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Corrective Action Plans

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Finding 1174860 (2025-003)
Material Weakness 2025
Northwestern Oklahoma State University
OK
Student Financial Aid Reporting
Award periods (AWPD) were set up in summer 2023 for the 24-25 award year. At that time, official semester start and end dates were unknown therefore the expected start date was entered in Colleague. When the semester start and end dates became official in spring 2024, the financial aid office update...
Award periods (AWPD) were set up in summer 2023 for the 24-25 award year. At that time, official semester start and end dates were unknown therefore the expected start date was entered in Colleague. When the semester start and end dates became official in spring 2024, the financial aid office updated AWPD in Colleague, not realizing students whose FAFSAs had already been received and packaged would not be updated with the official start date. Students who were packaged after the AWPD update were correct. Going forward, the financial aid office will ensure that AWPD is updated before packaging any student financial aid.
View Audit 388429
Finding 1174858 (2025-002)
Material Weakness 2025
Northwestern Oklahoma State University
OK
Student Financial Aid Reporting
Northwestern Oklahoma State University agrees with the auditor's findings. The issue is in relation to how the software (Colleague) is currently setup. Northwestern will work on a correction so that moving forward the dates are accurate with the academic year calendar. Northwestern will work to have...
Northwestern Oklahoma State University agrees with the auditor's findings. The issue is in relation to how the software (Colleague) is currently setup. Northwestern will work on a correction so that moving forward the dates are accurate with the academic year calendar. Northwestern will work to have this done for the next list to be sent to NSLDS.
View Audit 388429
Finding 1174847 (2025-002)
Material Weakness 2025
San Diego Community College District
CA
Student Financial Aid Special Tests & Provisions
Views of Responsible Officials and Corrective Action Plan We concur. The District has filed a bug with IT to have this issue addressed and the programming fixed promptly. Corrections have already been made with NSLDS by the campuses.
Views of Responsible Officials and Corrective Action Plan We concur. The District has filed a bug with IT to have this issue addressed and the programming fixed promptly. Corrections have already been made with NSLDS by the campuses.
View Audit 388422
Finding 1174842 (2025-001)
Material Weakness 2025
San Diego Community College District
CA
Special Tests & Provisions Student Financial Aid Subrecipient Monitoring
Views of Responsible Officials and Corrective Action Plan We concur. Management has revised its procedures for R2T4, as well as added additional monthly review to ensure compliance.
Views of Responsible Officials and Corrective Action Plan We concur. Management has revised its procedures for R2T4, as well as added additional monthly review to ensure compliance.
View Audit 388422
Finding 1174783 (2025-007)
Material Weakness 2025
Clarkson College
NE
Student Financial Aid Significant Deficiency Internal Control / Segregation of Duties
Student Financial Aid Cluster – Assistance Listing No. 84.063 Recommendation: We recommend the College review and strengthen its policies and procedures to ensure that all student credit balances resulting from federal funds are refunded within the required 14-day period. Explanation of disagreement...
Student Financial Aid Cluster – Assistance Listing No. 84.063 Recommendation: We recommend the College review and strengthen its policies and procedures to ensure that all student credit balances resulting from federal funds are refunded within the required 14-day period. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: This finding was from Fall of 2024. During the Fall semester of FY 25, Clarkson College experienced turnover with its financial aid department staff. From Spring 2025 on, the financial aid department now processes financial aid weekly on Monday through Wednesday each week. The student accounts team in turn runs a report for any credit balances on Thursday morning each week. Upon running the report, the student accounts team will then process and issue either a check or ACH payment refund that same day so that at most, there is a eight-day period. In addition, the College enhanced the check payment process so that the checks can be generated, printed, and mailed same-day. Name(s) of the contact person(s) responsible for corrective action: Nathan Wiegand, VP of College Finance/CFO Planned completion date for corrective action plan: Implemented in January, 2025.
View Audit 388309
Finding 1174775 (2025-006)
Material Weakness 2025
Clarkson College
NE
Student Financial Aid Reporting Significant Deficiency
Student Financial Aid Cluster – Assistance Listing No. 84.063 Recommendation: We recommend the College establish a process to ensure that all disbursement information is accurately reported to the COD system. Explanation of disagreement with audit finding: There is no disagreement with the audit fin...
Student Financial Aid Cluster – Assistance Listing No. 84.063 Recommendation: We recommend the College establish a process to ensure that all disbursement information is accurately reported to the COD system. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: It was noted in COD that a disbursement date did not match the date recorded in our Anthology system; the discrepancy was by one day. Once identified, the Financial Aid team corrected the error. Unfortunately, the correction was made outside the required 15-day window. All disbursement dates have now been updated, and we have implemented a new process to ensure that all dates in Anthology and COD align. The Financial Aid team is actively monitoring this to ensure that current and future disbursement dates consistently match providing an additional reconciliation of dates. Name(s) of the contact person(s) responsible for corrective action: Dr. Carla Dirkshneider, VP of Enrollment and Retention Planned completion date for corrective action plan: Implemented
View Audit 388309
Finding 1174767 (2025-005)
Material Weakness 2025
Clarkson College
NE
Student Financial Aid Eligibility Significant Deficiency
Student Financial Aid Cluster – Assistance Listing No. 84.063 Recommendation: We recommend the College implement a review process that compares enrolled credits to Pell awards to ensure all students receive the correct Pell Grant amounts. Explanation of disagreement with audit finding: There is no d...
Student Financial Aid Cluster – Assistance Listing No. 84.063 Recommendation: We recommend the College implement a review process that compares enrolled credits to Pell awards to ensure all students receive the correct Pell Grant amounts. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: There was one student in Fall 2024 who was under-awarded Pell Grant funds due to an error related to the student’s withdrawal status and the number of credits attempted. The Pell award was manually processed incorrectly based on this enrollment change. Beginning in Spring 2025, the Financial Aid team implemented a new process requiring a formal review of enrollment intensity for all students prior to determining and disbursing Pell Grant funds. This ensures that Pell awards are calculated and adjusted accurately. Additionally, the team now utilizes enrollment and Pell related reports to help identify potential changes in student enrollment and support timely, accurate award reviews. Name(s) of the contact person(s) responsible for corrective action: Dr. Carla Dirkshneider, VP of Enrollment and Retention Planned completion date for corrective action plan: Corrective action was implemented January, 2025.
View Audit 388309
Finding 1174759 (2025-004)
Material Weakness 2025
Clarkson College
NE
Student Financial Aid Eligibility Significant Deficiency
Student Financial Aid Cluster – Assistance Listing No. Various Recommendation: We recommend the College review the R2T4 requirements and implement procedures to ensure that calculations use the correct number of break days and are completed accurately and within the required timeframes. Explanation ...
Student Financial Aid Cluster – Assistance Listing No. Various Recommendation: We recommend the College review the R2T4 requirements and implement procedures to ensure that calculations use the correct number of break days and are completed accurately and within the required timeframes. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: During the review period, two students did not receive their Return to Title IV (R2T4) calculations within the required 45-day timeframe. The delay occurred because the Financial Aid Office did not receive the corresponding change of registration forms from the Registrar’s Office, which is necessary to initiate the R2T4 process. To prevent recurrence, the Financial Aid Office has implemented the following corrective actions: 1. Monitoring Reports: The team now runs a student status change report to independently identify potential R2T4 cases, even if documentation has not yet been forwarded. 2. Improved Communication Workflow: Financial Aid has been added to the Registrar’s change of registration email distribution list to ensure timely notification of withdrawals, drops, and status changes. These measures strengthen internal controls, improve cross departmental communication, and ensure that all future R2T4 calculations are completed within federal timelines. Name(s) of the contact person(s) responsible for corrective action: Dr. Carla Dirkshneider, VP of Enrollment and Retention Planned completion date for corrective action plan: Corrective action was implemented in June 2025.
View Audit 388309
Finding 1174751 (2025-003)
Material Weakness 2025
Clarkson College
NE
Student Financial Aid Matching / Level of Effort / Earmarking Internal Control / Segregation of Duties § 200.303
Student Financial Aid Cluster – Assistance Listing No. Various Recommendation: We recommend the College review and formalize its procedures to ensure that internal controls are in place to identify and correct any inconsistencies throughout the year. Explanation of disagreement with audit finding: T...
Student Financial Aid Cluster – Assistance Listing No. Various Recommendation: We recommend the College review and formalize its procedures to ensure that internal controls are in place to identify and correct any inconsistencies throughout the year. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: In the spring of 2025, Clarkson College made the decision to outsource majority of financial aid functions to the Higher Education Assistance Group (HEAG) due to a lack of internal controls. Since hiring HEAG in Spring 2025 to oversee our financial aid functions, Clarkson College has seen many improvements in our internal controls. Reconciliation of Direct Loans and Federal Pell Grant funds is conducted monthly by a designated Financial Aid staff member. Following completion, the reconciliation documentation is forwarded to the College Controller for independent review. Final approval is provided by the Vice President of Enrollment and Advising. A standing monthly meeting is also held between the Financial Aid and Finance teams to review reconciliation activity, address variances, and resolve any items requiring clarification. The Federal Work-Study (FWS) program is monitored and reviewed each pay period to ensure expenditures remain within authorized limits and align with student eligibility. Federal Supplemental Educational Opportunity Grant (FSEOG) and Federal Work-Study (FWS) funds are reviewed and reconciled periodically throughout each semester by a Financial Aid staff member. Upon completion of these reconciliations, supporting documentation is submitted to the College Controller for review and verification of accuracy. These procedures ensure compliance with federal regulations, promote internal control integrity, and provide appropriate oversight of all Title IV funding streams. Name(s) of the contact person(s) responsible for corrective action: Dr. Carla Dirkshneider, VP of Enrollment and Retention Planned completion date for corrective action plan: Corrective action was implemented Spring semester of FY 2025.
View Audit 388309
Finding 1174743 (2025-002)
Material Weakness 2025
Clarkson College
NE
Student Financial Aid Material Weakness Reporting
Student Financial Aid Cluster – Assistance Listing No. Various Recommendation: We recommend the College review and strengthen its reporting procedures to ensure that student statuses are accurately reported to NSLDS, as required by federal regulations. Explanation of disagreement with audit finding:...
Student Financial Aid Cluster – Assistance Listing No. Various Recommendation: We recommend the College review and strengthen its reporting procedures to ensure that student statuses are accurately reported to NSLDS, as required by federal regulations. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Clarkson College completed its implementation of Anthology as a new student information system (SIS) in FY 25. Enrollment reports from the new SIS are used to update the National Student Clearinghouse and thus the NSLDS. The Registrar’s Office is working with our Anthology partner to determine issues with the enrollment dates and statuses. Moving forward, the Registrar’s Office will also do an internal audit of enrollment records between the National Student Clearinghouse, NSLDS, and our internal SIS. Name(s) of the contact person(s) responsible for corrective action: Dr. Carla Dirkshneider, VP of Enrollment and Retention Planned completion date for corrective action plan: Corrective action was implemented in the Spring semester of FY 2025.
View Audit 388309
Finding 1174332 (2025-001)
Material Weakness 2025
San Bernardino Community College District
CA
Student Financial Aid Significant Deficiency Internal Control / Segregation of Duties
The District has reviewed the policies and procedures over the R2T4 calculation and has identified additional controls to prevent miscalculations going forward. The Student Financial Aid Office has begun the implementation of the following corrective action plan to prevent future recurrence: Impleme...
The District has reviewed the policies and procedures over the R2T4 calculation and has identified additional controls to prevent miscalculations going forward. The Student Financial Aid Office has begun the implementation of the following corrective action plan to prevent future recurrence: Implement a cross-check with the Common Origination & Disbursement (COD) site R2T4 calculator to supplement the tools within our internal financial system. The COD system automatically calculates dates attended by students, eliminating the manual element of this step in the calculation. Implement a second review to spot check calculations during each semester to ensure accuracy. Require Blue Icon R2T4 training and certification for staff preparing, reviewing, and processing R2T4 calculations. These controls began implementation in November 2025 and are expected to be fully in place by March 2026. New regulations for R2T4 are expected to be released in early 2026. Blue Icon training will be scheduled once the new regulations are released.
View Audit 388086
Finding 1174318 (2025-001)
Material Weakness 2025
Laredo College
TX
Student Financial Aid Reporting
Corrective Action Plan
Corrective Action Plan
View Audit 388074
Finding 1174318 (2025-001)
Material Weakness 2025
Laredo College
TX
Student Financial Aid Reporting
CORRECTIVE ACTION PLAN
CORRECTIVE ACTION PLAN
View Audit 388074
Finding 1174318 (2025-001)
Material Weakness 2025
Laredo College
TX
Student Financial Aid Reporting
Federal Program: Student Financial Aid Cluster
Federal Program: Student Financial Aid Cluster
View Audit 388074
Finding 1174318 (2025-001)
Material Weakness 2025
Laredo College
TX
Student Financial Aid Reporting
-ALN 84.063
-ALN 84.063
View Audit 388074
Finding 1174318 (2025-001)
Material Weakness 2025
Laredo College
TX
Student Financial Aid Reporting
Finding No. 2025-001 — Significant Deficiency
Finding No. 2025-001 — Significant Deficiency
View Audit 388074
Finding 1174318 (2025-001)
Material Weakness 2025
Laredo College
TX
Student Financial Aid Reporting
— Special Tests and Provisions-Enrollment Reporting
— Special Tests and Provisions-Enrollment Reporting
View Audit 388074
Finding 1174318 (2025-001)
Material Weakness 2025
Laredo College
TX
Student Financial Aid Reporting
Criteria: Federal regulations and related guidance governing Title IV student aid programs require schools to report the enrollment of students who receive federal student aid (U.S. Department of Education, National Student Loan Data System (NSLDS) Enrollment Reporting Guide, November 2022, Chapter ...
Criteria: Federal regulations and related guidance governing Title IV student aid programs require schools to report the enrollment of students who receive federal student aid (U.S. Department of Education, National Student Loan Data System (NSLDS) Enrollment Reporting Guide, November 2022, Chapter 2). At a minimum, schools are required to certify enrollment every 60 days and respond within 15 days of the date that NSLDS sends a roster file to the school or its third-party servicer. The administration of the Title IV programs depends heavily on the accuracy and timeliness of the enrollment information reported by institutions. Institutions must review, update, and certify student enrollment statuses, program information, and effective dates that appear on the Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS Professional Access (NSLDSFAP) website.
View Audit 388074
Finding 1174318 (2025-001)
Material Weakness 2025
Laredo College
TX
Student Financial Aid Reporting
Laredo College (College) uses the services of the National Student Clearinghouse (NSC) to report status changes to NSLDS. Under this arrangement, the college reports all students enrolled and their status to NSC. NSC then identifies any changes in status and reports those changes to NSLDS when requi...
Laredo College (College) uses the services of the National Student Clearinghouse (NSC) to report status changes to NSLDS. Under this arrangement, the college reports all students enrolled and their status to NSC. NSC then identifies any changes in status and reports those changes to NSLDS when required. Although the college uses the services of the NSC, the College still has the primary responsibility for ensuring any changes in student enrollment status is reported accurately and in a timely manner (NSLDS Enrollment Reporting Guide, November 2022, Chapter 3).
View Audit 388074
Finding 1174318 (2025-001)
Material Weakness 2025
Laredo College
TX
Student Financial Aid Reporting
Condition: For 18 out of 25 (72 percent) students tested, the college did not accurately and timely report enrollment status changes to NSLDS. Specifically:
Condition: For 18 out of 25 (72 percent) students tested, the college did not accurately and timely report enrollment status changes to NSLDS. Specifically:
View Audit 388074
Finding 1174318 (2025-001)
Material Weakness 2025
Laredo College
TX
Student Financial Aid Reporting
· For thirteen (13) students, the College did not report the students' withdrawal status until approximately eleven months after the student withdrew; additionally, for each of these students, the withdrawal date documented in the college's student records did not agree with the withdrawal dates doc...
· For thirteen (13) students, the College did not report the students' withdrawal status until approximately eleven months after the student withdrew; additionally, for each of these students, the withdrawal date documented in the college's student records did not agree with the withdrawal dates documented in the NSLDS system.
View Audit 388074
Finding 1174318 (2025-001)
Material Weakness 2025
Laredo College
TX
Student Financial Aid Reporting
· For two (2) students who both attended and withdrew from the College in the spring 2025 semester, the NSLDS system showed a withdrawn status effective in December 2024 that was reported to NSLDS ten months later in October 2025.
· For two (2) students who both attended and withdrew from the College in the spring 2025 semester, the NSLDS system showed a withdrawn status effective in December 2024 that was reported to NSLDS ten months later in October 2025.
View Audit 388074
Finding 1174318 (2025-001)
Material Weakness 2025
Laredo College
TX
Student Financial Aid Reporting
· For one (1) student who attended and withdrew from the College in February 2025, the NSLDS system did not have a withdrawal record. The most recent record shown was received in October 2025 and it shows a status of "L — Less than Half-time" effective in January 2025.
· For one (1) student who attended and withdrew from the College in February 2025, the NSLDS system did not have a withdrawal record. The most recent record shown was received in October 2025 and it shows a status of "L — Less than Half-time" effective in January 2025.
View Audit 388074
Finding 1174318 (2025-001)
Material Weakness 2025
Laredo College
TX
Student Financial Aid Reporting
· For one (1) student who attended and withdrew from the College in the spring 2025 semester, the most recent records in the NSLDS system were from 2017, with no status to show enrollment or withdrawal from the College in 2024-2025.
· For one (1) student who attended and withdrew from the College in the spring 2025 semester, the most recent records in the NSLDS system were from 2017, with no status to show enrollment or withdrawal from the College in 2024-2025.
View Audit 388074
Finding 1174318 (2025-001)
Material Weakness 2025
Laredo College
TX
Student Financial Aid Reporting
· For one (1) student who attended and withdrew from the College in the spring 2025 semester, the NSLDS enrollment details show a status of '2— No Record Found."
· For one (1) student who attended and withdrew from the College in the spring 2025 semester, the NSLDS enrollment details show a status of '2— No Record Found."
View Audit 388074
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