Corrective Action Plans

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2023-005: Special Tests & Provisions Federal Program Title: Student Financial Assistance Cluster Assistance Listing Number: Various Type of Finding: Significant Deficiency in Internal Control over Compliance Other Matte...
2023-005: Special Tests & Provisions Federal Program Title: Student Financial Assistance Cluster Assistance Listing Number: Various Type of Finding: Significant Deficiency in Internal Control over Compliance Other Matters Recommendation: ISU should review the requirements and implement a monitoring control to monitor the checks throughout the year. In addition, for the checks outstanding greater than 240 days, the University should return the funding to the U.S. Department of Education. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: ISU reopened the prior financial aid years in COD and completed returns of federal aid funds via G5/6 from identified outstanding checks. ISU has implemented the following monitoring controls: At the beginning of each month finance runs check reissue forms for all checks that the check date is 180 days or older. These are mailed to the check recipient. Around the 15th of the month any checks containing Title IV funds that have not been reissued will be turned to the financial aid office. Financial Aid is provided with the date by which the funds need to be returned. Financial Aid attempts to work with the student to get the checks cashed if they are not successful will return funds before the 240-day limit. They will then notify Finance to cancel the original check. Name(s) of the contact person(s) responsible for corrective action: Lisa Leyshon, AVP Finance/Controller, James Martin, Director of Financial Aid Planned completion date for corrective action plan: Implemented in 2020.
View Audit 316332 Questioned Costs: $1
Finding 2023-001 Condition The College did not notify the National Student Loan Data System (NSLDS) in a timely manner for 24 students with status changes in our sample of 25 students. The sample was not a statistically valid sample. Corrective Action Plan Corrective Action Planned: The College has ...
Finding 2023-001 Condition The College did not notify the National Student Loan Data System (NSLDS) in a timely manner for 24 students with status changes in our sample of 25 students. The sample was not a statistically valid sample. Corrective Action Plan Corrective Action Planned: The College has updated its policies and procedures to ensure notifications to the National Student Loan Data System are performed timely. In addition, all members of the responsible team will undergo formalized training to ensure their knowledge and proficiency regarding all applicable rules and regulations are kept up to date. Name(s) of Contact Person(s) Responsible for Corrective Action: Jeremy Sivillo, Institutional Registrar Kevin A. Thomas, D.O., Assistant Dean of Institutional Enrollment Management Anticipated Completion Date: Policies and procedure update implementation has been completed. Training for existing staff is to be completed by April 30, 2024. Training material development for new employees will be completed by May 31, 2024
Finding: 2023-007 Special Tests and Provisions Department’s Response: We concur Corrective Action: To make sure this issue does not occur again, the Director of Financial Aid will include a printout of the institutional charges at the time of the withdrawal to show what the amounts were during t...
Finding: 2023-007 Special Tests and Provisions Department’s Response: We concur Corrective Action: To make sure this issue does not occur again, the Director of Financial Aid will include a printout of the institutional charges at the time of the withdrawal to show what the amounts were during the R2T4 calculations. Contact: Katrina Hitzeman Anticipated Completion Date: Immediately
Finding: 2023-006 Special Tests and Provisions Department’s Response: We concur Corrective Action: To make sure this issue does not occur again, we will include an affirmation from all work-study students stating that they will not work during class hours. Contact: Katrina Hitzeman Anticipated C...
Finding: 2023-006 Special Tests and Provisions Department’s Response: We concur Corrective Action: To make sure this issue does not occur again, we will include an affirmation from all work-study students stating that they will not work during class hours. Contact: Katrina Hitzeman Anticipated Completion Date: Summer 2024
Finding: 2023-005 Special Tests and Provisions Department’s Response: We concur Corrective Action: This issue occurred as employee files and onboarding are managed by the Human Resources department, which had also been running payroll. The matter has since been resolved as the accounting depart...
Finding: 2023-005 Special Tests and Provisions Department’s Response: We concur Corrective Action: This issue occurred as employee files and onboarding are managed by the Human Resources department, which had also been running payroll. The matter has since been resolved as the accounting department reassumed responsibility for running payroll and is serving as a cross check to ensure that all necessary documentation has been verified as collected by the Human Resources department at the time of onboarding. The responsibility of the Human Resources department remains to ensure that all employee onboarding files are available for review while accounting as the payroll processor shall confirm that student work study hours have been documented and approved by the appropriate supervisor. Contact: Katrina Hitzeman Anticipated Completion Date: Immediately
Finding: 2023-004 Reporting Department’s Response: We concur Corrective Action: This issue occurred due to communication issues between departments of the college. The withdrawal process will be reviewed with the Director of Financial Aid, Director of Student and Alumni Affairs, and the Dean o...
Finding: 2023-004 Reporting Department’s Response: We concur Corrective Action: This issue occurred due to communication issues between departments of the college. The withdrawal process will be reviewed with the Director of Financial Aid, Director of Student and Alumni Affairs, and the Dean of Research and Postgraduate Studies. So that all are on the same page of deadlines and what the Financial Aid Office needs in order to complete the withdrawal process in a timely manner. Contact: Katrina Hitzeman Anticipated Completion Date: Immediately
Finding: 2023-003 Reporting Department’s Response: We concur Corrective Action: This issue occurred while the Director of Financial Aid was out of the office on Leave. This issue was caused by an issue in Populi’s system and a replacement Financial Aid Officer did not know who all was supposed...
Finding: 2023-003 Reporting Department’s Response: We concur Corrective Action: This issue occurred while the Director of Financial Aid was out of the office on Leave. This issue was caused by an issue in Populi’s system and a replacement Financial Aid Officer did not know who all was supposed to be included in the disbursement batch. The process will be updated so that a list of all students who are meant to be in a batch will be listed on a report as their requests come in, then the report will be referenced when creating a disbursement batch to make sure no students are missing. Contact: Katrina Hitzeman Anticipated Completion Date: Summer 2024
Finding: 2023-002 Cash Management Department’s Response: We concur Corrective Action: As the finding mentioned, this issue was found in the previous audit and corrective action was taken at that time. No further instances have occurred since. Contact: Katrina Hitzeman Anticipated Completion D...
Finding: 2023-002 Cash Management Department’s Response: We concur Corrective Action: As the finding mentioned, this issue was found in the previous audit and corrective action was taken at that time. No further instances have occurred since. Contact: Katrina Hitzeman Anticipated Completion Date: Immediately
Condition - Of the 40 students selected for enrollment reporting testing, 1 student did not have their status change updated appropriately. Planned Corrective Action: Management is developing a process between the Registrar's Office and the Office of Financial Aid to determine the proper reporting ...
Condition - Of the 40 students selected for enrollment reporting testing, 1 student did not have their status change updated appropriately. Planned Corrective Action: Management is developing a process between the Registrar's Office and the Office of Financial Aid to determine the proper reporting procedure for changes to enrollment status that fall between reporting windows to ensure timely and accurate reporting to the NSLDS. Contact person responsible for corrective action: Christopher Cox, Registrar Anticipated Completion Date: June 30, 2024
Finding 2023-001 - U.S. Department of Education {USDE), Title IV Student Financial Aid Programs: We observed the following conditions in connection with our testing of the various U.S. Department of Education, Title IV, Student Financial Assistance Programs. • The College had a difference in the Fed...
Finding 2023-001 - U.S. Department of Education {USDE), Title IV Student Financial Aid Programs: We observed the following conditions in connection with our testing of the various U.S. Department of Education, Title IV, Student Financial Assistance Programs. • The College had a difference in the Federal Work Study program which was not reconciled to the general ledger. Auditor's Recommendation - The University should implement corrective actions to ensure that the above findings are resolved and will not recur in future periods. Corrective Action - Management concurs with this finding. The College has implemented procedures to ensure that the Federal Work Study program reconciles to the general ledger.
View Audit 314668 Questioned Costs: $1
Finding 477957 (2023-001)
Significant Deficiency 2023
The University has adjusted the enrollment reporting calendar to ensure that updates, including the reporting of the graduation status (DegreeVerify), are certified, throughout the fiscal year, in order to maintain compliance with 34 CFR 682.610. The Office of the Registrar will prepare the certific...
The University has adjusted the enrollment reporting calendar to ensure that updates, including the reporting of the graduation status (DegreeVerify), are certified, throughout the fiscal year, in order to maintain compliance with 34 CFR 682.610. The Office of the Registrar will prepare the certification data during its monthly processes. The certification data will be reviewed for accuracy by the Registrar, who will be responsible for ascertaining timely submittal of the data with the National Student Clearinghouse. The Office of the Registrar has submitted changes to update the reporting of the graduation status (DegreeVerify) from quarterly to approximately every 45 days. This time frame is being tested to ensure timely data sharing between NSC and NSLDS, while optimizing the least amount of duplicate statuses and error warnings. The timing can be adjusted, but will never cause the institution to go out of compliance with the 60-day reporting requirement.
Finding 406431 (2023-024)
Significant Deficiency 2023
tudent Financial Aid Cluster: Federal Supplemental Educational Opportunity Grant – Assistance Listing No. 84.007 Federal Work Study Program – Assistance Listing No. 84.033 Federal Pell Grant Program – Assistance Listing No. 84.063 Federal Direct Student Loans – Assistance Listing No. 84.268 Reco...
tudent Financial Aid Cluster: Federal Supplemental Educational Opportunity Grant – Assistance Listing No. 84.007 Federal Work Study Program – Assistance Listing No. 84.033 Federal Pell Grant Program – Assistance Listing No. 84.063 Federal Direct Student Loans – Assistance Listing No. 84.268 Recommendation: We recommend the University review reporting processes to ensure all students that require exit counseling receive it in a timely manner. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The University will strengthen its processes to ensure that students needing exist counseling receive it in a timely manner. Name(s) of the contact person(s) responsible for corrective action: Mr. Heath Burge, Assistant Vice President for Strategic Enrollment and Advising Services. Planned completion date for corrective action plan: September 2024
Student Financial Aid Cluster: Federal Supplemental Educational Opportunity Grant – Assistance Listing No. 84.007 Federal Work Study Program – Assistance Listing No. 84.033 Federal Pell Grant Program – Assistance Listing No. 84.063 Federal Direct Student Loans – Assistance Listing No. 84.268 Rec...
Student Financial Aid Cluster: Federal Supplemental Educational Opportunity Grant – Assistance Listing No. 84.007 Federal Work Study Program – Assistance Listing No. 84.033 Federal Pell Grant Program – Assistance Listing No. 84.063 Federal Direct Student Loans – Assistance Listing No. 84.268 Recommendation: We recommend the University review current processes for reporting to NSLDS and implement procedures to ensure submissions are reported timely and accurately. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: This is a repeat finding that was first presented to the university in November 2023, in conjunction with the release of the 2022 audit report. The University will update its NSLDS reporting processes to ensure needed submissions are reported timely and accurately. Name(s) of the contact person(s) responsible for corrective action: Mr. Heath Burge, Assistant Vice President for Strategic Enrollment and Advising Services. Planned completion date for corrective action plan: September 2024
Finding 406415 (2023-022)
Significant Deficiency 2023
Student Financial Aid Cluster: Federal Supplemental Educational Opportunity Grant – Assistance Listing No. 84.007 Federal Work Study Program – Assistance Listing No. 84.033 Federal Pell Grant Program – Assistance Listing No. 84.063 Federal Direct Student Loans – Assistance Listing No. 84.268 Rec...
Student Financial Aid Cluster: Federal Supplemental Educational Opportunity Grant – Assistance Listing No. 84.007 Federal Work Study Program – Assistance Listing No. 84.033 Federal Pell Grant Program – Assistance Listing No. 84.063 Federal Direct Student Loans – Assistance Listing No. 84.268 Recommendation: We recommend that the University review policies and procedures related to R2T4 calculations to ensure calculations are performed correctly and timely. We also recommend the University implement formal review procedures to document the Return of Title IV calculations are being performed to minimize the likelihood that errors may go undetected and not be corrected in a timely manner. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: This is a repeat finding that was first presented to the university in November 2023, in conjunction with the release of the 2022 audit report. Procedures for review and return of Title IV funds are being updated to ensure refunds are returned in a timely manner. Return of Title IV calculations are being documented and reviewed by a party independent of the preparer to minimize the likelihood that errors go undetected and/or not be corrected in a timely manner. Name(s) of the contact person(s) responsible for corrective action: Mr. Heath Burge, Assistant Vice President for Strategic Enrollment and Advising Services. Planned completion date for corrective action plan: September 2024
View Audit 311623 Questioned Costs: $1
Finding 406407 (2023-021)
Significant Deficiency 2023
Student Financial Aid Cluster: Federal Supplemental Educational Opportunity Grant – Assistance Listing No. 84.007 Federal Work Study Program – Assistance Listing No. 84.033 Federal Pell Grant Program – Assistance Listing No. 84.063 Federal Direct Student Loans – Assistance Listing No. 84.268 Rec...
Student Financial Aid Cluster: Federal Supplemental Educational Opportunity Grant – Assistance Listing No. 84.007 Federal Work Study Program – Assistance Listing No. 84.033 Federal Pell Grant Program – Assistance Listing No. 84.063 Federal Direct Student Loans – Assistance Listing No. 84.268 Recommendation: We recommend that the University establish and maintain internal controls which provide reasonable assurance that federal award expenditures are in compliance with Federal statutes, regulations, and the terms and conditions of the Federal Award and that stale federal aid checks are returned to the Department of Education with 240 days after the date of issuance if not cashed. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The University will strengthen its controls to provide reasonable assurance that federal award expenditures are compliant with governing statutes, regulations, and award terms and conditions, as well as ensuring that stale dated federal aids checks are returned to the Department of Education within 240-days if not cashed. Name(s) of the contact person(s) responsible for corrective action: Mr. Heath Burge, Assistant Vice President for Strategic Enrollment and Advising Services and Mr. Chris Kuwitzky, Vice President for Fiscal and Administrative Affairs. Planned completion date for corrective action plan: September 2024
Student Financial Aid Cluster: Federal Supplemental Educational Opportunity Grant – Assistance Listing No. 84.007 Federal Work Study Program – Assistance Listing No. 84.033 Federal Pell Grant Program – Assistance Listing No. 84.063 Federal Direct Student Loans – Assistance Listing No. 84.268 Rec...
Student Financial Aid Cluster: Federal Supplemental Educational Opportunity Grant – Assistance Listing No. 84.007 Federal Work Study Program – Assistance Listing No. 84.033 Federal Pell Grant Program – Assistance Listing No. 84.063 Federal Direct Student Loans – Assistance Listing No. 84.268 Recommendation: We recommend the University review internal control reports and implement review controls for work performed by third party servicers. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. The University is already utilizing Visual Compliance to assess all vendors for suspension and debarment but will obtain and document the review of the SOC 2 report or Visual Compliance annually. Name(s) of the contact person(s) responsible for corrective action: Scott Schlotthauer, Chief Procurement Officer at Oklahoma State University. Planned completion date for corrective action plan: March 2024
Corrective Action: NTU has developed an information security plan, the plan will be presented to NTU Board of Regents for ratification and adoption Person Responsible: Jared Ribble, Information Technology Director Estimated Completion Date: July 31, 2024
Corrective Action: NTU has developed an information security plan, the plan will be presented to NTU Board of Regents for ratification and adoption Person Responsible: Jared Ribble, Information Technology Director Estimated Completion Date: July 31, 2024
Corrective Action: NTU will develop formal policies and procedures regarding enrollment reporting. This will include identifying the necessary enrollment data to update the National Student Loan Database System (NSLDS) on a timely basis in accordance with the Student Financial Aid Cluster requiremen...
Corrective Action: NTU will develop formal policies and procedures regarding enrollment reporting. This will include identifying the necessary enrollment data to update the National Student Loan Database System (NSLDS) on a timely basis in accordance with the Student Financial Aid Cluster requirements. NTU will be hiring an additional Financial Aid Technician and a Financial Aid Counselor to assist in addressing this finding. Person Responsible: Delores Becenti, Enrollment Director Estimated Completion Date: July 31, 2024
Corrective Action: NTU will establish formal policies and procedures for the Return of Title IV Funds, ensuring alignment with U.S. Department of Education requirements. These procedures will cover student withdrawals and the necessary data entry and monitoring within the student information system....
Corrective Action: NTU will establish formal policies and procedures for the Return of Title IV Funds, ensuring alignment with U.S. Department of Education requirements. These procedures will cover student withdrawals and the necessary data entry and monitoring within the student information system. The Accounting Manager in the Student Accounts section of NTU’s Business Office will review all student enrollment transactions to ensure compliance with Return to Title IV requirements. Person Responsible: Gary Segaye, Financial Aid Director, Delores Becenti, Enrollment Director, and Geraldine Gamble, Accounting Manager Estimated Completion Date: July 31, 2024
Audit Finding Number: 2023-001-Enrollment Reporting: Management concurs with the finding. The College submitted enrollment reports over the past year according to our approved submission schedule, but the reports were rejected due to configuration issues with our student information system (SIS). W...
Audit Finding Number: 2023-001-Enrollment Reporting: Management concurs with the finding. The College submitted enrollment reports over the past year according to our approved submission schedule, but the reports were rejected due to configuration issues with our student information system (SIS). We worked diligently to resolve these issues with assistance from Anthology and the National Student Clearinghouse. All the reporting configuration issues that prevented timely and accurate reporting have been resolved and verified by the National Student Clearinghouse. The College has implemented a process whereby the Registrar reports graduation statuses at the conclusion of each term to the College's SIS for upload to the National Student Clearinghouse and subsequent transmission to NSLDS. The Registrar will create a separate report of students who have completed a program yet are continuing their education at the College. In addition, the Registrar will generate a weekly report from the College's SIS listing the last date of attendance for drops/withdrawals, leaves of absence, and standard periods of non-enrollment and upload to the National Student Clearinghouse with subsequent transmission to NSLDS monthly. As an internal control, submitting the report will be a joint venture between the Registrar, the Financial Aid Manager, and the Associate Vice President of Education. These individuals have completed all the required training to ensure accurate reporting. To ensure timely reporting, all will receive transmission and error reports, and submission dates will be set on outlook calendars as a constant reminder. Successful report submission will be a required report at the College's bi-weekly operations meeting. William H. Dindy, Associate Vice President of Education
Finding 404732 (2023-011)
Significant Deficiency 2023
Finding number: 2023-011 Federal agency: U.S. Department of Education Programs: Student Financial Assistance Cluster Assistance listing #: 84.063 & 84.268 Award year: 2023 Corrective Action Plan: College Unbound has implemented a process to review eligibility for all new students. The Finan...
Finding number: 2023-011 Federal agency: U.S. Department of Education Programs: Student Financial Assistance Cluster Assistance listing #: 84.063 & 84.268 Award year: 2023 Corrective Action Plan: College Unbound has implemented a process to review eligibility for all new students. The Financial Aid Office works closely with Admissions/Recruiting to ensure proper documentation of all new students before the first disbursement. Timeline for Implementation of Corrective Action Plan: Ongoing. Started 8/22/24, fully implemented by the end of FY24. Contact Person: Diana Perdomo, Vice President for Institutional and Student Sustainability/CFO
View Audit 311103 Questioned Costs: $1
Finding 404731 (2023-010)
Significant Deficiency 2023
Finding number: 2023-010 Federal agency: U.S. Department of Education Programs: Federal Direct Student Loans Assistance listing #: 84.268 Award year: 2023 Corrective Action Plan: The college has implemented controls in place to ensure that exit counseling is conducted with Direct Loan borro...
Finding number: 2023-010 Federal agency: U.S. Department of Education Programs: Federal Direct Student Loans Assistance listing #: 84.268 Award year: 2023 Corrective Action Plan: The college has implemented controls in place to ensure that exit counseling is conducted with Direct Loan borrowers following changes in enrollment as required. As of FY24, this finding has been corrected. Exit interviews have been sent for FY24 and we will continue to work with our borrowers to understand their loan repayment options. Timeline for Implementation of Corrective Action Plan: Completed Contact Person: Diana Perdomo, Vice President for Institutional and Student Sustainability/CFO
Finding 404730 (2023-009)
Significant Deficiency 2023
Finding number: 2023-009 Federal agency: U.S. Department of Education Programs: Student Financial Assistance Cluster Assistance listing #: 84.063 Award year: 2023 Corrective Action Plan: The College has policies and procedures to ensure compliance for calculating the Title IV funds to be re...
Finding number: 2023-009 Federal agency: U.S. Department of Education Programs: Student Financial Assistance Cluster Assistance listing #: 84.063 Award year: 2023 Corrective Action Plan: The College has policies and procedures to ensure compliance for calculating the Title IV funds to be returned. This finding was the result of a rounding variance. The College will enact a checks and balances process in which a second party reviews R2T4 calculations. As this was not a repeat finding, and the sample size was 1, we are confident that this finding will not be repeated in the future. Timeline for Implementation of Corrective Action Plan: Corrected. Contact Person: Diana Perdomo, Vice President for Institutional and Student Sustainability/CFO
View Audit 311103 Questioned Costs: $1
Finding number: 2023-008 Federal agency: U.S. Department of Education Programs: Student Financial Assistance Cluster Assistance listing #: 84.268 Award year: 2023 Corrective Action Plan: College Unbound has implemented the process of monthly reconciliation for Pell and Direct Loans. This pr...
Finding number: 2023-008 Federal agency: U.S. Department of Education Programs: Student Financial Assistance Cluster Assistance listing #: 84.268 Award year: 2023 Corrective Action Plan: College Unbound has implemented the process of monthly reconciliation for Pell and Direct Loans. This process began in Spring 2023 (upon review of the FY21 Audit) and will continue in perpetuity. The issues identified in this finding were resolved by the school in advance of the audit, although we agree that it was not in a timely manner. There are no question costs in this finding. Timeline for Implementation of Corrective Action Plan: Completed Contact Person: Diana Perdomo, Vice President for Institutional and Student Sustainability/CFO
Finding 404727 (2023-007)
Significant Deficiency 2023
Finding number: 2023-007 Federal agency: U.S. Department of Education Programs: Student Financial Assistance Cluster Assistance listing #: 84.063 & 84.268 Award year: 2023 Corrective Action Plan: College Unbound hired two new positions, a Controller and a Bursar, who both started on 10/2/23...
Finding number: 2023-007 Federal agency: U.S. Department of Education Programs: Student Financial Assistance Cluster Assistance listing #: 84.063 & 84.268 Award year: 2023 Corrective Action Plan: College Unbound hired two new positions, a Controller and a Bursar, who both started on 10/2/23 (the role was previously filled by a single temporary employee). Part of the Controller’s scope of work is a monthly review of all uncashed checks. Beginning March 2024, the controller initiated a new process for outstanding checks issued to students. After monthly bank reconciliation, the list of outstanding checks will be forwarded to our Director of Employee Success and Student Accounts to follow up with the students and rectify the issues. In addition, College Unbound is undertaking a project to encourage students to receive credit balance refunds through ACH, as opposed to paper check, whenever possible. The ACH process will increase accuracy, security, and speed of delivery. Additionally, for students still opting to receive paper checks, College Unbound has initiated Positive Pay through the bank. Timeline for Implementation of Corrective Action Plan: Ongoing. Fully implemented by the end of FY24. Contact Person: Diana Perdomo, Vice President for Institutional and Student Sustainability/CFO
View Audit 311103 Questioned Costs: $1
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