Corrective Action Plans

Finding 7248 (2023-001)

None 2023

HI

Student Financial Aid Reporting Matching / Level of Effort / Earmarking

Finding No. 2023-001: Financial Aid Administration – Control Deficiency Federal Agency: U.S. Department of Education AL Number and Title: 84.063P – Federal Pell Grant Program Questioned Costs: $ – Responsible Individual: Pheng Xiong, Office of the Registrar, University Registrar Nikki Chun, Div. of ...

Finding No. 2023-001: Financial Aid Administration – Control Deficiency Federal Agency: U.S. Department of Education AL Number and Title: 84.063P – Federal Pell Grant Program Questioned Costs: $ – Responsible Individual: Pheng Xiong, Office of the Registrar, University Registrar Nikki Chun, Div. of Enrollment Management, Vice Provost for Enrollment Management Date Action Taken: August 2023 The Office of the Registrar is fully aware of and takes very seriously its enrollment and degree reporting requirements and responsibilities. The finding presented in Finding No. 2023-005 happened as a result of a processing error where students in the final Spring 2023 enrollment file were not cleared out. This prevented students in the Spring 2023 degree files, submitted on June 26th and July 3rd, from having their graduation statuses updated with the National Student Clearinghouse if they were in the affected initial Summer 2023 enrollment file. The August 2nd file could not be processed because the National Student Clearinghouse was working with the office to reject the Summer enrollment and Spring 2023 degree reports. The reports had to be rejected in order for the corrected Summer 2023 file to be applied. The existing business process requires use of an SQL script. Since the script requires complicated manual steps and can lead to errors, the Office of the Registrar has been working to implement the NSC reporting functionality in the student information system. The new business process will improve enrollment and degree reporting, including the reduction of errors resulting from human error. The Office of the Registrar aims to go live with new business process with Spring 2024 enrollment reporting.

View Audit 9418

Finding 7209 (2023-001)

None 2023

Yale University

CT

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

Views of Responsible Officials and Corrective Action Plan The University acknowledges the need for consistent policies, procedures, and the application of these requirements and has already begun to put in place corrective actions to address these issues for the 2023-24 academic year. Outlined below...

Views of Responsible Officials and Corrective Action Plan The University acknowledges the need for consistent policies, procedures, and the application of these requirements and has already begun to put in place corrective actions to address these issues for the 2023-24 academic year. Outlined below are corrective actions and proposed changes to align Yale with the stated recommendations: • Verification – Implementation of a university-wide document posting process with an expected implementation date by the end of the fiscal year 2024. This process will auto-populate federally required documents into Yale’s financial aid system, based on FAFSA/ISIR comment codes, in a way that will prevent disbursement to a student’s account unless collected. Schools will receive training from the University Financial Aid Office (“UFAO”) in concurrence with the implementation of this new automated population regarding the collection of the new university-wide form and the proper acceptance of identity requirements. • Electronic Transactions – Beginning in June of 2023, all financial aid recipients, not just Federal Financial Aid recipients, are asked to complete E-Consent on the new Student Portal Yale Hub. Students cannot view award offers, electronic documents that must be completed online, or personal historical financial aid data until the E-Consent question is answered. • Return of Title IV – Creation and implementation of a university-wide Return to Title IV funds policy and procedure is currently in process. This implementation will begin before the end of calendar year 2023 and will include training of several additional Financial Aid staff members across the university on the updated policies and procedures to create redundancies for timely and consistent processing of R2T4’s. • NSLDS Enrollment Reporting – The University Registrar is working with ITS to correct the custom Banner NSC extract job to ensure that not just the enrollment status is updated, but also the program level status. An additional staff member in the registrar’s office will be deployed to focus on compliance and enrollment reporting. • Satisfactory Academic Progress (“SAP”) – The University Financial Aid Office has begun a school-by-school review of SAP policies. Review and implementation of updated SAP policies will be concluded by June 2024 schoolwide. UFAO will set up an SAP review process for new programs as well as an annual review for each school. University contact: David Blackmon, Director, Office of Student Financial Aid David.Blackmon@yale.edu

View Audit 9367

Finding 7073 (2023-001)

Significant Deficiency 2023

Southeastern Illinois College

IL

Student Financial Aid Reporting Matching / Level of Effort / Earmarking

Southeastern Illinois College will be implementing remediation steps to ensure that enrollment information is accurate in the National Student Loan Data System (NSLDS). The College’s Information Technology (IT) department will work with the Registrar in creating a process where graduates who are not...

Southeastern Illinois College will be implementing remediation steps to ensure that enrollment information is accurate in the National Student Loan Data System (NSLDS). The College’s Information Technology (IT) department will work with the Registrar in creating a process where graduates who are not originally reported as graduated can be updated to graduated status in National Student Clearinghouse (NSC)’s website. This may include making a graduates’ only submission to NSC to update those graduates whose degrees were conferred after the original submission. Also, the Student Affairs department will now review submission data and give approval prior to submission to NSC. To assist in this review, the IT department will develop a data validation report that lists students who have completed a certificate and/or degree and are no longer attending.

View Audit 9099

Finding 7062 (2023-004)

Significant Deficiency 2023

Barton County Community College

KS

Student Financial Aid Special Tests & Provisions Reporting

Federal Program Student Financial Assistance Cluster Compliance requirements Special Tests and Provisions – Enrollment Reporting Condition During testing, we identified that three of the fourteen students tested did not have an enrollment status change reported. Recommendation We recommend th...

Federal Program Student Financial Assistance Cluster Compliance requirements Special Tests and Provisions – Enrollment Reporting Condition During testing, we identified that three of the fourteen students tested did not have an enrollment status change reported. Recommendation We recommend that the College review its controls to ensure that accurate enrollment information is reported to NSLDS. Comments on the Finding Recommendation Due to requirements of the Kansas State Board of Regents, students that drop courses after a certain point in the semester are considered “W” students, and they did not have their enrollment status changed within the system. Because of this, any status changes that occurred after that given point in the semester, that did not result in the total withdrawal of a student, were not reported to NSLDS. Action Taken The College is testing potential methods to ensure that changes to students’ enrollment statuses are properly reported. These solutions have been tested in the Student Information System (Banner) in the test environment and were successful. This will be moved into production and the next reporting date of November 16th should have the updated information for reporting.

View Audit 9062

Finding 7059 (2023-003)

Significant Deficiency 2023

Barton County Community College

KS

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

Federal Program Student Financial Assistance Cluster Compliance requirements Special Tests and Provisions – Return to Title IV Condition During testing, we identified that three of the sixteen students tested had an incorrect Return to Title IV calculation on file. Recommendation We recommend t...

Federal Program Student Financial Assistance Cluster Compliance requirements Special Tests and Provisions – Return to Title IV Condition During testing, we identified that three of the sixteen students tested had an incorrect Return to Title IV calculation on file. Recommendation We recommend that the College review its controls to ensure that accurate Return to Title IV calculations are completed. Comments on the Finding Recommendation The College used seven calendar break days upon the basis that the campus was only closed for seven days for both Spring Break and Thanksgiving Break. However, it was brought to the College’s attention that break days for Return to Title IV purposes are considered all days between the last scheduled day of classes, and the first day classes resume, which would be nine calendar break days for both the Fall and Spring semesters. Action Taken As of September 11, 2023, the financial aid office has recalculated the Return to Title IV calculations for all students whose calculations utilized the incorrect number of break days. Return amounts have been corrected based upon those calculations. Staff have also undergone training regarding use of the correct calendar for students.

View Audit 9062

Finding 6925 (2023-001)

Significant Deficiency 2023

Ashland University

OH

Student Financial Aid Matching / Level of Effort / Earmarking Subrecipient Monitoring

Management concurs with the finding. The Registrar’s Office and Financial Aid Office has performed a review of its policies and procedures and has revised them accordingly to ensure timely, accurate and complete submissions to the NSLDS. The determination of the review was that the enrollment effect...

Management concurs with the finding. The Registrar’s Office and Financial Aid Office has performed a review of its policies and procedures and has revised them accordingly to ensure timely, accurate and complete submissions to the NSLDS. The determination of the review was that the enrollment effective status data field required correction in the NSLDS Enrollment History system. Since the restoration of the NSLDS system in November 2022, the Registrar’s Office and Financial Aid has corrected the data which was completed on September 13, 2023.

View Audit 8911

Finding 6667 (2023-001)

Significant Deficiency 2023

The Art Institute of Chicago

IL

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

THE ART INSTITUTE OF CHICAGO Corrective Action Plan For the Year Ended June 30, 2023 2023-001 Inadequate Control over Return of Title IV Funds- Student Financial Aid Cluster -Assistance Listing Number 84.063, 84.268, Grant Period -Year Ended June 30, 2023. Condition Found The Institution did not acc...

THE ART INSTITUTE OF CHICAGO Corrective Action Plan For the Year Ended June 30, 2023 2023-001 Inadequate Control over Return of Title IV Funds- Student Financial Aid Cluster -Assistance Listing Number 84.063, 84.268, Grant Period -Year Ended June 30, 2023. Condition Found The Institution did not accurately calculate the return of Title IV funds and return the funds in a timely manner, as required by the federal regulations. Cause The Institute did not consistently implement its internal controls to ensure that the return of Title IV funds was correctly calculated and reported in a timely manner. Corrective Action Plan The Art Institute of Chicago has updated all student accounts and returned all funds. The Student Financial Services office will implement two additional procedures to the withdrawal/R2T4 process to ensure that they are processed accurately and timely. 1. A weekly Complete Withdrawal report will be run in PeopleSoft Campus Solutions and reviewed by the Associate Director of Financial Aid Processing. The report lists all students who have fully withdrawn after the add/drop period and through the end of the semester. The Associate Director will compare the list to the R2T4s that have been completed to identify and confirm that all R2T4s have been completed timely for all withdrawn recipients of federal student aid. 2. The Director of Student Financial Services, or an appropriately trained staff person as assigned, will perform a review of all completed R2T4 forms. This review will be conducted to ensure that the calculations are correct and that the adjustments to any federal funds as determined by the R2T4 calculations have been input correctly in PeopleSoft Campus Solutions. Documentation of the review of each R2T4 from the semester will be maintained on a spreadsheet by the Director of Student Financial Services. Responsible Persons for Corrective Action Plan Patrick James, Director of Student Financial Services Sherman Lee, Associate Director of Financial Aid Processing Implementation Date of Corrective Action Plan Immediately

View Audit 8642

Finding 6444 (2023-001)

None 2023

Converse University

SC

Student Financial Aid Subrecipient Monitoring Reporting

The finding was due in part to the lack of a process to correctly backdate administrative withdrawals when a student is awarded a grade of W after the stated date. This resulted in inconsistent dates reported to NSLDS and in the academic file. Management has met to address this issue. The Offices...

The finding was due in part to the lack of a process to correctly backdate administrative withdrawals when a student is awarded a grade of W after the stated date. This resulted in inconsistent dates reported to NSLDS and in the academic file. Management has met to address this issue. The Offices of Campus Technology, Financial Planning and Registrar have met to discuss processes in place and create new methods by which administrative withdrawals will be handled going forward. Additionally, management is working with Jenzabar to ensure the dates are consistent with the withdrawal option, specifically the awarding of W grades and the related date of last attendance. This process will assist the University in the following ways: students will be reported on the NSLDS report in the appropriate timeframe, a uniform withdrawal date will be recorded in the Offices of the Registrar and Financial Planning and students receive the appropriate grade as indicated by the official academic calendar. This action has been implemented for the final grading period ending on Monday, December 11, 2023. Management will continue to submit enrollment reports to the NSLDS on the schedule submitted annually, ensuring that any changes to student enrollment will be reported as required. The corrective action plan will be undertaken by the Office of the Registrar, under the supervision of the University Registrar and Director of Institutional Research and Effectiveness, Kendra Woodson (Kendra.woodson@converse.edu).

View Audit 8384

Finding 6373 (2023-002)

Material Weakness 2023

King's College

PA

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

Views of Responsible Officials and Planned Corrective Actions: The College agrees with the finding. The College had internally identified the failure to send the required notifications in January 2023 and took corrective action to create new processes and made system adjustments effective for the fa...

Views of Responsible Officials and Planned Corrective Actions: The College agrees with the finding. The College had internally identified the failure to send the required notifications in January 2023 and took corrective action to create new processes and made system adjustments effective for the fall 2023 semester. All required notifications were made for fall 2023 disbursements. The College is evaluating alternate notification processes to improve efficiencies and ensure completeness. Names of Contact Persons Responsible for Corrective Action: Barbara Schmitt, Director of Financial Aid Anticipated Completion Date: Changes were effective for the fall 2023 semester

View Audit 8234

Finding 6372 (2023-001)

None 2023

King's College

PA

Special Tests & Provisions Student Financial Aid Subrecipient Monitoring

Views of Responsible Officials and Planned Corrective Actions: The College agrees with the finding. The Associate Director of Financial Aid is responsible for calculating Return of Title IV (R2T4) refunds for all students who withdraw from the College within the first 60% of the payment period using...

Views of Responsible Officials and Planned Corrective Actions: The College agrees with the finding. The Associate Director of Financial Aid is responsible for calculating Return of Title IV (R2T4) refunds for all students who withdraw from the College within the first 60% of the payment period using the Colleague software R2T4 module for calculating refunds. The Director of Financial Aid will provide a secondary review of all calculated R2T4 refunds before funds are returned to the Common Origination and Disbursement system. Names of Contact Persons Responsible for Corrective Action: Barbara Schmitt, Director of Financial Aid Anticipated Completion Date: Changes were effective for the fall 2023 semester

View Audit 8234

Finding 6236 (2023-001)

None 2023

Yeshiva University

NY

Student Financial Aid Eligibility Reporting

Management Views and Corrective Action Plans 2023-001 – Inaccurate Submission of Student Enrollment Change Submissions to the National Student Loan Data System (NSLDS) Point of Contact – Jennifer Spiegel Goldberg, University Registrar, (646-592-6275) Management agrees with the current year finding a...

Management Views and Corrective Action Plans 2023-001 – Inaccurate Submission of Student Enrollment Change Submissions to the National Student Loan Data System (NSLDS) Point of Contact – Jennifer Spiegel Goldberg, University Registrar, (646-592-6275) Management agrees with the current year finding and the recommendations. The Office of the Registrar has recently been reorganized to create a dedicated, Records unit to assure that limited personnel will be responsible for leaves and withdrawals and who will use internal reports available to quality control data input before external reporting. All staff have been retrained to watch for the condition that led to this error when handling requests, including reminder of University policies and procedures. This retraining took place on September 6, 2023. The NSC Roster and NSLDS will be updated by December 29, 2023. We believe this finding will be remediated in fiscal 2024.

View Audit 8211

Finding 6099 (2023-002)

Significant Deficiency 2023

Columbia International University and Subsidiaries

SC

Student Financial Aid Reporting Significant Deficiency

Inaccurate and Untimely Returns of Title IV Funds (R2T4) Planned Corrective Action: In conjunction with the Registrar’s Office, we have implemented the following corrective actions to improve our processes/timeframe for withdrawals: 1) This summer, the Financial Aid Office was added to the workfl...

Inaccurate and Untimely Returns of Title IV Funds (R2T4) Planned Corrective Action: In conjunction with the Registrar’s Office, we have implemented the following corrective actions to improve our processes/timeframe for withdrawals: 1) This summer, the Financial Aid Office was added to the workflow in Etrieve (document management system used by CIU) so that 2 of our counselors (one for UG trad and one for online) now receive notifications directly of every withdrawal received by the Registrar’s Office. This allows our office to begin the process of returning funds without the reliance of emails forwarded from the Registrar’s Office. 2) Director and Associate Directors of Financial Aid met with the Registrar and Assistant Registrar on 10/31/23 to discuss how communication and processes could improve between offices. The following are several action items the Registrar will complete on their end that can assist in accomplishing this goal. • Registrar will ask Deans to explain to their faculty that when a student completes an assignment after their module is complete, the date to be entered must be the last date of that module so that our reports will capture the date needed for the return to process correctly. • Registrar will review their current procedures for processing official withdrawals and tighten their turn around time so that the Financial Aid Office can return aid within the required 45 days. 3) CIU made the decision to convert all 5-week UG online classes to 8-week classes starting the 23-24 academic year. These modules now fall within our standard academic calendar which should greatly improve our ability to monitor and process withdrawals for this student population. Person Responsible for Corrective Action Plan: Patty Hix, Director of Financial Aid; Lynsay Shumpert, Associate Director for Online Studies; Elizabeth Haselden, Registrar Anticipated Date of Completion: A follow-up meeting has been set before the end of fall semester to discuss the progress of our action plans with the Registrar.

View Audit 7973

Finding 5786 (2023-004)

None 2023

Simpson University

CO

Student Financial Aid

Inaccurate Pell Calculations Planned Corrective Action: The University recognized that this was an isolated concern based on the late notification from the Department of Education on Pell Grant Awards for the 2022-23 award year. System updates and 20 hours of system training have been scheduled and/...

Inaccurate Pell Calculations Planned Corrective Action: The University recognized that this was an isolated concern based on the late notification from the Department of Education on Pell Grant Awards for the 2022-23 award year. System updates and 20 hours of system training have been scheduled and/or implemented to prevent this from reoccurring. Person Responsible for Corrective Action Plan: Shondra Dickson, Director of Financial Aid Anticipated Date of Completion: April 2024

View Audit 7877

Finding 5784 (2023-002)

Significant Deficiency 2023

Simpson University

CO

Student Financial Aid Allowable Costs / Cost Principles Significant Deficiency

Need Analysis Planned Corrective Action: The University recognizes the federal regulations regarding over‐awarding and has implemented the use of a delivered report through the Student Information System to address this concern. Person Responsible for Corrective Action Plan: Shondra Dickson, Direc...

Need Analysis Planned Corrective Action: The University recognizes the federal regulations regarding over‐awarding and has implemented the use of a delivered report through the Student Information System to address this concern. Person Responsible for Corrective Action Plan: Shondra Dickson, Director of Financial Aid Anticipated Date of Completion: Implemented

View Audit 7877

Finding 5746 (2023-005)

Significant Deficiency 2023

Sterling College

KS

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

Finding 2023-005: Reporting of disbursement dates to the Common Origination and Disbursement system Contact person responsible for correction action – Mitzi Suhler, Vice President of Enrollment Services Anticipated completion date – June 30, 2023 Corrective action Sterling College agrees with t...

Finding 2023-005: Reporting of disbursement dates to the Common Origination and Disbursement system Contact person responsible for correction action – Mitzi Suhler, Vice President of Enrollment Services Anticipated completion date – June 30, 2023 Corrective action Sterling College agrees with the finding regarding the disbursement dates of two students who were reported incorrectly to the COD system. We will provide continued training to those who are responsible for compliance of reporting accurate disbursement dates. We will review processes and internal controls and make any necessary changes to prevent and/or detect issues so that they can be corrected in a timely manner.

View Audit 7826

Finding 5745 (2023-004)

Material Weakness 2023

Sterling College

KS

Reporting Student Financial Aid Subrecipient Monitoring

Finding 2023-004: Quarterly Reporting of Emergency Financial Aid Grants to Students and Annual Reporting for COVID-19 Education Stabilization Fund Contact person responsible for correction action – Mitzi Suhler, Vice President of Enrollment Services Anticipated completion date – June 30, 2023 Co...

Finding 2023-004: Quarterly Reporting of Emergency Financial Aid Grants to Students and Annual Reporting for COVID-19 Education Stabilization Fund Contact person responsible for correction action – Mitzi Suhler, Vice President of Enrollment Services Anticipated completion date – June 30, 2023 Corrective action Sterling College agrees with the finding of not meeting the posting deadline for the quarterly reports for March 31, 2023, and June 30, 2023. The reports were posted within the required month but did not meet the ten-day limit for posting. Sterling College recognizes the importance of meeting reporting requirements for all federal programs and if any additional programs were to arise that are similar in nature, we will review the compliance requirements, and prior findings, to ensure proper processes are in place to ensure compliance in reporting are met.

View Audit 7826

Finding 5743 (2023-002)

Material Weakness 2023

Sterling College

KS

Questioned Costs Student Financial Aid Eligibility

Contact person responsible for correction action – Mitzi Suhler, Financial Aid Director Anticipated completion date – June 30, 2023 Corrective action Sterling College agrees with the finding of the under award and over award of federal aid for two students. During the 2022-2023 year we hired new ...

Contact person responsible for correction action – Mitzi Suhler, Financial Aid Director Anticipated completion date – June 30, 2023 Corrective action Sterling College agrees with the finding of the under award and over award of federal aid for two students. During the 2022-2023 year we hired new financial aid staff that required significant training in the regulations of financial aid. Although checks and balances were in place these two instances were overlooked. Continued training, along with improved checks and balances through our updated software system, will enable the financial aid office to avoid issues with under and over-awarding federal student aid. The office will perform periodic reviews of awarding through reports from the system that will flag students who have potentially been under or over awarded federal aid.

View Audit 7826 Questioned Costs: $1

Finding 5742 (2023-001)

Material Weakness 2023

Sterling College

KS

Student Financial Aid Reporting Material Weakness

Finding 2023-001: Enrollment Reporting Contact person responsible for correction action – Mitzi Suhler, Financial Aid Director Anticipated completion date – June 30, 2023 Corrective action Sterling College agrees with the finding. A review of enrollment reporting is being done at the end of each...

Finding 2023-001: Enrollment Reporting Contact person responsible for correction action – Mitzi Suhler, Financial Aid Director Anticipated completion date – June 30, 2023 Corrective action Sterling College agrees with the finding. A review of enrollment reporting is being done at the end of each semester with particular attention being paid to students who have withdrawn during the semester or graduated at the end of the term. Along with reviewing those students, a random list of students that are not a part of the withdrawal or graduation list are being chosen for review, and if no student enrollment is found to be reported inaccurate, no further review is required per our policy. We feel that there are some changes soon that will help us with our enrollment reporting. One of them is that Sterling College is implementing a new version of our software system, Jenzabar, in 2024. This system will have better checks and balances for enrollment reporting, cleaner data, and will enable the College to have more accurate reporting. There will still be a need to do a review of each semester’s enrollment reporting. The financial aid office will review all student enrollment records that are enrolled for the semester to ensure the reporting dates are correct from this point forward. Once we have confidence that the system is doing what is expected, we will adjust the review to a random list of students.

View Audit 7826

Finding 5741 (2023-001)

Material Weakness 2023

Deliverance Manor Housing Corporation

IL

Questioned Costs Student Financial Aid Cash Management

CORRECTIVE ACTION PLAN Finding No. 2023-01: Credit Card was not reconciled and receipts were not obtained. Expenses were not properly recorded in the general ledger. Recommendation: Management should reconcile credit card accounts monthly and secure receipts for purchases and expenses should be post...

CORRECTIVE ACTION PLAN Finding No. 2023-01: Credit Card was not reconciled and receipts were not obtained. Expenses were not properly recorded in the general ledger. Recommendation: Management should reconcile credit card accounts monthly and secure receipts for purchases and expenses should be posted to the proper general ledger account. Action Taken or Planned: Credit card accounts will be reconciled and receipts will be requested for purchases. Accounting will review the nature of purchases and properly post to the general ledger. Responsible Person: Mary Amador, Property Manager Completion Date: October 31, 2023

View Audit 7824 Questioned Costs: $1

Finding 5737 (2023-002)

None 2023

Marietta College

OH

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

The College will examine the document destruction date on student related files related to federal compliance requirements to ensure accuracy of the document destruction date and accuracy of student files.

View Audit 7807

Finding 5702 (2023-001)

Significant Deficiency 2023

Quinnipiac University

CT

Procurement, Suspension & Debarment Student Financial Aid Cash Management

Uniform Guidance Corrective Action Plan Year ended June 30, 2023 Federal Finding #2023-001 Returns of Title IV funds are required to be deposited or transferred into the student financial assistance account or electronic fund transfers initiated to the Department of Education as soon as possible, bu...

Uniform Guidance Corrective Action Plan Year ended June 30, 2023 Federal Finding #2023-001 Returns of Title IV funds are required to be deposited or transferred into the student financial assistance account or electronic fund transfers initiated to the Department of Education as soon as possible, but no later than 45 days after the date the institution determines the student withdrew. Quinnipiac University agrees with the finding. For one student who withdrew during the 2022 – 2023 academic year, the Pell funds awarded to that student were not returned to the student financial assistance account within 45 days after the University determined the student withdrew. As a result of this finding, Management has implemented additional steps within the reconciliation process of Title IV awards in order to prioritize the return of any unearned Title IV awards so that they are remitted to the student financial assistance account in a timely manner. If the Office of Management and Budget have questions regarding this plan, please reach out to Stephen Allegretto, the Associate Vice President for Finance and Controller, who is responsible for ensuring this corrective action plan is implemented, at 203-582-7962.

View Audit 7701

Finding 5693 (2023-001)

Significant Deficiency 2023

Buena Vista University

IA

Student Financial Aid Reporting Matching / Level of Effort / Earmarking

2023 Corrective Action Plan Finding Reference Number 2023-001 Contact person - Stephanie Wilhelm, Registrar Cause - Management oversite during a status update report submission Current Status - All student enrollment statuses from spring 2023 semester has been reviewed and corrected as needed. All s...

2023 Corrective Action Plan Finding Reference Number 2023-001 Contact person - Stephanie Wilhelm, Registrar Cause - Management oversite during a status update report submission Current Status - All student enrollment statuses from spring 2023 semester has been reviewed and corrected as needed. All students that graduate at mid semester will be reviewed individually to ensure that they are not re-reported as enrolled after degree completion. We have also updated our conferring process to add a status flag to ensure the graduated status is sent to NSC-NSLDS for updates. For those students that begin our graduate program immediately after completing the undergraduate program, they will be managed individually for reporting mid-stream until the new term begins. Views of Responsible Officials and Planned Corrective Action - the software cause of the re-reportig of graduated students as enrolled has not been determined. All mid-term graduate prior to March 2023 worked correctly and those that graduated July 2023 all worked correctly. Reports have been created for mid-term graduates and students begining another program immediately after degree completion. Anticipated Completion Date - Already completed and ongoing.

View Audit 7684

Finding 5661 (2023-001)

Significant Deficiency 2023

Immaculata University

PA

Questioned Costs Student Financial Aid Significant Deficiency

Department of Education Immaculata University respectfully submits the following corrective action plan for the year ended June 30, 2023. Audit period: July 01, 2022 - June 30, 2023 The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consist...

Department of Education Immaculata University respectfully submits the following corrective action plan for the year ended June 30, 2023. Audit period: July 01, 2022 - June 30, 2023 The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. FINDINGS—FINANCIAL STATEMENT AUDIT No findings over financial statement audit. FINDINGS—FEDERAL AWARD PROGRAMS AUDITS Department of Education 2023-001 Student Financial Assistance Cluster – Federal Assistance Numbers 84.007, 84.063, 84.268 Recommendation: We recommend the University develop a process to ensure that all Title IV outstanding checks are returned back to the ED within the required timeframe and verify on a regular basis the process has been followed. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The University had an established monthly process for returning Title IV outstanding checks to the Department of Education. During the months of January, 2023 and May, 2023, the University did not follow this established monthly process. Beginning in August, 2023, the University began scheduling monthly meetings to ensure all Title IV outstanding checks are returned to the Department of Education within the required timeframe. Name(s) of the contact person(s) responsible for corrective action: Joanne Cristinzio Planned completion date for corrective action plan: August 15, 2023 If the Department of Education has questions regarding this plan, please call Joanne Cristinzio at 484- 323-3067.

View Audit 7583 Questioned Costs: $1

Finding 5649 (2023-001)

Significant Deficiency 2023

Dordt University, Inc.

IA

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

Finding 2023-001 - Special Tests and Provisions – Gramm-Leach-Bliley Act Responsible Individuals – Director of Computer Services and Vice President for Finance & Risk Management. Finding Summary: During testing of Gramm-Leach-Bliley Act and inquiry with management, it was determined that the Univ...

Finding 2023-001 - Special Tests and Provisions – Gramm-Leach-Bliley Act Responsible Individuals – Director of Computer Services and Vice President for Finance & Risk Management. Finding Summary: During testing of Gramm-Leach-Bliley Act and inquiry with management, it was determined that the University does not have a written comprehensive information security program in place. Corrective Action Planned: Dordt will be working with an external organization familiar with the policy requirements of the Gramm-Leach-Bliley Act to take existing procedures and incorporate them into a formal written information security policy that addresses the key areas of the Gramm-Leach-Bliley Act. Anticipated Completion Date: June 30, 2024.

View Audit 7569

Finding 5644 (2023-002)

Significant Deficiency 2023

Saint Martin's University

WA

Internal Control / Segregation of Duties Student Financial Aid Significant Deficiency

Action taken: Saint Martin’s University will review the requirements of 16 CFR 314.4, update our written policy to ensure that it addresses all the required elements 16 CFR 314.3(b), and perform an annual review of our updated policy to ensure that it continues to comply with all relevant regulation...

Action taken: Saint Martin’s University will review the requirements of 16 CFR 314.4, update our written policy to ensure that it addresses all the required elements 16 CFR 314.3(b), and perform an annual review of our updated policy to ensure that it continues to comply with all relevant regulations. The University is currently in the process of formally adopting a cybersecurity framework as well as securing a vendor to perform an IT security assessment. This ongoing work in the interest of the security, confidentiality, and integrity of student information will position us well to make the recommended updates to our policy Name of Responsible Party: Mary Donahoo, Chief Information Officer Anticipated completion date: 3/31/2024

View Audit 7568

Corrective Action Plans

Filters