Corrective Action Plans

Finding 529876 (2023-003)

Significant Deficiency 2023

Manor College

PA

Student Financial Aid Reporting Significant Deficiency

In conjunction with the overall implementation and enhancement of financial processes and procedures to enhance financial reporting, the month-end reporting process will ensure that the financial aid and financial accounting systems are reconciled. The monthly reconciliation process and a review pro...

In conjunction with the overall implementation and enhancement of financial processes and procedures to enhance financial reporting, the month-end reporting process will ensure that the financial aid and financial accounting systems are reconciled. The monthly reconciliation process and a review process by proper Manor personnel prior to submission of the FISAP will minimize the risk of errors in the FISAP report and will assist tracking of student financial aid for each respective student receiving financial aid.

View Audit 347913

Finding 528850 (2023-009)

Material Weakness 2023

Iliff School of Theology

CO

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

Condition: The School does not have evidence that exit counseling was provided to students who withdrew or graduated as required by 34 CFR 682.604. Planned Corrective Action: The Iliff School of Theology has contracted with a professional, third-party processing company to administer its student ai...

Condition: The School does not have evidence that exit counseling was provided to students who withdrew or graduated as required by 34 CFR 682.604. Planned Corrective Action: The Iliff School of Theology has contracted with a professional, third-party processing company to administer its student aid programs. The school has also ensured that this third-party processor is properly coordinated with the registrar’s office to meet federal requirements for exit counseling when status changes are processed. Contact person responsible for corrective action: Jason Warr, VP for Business, Controller Anticipated Completion Date: May 2024

View Audit 346899

Finding 528848 (2023-007)

Material Weakness 2023

Iliff School of Theology

CO

Questioned Costs Student Financial Aid Material Weakness

Condition: The School does not have a documented Direct Loan quality assurance program. Planned Corrective Action: The Iliff School of Theology has contracted with a professional, third-party processing company to administer its student aid programs. The school will coordinate with this third-party...

Condition: The School does not have a documented Direct Loan quality assurance program. Planned Corrective Action: The Iliff School of Theology has contracted with a professional, third-party processing company to administer its student aid programs. The school will coordinate with this third-party processor to ensure that there is a documented quality assurance program that is regularly exercised for compliance purposes. All documentation will be maintained. Contact person responsible for corrective action: Jason Warr, VP for Business, Controller Anticipated Completion Date: May 2024

View Audit 346899

Finding 528847 (2023-006)

Material Weakness 2023

Iliff School of Theology

CO

Questioned Costs Student Financial Aid Material Weakness

Condition: Our audit procedures identified an instance where the School could not locate evidence that the required R2T4 calculation under federal regulation was completed and another instance whereas the calculation was inaccurate. Planned Corrective Action: The Iliff School of Theology has contr...

Condition: Our audit procedures identified an instance where the School could not locate evidence that the required R2T4 calculation under federal regulation was completed and another instance whereas the calculation was inaccurate. Planned Corrective Action: The Iliff School of Theology has contracted with a professional, third-party processing company to administer its student aid programs. This third-party processor is adequately skilled to complete Return of Title IV calculations and includes an established review process for quality control. All documentation will be maintained. Contact person responsible for corrective action: Jason Warr, VP for Business, Controller Anticipated Completion Date: May 2024

View Audit 346899 Questioned Costs: $1

Finding 528846 (2023-005)

Material Weakness 2023

Iliff School of Theology

CO

Questioned Costs Student Financial Aid Material Weakness

Condition: The School does not reconcile institutional records with Direct Loan funds received from the Secretary of the U.S. Department of Education and the Direct Loan disbursement records submitted to and accepted by the Secretary of the U.S. Department of Education. Planned Corrective Action: T...

Condition: The School does not reconcile institutional records with Direct Loan funds received from the Secretary of the U.S. Department of Education and the Direct Loan disbursement records submitted to and accepted by the Secretary of the U.S. Department of Education. Planned Corrective Action: The Iliff School of Theology has contracted with a professional, third-party processing company to administer its student aid programs who will ensure that direct loan reconciliations are conducted on a monthly basis in coordination with the business office. Contact person responsible for corrective action: Jason Warr, VP for Business, Controller Anticipated Completion Date: May 2024

View Audit 346899

Finding 528843 (2023-002)

Material Weakness 2023

Iliff School of Theology

CO

Student Financial Aid Reporting Material Weakness

Condition: Our audit procedures identified instances of inaccurate or untimely reporting of enrollment information to NSLDS. Planned Corrective Action: The Iliff School of Theology has contracted with a professional, third-party processing company to administer its student aid programs. The school ...

Condition: Our audit procedures identified instances of inaccurate or untimely reporting of enrollment information to NSLDS. Planned Corrective Action: The Iliff School of Theology has contracted with a professional, third-party processing company to administer its student aid programs. The school has also ensured that this third-party processor is properly coordinated with the registrar’s office to meet federal requirements for NSLDS enrollment reporting. Contact person responsible for corrective action: Jason Warr, VP for Business, Controller Anticipated Completion Date: May 2024

View Audit 346899

Finding 528840 (2023-004)

Material Weakness 2023

Iliff School of Theology

CO

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

Condition: The School submitted a FISAP to the U.S. Department of Education that reported inaccurate information in several data fields within the report. In addition, there was no evidence that an individual other than the preparer reviewed the report. Planned Corrective Action: The Iliff School o...

Condition: The School submitted a FISAP to the U.S. Department of Education that reported inaccurate information in several data fields within the report. In addition, there was no evidence that an individual other than the preparer reviewed the report. Planned Corrective Action: The Iliff School of Theology has contracted with a professional, third-party processing company to administer its student aid programs. Preparation and submission of the FISAP will be completed with coordination between the VP of Business and the third-party processor. This includes a quality review process for accuracy. Contact person responsible for corrective action: Jason Warr, VP for Business, Controller Anticipated Completion Date: May 2024

View Audit 346899

Finding 528839 (2023-003)

Material Weakness 2023

Iliff School of Theology

CO

Questioned Costs Student Financial Aid Material Weakness

Condition: Due to the limited number of personnel within the Financial Aid Department, the director of financial aid is solely responsible for packaging, awarding, and disbursing to student accounts Federal Student Financial Aid (Title IV) as well as calculating return of Title IV funds for students...

Condition: Due to the limited number of personnel within the Financial Aid Department, the director of financial aid is solely responsible for packaging, awarding, and disbursing to student accounts Federal Student Financial Aid (Title IV) as well as calculating return of Title IV funds for students who withdraw from the School to student accounts. The packaging of Title IV aid and the return of Title IV funds are complex calculations that are not formally reviewed by another employee. Planned Corrective Action: The Iliff School of Theology has contracted with a professional, third-party processing company to administer its student aid programs. This third-party processing company is structured to properly segregate financial processing and includes a quality review function. Contact person responsible for corrective action: Jason Warr, VP for Business, Controller Anticipated Completion Date: May 2024

View Audit 346899

Finding 522899 (2023-002)

Significant Deficiency 2023

Clarkson University

NY

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

Management accepts this finding and notes that loan disbursement notifications are automatically sent to students (we mail notifications to parents and have copies of those saved). There was a glitch in the system that was discovered while going through the audit that occurred on 2 dates in 2023 (Ma...

Management accepts this finding and notes that loan disbursement notifications are automatically sent to students (we mail notifications to parents and have copies of those saved). There was a glitch in the system that was discovered while going through the audit that occurred on 2 dates in 2023 (May 31, 2023 and September 3, 2023) which has since been fixed. Financial Aid worked with the Office of Information Technology to develop a daily report that will notify the Director of Financial Aid of anyone that did not receive a notification.

View Audit 342222

Finding 522452 (2023-011)

Material Weakness 2023

Arkansas Baptist College

AR

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

Management concurs with this finding. The College will adhere to its policies, procedures, processes, and federal guidelines as it relates to disbursing loans within aggregate loan limits. Responsible Administrators: Director of Financial Aid Effective: Immediately and ongoing

View Audit 341725

Finding 522445 (2023-010)

Material Weakness 2023

Arkansas Baptist College

AR

Questioned Costs Student Financial Aid Subrecipient Monitoring § 200.512

Management concurs with this finding. The College will adhere to its policies, procedures, processes, and federal guidelines as it relates to competing and submitting the audit. The College has a new CFO and Controller. These measures will ensure stability and a timely audit. Responsible Administ...

Management concurs with this finding. The College will adhere to its policies, procedures, processes, and federal guidelines as it relates to competing and submitting the audit. The College has a new CFO and Controller. These measures will ensure stability and a timely audit. Responsible Administrators: Director of Financial Aid & Chief Financial Officer Effective immediately and ongoing

View Audit 341725

Finding 522444 (2023-009)

Material Weakness 2023

Arkansas Baptist College

AR

Student Financial Aid Eligibility Questioned Costs

Management concurs with this finding. The College will adhere to its policies, procedures, processes, and federal guidelines as it relates to calculating and awarding Pell. The College will return any ineligible funds accordingly. Responsible Administrators: Director of Financial Aid & Chief Fin...

Management concurs with this finding. The College will adhere to its policies, procedures, processes, and federal guidelines as it relates to calculating and awarding Pell. The College will return any ineligible funds accordingly. Responsible Administrators: Director of Financial Aid & Chief Financial Officer Effective: Immediately and ongoing

View Audit 341725 Questioned Costs: $1

Finding 522442 (2023-008)

Material Weakness 2023

Arkansas Baptist College

AR

Questioned Costs Student Financial Aid Eligibility

Management concurs with this finding. The College will adhere to its policies, procedures, processes, and federal guidelines as it relates to over awarding students. The College will return any ineligible funds accordingly. Responsible Administrators: Director of Financial Aid & Chief Financial ...

Management concurs with this finding. The College will adhere to its policies, procedures, processes, and federal guidelines as it relates to over awarding students. The College will return any ineligible funds accordingly. Responsible Administrators: Director of Financial Aid & Chief Financial Officer Effective: Immediately and ongoing

View Audit 341725 Questioned Costs: $1

Finding 522440 (2023-007)

Material Weakness 2023

Arkansas Baptist College

AR

Questioned Costs Student Financial Aid Procurement, Suspension & Debarment

Management concurs with this finding. The College will review and adhere to its practices, policies, and procedures along with federal guidelines as it relates to students meeting satisfactory academic progress. The College has an SAP appeal committee in place to enforce and abide by the College's...

Management concurs with this finding. The College will review and adhere to its practices, policies, and procedures along with federal guidelines as it relates to students meeting satisfactory academic progress. The College has an SAP appeal committee in place to enforce and abide by the College's policy. The College will return any ineligible funds accordingly. Responsible Administrators: Director of Financial Aid Effective: Immediately and ongoing

View Audit 341725 Questioned Costs: $1

Finding 522439 (2023-006)

Material Weakness 2023

Arkansas Baptist College

AR

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

Management concurs with this finding. The College will review and adhere to its practices, policies, and procedures along with federal guidelines as it relates to disbursing and administering federal aid. The College will return any ineligible funds accordingly. Responsible Administrators: Direct...

Management concurs with this finding. The College will review and adhere to its practices, policies, and procedures along with federal guidelines as it relates to disbursing and administering federal aid. The College will return any ineligible funds accordingly. Responsible Administrators: Director of Financial Aid, Chief Financial Officer & V.P. of Academic Affairs Effective: Immediately and ongoing

View Audit 341725 Questioned Costs: $1

Finding 522438 (2023-005)

Material Weakness 2023

Arkansas Baptist College

AR

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

Management concurs with this finding. The College will set policies, procedures and practices in place and adhere to ensure that changes in students’ enrollment are reported accurately and timely as defined in the Federal guidelines. Responsible Administrators: Director of Financial Aid & Regist...

Management concurs with this finding. The College will set policies, procedures and practices in place and adhere to ensure that changes in students’ enrollment are reported accurately and timely as defined in the Federal guidelines. Responsible Administrators: Director of Financial Aid & Registrar Effective: Immediately and ongoing

View Audit 341725

Finding 522436 (2023-004)

Material Weakness 2023

Arkansas Baptist College

AR

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

Management concurs with this finding. The College will review and adhere to its practices, policies, and procedures along with federal regulations as it relates to resolving credit balances. The College will resolve credit balances timely and within the 14-day period as defined in the Federal guid...

Management concurs with this finding. The College will review and adhere to its practices, policies, and procedures along with federal regulations as it relates to resolving credit balances. The College will resolve credit balances timely and within the 14-day period as defined in the Federal guidelines. Responsible Administrators: Director of Financial Aid & Chief Financial Officer Effective: Immediately and ongoing

View Audit 341725

Finding 522434 (2023-003)

Material Weakness 2023

Arkansas Baptist College

AR

Student Financial Aid Reporting Matching / Level of Effort / Earmarking

Management concurs with this finding. The College will ensure the accuracy of the data that is input into the COD system and the College will work to apply funds appropriately to students' accounts. The College will review and adhere to its practices, policies, and procedures along with federal gu...

Management concurs with this finding. The College will ensure the accuracy of the data that is input into the COD system and the College will work to apply funds appropriately to students' accounts. The College will review and adhere to its practices, policies, and procedures along with federal guidelines as it relates to managing the COD system. Responsible Administrators: Director of Financial Aid & Chief Financial Officer Effective: Immediately and ongoing

View Audit 341725

Finding 522432 (2023-002)

Material Weakness 2023

Arkansas Baptist College

AR

Questioned Costs Student Financial Aid Eligibility

Management concurs with this finding. The College will keep accurate attendance and participation records. The College will calculate R2T4s accurately and will return the funds in a timely manner. The College will review and adhere to its practices, policies, and procedures along with federal gui...

Management concurs with this finding. The College will keep accurate attendance and participation records. The College will calculate R2T4s accurately and will return the funds in a timely manner. The College will review and adhere to its practices, policies, and procedures along with federal guidelines as it relates to R2T4 regulations. The College will return any ineligible funds accordingly. Responsible Administrators: Director of Financial Aid & Chief Financial Officer Effective: Immediately and ongoing

View Audit 341725 Questioned Costs: $1

Finding 520695 (2023-001)

Significant Deficiency 2023

Fairfield University

CT

Student Financial Aid Special Tests & Provisions Reporting

Finding No. 2023-001 – Significant Deficiency and Noncompliance: Special Tests and Provisions – Enrollment Reporting Corrective Action The corrective action that will be taken is a graduates only enrollment report will be supplied to the National Student Clearinghouse (NSC) by the Registrar’s Offi...

Finding No. 2023-001 – Significant Deficiency and Noncompliance: Special Tests and Provisions – Enrollment Reporting Corrective Action The corrective action that will be taken is a graduates only enrollment report will be supplied to the National Student Clearinghouse (NSC) by the Registrar’s Office on a consistent schedule of submission within 60 days of each graduation period. Persons Responsible for Corrective Action The corrective action plan will be completed by Walter Rankin, Vice Provost for Graduate Continuing and Professional Studies and Danielle Quilligan, University Registrar. Completion Date Initial corrective action was completed by Lynn Kohrn, University Registrar and Allison Henderson, Assistant Registrar in October, 2023 with the submission of a graduates only enrollment report to the third-party service provider NSC. A schedule for consistent submissions of a graduates only enrollment report has already been provided to the NSC.

View Audit 340417

Finding 520251 (2023-004)

Material Weakness 2023

Briar Cliff University

IA

Student Financial Aid Matching / Level of Effort / Earmarking Reporting

Management’s Response: Briar Cliff will work with Ellucian on a review of the setup and processes that the Registrar’s Office currently follows, and we will work with Ellucian for recommendations on implementing a process/procedure that ensures the Registrar’s Office has been trailed and is in comp...

Management’s Response: Briar Cliff will work with Ellucian on a review of the setup and processes that the Registrar’s Office currently follows, and we will work with Ellucian for recommendations on implementing a process/procedure that ensures the Registrar’s Office has been trailed and is in compliance.

View Audit 339885

Finding 518136 (2023-004)

Material Weakness 2023

Contemporary Oriental Medicine Foundation

FL

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

Finding 2023-004: Annual Security Report and Campus Crime Awareness Requirements Not Met Comments on Finding and Recommendations: The College agrees with this finding as determined in the audit, and states that the College had failed to provide clear evidence that it had gathered the correct data fr...

Finding 2023-004: Annual Security Report and Campus Crime Awareness Requirements Not Met Comments on Finding and Recommendations: The College agrees with this finding as determined in the audit, and states that the College had failed to provide clear evidence that it had gathered the correct data from the local authorities, however, the College had not confirmed that the document was readily available to all students and prospective students upon the completion of the Annual Security Report on October 3, 2024. Actions Taken or Planned: The College has published the 2024 Annual Security Report on the web page as identified here. Disclosures – Dragon Rises College of Oriental Medicine The 2022 statistics for the Gainesville FL location have been provided to all students, and the College will be completing the required updates for the 2023 statistics and incorporating the findings into an updated Annual Security Report for publications in April of 2025. Name: Dr. Dorian G. Kramer DACM Title: Director Telephone: (941)-289-2456 Email: dkramer@dragonrises.edu

View Audit 336438

Finding 518135 (2023-003)

Material Weakness 2023

Contemporary Oriental Medicine Foundation

FL

Special Tests & Provisions Student Financial Aid Subrecipient Monitoring

Finding 2023-003: Failure to Meet the Standards for Safeguarding Customer Information Comments on Finding and Recommendations: The College agrees with this finding as determined in the audit and states that the College has complied with the requirement. Actions Taken or Planned: Dragon Rises Colleg...

Finding 2023-003: Failure to Meet the Standards for Safeguarding Customer Information Comments on Finding and Recommendations: The College agrees with this finding as determined in the audit and states that the College has complied with the requirement. Actions Taken or Planned: Dragon Rises College of Oriental Medicine has completed the requirements and published the Information Security Program Compliance with Gramm-Leach-Bliley Act (GLBA). The College is committed to the preservation and security of personal data and is dedicated to adhering to regulations pertaining to the safeguarding of personal, sensitive, and other protected data within its purview. Name: Dr. Dorian G. Kramer DACM Title: Director Telephone: (941)-289-2456 Email: dkramer@dragonrises.edu

View Audit 336438

Finding 518134 (2023-002)

Material Weakness 2023

Contemporary Oriental Medicine Foundation

FL

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

Finding 2023-002: Financial Responsibility Comments on Finding and Recommendation: The College agrees with this finding as determined in the audit and states that the College had a net reduction in student enrollments and had incurred additional expenses as it operated at two separate locations with...

Finding 2023-002: Financial Responsibility Comments on Finding and Recommendation: The College agrees with this finding as determined in the audit and states that the College had a net reduction in student enrollments and had incurred additional expenses as it operated at two separate locations within Florida. The College incurred additional losses in tuition revenue and services revenue as it restructured how to operate both locations appropriately during 2023. The College had additional interest expense in 2023 during the restructuring of the administration and the facilities of the College. Actions Taken or Planned: The College acted in 2024 to reduce the academic footprint to the facility it owned in Bradenton FL, while reporting the Gainesville FL location as no longer offering instruction, but maintaining a clinical facility to allow students to complete the requirements of their academic program. The College also removed and replaced the Executive Director and other members of administration that contributed to the financial issues faced by the College. Name: Dr. Dorian G. Kramer DACM Title: Director Telephone: (941)-289-2456 Email: dkramer@dragonrises.edu

View Audit 336438

Finding 517469 (2023-001)

None 2023

Phoenix Transitional Housing Plus INC

CA

Questioned Costs Student Financial Aid Reporting § 200.512

FINDING 2023-001 NONCOMPLIANCE - REPORT SUBMISSION Program Title/Federal Grantor/ALN: Foster Care Title IV-E U.S. Department of Health and Human Services Assistance Listing Number 93.658 Corrective Action Plan The Organization will file the SF-SAC Single Audit Data Collection Form by the due date or...

FINDING 2023-001 NONCOMPLIANCE - REPORT SUBMISSION Program Title/Federal Grantor/ALN: Foster Care Title IV-E U.S. Department of Health and Human Services Assistance Listing Number 93.658 Corrective Action Plan The Organization will file the SF-SAC Single Audit Data Collection Form by the due date or file an extension when needed. Name of the Contact Person Responsible for Corrective Action Brian Gambini, Administrator Anticipated Completion Date September 30, 2025

View Audit 335441

Corrective Action Plans

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