Corrective Action Plans

Finding 370217 (2023-002)

Significant Deficiency 2023

CA

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

Date: November 11, 2023 From: Verletta Jackson, Registrar To: Moss Adams Subject: Finding 2023-002 Special Tests and Provisions Enrollment Reporting: Significant Deficiency in Internal Control Over Compliance Item: Finding 2023-002 Special Tests and Provisions Enrollment Reporting: Significant Def...

Date: November 11, 2023 From: Verletta Jackson, Registrar To: Moss Adams Subject: Finding 2023-002 Special Tests and Provisions Enrollment Reporting: Significant Deficiency in Internal Control Over Compliance Item: Finding 2023-002 Special Tests and Provisions Enrollment Reporting: Significant Deficiency In Internal Control Over Compliance. Corrective Action: The University has updated the status of all students in our latest batch send. That includes and is not limited to all students selected In the Single Audit. Steps/Policies Implemented to avert problem: The process for reporting information to NSLDS through the Clearinghouse works efficiently. The problem in this case, is that the University has always had two individuals with access to the upload data into the Clearinghouse. When one of the individuals responsible for uploading's position was eliminated, authorization was not given to anyone else as a backup. So, when the then Registrar resigned, no one on-site was authorized to upload the already prepared "send". That issue has been resolved and there will always be, once again, two individuals with access to upload. Although the process to resolve this Issue was extremely timely, permission to access the Clearinghouse site was eventually provided. Contact Person: The Registrar, Verletta Jackson is the responsible person. Her contact information is, Verletta Jackson, email Verletta.Jackson@woodbury.edu, phone 818 252 5277. Anticipated Completion Date: Completed as of 10.15.2023

View Audit 291795

Finding 370216 (2023-002)

Significant Deficiency 2023

Lewis-Clark State College

ID

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

Student Financial Aid Cluster: Federal Perkins Loan Program – Assistance Listing No. 84.038 Recommendation: We recommend the college implement a checklist to reference to ensure all required elements of the Perkins loan records are retained as required. Explanation of disagreement with audit find...

Student Financial Aid Cluster: Federal Perkins Loan Program – Assistance Listing No. 84.038 Recommendation: We recommend the college implement a checklist to reference to ensure all required elements of the Perkins loan records are retained as required. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Reports from third-party servicer will be reviewed monthly and notifications of paid in full will be processed per requirements. A copy of the promissory note stamped paid in full will be retained according to recordkeeping requirements. Name(s) of the contact person(s) responsible for corrective action: Laura Hughes Planned completion date for a corrective action plan: Immediate Implementation

View Audit 291793

Finding 370210 (2023-001)

Material Weakness 2023

Lewis-Clark State College

ID

Student Financial Aid Reporting Material Weakness

Student Financial Aid Cluster: Federal Supplemental Educational Opportunity Grant – Assistance Listing No. 84.007 Federal Work Study Program – Assistance Listing No. 84.033 Federal Pell Grant Program – Assistance Listing No. 84.063 Federal Direct Student Loans – Assistance Listing No. 84.268 Te...

Student Financial Aid Cluster: Federal Supplemental Educational Opportunity Grant – Assistance Listing No. 84.007 Federal Work Study Program – Assistance Listing No. 84.033 Federal Pell Grant Program – Assistance Listing No. 84.063 Federal Direct Student Loans – Assistance Listing No. 84.268 Teacher Education Assistance. for College and Higher Education Grants– Assistance Listing No. 84.379 Nursing Student Loans – Assistance Listing No. 93.364 Recommendation: We recommend that the College work with its third-party servicer and implement procedures to ensure that enrollment data, changes in status, and effective dates within NSLDS are reported accurately and timely. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to the finding: The Financial Aid Office has temporarily taken over the administration of this process due to personnel changes in the Registrar’s Office. Enrollment reports are scheduled to be submitted monthly. The data is reviewed at various intervals of the process by Registrar and Financial Aid staff and the reviews are documented. Corrections and updates are provided and submitted as required. Procedures will be updated to reflect all changes and validations. An internal audit will be conducted using the third-party Audit Guide and will be documented. Name(s) of the contact person(s) responsible for corrective action: Laura Hughes, Soo Lee Bruce-Smith, Travis Osburn, Kim Tuschhoff, and John Bender Planned completion date for a corrective action plan: Immediate Implementation

View Audit 291793

Finding 370183 (2023-005)

Significant Deficiency 2023

Clarke University of Dubuque, Iowa

IA

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

Student Financial Assistance Program Cluster – Department of Education Federal Financial Assistance Listing #84.268 Federal Direct Student Loans 2022/2023 P268K211430 Federal Financial Assistance Listing #84.063 Federal Pell Grant Program 2022/2023 P063P201430 Special Tests & Provisions: Enrollment...

Student Financial Assistance Program Cluster – Department of Education Federal Financial Assistance Listing #84.268 Federal Direct Student Loans 2022/2023 P268K211430 Federal Financial Assistance Listing #84.063 Federal Pell Grant Program 2022/2023 P063P201430 Special Tests & Provisions: Enrollment Reporting Significant Deficiency in Internal Control and Noncompliance Finding Summary: One instance was noted where the enrollment status reported to the National Student Clearing House was not the same as the student’s actual enrollment status. Responsible Individuals: Robert Hoover, Director of Financial Aid and Kristi Bagstad, Registrar, Registrar’s Office Corrective Action Plan: The Registrar’s office will review clearing house batch errors reports and the Financial Aid office will conduct quality sampling once a semester. Anticipated Completion Date: Commenced December 1, 2023

View Audit 291731

Finding 370180 (2023-004)

Significant Deficiency 2023

Clarke University of Dubuque, Iowa

IA

Special Tests & Provisions Student Financial Aid Significant Deficiency

Student Financial Assistance Program Cluster – Department of Education Federal Financial Assistance Listing/CFDA #84.268 Federal Direct Student Loans 2022/2023 P268K211430 Federal Financial Assistance Listing/CFDA #84.063 Federal Pell Grant Program 2022/2023 P063P201430 Special Tests & Provisions: ...

Student Financial Assistance Program Cluster – Department of Education Federal Financial Assistance Listing/CFDA #84.268 Federal Direct Student Loans 2022/2023 P268K211430 Federal Financial Assistance Listing/CFDA #84.063 Federal Pell Grant Program 2022/2023 P063P201430 Special Tests & Provisions: Verification Significant Deficiency in Internal Control over Compliance Finding Summary: Four instances were identified where there was no documented control over student verification. Responsible Individuals: Robert Hoover, Director of Financial Aid and Sylma Fernandez, Assistant Director of Financial Aid Corrective Action Plan: With the recent filling of vacant positions, newer staff were being trained on these processes. As such, multiple reviews were occurring simultaneously and were not documented in their usual manner as they would occur outside phases of training. Now that staff have been trained, review processes are being documented to enhance the visibility of control practices. Anticipated Completion Date: Commenced November 1, 2023

View Audit 291731

Finding 370177 (2023-003)

Material Weakness 2023

Clarke University of Dubuque, Iowa

IA

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

Student Financial Assistance Program Cluster – Department of Education Federal Financial Assistance Listing/CFDA #84.268 Federal Direct Student Loans - 2022/2023 P268K211430 Federal Financial Assistance Listing/CFDA #84.063 Federal Pell Grant Program - 2022/2023 P063P201430 Special Tests & Provisio...

Student Financial Assistance Program Cluster – Department of Education Federal Financial Assistance Listing/CFDA #84.268 Federal Direct Student Loans - 2022/2023 P268K211430 Federal Financial Assistance Listing/CFDA #84.063 Federal Pell Grant Program - 2022/2023 P063P201430 Special Tests & Provisions:– Return of Title IV Funds Material Weakness in Internal Control over Compliance and Noncompliance Finding Summary: Eight instances were identified where there was no documented control over the return of Title IV calculation. Responsible Individuals: Robert Hoover, Director of Financial Aid and Sylma Fernandez, Assistant Director of Financial Aid Corrective Action Plan: With the recent filling of vacant positions, newer staff were being trained in these processes. As such, multiple reviews were occurring simultaneously and were not documented in their usual manner as they would occur outside phases of training. Now that staff have been trained, review processes are being documented to enhance the visibility of control practices. Anticipated Completion Date: Commenced November 1, 2023

View Audit 291731

Finding 370175 (2023-002)

Significant Deficiency 2023

Clarke University of Dubuque, Iowa

IA

Student Financial Aid Matching / Level of Effort / Earmarking Reporting

Student Financial Assistance Program Cluster – Department of Education Federal Financial Assistance Listing #84.038 Federal Perkins Loan Program & #84.033 Work-Study Program 2022/2023 P063P201430 - 2021/2022 Finding Summary: Certain amounts within the FISAP filed during fiscal year 2022 FISAP were ...

Student Financial Assistance Program Cluster – Department of Education Federal Financial Assistance Listing #84.038 Federal Perkins Loan Program & #84.033 Work-Study Program 2022/2023 P063P201430 - 2021/2022 Finding Summary: Certain amounts within the FISAP filed during fiscal year 2022 FISAP were reported incorrectly in Part III, Section B, Line 13 and in Part VI, Section A, Lines 1-23 columns e & f. Responsible Individuals: Robert Hoover, Director of Financial Aid and Deb Theill, Student Accounts Loan Coordinator Corrective Action Plan: The Financial Aid and Loan offices will obtain review from a non preparer of the FISAP report before submittal. Anticipated Completion Date: Tami Lansing did an initial review on 10/16/2023, another review will also be performed before May 1, 2024.

View Audit 291731

Finding 370164 (2023-002)

Significant Deficiency 2023

University of Louisville

KY

Student Financial Aid Reporting Matching / Level of Effort / Earmarking § 200.303

FINDINGS—FEDERAL AWARD PROGRAMS AUDITS SIGNIFICANT DEFICIENCY U.S. Department of Education 2023-002 Student Financial Assistance Cluster: Assistance Listing No. 84.007, 84.063, 84.268, 84.379, 84.033 UNIVERSITY OF LOUISVILLE CORRECTIVE ACTION PLAN YEAR ENDED JUNE 30, 2023 Recommendation: We recommen...

FINDINGS—FEDERAL AWARD PROGRAMS AUDITS SIGNIFICANT DEFICIENCY U.S. Department of Education 2023-002 Student Financial Assistance Cluster: Assistance Listing No. 84.007, 84.063, 84.268, 84.379, 84.033 UNIVERSITY OF LOUISVILLE CORRECTIVE ACTION PLAN YEAR ENDED JUNE 30, 2023 Recommendation: We recommend that the University work with their third-party servicer and implement procedures to ensure that enrollment data, changes in status and effective dates within NSLDS are reported timely. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The original guidance for missing or incorrect social security number from the Clearinghouse was to reach out to the student and obtain proof of the social security number or enter the student into the system without a social security number. The student was entered without using a social security number and this issue was not resolved. The University’s Registrar’s Office has inquired about this issue and have since been provided updated guidance on how to rectify the occurrence of such. The new guidance provided has already been implemented by the Registrar’s Office. The new guidance from the National Student Clearinghouse allows for a student’s information to be entered with the social security number supplied when registering and add enrollment information. Going forward, this missing information will not preclude a student from being reported. Name(s) of the contact person(s) responsible for corrective action: Chris Goodman Planned completion date for corrective action plan: Implemented 09/28/2023 If the U.S. Department of Education has questions regarding this plan, please call Beverly Santamouris at (502) 852-6272.

View Audit 291699

Finding 370161 (2023-003)

Significant Deficiency 2023

Culver-Stockton College

MO

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

The College implemented the following policies effective September 2023. The responsible college officer is Tina Wiseman, Director of Financial Aid. • Students that graduate will automatically be sent exit counseling within 30 days of their last date of at least part-time attendance. • Students that...

The College implemented the following policies effective September 2023. The responsible college officer is Tina Wiseman, Director of Financial Aid. • Students that graduate will automatically be sent exit counseling within 30 days of their last date of at least part-time attendance. • Students that identify to the college that they are not returning for the next term of enrollment will be sent exit counseling within 30 days of that notification. • Students that enroll for the next term, but then drop their enrollment before the start of the next term, will have exit counseling sent within 30 days of the drop date. If that date falls more than 30 days outside of their last date of at least part-time attendance, the financial aid office will document their file of that notification. • Students that do not enroll for the next term but have identified to the college they plan to enroll (example, they have a balance due they need to pay, are waiting to hear on placement within a program, waiting on class schedule confirmation, etc.), will receive exit counseling within 30 days of census date of the next term. If a student identifies at any time before census they are not returning, exit counseling will be sent within 30 days of learning they are not returning. • Students that do not enroll for the next term and have not had any communication with the college on their plans to enroll will receive exit counseling within 30 days of census date of the next term.

View Audit 291681

Finding 370156 (2023-002)

Significant Deficiency 2023

Culver-Stockton College

MO

Special Tests & Provisions Student Financial Aid Subrecipient Monitoring § 200.303

The College implemented a policy where all special circumstance requests and income verification overrides must be reviewed by a second staff member effective September 2023. The second staff member reviews each override, either approves or denies the paperwork, then signs and dates the paperwork. T...

The College implemented a policy where all special circumstance requests and income verification overrides must be reviewed by a second staff member effective September 2023. The second staff member reviews each override, either approves or denies the paperwork, then signs and dates the paperwork. The paperwork is returned to the first staff member to make the changes in PowerFAIDS. The responsible college official is Tina Wiseman, Director of Financial Aid.

View Audit 291681

Finding 370123 (2023-001)

Significant Deficiency 2023

Reading Area Community College

PA

Student Financial Aid

Federal Program Federal Pell Grant Program ALN 84.063, Contract #P063P223333 Criteria According to the Code of Federal Regulations (CFR) Title 34, Section 668.22(c), the withdrawal date for a student who ceases attendance at an institution that is not required to take attendance is the date, as de...

Federal Program Federal Pell Grant Program ALN 84.063, Contract #P063P223333 Criteria According to the Code of Federal Regulations (CFR) Title 34, Section 668.22(c), the withdrawal date for a student who ceases attendance at an institution that is not required to take attendance is the date, as determined by the institution, that the student began the withdrawal process prescribed by the institution or the date, as determined by the institution, that the student otherwise provided official notification to the institution. Condition/Cause Out of a sample of 25 students who withdrew or did not maintain attendance during a semester within the audit period, there was one instance where an incorrect withdrawal date was used. Effect An R2T4 calculation was performed using an incorrect withdrawal date of October 3, 2022 which required the student to return $453 of Pell funds. The correct withdrawal date is September 28, 2022. Using September 28, 2022 as the withdrawal date, the student would have been required to return $487 of Pell funds. Recommendation We recommend that a process be put in place at the College to strengthen its controls to ensure that it performs accurate return of Title IV calculations. Management Response The College agrees with the deviation noted in the testing. The financial aid office continues to refine its processes and controls over the return of Title IV calculations to ensure the calculations remain accurate, including a review of calculations being made. Sincerely, Kenneth Dearstyne, Senior Vice President of Finance and Administrative Services

View Audit 291639

Finding 370120 (2023-001)

Significant Deficiency 2023

Arcadia University

PA

Questioned Costs Student Financial Aid Subrecipient Monitoring

Finding 2023-001 – Error in Return of Title IV Aid – Significant Deficiency ALN Number: 84.007, 84.063, 84.268 Federal Award Identification Number: P007A223541, P063P222079, P268K232079 Recommendation: It is recommended that University personnel review the Return of Title IV calculations and agree f...

Finding 2023-001 – Error in Return of Title IV Aid – Significant Deficiency ALN Number: 84.007, 84.063, 84.268 Federal Award Identification Number: P007A223541, P063P222079, P268K232079 Recommendation: It is recommended that University personnel review the Return of Title IV calculations and agree final amounts for refund to the refunds made to the Department of Education. A manual review should also be performed by someone other than the person who enters the information into the software in order to verify the accuracy of the calculations and the amounts refunded. Action Taken: The University has returned the funds for the student tested. In addition, the University reviewed every Return of Title IV Aid calculation performed and the amounts refunded for the award year ended May 31, 2023 and has corrected any additional errors discovered. The University has provided additional training on this topic to financial aid staff, has increased the number of staff members who will monitor the accuracy of the work and has modified its procedures by developing a tracking system to add another level of review and accountability. This will enable the team to be sure the refund calculations are performed correctly for all students and consistently applied. Name of Contact Person Responsible for Corrective Action: Holly Kirkpatrick, Ed.D., Assistant Vice President for Financial Aid

View Audit 291636 Questioned Costs: $1

Finding 370089 (2023-004)

Material Weakness 2023

Westmoreland County Community College

PA

Questioned Costs Special Tests & Provisions Student Financial Aid

Finding 2023-004: Student Financial Assistance Cluster Return of Title IV Funds As previously noted, the root cause was human error based on the manual processes. Similar to the previous finding, the College has implemented increased internal control through the review of the R2T4 calculations. Add...

Finding 2023-004: Student Financial Assistance Cluster Return of Title IV Funds As previously noted, the root cause was human error based on the manual processes. Similar to the previous finding, the College has implemented increased internal control through the review of the R2T4 calculations. Additionally, when using the automated functionality within the system for the return of funds calculation, an independent review of the calculation will be performed moving forward. In the future, the new ERP will increase the levels of control configured in the system. The President will ensure the controls are in place.

View Audit 291618 Questioned Costs: $1

Finding 370088 (2023-003)

Material Weakness 2023

Westmoreland County Community College

PA

Questioned Costs Student Financial Aid Internal Control / Segregation of Duties

Finding 2023-003: Student Financial Assistance Cluster Allowable Costs and Allowable Activities and Eligibility and SEOG Pell The findings noted three separate issues related to policies and procedures verifying the accuracy of the student eligibility for grant funding and the proper amount paid to...

Finding 2023-003: Student Financial Assistance Cluster Allowable Costs and Allowable Activities and Eligibility and SEOG Pell The findings noted three separate issues related to policies and procedures verifying the accuracy of the student eligibility for grant funding and the proper amount paid to the student based on financial need. After a review of Pell grants, Return To Title IV funds, and the award of SEOG after a return of Title IV calculation, it was determined that human error as a result of manual work was the root cause. To correct the root cause, an increased level of internal control via another level of review and a re-review of aid for the FY24 year was implemented. Further, for students who had an enrollment status of less than full time, we have had increased the number reviews for compliance. Moving forward, the College is implementing a new ERP system in which internal controls are configured to alleviate manual work thus human error and increase compliance. The President will ensure the controls are in place.

View Audit 291618 Questioned Costs: $1

Finding 370076 (2023-001)

None 2023

The Methodist University, Inc.

NC

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

Contact Person: Bonnie Adamson, Director of Financial Aid Corrective Action: The student that was not reported within 15 calendar days as required had several outliers making it difficult to determine Pell amounts. The student had atended another university Summer 2022 and this par􀆟cular university...

Contact Person: Bonnie Adamson, Director of Financial Aid Corrective Action: The student that was not reported within 15 calendar days as required had several outliers making it difficult to determine Pell amounts. The student had atended another university Summer 2022 and this par􀆟cular university awarded the student’s Pell Grant off of the 22-23 award year. While this is an accepted prac􀆟ce, it can affect the student’s 22-23 Pell Grant eligibility if they transfer to another ins􀆟tu􀆟on. This student did transfer to Methodist University (MU) Fall 2022 and atended Fall 2022, Spring 2023, and Summer 2023. The student s􀆟ll had Pell eligibility remaining to be awarded Pell Grant at MU for Summer 23, but there was a rounding issue (PowerFAIDS rounds up) and this caused a POP (Poten􀆟al Pell Overpayment) situa􀆟on with MU and the prior university. The adjustment was processed outside of the required 􀆟meframe with COD; however, the award amounts were appropriately addressed and corrected. This is a unique situa􀆟on and happens rarely. The Office of Financial Aid will review more carefully when awarding Pell Grant for rounding issues. Anticipated Completion Date: December 15, 2023

View Audit 291593

Finding 370075 (2023-002)

None 2023

The Methodist University, Inc.

NC

Student Financial Aid Special Tests & Provisions Subrecipient Monitoring

Contact Person: Kasi Turner, Registrar Corrective Action: We manually reported a student as withdrawn on 2/17/2023. The status change came in as an error on the 3/16/2023 submission (the following month) and we manually updated the status and status start date for the student again. However, it loo...

Contact Person: Kasi Turner, Registrar Corrective Action: We manually reported a student as withdrawn on 2/17/2023. The status change came in as an error on the 3/16/2023 submission (the following month) and we manually updated the status and status start date for the student again. However, it looks like the student’s status reverted to Three-Quarter time on the final transmission on 5/1/2023. We will commit to closer monitoring of withdrawals submitted manually by our office on subsequent enrollment transmissions through the Clearinghouse. Anticipated Completion Date: December 15, 2023

View Audit 291593

Finding 370050 (2023-001)

Significant Deficiency 2023

Lawrence University of Wisconsin

WI

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

Student Financial Assistance Cluster – Assistance Listing No. 84.063, 84.268 Recommendation: We recommend that management review the process for ensuring the accuracy of the program effective date for students with changes in status within the NSLDS system. Explanation of disagreement with audit fin...

Student Financial Assistance Cluster – Assistance Listing No. 84.063, 84.268 Recommendation: We recommend that management review the process for ensuring the accuracy of the program effective date for students with changes in status within the NSLDS system. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The registrar’s office worked with Technology Services to review the National Student Clearinghouse data extract from Banner for the applicable term. Although the file aligned with previous submissions to National Student Clearinghouse, a fix was made for the Lawrence custom extract. The midyear 2023 grad file was run against the updated code and the extract looks as the auditors would expect. This should result in a program effective date equivalent to end date of student's final term for all Lawrence graduates in future submissions. Name of the contact person responsible for corrective action: Angi Long, Registrar Planned completion date for corrective action plan: 2/1/2024

View Audit 291560

Finding 369982 (2023-003)

Significant Deficiency 2023

Lehigh University

PA

Student Financial Aid Reporting Significant Deficiency

Federal Agency: U.S. Department of Education; Program Name: Student Financial Assistance Cluster; Assistance Listing Number: 84.063; Federal Award Year: Funding periods between July 1, 2022 and June 30, 2023; Compliance requirement: Reporting; Finding Type: Significant Deficiency; Lehigh is aware ...

Federal Agency: U.S. Department of Education; Program Name: Student Financial Assistance Cluster; Assistance Listing Number: 84.063; Federal Award Year: Funding periods between July 1, 2022 and June 30, 2023; Compliance requirement: Reporting; Finding Type: Significant Deficiency; Lehigh is aware of the 15-calendar day requirement and we have always met the deadline. Failure to report Pell Grant disbursements within 15 days in August of 2022 was the result of a well-documented Ellucian defect that denied Lehigh the ability to obtain the required data from our Banner system. By the time Lehigh received a patch from Ellucian, we had missed the 15-day window. Ellucian acknowledged the bug and Lehigh accepted that it was an anomaly. Name of contact: Jennifer Mertz, Assistant Vice Provost of Financial Services and Director of Financial Aid. Completion date: September 15, 2022

View Audit 291473

Finding 369979 (2023-002)

Significant Deficiency 2023

Lehigh University

PA

Student Financial Aid Eligibility Reporting

Federal Agency: U.S. Department of Education; Program Name: Student Financial Assistance Cluster; Assistance Listing Number: 84.038/84.063/84.268; Federal Award Year: Funding periods between July 1, 2022 and June 30, 2023; Compliance requirement: Enrollment Reporting; Finding Type: Significant Defic...

Federal Agency: U.S. Department of Education; Program Name: Student Financial Assistance Cluster; Assistance Listing Number: 84.038/84.063/84.268; Federal Award Year: Funding periods between July 1, 2022 and June 30, 2023; Compliance requirement: Enrollment Reporting; Finding Type: Significant Deficiency; The training of new staff is always a priority, but this finding is the result of unusually high turnover in the registrar’s office during FY23. Staff have since been hired and are now sufficiently trained on this issue. They run a weekly report to identify students who have withdrawn or have otherwise changed their attendance level. New staff are now fully trained in updating the NSLDS with student enrollment status changes. Name of contact: Jennifer Mertz, Assistant Vice Provost of Financial Services and Director of Financial Aid. Completion date: November 15, 2023

View Audit 291473

Finding 369959 (2023-001)

Material Weakness 2023

Lamar Institute of Technology

TX

Questioned Costs Student Financial Aid Eligibility

View of Responsible Officials: The Texas State University System's Office of Internal Audit {internal audit function for Lamar Institute of Technology) identified errors with the awarding of Title IV funds to students who were not maintaining satisfactory academic progress {SAP) in their course of s...

View of Responsible Officials: The Texas State University System's Office of Internal Audit {internal audit function for Lamar Institute of Technology) identified errors with the awarding of Title IV funds to students who were not maintaining satisfactory academic progress {SAP) in their course of study according to the Institution's published SAP standards. Lamar Institute of Technology {LIT) agrees with the external auditor's finding and recommendations. Corrective Action Plan In response to the external audit finding, LIT will implement the following corrective action plan. 1. Electronic processes for determining if a student is maintaining SAP was run in Banner for Fall 2023, and going forward, using guidance from the Ellucian Action Line, our Banner support group. Anticipated Completion Date: Corrective measures began on 8/11/2023 and anticipated completion is 90 days from the auditor's report {1/31/2024), which would be on or before April 30, 2024. 2. As an additional internal control procedure to test the Banner system, the Financial Aid Department reviewed SAP manually on all students enrolled in Fall 2023 and Spring 2024 with a FAFSA application to ensure their eligibility had been set correctly. Action plan will be extended to future semesters as needed. Anticipated Completion Date: Corrective measures began on 8/11/2023 and anticipated completion is 90 days from the auditor's report {1/31/2024), which would be on or before April 30, 2024, fo(Fall 202-3-and Spring 2024. - - 3. In addition to settingSAP prior to the semester and performing verification checks, LIT requested an additional mtemal con-trol proces-sin Banner- an automatic process to run nightly after the initial SAP is set to make sure each student's eligibility is set correctly before awarding aid. This process was devel-epe.a__and tested _b_y _the Information Technology Department before implementation under the direction and-in collaboration with the Financial Aid Department. Anticipated Completion Date: 1/29/2024. 4. A return of funds will be done for students that received Title IV funds for FY 2023 in error. In total, $673,780 will be returned via the Common Origination and Disbursement Web Site of the Department of Education. Anticipated Completion Date: 90 days from the auditor's report (1/31/2024), which would be on or before April 30, 2024. Individual Responsible Linda Korns, Director of Financial Aid

View Audit 291408 Questioned Costs: $1

Finding 369859 (2023-003)

Significant Deficiency 2023

University of Hartford

CT

Student Financial Aid Reporting Significant Deficiency

Student Financial Assistance Cluster – Federal Assistance Listing Nos. 84.063 and 84.268 Recommendation: We recommend the University review its policies and procedures on reporting enrollment information to the NSLDS to ensure that all relevant information is being captured accurately and reported...

Student Financial Assistance Cluster – Federal Assistance Listing Nos. 84.063 and 84.268 Recommendation: We recommend the University review its policies and procedures on reporting enrollment information to the NSLDS to ensure that all relevant information is being captured accurately and reported timely in accordance with applicable regulations. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: To ensure student enrollment is submitted to NSLDS in a timely manner, additional changes have been established. Students who have completed their degrees in a prior term (for example, summer/fall term), but with an award date in the next term (for example, September for summer term or January for the fall term), will be updated prior to the first of term enrollment file. This change will decrease potential errors as the terms are updated in the appropriate order and we can address any enrollment issues in the appropriate timeframe. Planned completion date for corrective action plan: January 31, 2024 Name(s) of the contact person(s) responsible for corrective action: Natalie Durant, Registrar at 860-768-5565.

View Audit 291373

Finding 369855 (2023-001)

Significant Deficiency 2023

University of Hartford

CT

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

Student Financial Assistance Cluster – Federal Assistance Listing No. 84.038 Recommendation: We recommend the University evaluate is procedures and policies around recordkeeping and retention. Management of the University agrees with the finding. We do have policies and procedures in regards to re...

Student Financial Assistance Cluster – Federal Assistance Listing No. 84.038 Recommendation: We recommend the University evaluate is procedures and policies around recordkeeping and retention. Management of the University agrees with the finding. We do have policies and procedures in regards to recordkeeping and retention of Perkins loan documents. Active, Assigned and Retired Perkins loans are maintained in a locked, fireproof container in the Bursar office. The repayment schedules are electronically kept in our borrower files with Heartland ECSI. The cancellation and deferment request for each Perkins loan made are electronically kept in our borrower files with Heartland ECSI. We typically retain original or true and exact copies of Master Promissory Notes (MPN). In some cases, the MPN may have been returned to the student during their entrance counseling. The Perkins loan program expired September 30, 2017. We are currently in the process of Assigning the remaining borrowers to close out our Perkins Loan Program. We are working as quickly and efficiently as possible. Staff availability will determine the completion date for this process. Planned completion date for corrective action plan: March 31, 2024 University Contact: Diane Purcell, Bursar Senior Accountant, (860) 768-4361

View Audit 291373

Finding 369852 (2023-004)

Significant Deficiency 2023

University of Hartford

CT

Student Financial Aid Cash Management Eligibility

Student Financial Assistance Cluster – Federal Assistance Listing Nos. 84.007, 84.003, 84.038, 84.063, and 84.268 Recommendation: We recommend the University review its policies and procedures on reporting requirements to the Department if Education in respects to these requirements. Explanation...

Student Financial Assistance Cluster – Federal Assistance Listing Nos. 84.007, 84.003, 84.038, 84.063, and 84.268 Recommendation: We recommend the University review its policies and procedures on reporting requirements to the Department if Education in respects to these requirements. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The University has updated the Department of Education Federal Student Aid website with the proper URL, effective January 23, 2024. Name(s) of the contact person(s) responsible for corrective action: Katherine Presutti, Director of Student Financial Aid at 860-768-4300.

View Audit 291373

Finding 369851 (2023-002)

Significant Deficiency 2023

University of Hartford

CT

Student Financial Aid Significant Deficiency Internal Control / Segregation of Duties

Student Financial Assistance Cluster – Federal Assistance Listing Nos. 84.007, 84.003, 84.038, 84.063, and 84.268 Recommendation: We recommend the University designate an individual to oversee the information security function and work to update the Universities written security program to ensure ...

Student Financial Assistance Cluster – Federal Assistance Listing Nos. 84.007, 84.003, 84.038, 84.063, and 84.268 Recommendation: We recommend the University designate an individual to oversee the information security function and work to update the Universities written security program to ensure compliance with all the standards. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. The University conducted a thorough gap assessment of our current GLBA procedures and the impending changes to the legislation that took effect in 2023. The assessment revealed the need to develop a comprehensive information security program that encompasses all nine elements of the GLBA Safeguards Rule. Our roadmap incorporates both existing practices and new measures to ensure that the resulting program meets the updated legislation's requirements. We are committed to ensuring the safety and security of our institution's sensitive information. Planned completion date for corrective action plan: April 15, 2024 Name(s) of the contact person(s) responsible for corrective action: Gregory Freidline, Director of Technology Services at 860-768-4272

View Audit 291373

Finding 369749 (2023-002)

Material Weakness 2023

Spoon River College District No. 534

IL

Student Financial Aid

We are implementing a process of sharing the responsibility of processing recalculations of aid on a weekly rotation. One week the Assistant Dean, Student Services will complete the calculations and share those with the Coordinator, Financial Aid for review. The next week processing will be comple...

We are implementing a process of sharing the responsibility of processing recalculations of aid on a weekly rotation. One week the Assistant Dean, Student Services will complete the calculations and share those with the Coordinator, Financial Aid for review. The next week processing will be completed by the Coordinator, Financial Aid and reviewed by the Assistant Dean, Student Services. This will help ensure that two individuals have reviewed the calculations and agree on the dates and awards amounts included in the calculations.

View Audit 291241

Corrective Action Plans

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