Material Weakness 2025

Tougaloo College

MS

Student Financial Aid

"U.S. Department of Education (ED), Student Financial Assistance Programs - NSLDS Enrollment (material weakness): Management Response and Corrective Action Plan The Office of the Vice President for Enrollment Management and Student Services concur with this finding. Responsible officials acknowledge...

"U.S. Department of Education (ED), Student Financial Assistance Programs - NSLDS Enrollment (material weakness): Management Response and Corrective Action Plan The Office of the Vice President for Enrollment Management and Student Services concur with this finding. Responsible officials acknowledge the seriousness of this finding and recognize that timely and accurate NSLDS enrollment reporting is critical to the integrity of Title IV programs and the proper administration of student loan repayment obligations. The institution is committed to maintaining compliance with all federal student aid requirements and agrees that this issue represents a control weakness that required immediate attention. While the error affected a limited number of students, officials understand the potential systemic implications and have taken corrective measures accordingly. Responsible officials will continue to monitor enrollment reporting through periodic reconciliations and management oversight to ensure all enrollment status changes—including withdrawals—are reported accurately and within the prescribed regulatory timeframe. Management believes the corrective actions implemented will prevent recurrence of this issue and demonstrate the institution’s commitment to compliance and accountability. "

View Audit 397293

Finding 1205643 (2025-007)

Material Weakness 2025

Tougaloo College

MS

Student Financial Aid

Finding 2025-007 U.S. Department of Education (USDE), Title IV Student Financial Aid Programs – Policy & Procedures Manual (material weakness): Management Response and Corrective Action Plan The Office of the Vice President for Enrollment Management and Student Services concur with this finding. We ...

Finding 2025-007 U.S. Department of Education (USDE), Title IV Student Financial Aid Programs – Policy & Procedures Manual (material weakness): Management Response and Corrective Action Plan The Office of the Vice President for Enrollment Management and Student Services concur with this finding. We recognize that the maintenance of a current and comprehensive Policy & Procedures Manual is a fundamental requirement under 34 CFR 668.16 and 34 CFR 668.34 to ensure the consistent and accurate administration of Title IV federal student aid. While the institution maintained operational compliance with Department of Education regulations throughout the audit period, we acknowledge that the formal documentation had not been updated since the 2018-2019 academic year. To address this finding and mitigate any risk of systemic processing errors, the Student Financial Aid Office has completed a comprehensive revision of the Financial Aid Policy & Procedures Manual. • Completion Status: The manual has been fully updated to reflect the 2024-2026 academic cycles. • Scope: The updated manual incorporates current federal regulations for all major programs, including the Federal Pell Grant, FSEOG, Federal Work-Study, Federal Direct Student Loans, and TEACH Grant programs. • Compliance: The new documentation aligns with the latest Federal Student Aid Handbook guidance and ensures that all institutional policies meet current USDE requirements. To ensure this remains a "one-time" finding rather than a recurring issue, the Financial Aid Director has implemented an Annual Review Protocol. Beginning in June each year, the manual will undergo a formal review and update cycle to coincide with the release of the new award year’s federal guidelines.

View Audit 397293

Finding 1205642 (2025-006)

Material Weakness 2025

Tougaloo College

MS

Student Financial Aid Internal Control / Segregation of Duties

Finding 2025-006 U.S. Department of Education (USDE), Title IV Student Financial Aid Programs – Federal Work-Study Community Service (material weakness): Management Response and Corrective Action Plan Tougaloo College acknowledges the auditor’s finding regarding the 7% Federal Work-Study (FWS) commu...

Finding 2025-006 U.S. Department of Education (USDE), Title IV Student Financial Aid Programs – Federal Work-Study Community Service (material weakness): Management Response and Corrective Action Plan Tougaloo College acknowledges the auditor’s finding regarding the 7% Federal Work-Study (FWS) community service expenditure requirement under 34 CFR 675.18. While the College has a storied history of community engagement, we recognize that the administrative tracking and placement of students into qualifying FWS community service positions for the 2024-25 academic year did not meet federal mandates. Management accepts the recommendation to strengthen internal controls and is committed to ensuring that our Student Financial Aid Office has the oversight necessary to maintain compliance and protect our participation in Title IV programs. Corrective Action Plan (CAP): • Expanded Community Partnerships: The Office of Enrollment Management and Student Services will immediately re-establish and formalize Memorandums of Understanding (MOUs) with local non-profit organizations and governmental agencies in the Jackson, MS metropolitan area. These partnerships will prioritize literacy and mathematics tutoring (consistent with the FWS "America Reads/America Counts" initiatives) and social service support. • Enhanced Internal Monitoring: The Director of Student Financial Aid will implement a monthly FWS Allocation Tracker. This internal control will monitor FWS expenditures specifically for community service to ensure the 7% threshold is reached well before the end of the academic year. • Administrative Oversight: The Vice President for Enrollment Management and Student Services will conduct a formal quarterly review of these trackers. This ensures that any shortfall in community service placements is identified early enough to initiate a Community Service Waiver request to the U.S. Department of Education, should unique circumstances arise. • Student Awareness Campaign: We will integrate community service FWS opportunities into our student orientation and "Federal Work-Study Fair" to ensure students are aware of these high-impact service opportunities. Completion Date: August 15, 2026

View Audit 397293

Finding 1205641 (2025-005)

Material Weakness 2025

Tougaloo College

MS

Student Financial Aid

Finding 2025-005 U.S. Department of Education (USDE), Title IV Student Financial Aid Programs – Fiscal Operations Report and Application to Participate (FISAP) (material weakness): Management Response and Corrective Action Plan The Office of Enrollment Management and Student Services acknowledge the...

Finding 2025-005 U.S. Department of Education (USDE), Title IV Student Financial Aid Programs – Fiscal Operations Report and Application to Participate (FISAP) (material weakness): Management Response and Corrective Action Plan The Office of Enrollment Management and Student Services acknowledge the auditor’s finding regarding the discrepancies in the Fiscal Operations Report and Application to Participate (FISAP) for the 2024-25 award year. We recognize the criticality of maintaining accurate records to support federal funding eligibility and are committed to resolving the underlying systemic issues identified. The College concurs with the finding. It was determined that the inaccuracies in Part 2, Section F (Information on Eligible Aid Applicants) resulted from a lack of synchronization between the latest federal reporting requirements and the institution’s current software version. Specifically, the manual compilation of data was used in lieu of automated Jenzabar reports due to a pending system update. To ensure future compliance and the accuracy of all Title IV reporting, the following actions have been initiated: • System Synchronization & Updates: The Information Technology (IT) Department, in coordination with the Office of Financial Aid, has established a priority schedule for all Jenzabar FA/SIS system updates. A mandatory "Systems Readiness" review will now occur 60 days prior to the FISAP submission deadline to ensure all regulatory patches are installed. • Standardization of Reporting Procedures: Management has mandated that all future FISAP data must be pulled directly from the Jenzabar system modules. Manual entries will only be permitted as a secondary verification measure to ensure data integrity against system-generated reports. • Inter-Departmental Oversight: A new "FISAP Task Force" comprising representatives from Financial Aid, IT, and Business/Finance has been formed. This group will perform a preliminary review of the FISAP data 30 days before submission to verify that the system-generated data aligns with institutional records and federal criteria (34 CFR 675.19 and 34 CFR 676.19). • Technical Assistance Engagement: The College is currently coordinating with the U.S. Department of Education to facilitate an On-site Title IV Technical Assistance & Support (OTA) visit. This visit will include a specific focus on optimizing our SIS reporting capabilities for campus-based program funds. 4) Implementation Timeline • System Update Completion: Immediate (April 2026) • Standard Operating Procedure (SOP) Revision: May 15, 2026 • On-site Technical Assistance Visit: Expected April/May 2026

View Audit 397293

Finding 1205640 (2025-004)

Material Weakness 2025

Tougaloo College

MS

Student Financial Aid Internal Control / Segregation of Duties

Finding 2025-004 U.S. Department of Education (USDE), Title IV Student Financial Aid Programs – Cost of Attendance Budgets (material weakness): Management’s Response and Corrective Action Plan The College concurs with this finding. We acknowledge that the absence of documented Cost of Attendance (CO...

Finding 2025-004 U.S. Department of Education (USDE), Title IV Student Financial Aid Programs – Cost of Attendance Budgets (material weakness): Management’s Response and Corrective Action Plan The College concurs with this finding. We acknowledge that the absence of documented Cost of Attendance (COA) budgets and the resulting inability to verify financial need calculations constitute a significant breakdown in internal controls. The College is committed to immediate remediation to ensure full compliance with Title IV regulations. 1) Corrective Action Plan (CAP) To address the root causes of this finding, the College will implement the following measures: • Establishment of Formal COA Budgets: The Financial Aid Office will immediately develop and document standardized COA budgets for the 2025-2026 academic year. These budgets will account for all required components (tuition, fees, housing, food, books, supplies, transportation, and personal expenses) as required by 34 CFR 668.2. • System Integration: We will update our Student Information System (SIS) to automate the application of these COA budgets to student records, ensuring that "Unmet Need" is calculated electronically and consistently for every applicant. • Formalized Internal Controls: A new Standard Operating Procedure (SOP) manual for Financial Aid Packaging will be authored and implemented by June 1, 2026. This manual will mandate the retention of COA tables used for each award year to provide a clear audit trail. • Enhanced Oversight and Training: The Vice President for Enrollment Management and Student Services will initiate a mandatory training program for all financial aid staff regarding federal packaging requirements. • Internal Quality Assurance (IQA): Beginning April 15, 2026, the College will implement a monthly "Mini-Audit" process where a random sample of 10% of student files is reviewed by a third-party or a non-conflicted administrator to verify COA accuracy before disbursements are finalized. 2) Designated Responsible Party-Director of Financial Aid. 3) Anticipated Completion Date-June 30, 2026

View Audit 397293

Corrective Action Plans

Filters