Corrective Action Plans

Finding 11301 (2023-003)

Significant Deficiency 2023

NJ

Questioned Costs Student Financial Aid Significant Deficiency

Student Financial Aid Cluster – Federal Assistance Listing Numbers 84.007, 84.033, 84.063 and 84.268 Recommendation: We recommend the University review the R2T4 requirements and implement procedures to ensure scheduled breaks are properly factored into the R2T4 calculations as well as the correct d...

Student Financial Aid Cluster – Federal Assistance Listing Numbers 84.007, 84.033, 84.063 and 84.268 Recommendation: We recommend the University review the R2T4 requirements and implement procedures to ensure scheduled breaks are properly factored into the R2T4 calculations as well as the correct date of withdrawal. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The error identified has been recalculated with the correct date and funds have been returned. The office of Financial Aid will have two staff members review each withdrawal to ensure that withdrawal dates are checked and that scheduled breaks are appropriately accounted for prior to finalizing the calculations. Name(s) of the contact person(s) responsible for corrective action: Jennifer Ragsdale, Director of Student Financial Aid, (201) 761-6060 Planned completion date for corrective action plan: Completed

View Audit 15156 Questioned Costs: $1

Finding 11297 (2023-002)

Significant Deficiency 2023

Saint Peter's University and Affiliates

NJ

Student Financial Aid Reporting Significant Deficiency

Student Financial Aid Cluster – Federal Assistance Listing Numbers 84.063 and 84.268 Recommendation: We recommend the University evaluate its procedures and review policies in overseeing submissions to the NSLDS completed by the third-party servicer. Additionally, we recommend the University review...

Student Financial Aid Cluster – Federal Assistance Listing Numbers 84.063 and 84.268 Recommendation: We recommend the University evaluate its procedures and review policies in overseeing submissions to the NSLDS completed by the third-party servicer. Additionally, we recommend the University review its policies and procedures on reporting enrollment information to the NSLDS to ensure that all relevant information is being captured and reported timely in accordance with applicable regulations. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: University has updated its policies and procedures for NSLDS submissions via their third-party servicer to ensure relevant information is being captured and reported timely in accordance with applicable regulations. Name(s) of the contact person(s) responsible for corrective action: Kamla Singh-Ramoutar, University Registrar, (201) 761-6051 Planned completion date for corrective action plan: Completed

View Audit 15156

Finding 11296 (2023-001)

Significant Deficiency 2023

Saint Peter's University and Affiliates

NJ

Questioned Costs Student Financial Aid Significant Deficiency

Student Financial Aid Cluster – Federal Assistance Listing Number 84.063 Recommendation: We recommend that the University establish a process to review changes and updates to a student’s FASFA prior to disbursing funds to ensure the most up to date and accurate information is being used for Pell aw...

Student Financial Aid Cluster – Federal Assistance Listing Number 84.063 Recommendation: We recommend that the University establish a process to review changes and updates to a student’s FASFA prior to disbursing funds to ensure the most up to date and accurate information is being used for Pell awards. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The error was identified prior to the end of the award year and the student’s award was corrected. The ISIR Alert Report (IART) is generated during the ISIR import process and identifies all ISIR transaction updates. All updates are reviewed and the student accounts are updated appropriately where necessary prior to the completion of the rest of the import process. The office of Financial Aid will add a 2nd reviewer of the IART report. Name(s) of the contact person(s) responsible for corrective action: Jennifer Ragsdale, Director of Student Financial Aid, (201) 761-6060 Planned completion date for corrective action plan: Completed

View Audit 15156 Questioned Costs: $1

Finding 11271 (2023-001)

Significant Deficiency 2023

Trinity Valley Community College

TX

Questioned Costs Student Financial Aid Significant Deficiency

Action taken in response to finding:  The Financial Aid Office (FAO) has implemented, another line of communication with the Registrar’s office to ensure that all complete withdrawals are sent to the financial aid office by forwarding them to a designated email box. The Financial Aid Office is also...

Action taken in response to finding:  The Financial Aid Office (FAO) has implemented, another line of communication with the Registrar’s office to ensure that all complete withdrawals are sent to the financial aid office by forwarding them to a designated email box. The Financial Aid Office is also working with IT services to develop a report that can be pulled to capture and compare all withdrawal students, with the Registrar’s office to make sure none are overlooked.  The Financial Aid Office is working with our 3rd Party Servicer, Ellucian, to identity the issues with our rules that do not capture the correct data elements, so that loans are not disbursed after a student has completely withdrawn.

View Audit 15077 Questioned Costs: $1

Finding 11248 (2023-004)

Significant Deficiency 2023

College of Lake County

IL

Questioned Costs Student Financial Aid Equipment & Real Property Management § 200.303

Identifying Number: 2023-004 Finding: While the College does have a program that addresses information security, the College did not have a readily accessible program document to address the required safeguards for the nine required elements under the implementing regulations of the Gramm-Leach Bl...

Identifying Number: 2023-004 Finding: While the College does have a program that addresses information security, the College did not have a readily accessible program document to address the required safeguards for the nine required elements under the implementing regulations of the Gramm-Leach Bliley Act (GLBA) known as the “Safeguards Rule” by June 9, 2023. Corrective Action Taken or Planned: The College will create a readily accessible written information security program document outlining all standards to meet and maintain compliance with the GLBA. While the College has not yet formally adopted an information security program, they have demonstrated substantial compliance with the required elements under the Gramm-Leach Bliley Act, including: • Development and implementation of risk assessment frameworks that include penetration testing (16 C.F.R. 314.4(b)); • Adoption of a cybersecurity roadmap and various College policies based on internationally recognized NIST standards (16 C.F.R. 314.4(c)); • Regular testing and monitoring of the effectiveness of the safeguards currently implemented (16 C.F.R. 314.4(d)); • Implementation of policies and procedures to ensure personnel can enact safeguards that should be formally included in the information security program (16 C.F.R. 314.4(e)); • Adoption of procedures and policies for the evaluating and adjusting the safeguards that have been implemented, including monthly vulnerability scans accompanied by a remediation plan for any vulnerabilities identified (16 C.F.R. 314.4(g)); • Creation of a Cybersecurity Incident Response Plan (16 C.F.R. 314.4(h)); and • Annual training and reporting for the College’s Board of Trustees on cybersecurity safeguards (16 C.F.R. 314.4(i)). The Director of Cybersecurity and the Chief Information Officer are designated as the responsible parties for oversight and implementation of the program. Anticipated Completion Date: June 30, 2024 Responsible Person: Allison Porterfield-Woods, Chief Information Officer

View Audit 15031 Questioned Costs: $1

Finding 10974 (2023-001)

Material Weakness 2023

Western Oregon University

OR

Reporting Special Tests & Provisions Student Financial Aid

Finding 2023-001 Federal Agency Name: U.S. Department of Education Federal Financial Assistance Listing: 84.063, 84.007, 84.268, 84.033, 84.038, 84.379 Program Name: Student Financial Assistance Cluster Compliance Requirement: Special Tests & Provisions – Enrollment Reporting Type of Finding: M...

Finding 2023-001 Federal Agency Name: U.S. Department of Education Federal Financial Assistance Listing: 84.063, 84.007, 84.268, 84.033, 84.038, 84.379 Program Name: Student Financial Assistance Cluster Compliance Requirement: Special Tests & Provisions – Enrollment Reporting Type of Finding: Material Weakness in Internal Controls Finding Summary: During the testing of compliance for Enrollment Reporting, there were instances where the National Student Loan Data System (NLSDS) did not reflect accurate or timely reporting of a student’s change in enrollment status. While records were submitted accurately and timely to the National Student Clearinghouse, those records were not reflected in NSLDS. Responsible Individuals: Kella Helyer, Director of Financial Aid and Amy Clark, University Registrar Corrective Action Plan: Management agrees with this finding. The initial response to this request for data did not include the active and inactive enrollment levels for the requested sample students. Initially it appeared that there was a systems issue between the National Student Clearinghouse (NSC) and the National Student Loan Data System (NSLDS); however, upon further investigation and in conversation with NSLDS, the required information was found and subsequently provided to Eide Bailly on December 1, 2023. The resolution of this request for data was resolved but after the final audit report was submitted. Anticipated Completion Date: Completed December 1, 2023

View Audit 14816

Finding 10952 (2023-001)

None 2023

Harvard University

MA

Student Financial Aid Eligibility Reporting

Enrollment Reporting Cluster: Student Financial Assistance Sponsoring Agency: Department of Education Award Name: Federal Pell Grant Program and Federal Direct Student Loans Award Numbers: Not applicable Assistance Listing Titles: Federal Pell Grant Program and Federal Direct Student Loans Assistanc...

Enrollment Reporting Cluster: Student Financial Assistance Sponsoring Agency: Department of Education Award Name: Federal Pell Grant Program and Federal Direct Student Loans Award Numbers: Not applicable Assistance Listing Titles: Federal Pell Grant Program and Federal Direct Student Loans Assistance Listing Numbers: 84.063 and 84.268 Award Year: 2022-2023 Pass-through entity: Not applicable The enrollment reporting exceptions identified by PwC were isolated to one Harvard school and did not impact the loan repayment status for any student. The exceptions were the result of system reporting and management has completed corrective actions. Program level enrollment effective date was addressed by correcting the enrollment reporting logic within the Harvard school’s reporting system, Ellucian Banner. This updated logic now provides accurate program status effective dates in the National Student Clearinghouse (NSC) reporting file. Harvard successfully transmitted its first file with the updated logic to NSC in November 2023. As program level enrollment data is not used to initiate loan repayment or other loan status changes; these students were not negatively impacted. Withdrawn versus graduation status issue was isolated to off-cycle graduation events in November and March. Although the final status was reported as withdrawn instead of graduated for these selections, there was no impact on the student’s loan repayment or eligibility as we appropriately reported the initial separation event. Harvard implemented a “Graduates Only” NSC reporting file to correctly transmit the graduation status for these off-cycle graduates which will ensure compliance going forward. Sincerely, Amanda McDonnell University Controller 617-495-8032

View Audit 14779

Finding 10920 (2023-001)

Significant Deficiency 2023

University of New Mexico

NM

Matching / Level of Effort / Earmarking Special Tests & Provisions Student Financial Aid § 200.303

Corrective Action Plan: Currently, UNM sends award information upon initial packaging which includes type of loan offered, if any, amount, and semester. The packaging process typically begins in March for the following aid year and runs on a nightly basis. A separate loan offer notification is sent ...

Corrective Action Plan: Currently, UNM sends award information upon initial packaging which includes type of loan offered, if any, amount, and semester. The packaging process typically begins in March for the following aid year and runs on a nightly basis. A separate loan offer notification is sent upon packaging which includes type of loan offered, amount, and semester. The loan offer also includes instructions on how to accept the loan and links to resources such as loan interest rates, promissory notes, entrance counseling and how to access loan history via NSLDS. If students choose to accept the loan(s), a loan acceptance notification is sent. This notification includes type of loan, amount, and semester. It also includes right to cancel information, cancellation procedures and instructions on accessing loan history. Loan acceptance notifications are sent nightly upon acceptance. The timing of the loan offer and acceptance notifications is based on when the student completes their financial aid file and is packaged, and when they accept their loan(s) but does not correspond with the actual loan disbursement. UNM has been relying on the loan offer and acceptance notifications and COD disbursement notifications to convey the loan disbursement notification information as required per 34 CFR 668.165. Effective immediately, UNM will establish an internal process to send loan disbursement notifications within 30 days of the actual loan disbursement. The internal process will duplicate our current offer and acceptance notifications. UNM will continue to opt in to COD disbursement notifications as a secondary method of communication. Contact Person: Elizabeth Jacquez-Amador Anticipated Completion Date: October 31, 2023

View Audit 14747

Finding 10884 (2023-001)

Significant Deficiency 2023

Gavilan Joint Community College District

CA

Student Financial Aid Special Tests & Provisions Reporting

Gavilan’s current process in submitting enrollment files to NSC involves a collaboration between two departments: Admissions and Records and Information Technology. During this period, primarily in Spring 2023, the two parties experienced a miscommunication between which file contained the current e...

Gavilan’s current process in submitting enrollment files to NSC involves a collaboration between two departments: Admissions and Records and Information Technology. During this period, primarily in Spring 2023, the two parties experienced a miscommunication between which file contained the current enrollment data versus which file was being submitted to NSC. Admissions and Records mistakenly submitted 4 incorrect files. Since, Admissions and Records has worked with IT to update procedures and strengthen communication when collecting the current enrollment data. To further correct the deficiency, discussions circled around Admissions and records working with a Banner Ellucian Consultant to review our Banner capabilities and strengthen the user control to oversee and submit the enrollment reports independent of IT’ s assistance. Admissions and Records will also develop a written manual to cover the step-by-step process in submitting the School Enrollment Transmission to National Student Clearinghouse in order for the correct NSLDS monitoring. The written manual will document: • Banner pages and strokes, including screen shots. • Current IT process, point of contact and ﬁle name • Link to future transmission page on the Na1onal Student Clearinghouse user page • Link to NSDLS Repor1ng page to validate and conﬁrm correct submissions have been reported. The Director of Admissions and Records will coordinate business practices with Admissions and Records, Financial Aid and IT to ensure the school enrollment transmissions are submitted on time and are correct. The business process will be documented by Admissions and Records and shared with Financial Aid, IT, and the VP of Student Services

View Audit 14642

Finding 10836 (2023-011)

Significant Deficiency 2023

Washoe County

NV

Reporting Student Financial Aid Significant Deficiency

Date: 12/26/2023 Division: Human Services Agency Corrective Action Plan Audit Report Number: Year ended June 30, 2023 Finding Number: 2023-011 Finding: The Washoe County Human Services Agency (HSA) did not have adequate internal controls to ensure the amounts reported on the quarterly CB-496 reports...

Date: 12/26/2023 Division: Human Services Agency Corrective Action Plan Audit Report Number: Year ended June 30, 2023 Finding Number: 2023-011 Finding: The Washoe County Human Services Agency (HSA) did not have adequate internal controls to ensure the amounts reported on the quarterly CB-496 reports agreed to underlying supporting records. Corrective Action Taken or To Be Taken: Notify DCFS partner of incorrect submission. Reviewed proper process with cost allocation team. Expanded and strengthened QA process for client count submissions. If already taken, date of completion: 8/14/2023 If to be taken, estimated date of completion: Agency Response Does the Agency Agree with finding?: Yes ☒ No ☐ Partially ☐ If No or Partial, Please explain reason(s) why: Additional Comments: Division Responsible for Corrective Action Plan Name, Title: Pamela Mann Address or Mailstop: 350 S. Center St. City, State, Zip Code: Reno, NV 89501 Phone Number: 775-685-6698 Email: pmann@washoecounty.gov Reviewed and Approved December 26, 2023 Signature Date:

View Audit 14489

Finding 10807 (2023-001)

Significant Deficiency 2023

Piedmont University

GA

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

Gramm-Leach-Bliley Act (GLBA) Recommendation: We recommend that the College review the updated GLBA requirements and ensure their written information security program (WISP) includes all required elements. Explanation of disagreement with audit finding: There is no disagreement with the audit find...

Gramm-Leach-Bliley Act (GLBA) Recommendation: We recommend that the College review the updated GLBA requirements and ensure their written information security program (WISP) includes all required elements. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Reason for finding: Non-compliance with GLBA Action taken in response to finding: Management has already taken action and developed a written information security plan and will implement the written policy that includes all the required elements. Name(s) of the contact person(s) responsible for corrective action: Brant Wright Planned completion date for corrective action plan: December 31, 2023

View Audit 14454

Finding 10633 (2023-001)

Significant Deficiency 2023

Brewton-Parker College

GA

Student Financial Aid Special Tests & Provisions Matching / Level of Effort / Earmarking § 200.303

Finding 2023-001: Special Tests and Provisions: Enrollment Reporting Context/Condition: Of the 40 students selected for enrollment reporting testing, 3 students within the sample were reported to NSLDS outside the maximum 60-day window. Recommendation: The auditor recommended that the College rev...

Finding 2023-001: Special Tests and Provisions: Enrollment Reporting Context/Condition: Of the 40 students selected for enrollment reporting testing, 3 students within the sample were reported to NSLDS outside the maximum 60-day window. Recommendation: The auditor recommended that the College review and update internal controls to ensure student enrollment status in the National Student Loan Data System (NSLDS) is updated in a timely manner to ensure compliance with Federal requirements. Persons Responsible for Corrective Action: Dr. Deokhyo Kim, Registrar Planned Corrective Action: We communicated with our software vendor, Aptron, to determine what caused the enrollment reporting issues. We identified two issues and worked with Aptron to put measures in place so that these issues do not happen in the future. 1. Missing withdrawn students who were not pulled up by system when they withdrew before or on the 1st enrollment report date. APTRON fixed the programming and the system now pulls those who are withdrawn before or on the 1st enrollment report date for each semester. 2. Missing graduates with their 2nd degree. APTRON fixed the programming, so that our Degree Verify file will now report a student who has earned a second degree with us. A Degree Verify File of graduates was submitted to the NSCH for any student who had earned a second degree not previously reported. Anticipated Completion Date: Fixes with our software vendor have been completed.

View Audit 14308

Finding 10499 (2023-002)

Significant Deficiency 2023

Payne Theological Seminary

OH

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

Student Financial Aid Cluster – CFDA No. 84.268 Recommendation: We recommend that the Seminary review the updated GLBA requirements and ensure their WISP includes all required elements. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in r...

Student Financial Aid Cluster – CFDA No. 84.268 Recommendation: We recommend that the Seminary review the updated GLBA requirements and ensure their WISP includes all required elements. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The seminary will update our current WISP to comply with additional requirements and newer standards. Name(s) of the contact person(s) responsible for corrective action: Raymond Ingram, Director of Finance Planned completion date for corrective action plan: February 1,2024

View Audit 14195

Finding 10498 (2023-001)

Significant Deficiency 2023

Payne Theological Seminary

OH

Student Financial Aid Matching / Level of Effort / Earmarking Internal Control / Segregation of Duties

Student Financial Aid Cluster – CFDA No. 84.268 Recommendation: We recommend the Seminary reevaluate its procedures and review policies surrounding reporting status changes to NSLDS to ensure timely reporting as well as put a process in place to ensure the enrollment effective date reported to NSLDS...

Student Financial Aid Cluster – CFDA No. 84.268 Recommendation: We recommend the Seminary reevaluate its procedures and review policies surrounding reporting status changes to NSLDS to ensure timely reporting as well as put a process in place to ensure the enrollment effective date reported to NSLDS is aligning with the Seminary's last date of attendance. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Seminary will continue to use the import / export function to report to NSLDS. Financial Aid Services will reiew the report, prior to submission, for any errors, duplications, etc. Name(s) of the contact person(s) responsible for corrective action: Maryjo Lewis, Registar Planned completion date for corrective action plan: January 1,2024

View Audit 14195

Finding 10472 (2023-002)

Significant Deficiency 2023

Mt. Hood Community College

OR

Student Financial Aid Matching / Level of Effort / Earmarking Internal Control / Segregation of Duties

Christopher Natelborg (Director of Financial Aid) and Dawn Sallee-Justesen (Director of Enrollment Services) will implement the following procedures and internal controls to ensure accurate dates are reported to NSLDS that agree with District records: • For NSLDS Enrollment Reporting purposes, 34 CF...

Christopher Natelborg (Director of Financial Aid) and Dawn Sallee-Justesen (Director of Enrollment Services) will implement the following procedures and internal controls to ensure accurate dates are reported to NSLDS that agree with District records: • For NSLDS Enrollment Reporting purposes, 34 CFR 685.305(c) requires schools to report the same withdrawal date that the school used for the return of Title IV funds (R2T4) purposes under 668.22(b) or (c). That is, the effective date for the withdrawn (‘W’) status is the withdrawal date used by the school in the R2T4 calculation. To ensure reporting is accurate, the Office of Financial Aid will communicate to the Registrar the specific student files and the dates of withdrawal used for any unofficial withdrawal R2T4 calculations after each term and the Registrar will update the student’s date of withdrawal on file with NSLDS within the required enrollment reporting deadlines. • The Director of Financial Aid and Director of Enrollment Services will also explore Information Technology automating the unofficial withdrawal date reporting to NSLDS. These corrective actions will be implemented by February 2024, including updating the dates in NSLDS for the 2023 summer and fall term unofficial withdrawals.

View Audit 14137

Finding 10437 (2023-004)

Material Weakness 2023

Solano Community College District

CA

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

2023-004: 240 Days Outstanding Check Recommendation: We recommend the District re-evaluate their procedures for processing and documenting outstanding Title IV funds to the Department of Education. Action taken in response to finding: This issue is the result of a conflict between the procedures use...

2023-004: 240 Days Outstanding Check Recommendation: We recommend the District re-evaluate their procedures for processing and documenting outstanding Title IV funds to the Department of Education. Action taken in response to finding: This issue is the result of a conflict between the procedures used by the awarding team (Financial Aid) and the disbursement team (Fiscal Services). The Financial Aid team was operating with a set of pre-pandemic instructions that had them contact students to fix their address information (the typical reason that disbursements timeout) and send a list of students with verified addresses to Fiscal Services for reissuing. Nothing in their procedures mentioned the need to rescind aid—only the need to verify addresses to allow funds to reach students. The Fiscal Services team’s procedures, on the other hand, assumed the Financial Aid team was rescinding aid as necessary and thus would reissue repeatedly as long as the funds remained awarded in the school’s information system, even in cases where the initial disbursement had been made more than 240 days prior. The combination of these two procedures led to the findings in this year’s audit and last year’s audit, as well. The Financial Aid team’s procedures were updated and presented to the team on October 4, 2023. These new procedures included:  Directions on how to rescind funds  A policy statement requiring recission when the time since first disbursement has exceeded 90 days (an institutional policy that is stricter than the 240 days allowable under federal regulations)  A clear set of instructions on how to make the determination to rescind funds. Name of the contact person responsible for corrective action: Patrick Scott, Dean – Financial Aid Planned completion date for corrective action plan: October 2023 for procedure correction. February 2024 for completed review of affected students in audit list.

View Audit 14106

Finding 10433 (2023-003)

Significant Deficiency 2023

Solano Community College District

CA

Student Financial Aid Matching / Level of Effort / Earmarking Internal Control / Segregation of Duties § 200.303

2023-003: NSLDS Enrollment Reporting Recommendation: We recommend that the District review its enrollment reporting procedures to ensure information is accurately reported to NSLDS as required by regulations. Action taken in response to finding: The District will review its enrollment reporting proc...

2023-003: NSLDS Enrollment Reporting Recommendation: We recommend that the District review its enrollment reporting procedures to ensure information is accurately reported to NSLDS as required by regulations. Action taken in response to finding: The District will review its enrollment reporting procedures to ensure information is accurately reported to NSLDS as required by regulations. Name of the contact person responsible for corrective action: Patrick Scott, Dean – Financial Aid Planned completion date for corrective action plan: Spring 2024

View Audit 14106

Finding 10429 (2023-002)

Significant Deficiency 2023

Solano Community College District

CA

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

Recommendation: We recommend that the District improve the existing procedures and controls to ensure compliance with the aforementioned criteria. Action taken in response to finding: This issue was discovered during the audit process and the staff member associated with this error was made aware of...

Recommendation: We recommend that the District improve the existing procedures and controls to ensure compliance with the aforementioned criteria. Action taken in response to finding: This issue was discovered during the audit process and the staff member associated with this error was made aware of it in July 2023. Refresher training occurred during August 2023 and we have added members to the R2T4 calculation team in December 2023 in hopes of spreading workload and allowing more time to complete calculations and returns before the relevant deadlines. Names of the contact persons responsible for corrective action: Patrick Scott, Dean – Financial Aid, and Kate Larot, Financial Aid Specialist Planned completion date for corrective action plan: January 2024

View Audit 14106

Finding 10428 (2023-001)

Significant Deficiency 2023

Solano Community College District

CA

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

2023-001: Student Eligibility and Awarding Recommendation: We recommend the District to evaluate its procedures related to the manual input of information from the student loan request. Action taken in response to finding: This issue was the result of using the Solano completed unit level, rather th...

2023-001: Student Eligibility and Awarding Recommendation: We recommend the District to evaluate its procedures related to the manual input of information from the student loan request. Action taken in response to finding: This issue was the result of using the Solano completed unit level, rather than the cumulative number that includes transfer units, when awarding a student in our small BS Biotechnology program. Student had completed 43.5 credits at Solano by the beginning of the aid year. As a result, the student was awarded a second-year subsidized amount when they were eligible for the third year and beyond amount. This resulted in the student receiving $1,000 less subsidized loans than they were eligible for. In July 2023, we trained the team to watch for this issue and evaluated the procedure log that we use for processing Direct Loans. This log now includes two checks that are relevant to ensuring subsidized loan amounts are correct: 1. Confirm the level of the student. If the student is in our BS Biotechnology program, they may have additional eligibility than the standard first-year and second-year loans that we normally process as a community college. 2. If the loan is a single-term loan, is the full subsidized eligibility exhausted before awarding any unsubsidized loan amounts? The student’s file was corrected on COD on 8/3/2023 to reflect a $5,500 subsidized award. Names of the contact persons responsible for corrective action: Patrick Scott, Dean – Financial Aid, and Kate Larot, Financial Aid Specialist Planned completion date for corrective action plan: August 2023

View Audit 14106 Questioned Costs: $1

Finding 10400 (2023-001)

Significant Deficiency 2023

College of Dupage Community College District 502

IL

Student Financial Aid Reporting Significant Deficiency

U.S. Department of Education College of DuPage, Community College District Number 502 (the College), respectfully submits the following corrective action plan for the year ended June 30, 2023. Name and address of independent public accounting firm: CliftonLarsonAllen LLP, Oak Brook, Illinois Audi...

U.S. Department of Education College of DuPage, Community College District Number 502 (the College), respectfully submits the following corrective action plan for the year ended June 30, 2023. Name and address of independent public accounting firm: CliftonLarsonAllen LLP, Oak Brook, Illinois Audit period: July 1, 2022 – June 30, 2023 The findings from the schedule of findings, responses, and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. Findings – Financial Statement Audit: None Findings – Federal Award Programs Audits: Department of Education 2023‐001 – Enrollment Status Reporting Recommendation: We recommend that the College review its procedures to ensure enrollment status changes are reported to NSLDS accurately, as required by regulations. Planned Corrective Action: The College of DuPage has reviewed and agrees with the enrollment reporting finding. The College has already taken multiple steps to resolve all issues ensuring complete, accurate and timely reporting. However, all those steps have not fully resolved the issue with enrollment reporting. As such, we will be working on a long‐term system improvement with the goal of limiting issues and future audit findings. The Financial Aid Office and the Registrar’s Office will work closely with the Information Technology department to automate a process of capturing unofficial withdrawal information, using the NSLDS template and then uploading that report directly to NSLDS on a weekly basis. The College will continue to send records to the National Student Clearinghouse and use this new report to supplement reporting and resolve the issues with reporting unofficial withdrawals. The goal is to implement this new report by June 30, 2024. Contacts Responsible for Corrective Action: Dr. Diana Del Rosario, Assistant Provost, Student Affairs Jill Pierson, Registrar Scott Brady, CFO & Treasurer Anticipated Completion Date: June 30, 2024 If the U.S. Department of Education has questions regarding this plan, please do not hesitate to call me at (630) 942‐2219.

View Audit 14059

Finding 10386 (2023-001)

Significant Deficiency 2023

Palmerton Area School District

PA

Reporting Student Financial Aid

Moving forward, we will implement procedures and develop oversight to ensure reports are filed in a timely manner.

View Audit 14048

Finding 10356 (2023-007)

Significant Deficiency 2023

Clatsop Community College

OR

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

Student Financial Assistance Cluster – Assistance Listing No. 84.268 Recommendation: We recommend the college implement procedures to ensure direct loan reconciliations are performed monthly and reviewed by someone other than the preparer. Explanation of disagreement with audit finding: There is no...

Student Financial Assistance Cluster – Assistance Listing No. 84.268 Recommendation: We recommend the college implement procedures to ensure direct loan reconciliations are performed monthly and reviewed by someone other than the preparer. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The financial aid office is aware of the requirement to perform direct loan reconciliation. We are now appropriately staffed with monthly reconciliation being performed by the Assistant Director and being sent to the Director of Accounting for review. Name(s) of the contact person(s) responsible for corrective action: Sarah Geleynse & Layla Solar Planned completion date for corrective action plan: Completed

View Audit 14009

Finding 10352 (2023-006)

Significant Deficiency 2023

Clatsop Community College

OR

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

Student Financial Assistance Cluster – Assistance Listing No. 84.063, 84.268, 84.007, 84.033 Recommendation: We recommend the College implement procedures to ensure all requirements of a Tier One arrangement for Third Party Servicers are being met. Explanation of disagreement with audit finding: Th...

Student Financial Assistance Cluster – Assistance Listing No. 84.063, 84.268, 84.007, 84.033 Recommendation: We recommend the College implement procedures to ensure all requirements of a Tier One arrangement for Third Party Servicers are being met. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The links to the BankMobile contract and costs have been posted on the College web page that explains student stipends and the College use of Bank Mobile to provide these stipends. The links have been given to the College Financial Aid Director to upload to the US Dept of Education. Name(s) of the contact person(s) responsible for corrective action: Margaret Antilla Planned completion date for corrective action plan: Completed

View Audit 14009

Finding 10348 (2023-005)

Material Weakness 2023

Clatsop Community College

OR

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

Student Financial Assistance Cluster – Assistance Listing No. 84.063, 84.268, 84.007, 84.033 Recommendation: We recommend the College draft and implement IT policies and create an updated WISP to ensure the College is compliant with the GLBG Safeguards Rule. Explanation of disagreement with audit ...

Student Financial Assistance Cluster – Assistance Listing No. 84.063, 84.268, 84.007, 84.033 Recommendation: We recommend the College draft and implement IT policies and create an updated WISP to ensure the College is compliant with the GLBG Safeguards Rule. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Clatsop Community College is working on its information security plan, as well as vendor and change management plans. The plans will be presented to College Council in spring 2024 before they are finalized. Name(s) of the contact person(s) responsible for corrective action: Greg Riehl Planned completion date for corrective action plan: June 30, 2024

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Finding 10344 (2023-004)

Material Weakness 2023

Clatsop Community College

OR

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

Student Financial Assistance Cluster – Assistance Listing No. 84.063, 84.268, 84.007, 84.033 Recommendation: We recommend a process be put in place to ensure documentation is maintained and available, particularly when making software changes. Explanation of disagreement with audit finding: There i...

Student Financial Assistance Cluster – Assistance Listing No. 84.063, 84.268, 84.007, 84.033 Recommendation: We recommend a process be put in place to ensure documentation is maintained and available, particularly when making software changes. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The college will create a stronger infrastructure around records and reporting by reducing the number of staff who have access to student coding. The number of staff allowed access to student program changes and enrollment transactions results in a significant number of errors on the NSC report due to effective dating issues. The volume of errors is not manageable with the current staff and will continue to be so regardless of additional infrastructure if changes in the business process are not implemented. The Registrar is creating a system for effective dating and reducing the number of employees with access to student program coding and enrollment transactions as part of the implementation of the new ERP system Colleague. In addition, the Registrar will create a student coding and effective dating chart that outlines the dates and deadlines associated with allowable student program changes and enrollment transactions. The reduction in staff access and implementation of effective dating in alignment with the new enterprise system Colleague and NSC reporting requirements will result in compliance with NSLDS reporting requirements. Name(s) of the contact person(s) responsible for corrective action: Siv Barnum Planned completion date for corrective action plan: FY2024-25

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