Corrective Action Plans

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Finding 501787 (2024-001)
Significant Deficiency 2024
Student Financial Assistance Cluster— Assistance Listing Nos. 84.007, 84.033, 84.063, 84.268 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 disagreeme...
Student Financial Assistance Cluster— Assistance Listing Nos. 84.007, 84.033, 84.063, 84.268 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: Student Financial Services is working with the Registrar and IT to review the current reporting system. Adjustments will be made to reporting process to ensure accurate and timely reporting of students’ enrollment status to NSLDS. Names of the contact persons responsible for corrective action: Amanda Burgess Planned completion date for corrective action plan: May 31, 2025
Inaccurate and Untimely Return of Title IV Funds (R2T4): Planned Corrective Action: The Financial Aid Department corrected the current year errors by completing the R2T4s for the students identified. In addition to those corrections, a full file review was done to ensure that no other students were...
Inaccurate and Untimely Return of Title IV Funds (R2T4): Planned Corrective Action: The Financial Aid Department corrected the current year errors by completing the R2T4s for the students identified. In addition to those corrections, a full file review was done to ensure that no other students were missed. To prevent the recurrence of this issue going forward, the Financial Aid Office will pull a 0 credit hour report at the end of each module to ensure that all unofficial withdrawals are followed up on and that all R2T4s are filed in a timely manner. Persons Responsible for Corrective Action Plan: Veronica L. Hamblin, Director of Accounting Anticipated Date of Completion: The corrections for the 2023-2024 Academic year have already been completed, and the new process will be implemented by October 18, 2024 following the completion of the August online module.
Inaccurate Enrollment Reporting to National Student Loan Data System (NSLDS) Planned Corrective Action: To ensure that both accurate and timely enrollment reporting is transmitted to the National Student Loan Data System (NSLDS) an NSC / NSLDS enrollment confirmation process will be established and ...
Inaccurate Enrollment Reporting to National Student Loan Data System (NSLDS) Planned Corrective Action: To ensure that both accurate and timely enrollment reporting is transmitted to the National Student Loan Data System (NSLDS) an NSC / NSLDS enrollment confirmation process will be established and implemented by Student Financial Services. For official withdrawals, an additional processing step will be added to the SFS Withdrawal Tracker. The Student Financial Services rep will confirm that the correct withdrawal date has been accurately reported to the National Student Clearinghouse (NSC) by the Registrar’s office and then correctly transmitted to the National Student Loan Data System (NSLDS). If the reported enrollment date does not align with the Last Date of Academic Related Activity, the SFS Representative will notify either the Director of Student Financial Services (Michelle Baker) or the Chief Student Finance Officer (David Burney) to manually adjust the dates in NSLDS. The SFS office will then notify the Registrar’s office that the dates have been manually updated. For unofficial withdrawals, if a student is identified as an unofficial withdrawal (e.g. lack of attendance in a course resulting in an R2T4 calculation being performed) once the withdrawal list has been reported at the end of each semester by the Registrar’s office, the Student Financial Services Representative will confirm that the correct withdrawal date has been accurately reported to the National Student Clearinghouse (NSC) by the Registrar’s office and then correctly transmitted to the National Student Loan Data System (NSLDS). If the reported enrollment date does not align with the Last Date of Academic Related Activity, the SFS Representative will notify either the Director of Student Financial Services (Michelle Baker) or the Chief Student Finance Officer (David Burney) to manually adjust the dates in NSLDS. The SFS office will then notify the Registrar’s office that the dates have been manually updated. Person Responsible for Corrective Action Plan: David Burney, Chief Student Finance Officer Anticipated Date of Completion: Implementation of process will begin 9/30/2024
Untimely and Inaccurate Returns of Title IV Funds (R2T4) Planned Corrective Action: In addition to the Withdrawal Tracker created last year to document the withdrawal process and communicate across the department, the SFS team will now also pull official withdrawal lists (including unofficial withdr...
Untimely and Inaccurate Returns of Title IV Funds (R2T4) Planned Corrective Action: In addition to the Withdrawal Tracker created last year to document the withdrawal process and communicate across the department, the SFS team will now also pull official withdrawal lists (including unofficial withdrawals) every semester with assistance from the Director of Institutional Research and Assessment –Lynette Duncan. We will also work with her to create a report which will pull that data directly from Colleague SIS rather than relying on communication from the registrar’s office or professor. We have several new arrangements that will improve our R2T4 processes and ensure accuracy. Firstly, the registrar’s office has created a new automated withdrawal form detailing all elements pertaining to LDA dates that will produce automated email notifications to our office. This form will pull data from BlackBoard listing the last interaction date the student had with the BB system. This will encourage our tracking processes to run more swiftly. In addition, we will still track each withdrawal in real time on the SFS Withdrawal Tracker, but the information will be cross-referenced against the system generated withdrawal data from the Director of Institutional Research and Assessment to ensure precision and compliance. After the Director of Student Financial Services processes an R2T4 calculation, the Chief Student Finance Officer will review the work to ensure accuracy on a weekly basis. Finally, we will move the R2T4 process into Colleague rather than doing this process on the COD website. This will add another layer of checks and balances for correct data and greatly increase the speed with which the Director of Student Financial Services can perform R2T4s. Person Responsible for Corrective Action Plan: Michelle Baker McFadden, Director of Student Financial Services Anticipated Date of Completion: Implementation of process will begin 9/30/2024
Student financial aid programs cluster Significant Deficiency in Internal Control Condition: During our testing of the regulations, one student who was identified as a withdrawn student did not have the proper calculation performed to determine if funds should be returned in accordance with the ...
Student financial aid programs cluster Significant Deficiency in Internal Control Condition: During our testing of the regulations, one student who was identified as a withdrawn student did not have the proper calculation performed to determine if funds should be returned in accordance with the regulations. Auditor Recommendations: The University should continue to update processes and procedures to ensure compliance in the future. These updated processes should include adequate segregation of duties and review steps to ensure that all students who are subject to potential recapture and return of funds are analyzed in the time frame dictated by the CFR. Action Taken: A new weekly quality assurance report has been created that identifies all withdrawn students. It identifies any student that requires a return calculation in the financial aid management system, and that all required Title IV aid has been returned. The report is generated and reviewed by both the Associate Director and Assistant Director of Financial Aid to ensure adequate segregation of duties and review. This report was run for the entirely of fiscal year 2024 and no other returns were found to be outstanding.
FINDING 2024‐002 – Special Tests and Provisions – Return of Title IV (R2T4) Funds Significant Deficiency in Internal Control over Compliance Recommendation: The University should design and implement a robust review process of all R2T4 calculations for official and unofficial withdrawals. This will ...
FINDING 2024‐002 – Special Tests and Provisions – Return of Title IV (R2T4) Funds Significant Deficiency in Internal Control over Compliance Recommendation: The University should design and implement a robust review process of all R2T4 calculations for official and unofficial withdrawals. This will help ensure the accuracy of the calculation before the return of funding. Response: There is no disagreement with this audit finding. Action taken in response to finding: To ensure the accuracy of R2T4 calculations, the Student Financial Services Office will take the following actions: • Implementation of R2T4 Module: Starting with the 2024-2025 academic year, the Financial Aid Office will utilize the Banner-delivered R2T4 module to perform calculations, ensuring more accurate and consistent data management. • Multi-Step Review Process: A multi-step review process has been implemented by Student Financial Services staff to ensure thorough verification of all R2T4 calculations and timely returns of funds. • Enhanced Training: Staff are pursuing additional training on R2T4 regulations and procedures to further strengthen their expertise and reduce the risk of future discrepancies. These actions are in process currently, and expected to be fully implemented and corrected by October 2024 to ensure that R2T4 calculations are prepared and reviewed for accuracy for the 2024-2025 award year. Enhanced training will continue on a go forward basis. Contact Person(s): Louisa Diana, Director of Compliance; Sarah Everitt, Dean of Student Financial Services;
FINDING 2024‐001 – Special Tests and Provisions – Enrollment Reporting Significant Deficiency in Internal Control over Compliance Recommendation: The University should implement a policy to ensure graduates for all semesters/terms are reported timely. Response: There is no disagreement with this aud...
FINDING 2024‐001 – Special Tests and Provisions – Enrollment Reporting Significant Deficiency in Internal Control over Compliance Recommendation: The University should implement a policy to ensure graduates for all semesters/terms are reported timely. Response: There is no disagreement with this audit finding. Action taken in response to finding: Upon identifying this deficiency, Gonzaga University immediately updated its enrollment reporting schedules to ensure timely reporting of mid-summer conferrals. Going forward, all mid-summer degree conferrals will be reported within the required federal timeframe to maintain compliance with Title IV regulations. This adjustment guarantees accurate and timely data submission to the National Student Loan Data System (NSLDS), preventing future delays or discrepancies in reporting. Our new schedule has 9 reporting dates for degree transmission and 14 reporting dates for enrollment transmission in a calendar year. The increased frequency ensures compliance with the 60-day threshold and guarantee that no student will be reported outside the 60-day threshold. We consider this to be remediated. Contact Person(s): Sarah Everitt, Dean of Student Financial Services; Maxwell Kwenda, University Registrar & Director of Institutional Research
Criteria: Under the Pell grant and ED loan programs, Institutions are responsible for timely enrollment reporting to NSLDS whether they report directly or via a third-party servicer such as the National Student Clearinghouse (NSC). Enrollment Reporting in a timely and accurate manner is critical for...
Criteria: Under the Pell grant and ED loan programs, Institutions are responsible for timely enrollment reporting to NSLDS whether they report directly or via a third-party servicer such as the National Student Clearinghouse (NSC). Enrollment Reporting in a timely and accurate manner is critical for effective management of the programs. Enrollment information must be reported within 60 days whenever the enrollment status changes for students, unless a roster will be submitted within 60 days. These changes include reductions or increases in attendance levels, withdrawals, graduations, or approved leaves-of-absences. The University concurs with the audit finding and will adhere to the corrective action plan. Corrective Action Plan: Viginia Union University has signficiantly imprved its compliance with federal regulations for enrollment reporting to the National Student Loan Data System (NSLDS). During FY24, a comprehensive review of all files from FY21 to FY23 was conduted to ensure accurate and timely reporting of students' enrollment statuses to the NSLDS. In addition to reviewing previous years, any delinquent reporting for FY24 was also updated to reflect the current status. By April 2024, reporting to NSLDS was synched to a cycle to ensure compliance with the 60-day window. In October 2023, Virginia Union revised its Enrollment Reporting Policy to outline the reporting schedule for submissions to the National Student Clearinghouse (NSC). This updated policy sets forth the timeline and guidelines for enrollment reporting. In addition, Virginia Union University implemented a process to code students who are identified as Unofficial Withdrawal in teh Jenzabar system. This process will ensure these students are included in the monthly reporting to the National Student Clearinghouse even if they do not complete the formal withdrawal process. Responsible person(s): Doreen Dixon, Registrar, ddixon@vuu.edu, 804-257-5845. Robert Merino, Executive Director of Financial Aid, jrmerino@vuu.edu, 804-254-3973. Planned Date of Completion of Corrective Action: August 31, 2024.
We will implement the following solutions immediately to help mitigate our R2T4 processes: the Business Office (BO) will submit refunds to the Department of Education (DOE) as separate transactions rather than netting them with drawdowns; Financial Aid (FA) will confirm correct withdrawal date befor...
We will implement the following solutions immediately to help mitigate our R2T4 processes: the Business Office (BO) will submit refunds to the Department of Education (DOE) as separate transactions rather than netting them with drawdowns; Financial Aid (FA) will confirm correct withdrawal date before starting R2T4 processes and the BO will also confirm after FA has completed these processes; and the BO will save the Student Complete Withdrawal Form, R2T4 Workflow item, ROFC screenshot, FATP email and file from FA, Student Statement, G5/G6 screenshot and email confirmation of refund
View Audit 322507 Questioned Costs: $1
Students’ information is submitted by the Clearinghouse to NSLDS based on a report generated from the University’s Student Information System database. Due to significant database software changes, the report no longer included all of the information required on a student who had withdrawn. The Un...
Students’ information is submitted by the Clearinghouse to NSLDS based on a report generated from the University’s Student Information System database. Due to significant database software changes, the report no longer included all of the information required on a student who had withdrawn. The University has identified the error with the report and has created a new database report that includes all of the required information, including for students who have withdrawn. The new database report will be submitted to the Clearinghouse and to NSLDS. Student information, including social security numbers, is submitted to the Clearinghouse based on reports from the University’s Student Information System database. To prevent submitting batches with incorrect social security numbers, the Registrar’s Office will provide a report of student information to the Financial Aid Office prior to submitting batches to the Clearinghouse. The Financial Aid Office will verify the SIS data with the Financial Aid database, and report any discrepancies to the Registrar’s Office for correction, prior to the batch submission.
Enrollment Reporting Corrective Action Plan: The Office of the Registrar will lead the implementation of new internal controls to ensure all enrollment status changes are reviewed and submitted in a timely manner in accordance with federal requirements. Specifically, measures will be taken to me...
Enrollment Reporting Corrective Action Plan: The Office of the Registrar will lead the implementation of new internal controls to ensure all enrollment status changes are reviewed and submitted in a timely manner in accordance with federal requirements. Specifically, measures will be taken to meet the Title IV requirement that the College completes and reports within a minimum of 60 days all student status changes to the National Student Loan Data System (NSLDS). Anticipated Completion Date: Fiscal Year 2025. Name of Contact Person Responsible for the Corrective Action Plan: Rashad Rogers
Return of Title IV Funds Corrective Action Plan: The College Financial Aid Office and Business Office will implement new internal controls and procedures to ensure all student Title IV calculations are calculated correctly, reviewed in a timely manner, and ensure funds are returned promptly. Dea...
Return of Title IV Funds Corrective Action Plan: The College Financial Aid Office and Business Office will implement new internal controls and procedures to ensure all student Title IV calculations are calculated correctly, reviewed in a timely manner, and ensure funds are returned promptly. Deadlines have been created to submit student withdrawals timely to the Financial Aid Department. A monthly reconciliation between the Registrar and Financial Aid Office will ensure withdrawals and correct withdrawal dates are reported to the Financial Aid Office in a timely manner. The Business Office will review the Financial Aid Office's calculation of funds for accuracy to ensure the correct amount is returned to the Department of Education. Anticipated Completion Date: Fiscal year 2025. Name of Contact Person Responsible for the Corrective Action Plan: Rashad Rogers
Incorrect Return of Title IV Funds Calculation Planned Corrective Action: Extensive training on module (Summer, Summer 1, and Summer 2) refunds have been completed. Each summer refresher training will take place due to the complicated nature of summer module calculation. Students who complete FA...
Incorrect Return of Title IV Funds Calculation Planned Corrective Action: Extensive training on module (Summer, Summer 1, and Summer 2) refunds have been completed. Each summer refresher training will take place due to the complicated nature of summer module calculation. Students who complete FAFSA after a term will be reviewed to determine how much Title IV aid they are eligible to have disbursed. The R2T4 calculation will be processed to learn the percentage earned. Exception to the R2T4 will be if student completed the module/term successfully. Person Responsible for Corrective Action Plan: Karen LaQuey, Director of Student Financial Aid Anticipated Date of Completion: Immediately
View Audit 320424 Questioned Costs: $1
The University respectfully submits the following corrective action plan. Audit Period: June 30, 2024. The finding discussed below is numbered consistently with the number assigned in the schedule of findings and questioned costs. Corrective Action Plan for Federal Awards Findings and Questioned Cos...
The University respectfully submits the following corrective action plan. Audit Period: June 30, 2024. The finding discussed below is numbered consistently with the number assigned in the schedule of findings and questioned costs. Corrective Action Plan for Federal Awards Findings and Questioned Costs. 2024-001 Special Tests and Provisions - Enrollment Reporting. As a result of the delayed NSLDS enrollment reporting and subsequent finding, William Carey University has implemented the following measures to ensure timely future reporting. 1. Any difficulties in federal reporting, technical or otherwise, will be reported to the area vice president and to the CFO promptly. 2. Any difficulties in federal reporting, technical or otherwise, will be reported to the federal agency promptly for purposes of notification, to seek guidance regarding possible alternative reporting methods, and/or to request extension to the reporting period. 3. All documentation and communication regarding the reporting difficulty will be kept by the responsible department director and submitted to the CFO. The offices of Academic Affairs and Business Affairs will cooperate to ensure immediate implementation. Name of Responsible Person: Grant Guthrie, Vice President and Chief Financial Officer. Expected Date of Completion: Current.
Responsible Individual: Tamara Long Vice President for Enrollment and Student Engagement Abilene Christian University Finding 2024-002 Special Tests & Provisions - Bonus & Incentives Related to Enrollment Agency Name: U.S. Deparlment of Education Program Name: Federal Pell Grant, Federal Direct Stud...
Responsible Individual: Tamara Long Vice President for Enrollment and Student Engagement Abilene Christian University Finding 2024-002 Special Tests & Provisions - Bonus & Incentives Related to Enrollment Agency Name: U.S. Deparlment of Education Program Name: Federal Pell Grant, Federal Direct Student Loans, SEOG, Federal Work Study and TEACH Grants August 19, 2024 Finding Summary: Incentive Compensation (34 CFR 668.14(b)(22)(i) Institutions are required, within the Program Participation Agreement (PPA), to acknowledge that they will not provide any commission, bonus, or other incentive payment based on any part, directly or indirectly, upon success in securing enrollments or awards of financial aid. The university documented several bonus payments to individuals related to enrollment strategies and goals. Corrective Action Plan (CAP): Based on the findings of the Special Tests and Provisions for Incentive Compensation as part of (34 CFR668.14(b)(22}(i), the offices of enrollment and financial operations have identified additional review and controls that will be put in place to mitigate future risk of non-compliance. Additional review will be required by a financial operations member for any requests made for enrollment related staff. In addition, a formal tenure bonus structure has already been put in place to ensure that no bonuses or incentives are given based on enrollment goals. Anticipated Completion Date: As the tenured bonus structure has already been activated, the review of bonuses raises, and incentive pay will immediately be required to go through an additional financial review for compliance. The anticipated completion date is July 1, 2024
View Audit 318751 Questioned Costs: $1
Responsible Individual: Eric Gumm Registrar and Director of First Year Program and Academic Development Center Abilene Christian University Finding 2024-001 concerning Enrollment Reporting Agency Name: U.S. Department of Education Program Name: Federal Pell Grant, Federal Direct Student Loans August...
Responsible Individual: Eric Gumm Registrar and Director of First Year Program and Academic Development Center Abilene Christian University Finding 2024-001 concerning Enrollment Reporting Agency Name: U.S. Department of Education Program Name: Federal Pell Grant, Federal Direct Student Loans August 19, 2024 Finding Summary: Enrollment Reporting (34 CFR 690.93(b)(2); 34 CFR 682.610; 34 CFR 685.309) Institutions are required to report enrollment information. The University's processes did not ensure timely and accurate student status reporting to National Student Loan Data System (NSLDS). Out of the population of 829 students with student attendance changes required to be reported, a sample of 25 students were selected for testing. The University failed to report 3 students who had changes in enrollment status. Of the three students the University failed to report, 2 students had withdrawn from the University. The University reported the incorrect enrollment effective dates for 3 students at the program and campus levels. The University failed to report graduated status for 2 students (students were reported as withdrawn and the University failed to subsequently update the status to graduated). The University reported the incorrect Program Enrollment Effective Date for 1 student. The University did not report a change in enrollment status in a timely manner for 1 student. Corrective Action Plan (CAP): Based on the findings within the Federal and State Financial Assistance Program audit, it was determined that a significant deficiency exists within the review of reporting for student enrollment through the National Student Loan Data System (NSLDS). The office of Student Financial Services has identified the need for regular reconciliation of updates to student enrollment status from the Banner point of record to the NSLDS system. Our plan of action begins with a comprehensive understanding of the roles and responsibilities between the financial aid office and the registrar's office. Once this is well documented, the Office of the Registrar will begin a monthly reconciliation of enrollment reporting for any student status changes that have happened within that month. Anticipated Completion Date: The timeline for this CAP begins with the formal documentation of the enrollment reporting process. This will take place prior to the start of the Fall 2024 semester. The reconciliation of reporting will begin in September 2024 after 12th day of enrollment is confirmed and sent to the Clearinghouse for updates. The anticipated completion date is July 1, 2024
2024-002 Student Financial Aid – 84.268 – Federal Direct Loan Program, 84.063 – Federal Pell Grant Program, 84.007 – Federal Supplemental Educational Opportunity Grant Program, 84.033 – Federal Work-Study Program Recommendation: We recommend the review process for awarding be documented and retain...
2024-002 Student Financial Aid – 84.268 – Federal Direct Loan Program, 84.063 – Federal Pell Grant Program, 84.007 – Federal Supplemental Educational Opportunity Grant Program, 84.033 – Federal Work-Study Program Recommendation: We recommend the review process for awarding be documented and retained as support for the review and approval process. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Director of Financial Aid will document each change to an award by printing a new award offer and saving to document tracking. As this is the final year in which Lincoln Christian University will have academic operations, we believe this corrective action to be sufficient for the remainder of the year. Name of the contact person responsible for corrective action: Margie Martin, Director of Accounting Planned completion date for corrective action plan: May 31, 2024.
Finding 485172 (2024-002)
Significant Deficiency 2024
Finding 2024-002 Personnel Responsible for Corrective Action: Cathy Gorrell, Registrar Anticipated Completion Date: September 30, 2024 Corrective Action Plan: The Office of the Registrar recognizes the systematic programming of a pseudo academic program after a pseudo course has been added with a ...
Finding 2024-002 Personnel Responsible for Corrective Action: Cathy Gorrell, Registrar Anticipated Completion Date: September 30, 2024 Corrective Action Plan: The Office of the Registrar recognizes the systematic programming of a pseudo academic program after a pseudo course has been added with a future date after the student’s current program has been inactivated or graduated. This process has been at the request of the Office of Student Accounts for the graduation fee. The Office of the Registrar will work with the Office of Student Accounts to move to the system Graduation Application process rather than the customized and manual process of pseudo courses. Further, the Office of the Registrar has increased its data quality checks on the pseudo programs and courses. In conjunction, this should eliminate the reporting of active programs when the student has graduated.
Corrective Action: The University recognizes the importance of submitting an accurate FISAP and maintaining supporting documentation. Data challenges are being addressed, and additional controls are now in place to ensure this is not a repeat finding moving forward. These include new personnel, addi...
Corrective Action: The University recognizes the importance of submitting an accurate FISAP and maintaining supporting documentation. Data challenges are being addressed, and additional controls are now in place to ensure this is not a repeat finding moving forward. These include new personnel, additional training and system upgrades that ensure accurate reporting. Responsible Person: Matthew Kirksey, Financial Aid Director Completion Date: December 31, 2026
Corrective Action: The University is actively reviewing and updating policies and procedures regarding eligibility and disbursement controls. The University has implemented various new reports for monitoring and correcting over/under award situations. Responsible Person: Matthew Kirksey, Financial A...
Corrective Action: The University is actively reviewing and updating policies and procedures regarding eligibility and disbursement controls. The University has implemented various new reports for monitoring and correcting over/under award situations. Responsible Person: Matthew Kirksey, Financial Aid Director Completion Date: December 31, 2026
Corrective Action: The University is actively reviewing and updating policies and procedures regarding Return to Title IV aid calculations. Data challenges are being addressed, and additional controls are now in place to ensure this is not a repeat finding moving forward. These include new personnel...
Corrective Action: The University is actively reviewing and updating policies and procedures regarding Return to Title IV aid calculations. Data challenges are being addressed, and additional controls are now in place to ensure this is not a repeat finding moving forward. These include new personnel, additional training and system upgrades that ensure accurate and timely R2T4 processing. In addition, the University is recalculating R2T4 calculations covering this audit period as part of a separate engagement. Responsible Person: Matthew Kirksey, Financial Aid Director Completion Date: December 31, 2026
Special Tests and Provisions- Gramm-Leach-Bliley Act-Student Information System The College agrees with the finding and acknowledges the need to strengthen compliance with GLBA Safeguards Rule requirements related to student information security. Although the College already maintain Information Tec...
Special Tests and Provisions- Gramm-Leach-Bliley Act-Student Information System The College agrees with the finding and acknowledges the need to strengthen compliance with GLBA Safeguards Rule requirements related to student information security. Although the College already maintain Information Technology policies addressing many of the required safeguards, a formalized written Information Security Program specifically referencing GLBA requirements had not been fully established during the audit period. To address this finding, the College is developing a formalizing a comprehensive written ISP under the College Information Technology policies and procedures, with applicable student information confidentiality provisions also incorporated into the FAO policies and procedures. The College continues to provide training and guidance to staff regarding student information security and data protection to support ongoing compliance with federal requirements.
Special Tests and Provisions- Enrollment Reporting The College agrees with the finding; however, the issues resulted from a misunderstanding regarding the type of NSLDS documentation requested during the audit process. Enrollment reporting was completed manually through the NSLDS web portal on an in...
Special Tests and Provisions- Enrollment Reporting The College agrees with the finding; however, the issues resulted from a misunderstanding regarding the type of NSLDS documentation requested during the audit process. Enrollment reporting was completed manually through the NSLDS web portal on an individual student basis rather than through batch processing; therefore, batch files were not available to provide during fieldwork. The FAO staff has since received additional guidance and training regarding NSLDS enrollment reporting documentation and audit requirements. The FAO staff will continue participating in training opportunities to strengthen compliance and documentation practices for future audits.
Special Tests and Provisions – Disbursements to or on Behalf of Students The College agrees with the finding and acknowledges that, during the audit period, certain Title IV disbursement notification, credit balance disbursement, and ISIR review procedures were not consistently completed in accordan...
Special Tests and Provisions – Disbursements to or on Behalf of Students The College agrees with the finding and acknowledges that, during the audit period, certain Title IV disbursement notification, credit balance disbursement, and ISIR review procedures were not consistently completed in accordance with federal requirements. To address this issue, the College reviewed and updated its FAO policies and procedures related to award notifications, cash management, disbursement processing, and verification procedures. The College also implemented JFA system to improve the tracking and monitoring of student awards, disbursements, verification activities, and credit balance timelines. In addition, the implementation of FAFSA priority deadline prior to each semester provides additional time for staff to review files, complete packaging, finalize verification requirements, and issue timely award notifications before processing begins. The College also amended its internal verification policy to align with the US DOE’s verification requirements by verifying only students selected by US DOE as indication on the student’s ISIR. The College will continue monitoring these corrective actions to support ongoing compliance with Title IV requirements.
Special Tests and Provisions – Verification The College agrees with the finding and acknowledges that the Financial Aid Office policies and procedures related to FAFSA verification did not fully incorporate all required federal verification provisions during the audit period and that discrepancies e...
Special Tests and Provisions – Verification The College agrees with the finding and acknowledges that the Financial Aid Office policies and procedures related to FAFSA verification did not fully incorporate all required federal verification provisions during the audit period and that discrepancies existed between supporting verification document, verification worksheets, and certain students’ ISIR. Corrective actions have already been implemented. The College reviewed and updated the FAO verification policies and procedures to incorporate applicable federal verification requirements, including verification deadlines, required documentation, correction procedures, conflicting information resolution, applicant responsibilities, and the requirement that verification must be completed prior to professional judgement adjustments in accordance with federal regulations and FSA Handbook requirements. In addition, the College strengthened its verification review, document collection, and conflicting resolution procedures to improve the accuracy of Title IV eligibility determinations and related reporting. The implementation of Jenzabar Financial Aid (JFA) system has also improved the FAO’s ability to track, organize, and monitor verification documents and related processing activities. The College will continue monitoring these procedures to ensure ongoing compliance with federal verification requirements.
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