Corrective Action Plans

Finding 1187023 (2025-008)

Material Weakness 2025

NC

Student Financial Aid Subrecipient Monitoring Eligibility § 200.303

No Internal Controls Over Student Enrollment Status Reporting Financial Aid Control for NSLDS Enrollment Reporting: •Enrollment is reported via the National Student Clearinghouse by the Registrar. •Financial Aid Staff (Associate Director of Financial Aid) will pull a list of enrolled students for th...

No Internal Controls Over Student Enrollment Status Reporting Financial Aid Control for NSLDS Enrollment Reporting: •Enrollment is reported via the National Student Clearinghouse by the Registrar. •Financial Aid Staff (Associate Director of Financial Aid) will pull a list of enrolled students for the semester and create a sample population for the control check. •Financial Aid Staff (Associate Director of Financial Aid) will Ched each individual student in the Enrollment section of NSLDS to ensure the student's enrollment status has been reported correctly. •Financial Aid Staff (Associate Director of Financial Aid) will perform this check 2-3 weeks after census each semester and document the check in the quality control folder in the shared drive. Corrective Action was Completed on: December 5, 2025.

View Audit 394732

Finding 1187022 (2025-007)

Material Weakness 2025

State of North Carolina

NC

Student Financial Aid Subrecipient Monitoring Eligibility

No Internal Controls Over Student Enrollment Status Reporting Like many schools, ECU relies on the National Student Clearinghouse (NSC) to submit student enrollment status data to the NSLDS (National Student Loan Data System). In response to the audit recommendation, an Assistant Director in the Off...

No Internal Controls Over Student Enrollment Status Reporting Like many schools, ECU relies on the National Student Clearinghouse (NSC) to submit student enrollment status data to the NSLDS (National Student Loan Data System). In response to the audit recommendation, an Assistant Director in the Office of Student Financial Aid has been assigned to regularly review automated reports that identify students whose data in the ECU, NSC, and NSLDS databases doesn’t match. (This task was not completed during the audit period due to position vacancies.) When a student is identified on the error report, the Assistant Director reviews the data in ECU’s student system and the NSLDS to determine the differences and the root cause of the problem. The Financial Aid Office and/or Registrar Office then takes corrective action to ensure the NSLDS record and ECU’s record matches. Corrective action was completed on: October 1, 2025.

View Audit 394732

Finding 1187021 (2025-006)

Material Weakness 2025

State of North Carolina

NC

Student Financial Aid Reporting

Student Enrollment Status Reporting Errors The NSC Parameter Definition (SITS) form in Colleague will be updated to report only active courses at census. As a result of this change, the first of term enrollment submissions to NSCH will reflect all courses enrolled during the semester, and the subseq...

Student Enrollment Status Reporting Errors The NSC Parameter Definition (SITS) form in Colleague will be updated to report only active courses at census. As a result of this change, the first of term enrollment submissions to NSCH will reflect all courses enrolled during the semester, and the subsequent enrollment submissions will only report active courses at the time of the submission. This should accurately report enrollment status changes due to latter 8-week term course enrollment. The update will take place for the Spring 2026 first-of-term submission scheduled for January 30, 2026. Anticipated Completion Date: February 1, 2026.

View Audit 394732

Finding 1187020 (2025-005)

Material Weakness 2025

State of North Carolina

NC

Eligibility Student Financial Aid Matching / Level of Effort / Earmarking

Financial Assistance Disbursed Without Evaluating Satisfactory Academic Progress SAP Policies and Procedures will be updated to include running the new SAP report during the ISIR Load Process, prior to submitting disbursements, and during the End of Term SAP Evaluation Process to ensure SAP is evalu...

Financial Assistance Disbursed Without Evaluating Satisfactory Academic Progress SAP Policies and Procedures will be updated to include running the new SAP report during the ISIR Load Process, prior to submitting disbursements, and during the End of Term SAP Evaluation Process to ensure SAP is evaluated on all financial aid students. Anticipated Completion Date: February 1, 2026.

View Audit 394732

Finding 1187019 (2025-004)

Material Weakness 2025

State of North Carolina

NC

Student Financial Aid Subrecipient Monitoring Eligibility

Student Enrollment Status Reporting Errors Craven Community College (College) received guidance from the North Carolina System Office to improve the accuracy and timeliness of enrollment reporting. The new process involves updating Colleague system parameters to enhance data gathering and streamline...

Student Enrollment Status Reporting Errors Craven Community College (College) received guidance from the North Carolina System Office to improve the accuracy and timeliness of enrollment reporting. The new process involves updating Colleague system parameters to enhance data gathering and streamline report submissions. The College added an additional report submission following each term to capture graduation status changes. These changes were implemented in September 2025. The College changed the enrollment report submission date to capture student status changes in a timely manner. This change was implemented in September 2025. An Internal Control Process (ICP) will be developed that outlines steps to be taken to conduct two self-audits each semester. The ICP will be located on the college’s shared drive accessible by all employees. The ICP will be available by March 1, 2026. The College will self-audit student records submitted to the National Clearinghouse and National Student Loan Data System (NSLDS) twice per semester at the mid-point and at end-of-term. The self-audit will be conducted by the Executive Director of Financial Aid and the Director of Admissions and Student Records. The Directors will review a total of 50 files per audit. A record of each audit will be stored on the secured shared directory. The shared directory can only be accessed by the staff in Student Services. The first self-audit will occur during March 2026. Anticipated Completion Date: June 30, 2026.

View Audit 394732

Finding 1187018 (2025-003)

Material Weakness 2025

State of North Carolina

NC

Student Financial Aid Subrecipient Monitoring Eligibility

No Internal Controls Over Student Enrollment Status Reporting Assignment of Responsibility: The Registrar will provide a copy of each NSC enrollment report to the Director of Financial Aid for review. The Director of Financial Aid will review a sample of students included in the report by comparing ...

No Internal Controls Over Student Enrollment Status Reporting Assignment of Responsibility: The Registrar will provide a copy of each NSC enrollment report to the Director of Financial Aid for review. The Director of Financial Aid will review a sample of students included in the report by comparing enrollment information with records in the National Student Loan Data System (NSLDS). Any discrepancies or enrollment status changes not accurately reflected in NSLDS will be identified and corrected in a timely manner. This review and reconciliation process will be conducted monthly for enrollment status changes and once per semester for graduation status updates. Written Policies and Procedures: CFCC maintains an internal document that outlines the procedures required to complete all NSC reporting. This document will be updated to incorporate the reconciliation and review process involving the Director of Financial Aid to ensure accuracy, consistency, and continuity. Corrective action was completed on: January 21, 2026.

View Audit 394732

Finding 1187017 (2025-002)

Material Weakness 2025

State of North Carolina

NC

Student Financial Aid Subrecipient Monitoring Eligibility

Student Enrollment Status Reporting Errors Since October 2025, the College has operated under a rigorous review process. This initiative is managed through a cross-functional collaboration between Financial Aid and Records and Registration, with executive oversight provided by the Vice President of ...

Student Enrollment Status Reporting Errors Since October 2025, the College has operated under a rigorous review process. This initiative is managed through a cross-functional collaboration between Financial Aid and Records and Registration, with executive oversight provided by the Vice President of Student Services, the Executive Director of Enrollment Management, and the Director of Financial Aid. •Error Resolution and Reconciliation: Error files and NSLDS reject logs are shared immediately with the Financial Aid Director. Staff are required to review every student flagged in these files and verify that corrections are accurately reflected in the NSLDS database. Process implemented since October 2025. •Increase in Control: To streamline communication and sharing of information, CCC& Tl is launching a centralized Microsoft Teams site for all stakeholders. This site will serve as a repository for National Student Clearinghouse (NSC) term enrollment status error files, graduate error files, and comprehensive PDF lists of all students submitted to the NSC. The site will also include written procedures for identifying and reporting enrollment status changes, and defined roles and responsibilities. Process to be completed by March 13, 2026. •Staff Training and Accountability: All relevant staff will receive comprehensive training on these new protocols. A standardized checklist has been developed to track completed steps. Process will be completed by March 13, 2026. These steps are designed to increase control and significantly improve the accuracy and timeliness of student status updates, thereby ensuring full compliance with state and federal reporting requirements. Anticipated Completion Date: March 13, 2026.

View Audit 394732

Finding 1187016 (2025-002)

Material Weakness 2025

University of Holy Cross

LA

Student Financial Aid Matching / Level of Effort / Earmarking Eligibility

The Financial Aid Office identified suspicious activity in FY2025 and collaborated with IT and Admissions to verify the integrity of financial aid applications. The Financial Aid Office has implemented additional procedures and reporting controls to strengthen the financial aid awarding process. Dur...

The Financial Aid Office identified suspicious activity in FY2025 and collaborated with IT and Admissions to verify the integrity of financial aid applications. The Financial Aid Office has implemented additional procedures and reporting controls to strengthen the financial aid awarding process. During the packaging process, a report is generated and reviewed to verify the Cost of Attendance (COA), Student Aid Index (SAI), and any other estimated financial assistance prior to loan disbursement. This review helps ensure that total financial aid does not exceed allowable limits and prevents the overawarding of aid to students.

View Audit 394728

Finding 1187012 (2025-002)

Material Weakness 2025

University of Maine System

ME

Student Financial Aid Eligibility Significant Deficiency

Student Financial Assistance Cluster – 84.063 Recommendation: We recommend that a review is implemented which compares enrolled credits to Pell award to ensure all Pell funds are awarded at proper amounts. Explanation of disagreement with audit finding: There is no disagreement with the audit findin...

Student Financial Assistance Cluster – 84.063 Recommendation: We recommend that a review is implemented which compares enrolled credits to Pell award to ensure all Pell funds are awarded at proper amounts. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Upon notification of the finding, a query was developed and a review performed to identify potentially impacted records in advance of the 2025-2026 academic year. The University has also added review mechanisms to its semester-based enrollment adjustment and repackaging process designed to identify Enrollment Intensity (EI) coding changes, either by batch or manual processes. These review mechanisms allowed for the increased monitoring and correction of potentially incorrect EI coding that would ultimately increase the likelihood of an incorrect Pell Grant amount. A formal bi-weekly query and review process has recently been implemented that compares the student’s total enrollment for a term with the coded EI, confirming accuracy of the EI percentage. The query process also checks that the posted Pell award is the correct amount based on the EI percentage. Name(s) of the contact person(s) responsible for corrective action: Connie Smith, Executive Director of Student Financial Services Planned completion date for corrective action plan: March 2026

View Audit 394719

Finding 1187011 (2025-001)

Material Weakness 2025

University of Maine System

ME

Student Financial Aid Reporting Significant Deficiency

Student Financial Assistance Cluster – Assistance Listing No. Various Recommendation: We recommend the University review its reporting procedures to ensure that students’ statuses are accurately and timely reported to National Student Loan Data System (NSLDS) within the appropriate timeframe as requ...

Student Financial Assistance Cluster – Assistance Listing No. Various Recommendation: We recommend the University review its reporting procedures to ensure that students’ statuses are accurately and timely reported to National Student Loan Data System (NSLDS) within the appropriate timeframe as required by regulations. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: A weekly query process was implemented to identify continuing, degree-seeking students with cancellations or term withdrawals. This process allows us to identify this population of students and accurately report status changes to National Student Clearinghouse (NSC) within a week, ensuring plenty of time for information to be sent from NSC to NSLDS. Name(s) of the contact person(s) responsible for corrective action: Jack Campbell, Registrar, University of Maine and Saman Lesinski, Senior Associate Registrar, University of Southern Maine Planned completion date for corrective action plan: University of Maine – August 2025, University of Southern Maine – March 2026

View Audit 394719

Finding 1187003 (2025-001)

Material Weakness 2025

Ursinus College

PA

Student Financial Aid Subrecipient Monitoring Reporting

Finding 2025-001 Condition During our audit, for 1 out of 25 students selected for testing, the College did not report to the National Student Clearninghouse (NSC) and the National Student Loan Data System (NSLDS) within 30 days or included in a response to a roster file within 60 days. However, the...

Finding 2025-001 Condition During our audit, for 1 out of 25 students selected for testing, the College did not report to the National Student Clearninghouse (NSC) and the National Student Loan Data System (NSLDS) within 30 days or included in a response to a roster file within 60 days. However, the student was ultimately reported to the NSC and NSLDS. Corrective Action Plan The graduation status of the student was not reported to NSC and NSLDS in a timely manner. The student qualified as a May 2025 graduate. However, at the point in time at which May graduates were reported to NSC, the final transcripts for the off-campus credits the student used to complete his degree had not yet been received. As a result, his degree was not conferred in the student information system until after the degree upload was sent to NSC. Then, by human error, once the student’s transcripts were received, his graduation status was not manually reported to NSC until after the 60-day reporting period had passed. To prevent this situation from arising in the future, we have changed the way we track students whose degree conferrals are entered into the SIS after the date on which the graduates upload has been sent to NSC. This process change will highlight those students whose conferrals must be manually reported to NSC because they were not included in the initial upload of graduates sent to NSC. We will also require students sending transcripts for credits taken off campus to have those transcripts received by our office within 30 days of the conferral date. If transcripts containing credits necessary for graduation are received more than 30 days after the conferral date, the student’s degree conferral will be pushed back to the next available degree conferral data. Name of Contact Person Responsible for Corrective Action: Michael Reig, Registrar Completion Date: December 1, 2025

View Audit 394717

Finding 1186905 (2025-003)

Material Weakness 2025

University System of New Hampshire

NH

Reporting Student Financial Aid Significant Deficiency

Student Financial Assistance Cluster – Assistance Listing Numbers 84.007, 84.033, 84.038, 84.063, 84.268 Recommendation: We recommend the University review its reporting procedures to ensure that students’ statuses are timely reported to NSLDS as required by regulations. Explanation of disagreement ...

Student Financial Assistance Cluster – Assistance Listing Numbers 84.007, 84.033, 84.038, 84.063, 84.268 Recommendation: We recommend the University review its reporting procedures to ensure that students’ statuses are timely reported to NSLDS as required by regulations. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Plymouth State University: The registrar’s office will be examining how these situations came about. Given that our records pulled from Banner are correct and were sent to NSC as per reporting compliance requirements, we believe that there are issues with the NSC side of the current reporting process. We will connect with the NSC audit team with the expectation that there will be a noticeable fix – one that can be used in the future to preempt findings. Additionally, teams at USNH will explore two items: 1) Review of how the NSC template is set up and working in PSU-Banner, and provide assistance in correcting any portions of the process that are out of line. 2) Investigate downloading PSU data from NSLDS to compare with the data pulled from PSU-Banner so potential mismatches on statuses can be caught in real time. Keene State College: KSC Registrar, which is responsible for reporting enrollment statuses to NSLDS, confirmed with NSC the record was sent in a time manner to NSC. The records for unknown reasons were not processed by NSC until a later date. The Registrar has been made aware this is a repeat finding and additional training will be provided, along with a review of the procedures. Name(s) of the contact person(s) responsible for corrective action: Tonya LaBrosse, Registrar, Plymouth State College Cathy Mullins, Director of Financial Aid and Scholarships, Keene State College Planned completion date for corrective action plan: July 1, 2026

View Audit 394674

Finding 1186900 (2025-002)

Material Weakness 2025

University System of New Hampshire

NH

Student Financial Aid Significant Deficiency Internal Control / Segregation of Duties

Student Financial Assistance Cluster – Assistance Listing Numbers 84.007, 84.033, 84.038, 84.063, 84.268 Recommendation: We recommend that the College put a process in place to refund student credit balances that arose from federal funds within 14 days. Explanation of disagreement with audit finding...

Student Financial Assistance Cluster – Assistance Listing Numbers 84.007, 84.033, 84.038, 84.063, 84.268 Recommendation: We recommend that the College put a process in place to refund student credit balances that arose from federal funds within 14 days. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: This repeat finding was partially due to the implementation of Workday, the adjustments of aid to individual student records, and a shortage of staff. We have hired an additional staff member and trained additional staff to help with federal refunds during the demanding time of the term. Name(s) of the contact person(s) responsible for corrective action: Cathy Mullins, Director of Financial Aid and Scholarships. Keene State College Planned completion date for corrective action plan: July 1, 2026

View Audit 394674

Finding 1186895 (2025-001)

Material Weakness 2025

New England Conservatory of Music

MA

Student Financial Aid

CORRECTIVE ACTION PLAN YEAR ENDED JUNE 30, 2025 Finding No. 2025-001 – Return of Title IV Funds Finding: During the audit, for the 2 students selected for testing of Title IV disbursements, the institution improperly calculated the number of days used in the Return of Title IV Funds (R2T4) calculati...

CORRECTIVE ACTION PLAN YEAR ENDED JUNE 30, 2025 Finding No. 2025-001 – Return of Title IV Funds Finding: During the audit, for the 2 students selected for testing of Title IV disbursements, the institution improperly calculated the number of days used in the Return of Title IV Funds (R2T4) calculation for the Fall 2024 semester, resulting in an incorrect percentage of Title IV aid earned. Consequently, the amount of Title IV aid refunded was not calculated in accordance with federal requirements. Corrective Action Taken or Planned: Senior management at NEC takes Title IV requirements seriously. Moving forward, the institution review its academic calendar and will strengthen controls over R2T4 calculations to ensure that the number of calendar days used in determining earned Title IV aid is calculated accurately and in accordance with federal requirements. Responsible Person: Rebecca Barry-Wolff, Director of Student Financial Planning Update: The corrective actions noted are all in place for fiscal year 2026.

View Audit 394669

Finding 1186889 (2025-003)

Material Weakness 2025

Bluefield University

VA

Student Financial Aid Matching / Level of Effort / Earmarking

Bluefield University does include required disbursement information, including the right to cancel Title IV funds, in financial aid award letters, Master Promissory Notes, and entrance counseling. However, effective January 1, 2026, the University implemented a policy in the financial aid office req...

Bluefield University does include required disbursement information, including the right to cancel Title IV funds, in financial aid award letters, Master Promissory Notes, and entrance counseling. However, effective January 1, 2026, the University implemented a policy in the financial aid office requiring use of the PowerFAIDS system-generated disbursement notice at the time of each type of disbursement: direct loan, plus loan, and alternative loan. This auto-generated notice is an email to the student clearly noting the student’s right to cancel all or a portion of that specific loan disbursement, referencing the timeline and process by which a student may exercise this cancellation right.

View Audit 394660

Finding 1186888 (2025-002)

Material Weakness 2025

Bluefield University

VA

Student Financial Aid Reporting

Effective February 1, 2026, Bluefield University’s top management set forth the expectation of the University Registrar/Veteran Certifying Official that she ultimately is responsible for routine enrollment reporting and withdrawal reporting in accordance with NSLDS requirements. The University has d...

Effective February 1, 2026, Bluefield University’s top management set forth the expectation of the University Registrar/Veteran Certifying Official that she ultimately is responsible for routine enrollment reporting and withdrawal reporting in accordance with NSLDS requirements. The University has drafted a process to support this task, designating a Compliance Reporting Officer within the Registrar’s Office to be responsible for reporting enrollment and withdrawal data to the NSC. This responsibility is included in the job description and performance evaluation metrics for this position. The documented process notes that the University has implemented a tracking sheet to use for monitoring the University’s progress on bringing current enrollment reporting for previous semesters and identifying dates going forward that align with federal enrollment reporting deadlines. Further, the process includes a secondary review by the Director of Financial Aid or designee to verify submission of required enrollment reporting through NSC acknowledgement reports. The University also has engaged an external consultant to help address prior reporting gaps and accelerate reporting and reconciliation efforts, with the goal of achieving full operational compliance and current reporting by June 30, 2026.

View Audit 394660

Finding 1186880 (2025-001)

Material Weakness 2025

Prescott College, Inc.

AZ

Student Financial Aid Reporting Significant Deficiency

National Student Loan Database System (NSLDS) Enrollment Reporting Recommendation: We recommend the College reevaluate their procedures and review policies surrounding reporting status changes to NSLDS to ensure timely and accurate reporting. Explanation of disagreement with audit finding: There is ...

National Student Loan Database System (NSLDS) Enrollment Reporting Recommendation: We recommend the College reevaluate their procedures and review policies surrounding reporting status changes to NSLDS to ensure timely and accurate reporting. Explanation of disagreement with audit finding: There is no disagreement with the auditfinding. Action taken in response to finding: The Registrar will re-evaluate policies, procedures and training materials to ensure timely and accurate reporting. Name(s) of the contact person(s) responsible for corrective action: Michele Peterson Planned completion date for corrective action plan: 03/31/26 If

View Audit 394632

Finding 1186853 (2025-001)

Material Weakness 2025

Depaul University

IL

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

Finding 2025-001 – Inaccurate NSLDS Reporting Corrective Action Plan: Now that this protocol has been identified, our NSC coordinator has been manually updating the enrollment statuses for this population of students, changing their indicators from “W” to “G” as required. Contact Person(s): Jennifer...

Finding 2025-001 – Inaccurate NSLDS Reporting Corrective Action Plan: Now that this protocol has been identified, our NSC coordinator has been manually updating the enrollment statuses for this population of students, changing their indicators from “W” to “G” as required. Contact Person(s): Jennifer Seyer, University Registrar Office Anticipated Completion Date: We identified all students who met this specific scenario, ran the necessary reports, and manually updated their enrollment statuses accordingly within the NSC. All updates were completed in February 2026.

View Audit 394596

Finding 1186689 (2025-101)

Material Weakness 2025

Maricopa County Community College District

AZ

Student Financial Aid Special Tests & Provisions § 200.303

2025-101 Cluster name: Student Financial Assistance Cluster Assistance Listing number and name: 84.007 Federal Supplemental Educational Opportunity Grants 84.033 Federal Work Study Program 84.038 Federal Perkins Loan Program – Federal Capital Contributions 84.063 Federal Pell Grant Program 84.268 Fe...

2025-101 Cluster name: Student Financial Assistance Cluster Assistance Listing number and name: 84.007 Federal Supplemental Educational Opportunity Grants 84.033 Federal Work Study Program 84.038 Federal Perkins Loan Program – Federal Capital Contributions 84.063 Federal Pell Grant Program 84.268 Federal Direct Student Loans Award numbers and years: P063P241066 July 1, 2024 to June 30, 2025 P007A240115 July 1, 2024 to June 30, 2025 P033A240115 July 1, 2024 to June 30, 2025 P268K241066 July 1,2024 to June 30, 2025 Federal Agency: U.S. Department of Education Compliance Requirements: Special Tests and Provisions – return of Title IV funds Questioned Costs: None Name of Contact Persons: Kristina Winterstein, Controller Anticipated Completion Date: December 31, 2025 The Maricopa County Community College District understands the importance of adhering to District polices and procedures for the return of Title IV funds. During Fiscal Year 2025, the District Student Financial Services office experienced the unexpected death of a team member, which caused a temporary disruption of workflow and necessitated the reassignment of job duties. This disruption and reassignment caused a delay of return of Title IV completion within the required timeframe. The District has since updated it’s return of Title IV tracking procedures and added supervisory monitoring to ensure calculations are completed within the 45 day regulatory timeframe to ensure compliance with both District and Federal guidelines.

View Audit 394393

Finding 1186674 (2025-001)

Material Weakness 2025

Mount Mercy University

IA

Student Financial Aid

Student Financial Assistance Cluster – Assistance Listing No. Various 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: ...

Student Financial Assistance Cluster – Assistance Listing No. Various 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: The University is reviewing its enrollment reporting process in coordination with the Registrar’s Office to identify any potential issues affecting data transmission through the National Student Clearinghouse. As part of this review, the University is evaluating additional reconciliation and verification procedures to confirm that enrollment status data submitted to the Clearinghouse is accurately reflected in NSLDS. The University will continue to monitor enrollment status reporting on an ongoing basis to ensure compliance with federal reporting requirements. Name(s) of the contact person(s) responsible for corrective action: Mark Freed Planned completion date for corrective action plan: 06/30/2026

View Audit 394371

Finding 1186663 (2025-001)

Material Weakness 2025

Regent University

VA

Student Financial Aid Reporting Matching / Level of Effort / Earmarking § 200.303 § 200.516

Regent University agrees with this finding. The University will engage with the National Student Clearinghouse audit support office to further understand the analyst processing timelines to strategize effective submission and error resolution dates to ensure output is captured in the monthly NSC bat...

Regent University agrees with this finding. The University will engage with the National Student Clearinghouse audit support office to further understand the analyst processing timelines to strategize effective submission and error resolution dates to ensure output is captured in the monthly NSC batches. The University will continue to engage the established working group with appropriate Regent stakeholders to review suggested changes made by the NSC to reporting methods, time buffers between reports, reporting frequency, and other “upstream” preventative measures that may be taken to prevent file backlogs. Internally, the University will establish a customized and shared enrollment reporting tracker available to all stakeholders in the working group. This will transparently represent the dates to maintain the 60-day compliance window and allow us to manually intervene where possible. Regent University will implement the plan by June 30, 2026. Name of responsible parties: Elizabeth Bayless (University Registrar) & Tameka Lyons (Senior Associate Registrar)

View Audit 394364

Finding 1186655 (2025-003)

Material Weakness 2025

Prairie State College - Community College District No. 515

IL

Special Tests & Provisions Student Financial Aid Material Weakness

2025-003: Late Return of Title IV Financial Aid - Student Financial Aid Cluster – Assistance Listing #s 84.007, 84.033, 84.063, 84.268 - Grant Period - Year Ended June 30, 2025 Condition Found During our Return of Title IV Fund testing, we noted that the College did not calculate or return Title IV ...

2025-003: Late Return of Title IV Financial Aid - Student Financial Aid Cluster – Assistance Listing #s 84.007, 84.033, 84.063, 84.268 - Grant Period - Year Ended June 30, 2025 Condition Found During our Return of Title IV Fund testing, we noted that the College did not calculate or return Title IV Student Financial Aid for ten out of twenty-five students tested until after 45 days when the student ceased attendance. We consider the untimely calculation and Return of Title IV Student Financial Aid to be a material weakness relating to the Special Tests and Provisions Compliance Requirement. Corrective Action Plan The weekly Official Withdrawal report is reviewed and processed by the Assistant Dean. As applicable, a week after the calculation is performed and funds are returned to DOE, each student recorded is reviewed on the Common Origination and Disbursement (COD) site to ensure that funds were returned. This additional step is conducted monthly by members of the Financial Aid Management and student worker teams. Additionally, the Assistant Dean performs a monthly check of the Official Withdrawal report to ensure that the Return to Title IV calculation was performed for all required students. The review includes viewing the record in Colleague as well as COD. Responsible Person for Corrective Action Plan Yvette M. McGhee Assistant Dean of Financial Aid Implementation Date of Corrective Action Plan The Correction Action Plan was implemented at the beginning of the Fall 25 semester (approximately August 15, 2025)

View Audit 394348

Finding 1186644 (2025-004)

Material Weakness 2025

Sterling College

KS

Internal Control / Segregation of Duties Student Financial Aid Material Weakness

Contact person responsible for correction action – Michell Hall, CFO Anticipated completion date – June 30, 2025 Corrective action Sterling College is in agreement with the finding. At the time of noncompliance in this area the college was transitioning to a new software system for the college. The ...

Contact person responsible for correction action – Michell Hall, CFO Anticipated completion date – June 30, 2025 Corrective action Sterling College is in agreement with the finding. At the time of noncompliance in this area the college was transitioning to a new software system for the college. The software was required to “go dark” for a period time and during this time no processing could be completed. Because of other issues with the system, the R2T4 timeline for returning the funds was not calculated correctly and the deadline was missed by a few days. Administration did not realize the error until after the deadline had passed. As soon as the error was found, the process was completed immediately. We do not expect to have this issue in the future. The R2T4 process for review has always been that one person in the financial aid office is responsible for completing the process and another person reviews the documents once the process is complete. We will continue this process and look for other procedures to implement to ensure an accurate R2T4 process is completed.

View Audit 394339

Finding 1186643 (2025-003)

Material Weakness 2025

Sterling College

KS

Student Financial Aid Reporting

Contact person responsible for correction action – Michell Hall, CFO Anticipated completion date – June 30, 2025 Corrective action Sterling College agrees with the finding. The college realizes this is a repeat finding and we have struggled with compliance in this area due to the inadequacy of the s...

Contact person responsible for correction action – Michell Hall, CFO Anticipated completion date – June 30, 2025 Corrective action Sterling College agrees with the finding. The college realizes this is a repeat finding and we have struggled with compliance in this area due to the inadequacy of the system we were using and turnover in the financial aid office and the registrar’s office. With the new system, and the more seasoned personnel in each of the departments, we strive to make improvements in the enrollment reporting process. We are still actively running monthly processes to review enrollment reporting data to ensure the accuracy of our reporting. The new system will aid us in doing these processes better and continued training with personnel will be prioritized. We will continue to review policy and procedures and look for ways to make this process better.

View Audit 394339

Finding 1186642 (2025-002)

Material Weakness 2025

Sterling College

KS

Student Financial Aid Significant Deficiency

Contact person responsible for correction action – Mitzi Suhler, Financial Aid Director Anticipated completion date – June 30, 2025 Corrective action Sterling College agrees with the finding. At the time of this noncompliance the College was implementing a new financial aid system (JFA). The financi...

Contact person responsible for correction action – Mitzi Suhler, Financial Aid Director Anticipated completion date – June 30, 2025 Corrective action Sterling College agrees with the finding. At the time of this noncompliance the College was implementing a new financial aid system (JFA). The financial aid system went live in July 2024. The business office module did not go live until November 2024. The college’s IT implemented a bridge to connect the two systems while we waited for the business office module to go live. There were issues with the bridge between the two systems which caused the aid posting process to work inaccurately. We immediately contacted IT to help with the situation, but they took longer than expected to find a solution. Because we knew time was of the essence and our system would be “going dark” (unable to process anything for a period of time), we manually started processing aid in order to post aid to student accounts so that students could receive their refunds. The financial aid system had disbursement dates already set up and all of those dates had to be manually updated. Unfortunately, the College missed updating one date for the student that was found during audit, and the date that was reported to COD was the original disbursement date instead of the actual disbursement date. The system no longer requires the bridge, and we have not experienced any issues since all systems came on board. Now that the system is working properly, there is a process that looks at the disbursement date on the student account and compares it to what the financial aid system has in place. If the dates do not match, the system automatically updates the disbursement date in the financial aid system and there is a file that is generated to send an update to COD automatically. We do not expect to have this issue in the future but have implemented processes to review disbursement dates through the reconciliation process in the new system.

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