Corrective Action Plans

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Individual Responsible for Corrective Action: Everett Jeter, Director of Compliance Corrective Action: The error falls into the category of human oversight rather than fundamental misunderstanding of the regulation or timing of processes. A loan disbursement notification was sent to the student for...
Individual Responsible for Corrective Action: Everett Jeter, Director of Compliance Corrective Action: The error falls into the category of human oversight rather than fundamental misunderstanding of the regulation or timing of processes. A loan disbursement notification was sent to the student for both the fall 2022 and spring 2023 semesters. We can document the spring 2023 loan disbursement notification was sent but are unable to document the date. Our internal processes dictate that the notification would normally be sent on the date of disbursement. We will develop and implement additional controls to effectively capture a student’s disbursement notification to ensure that both a record of the notification and the date are maintained. Anticipated Completion Date: August 15, 2024
Individual Responsible for Corrective Action: Linda Fleischman, Registrar Corrective Action: The Registrar’s Office will reach out to Jenzabar to determine what is triggering the incorrect program start date. Beginning with the summer 2024 students, each new student record will be reviewed prior to...
Individual Responsible for Corrective Action: Linda Fleischman, Registrar Corrective Action: The Registrar’s Office will reach out to Jenzabar to determine what is triggering the incorrect program start date. Beginning with the summer 2024 students, each new student record will be reviewed prior to the initial National Student Clearinghouse submission to ensure that the start date is being reported correctly. Anticipated Completion Date: August 15, 2024
Individual Responsible for Corrective Action: Everett Jeter, Director of Compliance Corrective Action: The error falls into the category of human oversight rather than fundamental misunderstanding of the regulation or timing of processes. The break days for fall 2022 were not properly calculated to...
Individual Responsible for Corrective Action: Everett Jeter, Director of Compliance Corrective Action: The error falls into the category of human oversight rather than fundamental misunderstanding of the regulation or timing of processes. The break days for fall 2022 were not properly calculated to include a break of 5 days. We will develop and implement a process within Student Financial Services to audit all R2T4 records for accuracy, completeness, and consistency regarding length of academic periods. Anticipated Completion Date: August 15, 2024
Individual Responsible for Corrective Action: Everett Jeter, Director of Compliance Corrective Action: The error falls into the category of human oversight rather than fundamental misunderstanding of the regulation or timing of processes. A transfer monitoring record was originated for this student...
Individual Responsible for Corrective Action: Everett Jeter, Director of Compliance Corrective Action: The error falls into the category of human oversight rather than fundamental misunderstanding of the regulation or timing of processes. A transfer monitoring record was originated for this student approximately six weeks prior to the spring 2023 semester. We did not receive a transfer monitoring response from NSLDS and therefore student was awarded aid as a non-transfer student. We recognized the oversight and the student’s award amount was updated to maintain appropriate annual limit during the spring 2023 semester. We will develop and implement additional controls to effectively capture transfer students for monitoring when a response from NSLDS is not received to ensure award accuracy. Anticipated Completion Date: August 15, 2024
I will ensure the Financial Aid Office works closely with the Accounts Payables department to monitor that all Title IV refund checks have been cashed after 30 days of issuance of the refund. If a check has not been cashed a new check will be reissued immediately. If, after 30 days of the reissuance...
I will ensure the Financial Aid Office works closely with the Accounts Payables department to monitor that all Title IV refund checks have been cashed after 30 days of issuance of the refund. If a check has not been cashed a new check will be reissued immediately. If, after 30 days of the reissuance, the check has not been cashed then the funds will be returned to the Department of Education within the mandated 45-day period.
View Audit 300889 Questioned Costs: $1
We recently completed the transition and onboarding of departmental staff which would allow the University to fully enact its plan to ensure both the financial aid and the Registrar's office will perform prompt review of processing University withdrawals. The Registrar's office will develop process ...
We recently completed the transition and onboarding of departmental staff which would allow the University to fully enact its plan to ensure both the financial aid and the Registrar's office will perform prompt review of processing University withdrawals. The Registrar's office will develop process and procedures documentation as an internal control measuring tool to ensure that Administrative Withdrawals (AW) and Withdrawals for lack of attendance (WA) that affect student emollment are identified immediately. Staff in the Financial Aid and the Registrar's office will actively take part in training workshops and webinars provided by the Depatiment of Education and NASF AA for continuing education to stay abreast of new developments and best practices in the industry.
View Audit 300889 Questioned Costs: $1
Finding 389879 (2023-003)
Significant Deficiency 2023
2023-003 Significant Deficiency: National Student Loan Data System (NSLDS) Report (U.S. Department of Education, William D. Ford Direct Loan Program, ALN #84.268 and Federal Pell Grant Program, ALN #84.063) (Repeat finding of 2022-001) Name of Contact Person Casey Reagan, Registrar, is responsible ...
2023-003 Significant Deficiency: National Student Loan Data System (NSLDS) Report (U.S. Department of Education, William D. Ford Direct Loan Program, ALN #84.268 and Federal Pell Grant Program, ALN #84.063) (Repeat finding of 2022-001) Name of Contact Person Casey Reagan, Registrar, is responsible for ensuring student enrollment status for changes in enrollment are correct. Melissa White, Director of Financial Aid, is responsible for uploading the enrollment status reports to clearinghouse. Corrective Action Planned During the audit, it was noted that Tusculum reported student enrollment status at changes in enrollment incorrectly. The Registrar and the Director of Financial Aid will work in conjecture to determine why the report that is pulled to upload to clearinghouse is not pulling accurate student enrollment status changes in enrollment. Once the error is identified and fixed, financial aid will pull the report and check to ensure everything is pulling correctly. Then, each month as the report is pulled, a random sampling of students will be pulled out of the report to be checked against the enrollment records to ensure that the report continues to pull correctly. Anticipated Completion Date The Registrar and Director of Financial Aid still needs to identify where the error is occurring. It is the goal to have this issue resolved before the end of the spring 2024 semester.
2023-002 Material Weakness: Gramm-Leach-Bliley Act (GLBA) (U.S. Department of Education, William D. Ford Direct Loan Program, ALN #84.268) Name of Contact Person Casey Reagan, Registrar, and Chris Summey, Head of our IT Department, are the Designated Employees in charge of overseeing the GLBA polic...
2023-002 Material Weakness: Gramm-Leach-Bliley Act (GLBA) (U.S. Department of Education, William D. Ford Direct Loan Program, ALN #84.268) Name of Contact Person Casey Reagan, Registrar, and Chris Summey, Head of our IT Department, are the Designated Employees in charge of overseeing the GLBA policy. Corrective Action Planned During the audit, it was noted that Tusculum did not fully address all of the requirements as described by 16 CFR 314.4. In addition, the application of the comprehensive information security program was not effectively administered by the University for the 2023 year. In fall 2023, IT, the Registrar, and the Director of Financial Aid met to discuss making sure that all of the new pieces of the GLBA policy were being implemented properly. In December of 2023, IT began the latest vulnerability scan and risk assessment to be in compliance with the risk assessment requirements of the GLBA Policy. This assessment should be completed by the end of spring 2024. The University is also working on updating its GLBA policies and procedures to align with the GLBA Policy. Anticipated Completion Date This process is currently ongoing and it is the University's goal to have ongoing GLBA policies updated and the risk assessment completed before the end of the 2023-2024 academic year.
Finding number: 2023-001 Federal agency: U.S. Department of Education Programs: Student Financial Assistance Cluster Assistance Listing #: 84.063 Award year: 2023 Corrective Action Plan: The Registrar’s Office is responsible for enrollment reporting to the National Student Clearinghouse. Af...
Finding number: 2023-001 Federal agency: U.S. Department of Education Programs: Student Financial Assistance Cluster Assistance Listing #: 84.063 Award year: 2023 Corrective Action Plan: The Registrar’s Office is responsible for enrollment reporting to the National Student Clearinghouse. After consulting with the Interim Registrar, it was determined that the two students in question were manually updated in the National Student Clearinghouse. There was no recollection regarding why the particular effective dates were used. The two student records have been corrected both in the National Student Clearinghouse and the National Student Loan Data System. Going forward, the Registrar’s Office will diligently ensure that the proper reporting of effective dates is submitted to the National Student Clearinghouse. We do not foresee any future issues. Timeline for Implementation of Corrective Action Plan: The corrective action plan has been implemented as of March 2024. Contact Person Despina Lambropoulos, Director of Financial Aid Shawna Lind, Interim Registrar
Name of Responsible Individual: Montague Blount Corrective Action: The University Registrar will develop a plan to ensure appropriate cross-training, position backup, and a system of proper checks and balances to improve quality control and continuity in executing core functions in the Registrar's O...
Name of Responsible Individual: Montague Blount Corrective Action: The University Registrar will develop a plan to ensure appropriate cross-training, position backup, and a system of proper checks and balances to improve quality control and continuity in executing core functions in the Registrar's Office. Enrollment reporting is a critical function that will be prioritized in the implementation of the referenced plan. Anticipated Completion Date: June 30, 2024
Names of Responsible Individuals: Chad Wick, Director Financial Aid and Brian Emery, Associate Director Financial Aid Corrective Action: The Financial Aid office made several staffing changes in 2022-2023. The newly hired staff did not receive the proper training to perform their roles effectively. ...
Names of Responsible Individuals: Chad Wick, Director Financial Aid and Brian Emery, Associate Director Financial Aid Corrective Action: The Financial Aid office made several staffing changes in 2022-2023. The newly hired staff did not receive the proper training to perform their roles effectively. This led to errors identifying and calculating the unearned amount of Title IV assistance to be returned. The previous Financial Aid Director was terminated before the prior corrective action plan could be fully completed. New leadership, in collaboration with the Office of Information Technology, has developed an automated weekly report confirming student withdrawal dates. The report is scheduled to be emailed to Financial Aid office every Friday. The Financial Aid Director reviews the report and identifies Title IV recipients. The return of title IV funds calculation would be performed for those students. Any funds required to be disbursed or returned would then be processed. Anticipated Completion Date: February 28, 2024
View Audit 300714 Questioned Costs: $1
Names of Responsible Individuals: Brandon Rhone, Analyst, Financial Aid Systems, Chad Wick, Director Financial Aid, and Mark Hergan, VP Enrollment Management Corrective Action: The Financial Aid office made several staffing changes in 2022-2023. The loan coordinator left the institution. Newly hire...
Names of Responsible Individuals: Brandon Rhone, Analyst, Financial Aid Systems, Chad Wick, Director Financial Aid, and Mark Hergan, VP Enrollment Management Corrective Action: The Financial Aid office made several staffing changes in 2022-2023. The loan coordinator left the institution. Newly hired staff were not properly trained, resulting in the failure to carry out loan notification as required. The VP of Enrollment created a process, implemented in the Spring of 2023, that automated the student loan disbursement notifications with-in the required 30 days of student accounts transmitting their loans. Anticipated Completion Date: February 28, 2024
Name of Responsible Individual: Chad Wick, Director Financial Aid Corrective Action: In an effort to maximize the utilization of student aid, current student workers were reviewed for FWS eligibility. Those students identified were awarded the FWS funds without being notified though they did indicat...
Name of Responsible Individual: Chad Wick, Director Financial Aid Corrective Action: In an effort to maximize the utilization of student aid, current student workers were reviewed for FWS eligibility. Those students identified were awarded the FWS funds without being notified though they did indicate they were interested in FWS funds. The Financial Aid Office and Human Resources will collaborate to ensure that work study students are not allowed to start work until they have followed proper hiring procedures within the PeopleAdmin system. The Financial Aid office is also modifying the way this award will be offered in 2024-2025. The Financial Aid office will add this award to the automated process when students are first packaged. At that time, they will need to accept or decline the offer. From acceptance, the student will be prompted to complete a short training video on acquiring a University job. Upon completion of the video the students will be provided an automated link to the PeopleAdmin system where they will have access to the open jobs on campus. The Financial Aid office will receive an automated confirmation from the PeopleAdmin system that all necessary documents and training have been completed. The Financial Aid office will assign an individual to oversee this process. Anticipated Completion Date: June 30, 2024
Names of Responsible Individuals: Brian Emery, Associate Director Financial Aid and Chad Wick, Director Financial Aid Corrective Action: During the 2023 and 2024 fiscal years, the Financial Aid office experienced several staffing changes, including the termination of the Financial Aid Director. The ...
Names of Responsible Individuals: Brian Emery, Associate Director Financial Aid and Chad Wick, Director Financial Aid Corrective Action: During the 2023 and 2024 fiscal years, the Financial Aid office experienced several staffing changes, including the termination of the Financial Aid Director. The newly hired staff did not receive the proper training to perform their roles effectively. This led to errors in verifying certain data when performing verification. The previous Financial Aid Director was terminated before the prior corrective action plan could be completed. In March 2023, a consultant firm was engaged to assist with the 2024 fiscal year. The Financial Aid office will implement a Quality Assurance two-step verification process. The financial aid advisor will work with the student to gather necessary documents and perform the original verification. The Associate Director of Financial Aid will review these verifications and update them in Colleague to be transmitted to COD for corrections if needed. The Financial Aid office will run a report to identify all students selected for verification for 2023- 2024 and review them for accuracy. If any corrections are needed they will be updated and awards will be adjusted as needed. Anticipated Completion Date: June 30, 2024.
View Audit 300714 Questioned Costs: $1
Names of Responsible Individuals: Chad Wick, Director Financial Aid and Mark Hergan, VP Enrollment Management Corrective Action: After running the FISAP required reports in Colleague, the Financial Aid office will be required to save the reports so they are available to be used as supporting documen...
Names of Responsible Individuals: Chad Wick, Director Financial Aid and Mark Hergan, VP Enrollment Management Corrective Action: After running the FISAP required reports in Colleague, the Financial Aid office will be required to save the reports so they are available to be used as supporting documents. This past year after the data was collected and the reports ran in Colleague the reports were not saved to the network drive and were lost. The reports cannot be recreated at a later date. Anticipated Completion Date: June 30, 2024
Names of Responsible Individuals: Brandon Rhone, Analyst Financial Aid Systems, Chad Wick, Director Financial Aid and Brian Emery, Associate Director Financial Aid Corrective Action: The University will transition from a manual to an automated review process. The COA data that was inputted at the be...
Names of Responsible Individuals: Brandon Rhone, Analyst Financial Aid Systems, Chad Wick, Director Financial Aid and Brian Emery, Associate Director Financial Aid Corrective Action: The University will transition from a manual to an automated review process. The COA data that was inputted at the beginning of the award year did not match all budget components causing inaccuracies. The Financial Aid office was adjusting the budget components of the COA manually, which resulted in miscalculations. When these calculations were performed COD might not have been updated and therefore the COA could be inaccurately reported. During the 2023 and 2024 fiscal years the Financial Aid office experienced several staffing changes. The Financial Aid office will review all student COA calculations to ensure that the COA used for originating and disbursing funds is correct. The Financial Aid office will set up automatic processing of key reports to identify rejected origination records. The Financial Aid office will set up the Direct Loan COD Reject Report (DCRR) and the Pell COD Reject Report (PCRR) to run Sunday night and be available Monday morning to be reviewed by the Financial Aid Advisors. The Financial Aid office will make the necessary corrections and update by the end of the week. The Financial Aid office will run Batch FA Transmittal Register (FATR) to confirm that all anticipated awards have passed all rules and are ready to transmit. Those that don’t pass will be reviewed and students will be contacted for updated/corrected information. COD records will be exported nightly through an automated process to ensure all deadlines are met and that we are not exceeding the 15 calendar day limit. The Financial Aid office has also modified the setup of their Student Information System for 2024-2025 so that the COA will be automatically calculated which will eliminate the need for any manual calculations of COA. This automated process should eliminate improperly calculated COAs. Anticipated Completion Date: June 30, 2024
Names of Responsible Individuals: Chad Wick, Director Financial Aid and Brian Emery, Associate Director Financial Aid Corrective Action: The University will transition from a manual awarding process to an automated process. The Financial Aid office was awarding this manually which led to mistakes wh...
Names of Responsible Individuals: Chad Wick, Director Financial Aid and Brian Emery, Associate Director Financial Aid Corrective Action: The University will transition from a manual awarding process to an automated process. The Financial Aid office was awarding this manually which led to mistakes when ISIR data changed or other awards were added or removed. FSEOG funds were used to assist students to pay off balances allowing them to register for the next semester. During the 2023 and 2024 fiscal years the Financial Aid office experienced several staffing changes including the termination of the Financial Aid Director. In March 2023, a consultant firm was engaged to assist with the 2024 fiscal year. The Financial Aid office will review all 2023-2024 FSEOG awards to ensure that student aid is calculated, awarded and disbursed correctly. The Financial Aid office will run a Fund Management Report to obtain a list of all students who were awarded FSEOG and compare that to the Pell Fund Management Report. This will ensure that all students who received FSEOG funds were also awarded Pell. The Financial Aid office will then review the amounts of the FSEOG awards to make sure no one was awarded more than the maximum threshold. The Financial Aid office will review the COA calculation for each student awarded FSEOG to verify that it was calculated correctly. For 2024-2025 the Financial Aid office has modified the packaging rules to automate the packaging of FSEOG which will eliminate any manual changes to the award. This should ensure that only students eligible for the award receive it and the amount is correct. The Financial Aid office has also modified the setup of their Student Information System for 2024-2025 so that the COA will be automatically calculated which should eliminate the need for any manual calculating of COA and eliminate improperly calculated COAs. Anticipated Completion Date: June 30, 2024
View Audit 300714 Questioned Costs: $1
Name of Responsible Individual: Mary Beth Schiller-Schwenke, Controller Corrective Action: The FWS Program instances were the result of a minor type error on the federaldraw reconciliation worksheet. To prevent a similar error in the future, the Business Office has modified its draw recordkeeping pr...
Name of Responsible Individual: Mary Beth Schiller-Schwenke, Controller Corrective Action: The FWS Program instances were the result of a minor type error on the federaldraw reconciliation worksheet. To prevent a similar error in the future, the Business Office has modified its draw recordkeeping process to require the employees that record or approve the draw journal entry also review the draw worksheet for accuracy and correct if needed. The FSEOG Program instances resulted from reversals of student awards in fiscal year 2024 for the fiscal year 2023. The Business Office routinely monitors the general ledger for award transactions, however, reversals of student aid awarded in a prior fiscal year can be offset by current year activity and missed. The Financial Aid Office will be responsible to notify the Business Office when they initiate prior award transactions. In addition to the weekly monitoring of the related general ledger accounts, the Business Office will also generate financial aid award reporting and monitor for changes. Anticipated Completion Date: February 28, 2024
The University verified the internal processes related to this report and verified the operating system manual used by the University since the repo1t is sent electronically. In addition, the University continues with the process of continuous training for the Register Office, Academic Office and Fi...
The University verified the internal processes related to this report and verified the operating system manual used by the University since the repo1t is sent electronically. In addition, the University continues with the process of continuous training for the Register Office, Academic Office and Financial Aid Office with the purpose of sending this report in the time required according to regulations
Corrective Action Plan: Beginning this semester (Fall 2023) a nightly process has been put in place to capture time status changes. As suggested by Ellucian, the SFRTMST report (Time Status Calculation Update process) is run nightly at 11:30pm. This process is initially run the day before classes be...
Corrective Action Plan: Beginning this semester (Fall 2023) a nightly process has been put in place to capture time status changes. As suggested by Ellucian, the SFRTMST report (Time Status Calculation Update process) is run nightly at 11:30pm. This process is initially run the day before classes begin and then throughout the semester to ensure that Time Statuses are now as accurate as possible so that the NSLC submissions have the most up to date information. The Registrar and Associate Registrar will also seek additional training for the NSLDS process to make sure we are up to date with current practices and procedures. Timeline for Implementation of Corrective Action Plan: In place for Fall 2023 Contact Person: Jeffrey Mei, Registrar
Views of responsible officials and planned corrective action: Areas of focus will be to put in place written policies and procedures for the Financial Aid office, including the area of disbursements that includes additional controls and documentation of such. Our objectives will be that all current ...
Views of responsible officials and planned corrective action: Areas of focus will be to put in place written policies and procedures for the Financial Aid office, including the area of disbursements that includes additional controls and documentation of such. Our objectives will be that all current and incoming Financial Aid staff will be required to maintain documentation of any drawdowns of funds related to student financial aid. We have put in place a shared an electronic folder with restricted access to provide confidentiality and provide documentation of the shared communication between offices. Documentation of drawdowns and/or returns will be maintained within this folder. Staff will be trained on using the daily generated reports from Poise to watch for students who have withdrawal on their records so that this can be updated and proper calculations done. Measurable targets will be achieved by documenting the records within a shared electronic drive between the Financial Aid office and the Business Office, who handles the return of funds. This will become of a part of the weekly duties of staff.
Views of responsible officials and planned corrective action: Areas of focus will be to put in place written policies in procedures for the Financial Aid office, including the area of enrollment reporting, which is also done by Institutional Research, to provide appropriate updating of the NSLDS rec...
Views of responsible officials and planned corrective action: Areas of focus will be to put in place written policies in procedures for the Financial Aid office, including the area of enrollment reporting, which is also done by Institutional Research, to provide appropriate updating of the NSLDS records. This will include creating checks and balances to be sure that enrollment reporting is working and being updating timely. The Federal Student Aid website offers many resources in the form of training, including access to on-demand resources which provide a documented learning assessment. Our objectives will be that all current and incoming Financial Aid staff, along with Institutional Research staff, will be required to undergo training in the area of enrollment reporting, including the supervisor with whom the Financial Aid office reports to. This training will be annually and periodically throughout the year. In addition, daily add and drop reports are generated which would allow more frequent updating of the NSLDS system. Objectives will be to put in place to provide checks and balances to be sure that enrollment reporting is timely. Measurable targets will be achieved by documenting the training within a shared electronic drive between the supervisor and the Financial Aid office. The Financial Aid office shall be responsible for monitoring that the enrollment reporting is being done timely. In addition, periodic and monitored checks-ins of staff in Institutional Research with whom the responsibility to update NSLDS is with.
Views of responsible officials and planned corrective action: Areas of Focus will be in the documentation of polices and procedures to provide clear expectations of internal control documentation used to complete the drawdowns from the Department of Education and for a process of record retention. O...
Views of responsible officials and planned corrective action: Areas of Focus will be in the documentation of polices and procedures to provide clear expectations of internal control documentation used to complete the drawdowns from the Department of Education and for a process of record retention. Our objective would be to formalized the policies and procedures be updated in the Financial Aid policy manual with shared access between the Financial Aid office who approves the aid, the Business Office who ultimately pulls down from the Department of Education, and with the Cashier who distributes any refunds. We have put in place an electronic folder with restricted access to provide confidentiality and provide documentation of the shared communication between offices. The POISE system already generates a listing of students. That workflow will be amended to retain that documentation to be available. Measurable targets will be to do this weekly or as batches are prepared for draw-down. This documentation will be found in the shared electronic folder, which has already been implemented. The transfer of student records into the financial system is being done weekly and documentation is retained of students for which transactions occur.
Two staff members were assigned the responsibility and access to EDExpress, which allows the college to send and receive files (including ISIRs) between college and federal databases. Both employees were placed on immediate and unanticipated leave in March 2023, leaving interim staff without the acc...
Two staff members were assigned the responsibility and access to EDExpress, which allows the college to send and receive files (including ISIRs) between college and federal databases. Both employees were placed on immediate and unanticipated leave in March 2023, leaving interim staff without the access or authority to perform these functions. It took some time to update the school’s online access and we were instructed to start using a different software, EDconnect, since EDExpress was becoming obsolete. Administration rights and training were then given to interim staff on uploading ISIRs into the FA system (SAM), and written procedures were developed. In the case cited here, the student was paid just as the staffing and access issues occurred. Updated records were not downloaded until after access to EDconnect was implemented and staff received guidance on the correct procedure. Initially, the student’s file did not require verification prior to payment, but changes made to their FAFSA generated ISIR #2 which resulted in a new request for verification. This update was received late due to the access and software issue. Since that time, we have developed written procedures on this process and trained additional staff. We have also created a new awarding and disbursement process and timeline, including required reconciliation of COD authorizations versus student awards and disbursements. This ensures students are properly awarded and disbursed, and that records between the two systems match. Uploads and downloads are now performed multiple times per week to ensure records are frequently updated. In addition, the Financial Aid Office transition from the SAM to the Colleague Financial System will automate these functions to run daily, eliminating the need for manual uploads and downloads of data between the systems. Staff absences will no longer impact the timely updating of records.
Due to a sudden and unanticipated staffing shortage, R2T4 calculations were performed beyond the required timeframe. In the case where a student receives all F’s on their transcript, we cannot determine the students’ last date of attendance or academic activity, since F grades do not include this in...
Due to a sudden and unanticipated staffing shortage, R2T4 calculations were performed beyond the required timeframe. In the case where a student receives all F’s on their transcript, we cannot determine the students’ last date of attendance or academic activity, since F grades do not include this information (unlike W grades) and the college is a non-attendance taking institution. In this case, federal guidelines allows schools to use the midpoint of the payment period for the calculation. In these cases, all calculations would be based on the same date each term. In review of FA22 records, the calculations were performed in March 2023, but the withdrawal dates used to calculate eligibility were 10/21/22, the FA22 term midpoint. All policies and procedures relating to R2T4 processing have been reviewed and updated, and a review of all prior year calculations will be performed as well, to ensure compliance. Additional staff have been trained in the process, and calculations are being performed. Adequate and trained staff will ensure that all required calculations are performed accurately, and according to required timelines. In addition, the Financial Aid Office is transitioning from the SAM to the Colleague Financial Aid System (starting in 2024-25) which will provide a more automated and integrated process, with enhanced internal controls.
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