Corrective Action Plans

Finding 389281 (2023-001)

Significant Deficiency 2023

MD

Matching / Level of Effort / Earmarking Student Financial Aid Subrecipient Monitoring § 200.303

Hagerstown Community College respectfully submits the following corrective action plan for the year ended June 30, 2023. Audit period: July 1, 2022 - June 30, 2023 The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the num...

Hagerstown Community College respectfully submits the following corrective action plan for the year ended June 30, 2023. Audit period: July 1, 2022 - June 30, 2023 The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. FINDINGS- FEDERAL AWARD PROGRAMS AUDITS U.S. Department of Education 2023-001 NSLDS Enrollment Reporting Student Financial Aid Cluster-Assistance Listing No. 84.063, 84.268 Condition: During testing of enrollment status reporting, we noted that the incorrect enrollment status and effective date was reported to NSLDS. Recommendation: The College should evaluate their procedures and policies related to reporting status changes to NSLDS and enhance as deemed necessary to ensure that accurate information is reported to NSLDS. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Cause-Enrollment Status Reporting: Hagerstown Community College utilizes the National Student Clearinghouse (NSC) as a third-party provider in order to submit student information to the NSLDS. Student enrollment status corrections were uploaded to NSC timely and correctly; however, monitoring of the upload through success was inconsistent, resulting in error reports preventing the accurate and timely update to the enrollment statuses in NSLDS. No review was completed to ensure the upload was completed in NSLDS. Cause for Effective Date Reporting - Hagerstown Community College utilizes the National Student Clearinghouse (NSC) as a third-party provider in order to submit student information to the NSLDS. Student effective date corrections were uploaded to NSC correctly; however, monitoring of the upload through success was inconsistent, resulting in error reports preventing the accurate update of the status effective date NSLDS. No review was completed to ensure the upload was completed in NSLDS. The following actions have been implemented to resolve the deficiencies: The Director of Financial Aid has reached out to NSC to determine the errors in the file transmissions. NSC responded back with the issues that need to be research by HCC's Student Financial Aid Office and Registrar's office. Both offices will collaborate to identify the error and develop procedures to minimize the error from happening again. HCC plans to review the reporting procedures for withdrawn and graduating students. NSC sent HCC a detailed explanation of what needs to be reviewed to make sure the correct information is transmitted. Name(s) of the contact person(s) responsible for corrective action: Dr. Charles M. Scheetz, Director of Financial Aid and W. Christopher Baer, Registrar Planned completion date for corrective action plan: Summer 2024

View Audit 300295

Finding 389279 (2023-003)

Material Weakness 2023

Saint Louis University

MO

Matching / Level of Effort / Earmarking Student Financial Aid Internal Control / Segregation of Duties § 200.303

Based on the recommendations outlined in this report, we are committed to enhancing our internal control process to ensure timely submission of Direct Loan and Pell Grant disbursement records to COD. This includes allocating necessary resources, providing additional training, and implementing robust...

Based on the recommendations outlined in this report, we are committed to enhancing our internal control process to ensure timely submission of Direct Loan and Pell Grant disbursement records to COD. This includes allocating necessary resources, providing additional training, and implementing robust monitoring and oversight mechanisms to address capacity constraints effectively and prevent future instances of noncompliance. Alex DeLonis, Assistant Vice President for Student Financial Services, is responsible for addressing the above items by June 2024.

View Audit 300294

Finding 388573 (2023-006)

Significant Deficiency 2023

Mid-Atlantc Christian University

NC

Questioned Costs Student Financial Aid Reporting

2023-006 Initial Fiscal Year End, 2023 Summary of Finding- During the audit, it was noted that the University incorrectly calculated institutional charges used in determining the amount of unearned aid to withdrawal. Name and Title of Responsible Contact Person(s)- Sara Shepherd, Vice President for ...

2023-006 Initial Fiscal Year End, 2023 Summary of Finding- During the audit, it was noted that the University incorrectly calculated institutional charges used in determining the amount of unearned aid to withdrawal. Name and Title of Responsible Contact Person(s)- Sara Shepherd, Vice President for Finance and Nicole Umphlett, Financial Aid Administrator Corrective Action Plan Summary- The University has recently made improvements to the process of completing the return to Title IV calculations. This was achieved by providing additional training and workshops offered through the Department of Education. Furthermore, we have also developed a spreadsheet to assist with calculating the returned aid due to withdraw. We will utilize this information to thoroughly double-check our calculations before issuing official documentation. Anticipated Completion Date- July 1, 2024

View Audit 300264 Questioned Costs: $1

Finding 388572 (2023-005)

Significant Deficiency 2023

Mid-Atlantc Christian University

NC

Questioned Costs Student Financial Aid Reporting

2023-005 Initial Fiscal Year End, 2023 Summary of Finding- During the audit, it was noted that the University used the incorrect sum of aid disbursed or disbursable to the student when applying the percentage earned in calculating the return to Title IV Funds upon student withdrawal. Name and Title ...

2023-005 Initial Fiscal Year End, 2023 Summary of Finding- During the audit, it was noted that the University used the incorrect sum of aid disbursed or disbursable to the student when applying the percentage earned in calculating the return to Title IV Funds upon student withdrawal. Name and Title of Responsible Contact Person(s)- Sara Shepherd, Vice President for Finance and Nicole Umphlett, Financial Aid Administrator Corrective Action Plan Summary- The University has enhanced the process of completing return to Title IV calculations by incorporating additional training and workshops provided by the Department of Education. The financial aid office has designed a calendar that displays the attendance days from the first day of school to the last day of school, referring to the school's master calendar. This will be used as a cross-check of days when computing returns. The return calculations were one day off due to the misinterpretation of the semester's ending date. Anticipated Completion Date- July 1, 2024

View Audit 300264 Questioned Costs: $1

Finding 388571 (2023-004)

Significant Deficiency 2023

Mid-Atlantc Christian University

NC

Questioned Costs Student Financial Aid Reporting

2023-004 Initial Fiscal Year End, 2023 Summary of Finding- During the audit, the University used the incorrect value for the total days in the students return to Title IV calculation. In completing the student's withdrawal, the institution used the incorrect amount of aid awarded/ disbursed for the ...

2023-004 Initial Fiscal Year End, 2023 Summary of Finding- During the audit, the University used the incorrect value for the total days in the students return to Title IV calculation. In completing the student's withdrawal, the institution used the incorrect amount of aid awarded/ disbursed for the applicable period. The university incorrectly calculated the institutional charges within the return to Title IV calculation. Name and Title of Responsible Contact Person(s)- Sara Shepherd, Vice President for Finance and Nicole Umphlett, Financial Aid Administrator Corrective Action Plan Summary-The University improved the process for completing return to Title IV calculations by adding in additional training and workshops offered through the Department of Education. The financial aid office created a calendar showing days of attendance from the first day of school to the last using the school's master calendar as a reference. This will be used also as a double check of days when calculating returns. The dates used in the return calculations were off a day due to misreading the ending date of semester. Anticipated Completion Date- July 1, 2024

View Audit 300264 Questioned Costs: $1

Finding 388570 (2023-003)

Significant Deficiency 2023

Mid-Atlantc Christian University

NC

Student Financial Aid Reporting Significant Deficiency

2023-003 Initial Fiscal Year End, 2023 Summary of Finding- During the audit, the University did not correctly report the student's enrollment status to National Student Loan Data System (NSLDS). The Department of Education had a waived window of errors from July 2022 to February 2023. Name and Title...

2023-003 Initial Fiscal Year End, 2023 Summary of Finding- During the audit, the University did not correctly report the student's enrollment status to National Student Loan Data System (NSLDS). The Department of Education had a waived window of errors from July 2022 to February 2023. Name and Title of Responsible Contact Person(s)- Sara Shepherd, Vice President for Finance and Nicole Umphlett, Financial Aid Administrator Corrective Action Plan Summary-The University is continuing to improve communication between the Registrar's office, Financial Aid office, National Student Clearinghouse, and NSLDS with the goal of clear and correct reporting to NSLDS. Staff between the different departments have participated in training on enrollment reporting and how National Student Clearinghouse works directly with NSLDS. A monthly check list has also been created to make sure items are getting completed. Anticipated Completion Date- July 1, 2024

View Audit 300264

Finding 388569 (2023-002)

Material Weakness 2023

Mid-Atlantc Christian University

NC

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

2023-002 Initial Fiscal Year End, 2023 Summary of Finding- During the 2023 audit, it was noted that the University's Gramm-Leach-Bliley Act Policy did not fully address all of the requirements as described by 16 CFR 314.4. In addition, the application of the comprehensive information security progra...

2023-002 Initial Fiscal Year End, 2023 Summary of Finding- During the 2023 audit, it was noted that the University's Gramm-Leach-Bliley Act Policy 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. Name and Title of Responsible Contact Person(s)- Sara Shepherd, Vice President for Finance and Nicole Umphlett, Financial Aid Administrator Corrective Action Plan Summary-The University has updated its Gramm-Leach-Bliley Act Policy to be in accordance with the requirements, and we have also put in place adequate controls and practices to ensure that the policy is monitored effectively. Anticipated Completion Date- February 1, 2024

View Audit 300264

Finding 388544 (2023-005)

Significant Deficiency 2023

State System of Higher Education, Commonwealth of Pennsylvania

PA

Matching / Level of Effort / Earmarking Student Financial Aid Significant Deficiency § 200.303

East Stroudsburg University: The University will implement the following processes for monthly reconciliations and maintenance of documentation: Federal direct loan reconciliations will be prepared on a monthly basis by a member of the financial aid office. A log will be kept of notating the month r...

East Stroudsburg University: The University will implement the following processes for monthly reconciliations and maintenance of documentation: Federal direct loan reconciliations will be prepared on a monthly basis by a member of the financial aid office. A log will be kept of notating the month reconciled, date reconciled and preparer. The monthly reconciliations will be reviewed and approved by the Director of Financial Aid or the Assistant Director of Financial Aid. The approver will notate the date reviewed and their initial in the reconciliation log. Records of direct loan reconciliations will be retained for 5 years for auditing purposes. Reconciliation procedures will be documented, and employees will receive proper training and support on an on‐going basis.

View Audit 300242

Finding 388538 (2023-004)

Significant Deficiency 2023

State System of Higher Education, Commonwealth of Pennsylvania

PA

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

West Chester University: The WCU financial aid team will request the Pell Reconciliation report on COD bi-weekly or weekly basis depending on our disbursements. This report contains Pell awards that have disbursed in our student information system (SIS) and are not recorded at COD. The report will b...

West Chester University: The WCU financial aid team will request the Pell Reconciliation report on COD bi-weekly or weekly basis depending on our disbursements. This report contains Pell awards that have disbursed in our student information system (SIS) and are not recorded at COD. The report will be uploaded into our SIS within 1-2 days. When the report is loaded in our SIS, we will review each file to see which files did not transmit to COD. For the files that fail, we will correct the error/issue in our SIS and send the file out to COD in a timely manner for processing. After our Pell reconciliation is complete, we wll review our SIS and COD to ensure records agree between our SIS and COD (award amounts and processing dates). WCU is currently reviewing its policies and procedures around COD reporting and will ensure students' information is reported timely and accurately between our SIS and COD. WCU understands and agrees that the errors identified in the program review relate to Pell Grant disbursement reporting; and agrees, if a similar error related to Direct Loan disbursement reporting occurred, it could result in skewed interest calculation as students' interest accrues based on the disbursement date reported to COD. Going forward, WCU will review the SIS and COD data to ensure that all booked files link to the appropriate dates between our SIS and COD. Kutztown University: We reviewed our policies and procedures for COD reporting. A financial aid resource has implemented a sweep every fourteen days to ensure that compliance with the 15-day rule for PELL reporting is met consistently.

View Audit 300242

Finding 388537 (2023-003)

Significant Deficiency 2023

State System of Higher Education, Commonwealth of Pennsylvania

PA

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

East Stroudsburg University: The University Records’ Office will implement policy and procedures to ensure the enrollment effective date, and program enrollment effective date are in alignment between the University system, the National Student Clearinghouse and NSLDS. In the situation where a stude...

East Stroudsburg University: The University Records’ Office will implement policy and procedures to ensure the enrollment effective date, and program enrollment effective date are in alignment between the University system, the National Student Clearinghouse and NSLDS. In the situation where a student is withdrawing from the University or being administratively withdrawn due to an unofficial withdrawal, the University Records” Office will monitor student accounts to ensure that adjustments made to student records are not overridden by automated procedures. All reporting will be completed through the National Student Clearinghouse. Kutztown University: We re-evaluated policies and procedures to ensure compliance in reporting. We worked with the Registrar’s Office to rectify any errors in a timely fashion, as well as to detail and update our processes moving forward. A new resource was identified for this responsibility, who is continuously monitoring our submissions to ensure they are accepted in a timely manner. A financial aid resource works in conjunction with the Registrar’s Office to ensure errors are addressed timely to certify the accuracy of our reporting. Cheyney University: Cheyney University of Pennsylvania currently utilizes the National Student Clearinghouse as a third-party service provider for enrollment reporting and provides all enrollment data to National Student Clearinghouse. The National Student Clearinghouse only includes enrollment data for students on the enrollment roster they receive from the National Student Loan Data System (NSLDS). Students did not appear on the rosters, so the National Student Clearinghouse did not provide the enrollment data to NSLDS. Cheyney University learned that NSLDS did not receive students' enrollment status changes from NSC. As of Spring 2023, Cheyney University has implemented procedures to report enrollment status changes and last date of attendance for all Title IV recipients to NSLDS. Beginning August 2024, Cheyney University will begin utilizing BANNER to create the required enrollment file and transmit the information directly to NSLDS vis EdConnect or TDClient. Commonwealth University (Lock Haven): Controls have been put in place across multiple offices to ensure that program enrollment effective date and program enrollment status is reported correctly to NSLDS. Actions will include, but are not limited to, timely review of changes and checking data files prior to upload. West Chester University: Initial action has been taken to update the student's record with NSLDS. WCU will also add an additional check to our transmission process to review the file for this specific scenario. We will develop a report from our student information system to assist us in this review.

View Audit 300242

Finding 388536 (2023-002)

Significant Deficiency 2023

State System of Higher Education, Commonwealth of Pennsylvania

PA

Student Financial Aid Reporting Significant Deficiency § 200.303

West Chester University: We have recently modified our submission schedule to ensure we have adequate time to prepare our files, conduct our pre-submission checks, and resolve errors prior to the monthly exchange of data between the National Student Clearinghouse and NSLDS. We will continue to monit...

West Chester University: We have recently modified our submission schedule to ensure we have adequate time to prepare our files, conduct our pre-submission checks, and resolve errors prior to the monthly exchange of data between the National Student Clearinghouse and NSLDS. We will continue to monitor the time it takes to complete these tasks and make any necessary modifications to support timely reporting to NSLDS. East Stroudsburg University: The University Records’ Office will implement policy and procedures to ensure students’ enrollment statuses are being reported to NSLDS through the National Student Clearinghouse. Reporting will occur on a monthly basis by means of the University Records’ Office transmitting a file to the National Student Clearinghouse. The University Records’s Office will monitor student statuses in NSLDS by randomly sampling students reported through the National Student Clearinghouse to ensure the accuracy of data being reported to NSLDS. Kutztown University: We re-evaluated our reporting procedures and worked with the Registrar’s Office to further redefine our process(es). The Registrar’s Office submits monthly transmissions to NSC (National Student Clearinghouse), who in turn updates our information to NSLDS. A new resource was identified for this responsibility, who is continuously monitoring our submissions to ensure they are accepted in a timely manner. A financial aid resource works in conjunction with the Registrar’s Office to ensure errors are addressed timely to certify the accuracy of our reporting. Cheyney University: Cheyney University of Pennsylvania currently utilizes the National Student Clearinghouse as a third-party service provider for enrollment reporting and provides all enrollment data to NSC, believing that enrollment would be reported to NSLDS in compliance with federal regulations; unfortunately, NSC only includes enrollment data for students on the enrollment roster they receive from the National Student Loan Data System (NSLDS). Cheyney University is a Heightened Cash Monitoring 2 (HCM2) institution, and students' Title IV aid/disbursements are reported differently than advance pay institutions. Students did not appear on the rosters, so NSC did not provide the enrollment data to NSLDS. While investigating the issues with enrollment reporting for our HCM2 students, Cheyney University learned that NSLDS did not receive students' enrollment from NSC. As of Spring 2023, Cheyney University has implemented procedures to report enrollment for all Title IV recipients to NSLDS. Beginning August 2024, Cheyney University will begin utilizing BANNER to create the required enrollment file and transmit the information directly to NSLDS vis EdConnect or TDClient.

View Audit 300242

Finding 388533 (2023-006)

Significant Deficiency 2023

State System of Higher Education, Commonwealth of Pennsylvania

PA

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

Pennsylvania Western University: This finding resulted from reporting issues caused by the complexity of integration. These reporting issues have been corrected and now accurately identify students who need to be reviewed for official and unofficial withdrawals. Cheyney University: In July 2023, Ch...

Pennsylvania Western University: This finding resulted from reporting issues caused by the complexity of integration. These reporting issues have been corrected and now accurately identify students who need to be reviewed for official and unofficial withdrawals. Cheyney University: In July 2023, Cheyney University signed an agreement with Financial Aid Services, LLC (FAS) to outsource many of the financial aid related functions. Return to Title IV (R2T4) was one of the functions outsourced. The process to begin outsourcing was started in December 2023. In addition to outsourcing R2T4, the Office of the Registrar will provide the Office of Student Financial Services (SFS) with a list of students who are not registered for each semester. This distribution will culminate with census reporting to PASSHE and allow SFS to notify about repayment and Return to Title IV processes. For students who apply for graduation for a particular semester, a distribution of names, identification numbers, and anticipated graduation semester, will be provided to SFS so that they can complete their exit counseling procedures.

View Audit 300242

Finding 388527 (2023-002)

Significant Deficiency 2023

Wittenberg University

OH

Student Financial Aid Matching / Level of Effort / Earmarking

Corrective Action Planned: The Office of Financial Aid acknowledges that there have previously been a lack of controls in place when monitoring the R2T4 process. The staff member who was previously responsible for this process is no longer employed at Wittenberg University. The Director of Financia...

Corrective Action Planned: The Office of Financial Aid acknowledges that there have previously been a lack of controls in place when monitoring the R2T4 process. The staff member who was previously responsible for this process is no longer employed at Wittenberg University. The Director of Financial Aid who joined Wittenberg in a permanent capacity in May 2023 has been cross-training the new staff in the office to ensure a system of checks and balances on each of the federal aid processes. Wittenberg will also be using the R2T4 process within Ellucian Colleague to ensure that there is no need for additional manual calculations and/or data entry to be done. Person Responsible for Corrective Action: Sigrun Olafsdottir, Director of Financial Aid Anticipated Completion Date: Fiscal year 2024

View Audit 300226

Finding 388475 (2023-001)

None 2023

Universidad Central Del Caribe, Inc.

PR

Student Financial Aid Eligibility Reporting

To correct the student reporting process in NSLDS and in addition to the actions already implemented, the following actions will be executed: 1. By June 30, 2024, achieve 100 % accurate reporting by performing a bi-monthly internal reconciliation (July, September, November, January, March, May): a. ...

To correct the student reporting process in NSLDS and in addition to the actions already implemented, the following actions will be executed: 1. By June 30, 2024, achieve 100 % accurate reporting by performing a bi-monthly internal reconciliation (July, September, November, January, March, May): a. Bi-monthly the first day of the month of the reporting period, the IEO and Registrar offices will prepare the Enrollment Changes List (ECL). The list will include withdrawals, LOA, graduations, and other enrollment status changes. The ECL will be conciliated with each academic program leader within 24 hours. b. 2 calendar days after (a), the Registrar will certify and sign the list to assure the enrollment status is accurate. c. 3 calendar days after (b), the Registrar Office and IEO will do the data entry in the NSLDS platform. d. 1 calendar days after (c), the reconciled Enrollment Changes List will be revised by the Assistant Dean of Licensing and Accreditation for validation. e. 2 days calendar after (d), the reconciled and validated ECL be revised by Academic Dean and Vice-President for certification of the accurate NSLDS reporting. 2. By June 30, 2024, achieve 100 % of accurate reporting to the NSLDS by continuing the implementation of the monthly process of reconciliation of withdrawals and verification of attendance in the SharePoint. 3. By June 30, 2024, assure quality improvement through re-training of all Registrar Office staff and academic programs leadership in the processes and responsibilities regarding compliance reporting of student status in NSLDS and our internal policies and procedures.

View Audit 300200

Finding 388472 (2023-005)

None 2023

Saint Elizabeth University

NJ

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

Federal Direct Loans Reconciliations Planned Corrective Action: The University’s Financial Aid Office will review the reconciliations to ensure that the Direct Loan Program is reconciled. We will also refer the ED announcement DL-22-07 to maintain consistent and accurate reconciliations. Person ...

Federal Direct Loans Reconciliations Planned Corrective Action: The University’s Financial Aid Office will review the reconciliations to ensure that the Direct Loan Program is reconciled. We will also refer the ED announcement DL-22-07 to maintain consistent and accurate reconciliations. Person Responsible for Corrective Action Plan: Nicholas Capodice, Director of Financial Aid Anticipated Date of Completion: April 30, 2024

View Audit 300191

Finding 388469 (2023-004)

Significant Deficiency 2023

Saint Elizabeth University

NJ

Questioned Costs Student Financial Aid Significant Deficiency

Unofficial Withdrawals Planned Corrective Action: The University will run zero credit reports at the end of each semester to ensure all potential unofficial withdrawals are followed up on so that R2T4’s are completed timely when required. Person Responsible for Corrective Action Plan: Nicholas Cap...

Unofficial Withdrawals Planned Corrective Action: The University will run zero credit reports at the end of each semester to ensure all potential unofficial withdrawals are followed up on so that R2T4’s are completed timely when required. Person Responsible for Corrective Action Plan: Nicholas Capodice, Director of Financial Aid Anticipated Date of Completion: June 30th, 2024

View Audit 300191 Questioned Costs: $1

Finding 388467 (2023-003)

Significant Deficiency 2023

Saint Elizabeth University

NJ

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

Common Origination and Disbursement (COD) Reporting Planned Corrective Action: The University’s Financial Aid Office will update the anticipated disbursement date to reflect the actual disbursement for 2022-23. We will review the current award year to ensure that the anticipated disbursement dates...

Common Origination and Disbursement (COD) Reporting Planned Corrective Action: The University’s Financial Aid Office will update the anticipated disbursement date to reflect the actual disbursement for 2022-23. We will review the current award year to ensure that the anticipated disbursement dates reflect the actual disbursement date. Person Responsible for Corrective Action Plan: Nicholas Capodice, Director of Financial Aid Anticipated Date of Completion: April 30, 2024

View Audit 300191

Finding 388461 (2023-002)

Significant Deficiency 2023

Brooklyn Law School

NY

Student Financial Aid Matching / Level of Effort / Earmarking Reporting

2023-002 Enrollment Reporting – Significant Deficiency United States Department of Education— ALN 84.268 Federal Direct Student Loans Program Criteria: Per CFR §658.309, unless it expects to submit its next updated enrollment report to the Secretary within the next 60 days, a school must notify the ...

2023-002 Enrollment Reporting – Significant Deficiency United States Department of Education— ALN 84.268 Federal Direct Student Loans Program Criteria: Per CFR §658.309, unless it expects to submit its next updated enrollment report to the Secretary within the next 60 days, a school must notify the Secretary within 30 days after the date the school discovers that: (i) a loan under title IV of the Act was made to or on behalf of a student who was enrolled or accepted for enrollment at the school, and the student has ceased to be enrolled on at least a half-time basis or failed to enroll on at least a half-time basis for the period for which the loan was intended; or (ii) a student who is enrolled at the school and who received a loan under title IV of the Act has changed his or her permanent address. Condition: For one out of 25 students sampled, the effective date reported in NSLDS was incorrect. For four out of 25 students sampled, the status change was not reported in NSLDS in the next enrollment report or within 30 days of the date of determination. Cause: The Law School does not have a formalized policy to address enrollment reporting for summer terms. Effect: Enrollment reporting was inaccurate. Federal loan servicers utilize this information to determine the appropriate status for repayment terms and as such, had incorrect information. Enrollment reporting was not submitted within the required time frame. Questioned Costs: None. Context: See condition above. Recommendation: We recommend the Law School enhance their procedures and formalize a written policy for all terms of enrollment reporting. Corrective Actions Taken: Julie Brown, the Registrar will be given access to the NSLDS database to verify the information submitted through the National Student Clearinghouse is reported completely and accurately, particularly in relation to enrollment statuses that change during the non-required summer terms. This is part of an ongoing process as this information is updated multiple times per year. The Registrars Office will also draft a policy including timelines for uploading information to the National Student Clearinghouse and dates for verification of information in NSLDS. Responsible party: Julie Brown, Registrar. 718-780-7918 julie.brown@brooklaw.edu

View Audit 300177

Finding 388456 (2023-003)

Significant Deficiency 2023

Colorado Mountain College

CO

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

Student Financial Aid Cluster: Federal Pell Grant Program – Assistance Listing No. 84.068 Federal Direct Student Loans – Assistance Listing No. 84.268 Recommendation: We recommend that the College work with their third-party servicer and implement procedures to ensure that enrollment data, changes ...

Student Financial Aid Cluster: Federal Pell Grant Program – Assistance Listing No. 84.068 Federal Direct Student Loans – Assistance Listing No. 84.268 Recommendation: We recommend that the College work with their third-party servicer and implement procedures to ensure that enrollment data, changes in status and effective dates within NSLDS are reported accurately and timely. And we recommend that the College implement formal review procedures to document the review process. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Registrar and Financial Aid departments have established a set schedule for enrollment reporting to the National Student Clearinghouse (NSC) and National Student Loan Database System (NSLDS) to ensure accurate and timely reporting happens each month and graduate reporting at the end of semester, within the 60-day window. To ensure CMC meets requirements to report all changes to enrollment and continuing enrollment within the 60-days, the monthly enrollment will follow best practice to submit every 30 days to allow time for correction of any errors prior to submission to NSLDS. The Student Affairs Systems Specialist will pull the enrollment report from CMC’s Student Information System (SIS) on the 19th for submission to NSC on the 20th of each month. If the 20th falls on the weekend it will be the Friday before. The Student Affairs Systems Specialist will correct any enrollment errors with NSC within 3 business days from the time of submission. The enrollment submission from NSC to NSLDS is scheduled for the 3rd of each month, and the Assistant Director of Financial Aid will pull a list from CMC’s SIS to match with NSLDS on the 15th of each month. If the 15th falls on the weekend it will be the Friday before. If there are any enrollment errors or missing students in NSLDS the Assistant Director of Financial Aid will notify the Student Affairs Systems Specialist to update student enrollment data within NSLDS. If there are no errors or missing enrollments in NSLDS, the Assistant Director of Financial Aid will send an email to the Student Affairs Systems Specialist to confirm the report is accurate and submitted. The graduate report will be submitted to NSC by the Student Affairs Systems Specialist on the second Friday after the end of the semester to allow for grade and graduation processing. The Assistant Director of Financial Aid will verify the graduate report within NSLDS two weeks after submission to NSC and email confirmation or request corrections with the Student Affairs Systems Specialist. Name(s) of the contact person(s) responsible for corrective action: Natalie Torres and Janelle Cook Planned completion date for corrective action plan: May 2024

View Audit 300168

Finding 388452 (2023-002)

Significant Deficiency 2023

Colorado Mountain College

CO

Questioned Costs Student Financial Aid Subrecipient Monitoring § 200.303

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 Reco...

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 Recommendation: CLA recommends that the College review the requirement and implement a monitoring control to monitor the checks throughout the year. In addition, for the checks outstanding greater than 240 days, the College should return the funding to the U.S. Department of Education. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: To enhance the 240 Day Outstanding refund check processing efficiency and compliance, a streamlined procedure was developed and implemented to monitor all uncashed refund checks, including those from federal aid sources. This process will involve utilizing an Informer report every two weeks to compile a comprehensive list of uncashed refund checks for current and prior terms. Upon identification, a system-generated communication will be promptly dispatched to students, notifying them of the outstanding refund check and providing clear instructions to contact the Business Office. Calculations will be performed to ascertain if the refund originates from a federal aid source. For students with federal aid-related outstanding refunds, outreach efforts will be undertaken. Additionally, a progressive maintained cumulative report will serve as a real-time monitoring mechanism to track the status of refunds and ensure timely compliance. Continuous open communication will be maintained with the Financial Aid and Compliance team, facilitating the provision of student refunds requiring action and fostering collaboration across departments to address any outstanding issues effectively. The above-detailed process has already proven effective and noticeably successful in addressing the challenges associated with uncashed refund checks, particularly those originating from federal aid sources. Moving forward, this process will be continuously optimized and refined as system enhancements allow. Regular evaluations will be conducted to identify areas for improvement and implement necessary adjustments, ensuring that the refund processing workflow remains efficient, compliant, and responsive to the evolving needs of both students and regulatory requirements. This commitment to ongoing optimization underscores our dedication to providing timely and accurate refunds while upholding the highest standards of financial stewardship and accountability. Name(s) of the contact person(s) responsible for corrective action: Renee McBride Planned completion date for corrective action plan: January 2024

View Audit 300168 Questioned Costs: $1

Finding 388448 (2023-001)

Significant Deficiency 2023

Colorado Mountain College

CO

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

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 Reco...

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 Recommendation: We recommend the college reevaluate their procedures regarding the return of Title IV funds including the implementation of secondary review of calculations. This would prevent future errors, and provide a greater level of internal control. Additionally, we recommend they review policies regarding the timeliness and accuracy of student enrollment. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: CMC established a new secondary review procedure to help prevent future errors and provide a greater level of internal control regarding the return of Title IV funds (R2T4). Going forward, after an R2T4 is completed, the Quality Assurance (QA) review will be processed. As part of this review, the Financial Aid and Scholarship Coordinator will be notified that all R2T4’s have been completed for the current week. They will then pull up the spreadsheet of students who had an R2T4 completed and select at random at least 10% of the students on that list to review. In this review they will examine the following data for each of the selected students:  Each class for that semester including the name of the class, the dates the class took place, the credit load of the class, the last date of attendance (LDA) for each class, if the class counts towards the program, if the class was marked as never attended, and if the class should be used in the R2T4.  The Institutional charges to ensure the correct charges were used.  The Days attended vs Total days to ensure that any break of 5 or more days was removed. To document the review, the Financial Aid and Scholarship Coordinator will initial next to each class that they check as they review. The Financial Aid and Scholarship Coordinator will also review that the awards were updated in the Colleague AIDE screen correctly based on the calculation and ensure that any Post-Withdrawal Disbursement (PWD) or return is processed accurately. They will also verify that the Exit counseling request was sent to the student (this is indicated in the CRI screen). Once the review is completed, the Financial Aid and Scholarship Coordinator will initial and date the spreadsheet for the student that they performed the review on. They will then change the color on the spreadsheet tab to indicate that it was reviewed. Name(s) of the contact person(s) responsible for corrective action: Reilly Watanabe, JoAnna Hulett and Janelle Cook Planned completion date for corrective action plan: July 2023

View Audit 300168 Questioned Costs: $1

Finding 388403 (2023-002)

Significant Deficiency 2023

Heidelberg University

OH

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

Due to turnover in the financial aid office, verification was performed incorrectly prior to the employment of the current Director of Financial Aid. Since a new Director of Financial Aid has been employed, the verification tracking group of each student selected is reviewed prior to completing the ...

Due to turnover in the financial aid office, verification was performed incorrectly prior to the employment of the current Director of Financial Aid. Since a new Director of Financial Aid has been employed, the verification tracking group of each student selected is reviewed prior to completing the verification process to ensure each student is verified in accordance with the CPS assigned tracking group.

View Audit 300140

Finding 388399 (2023-001)

Significant Deficiency 2023

Heidelberg University

OH

Questioned Costs Student Financial Aid Special Tests & Provisions

The academic calendar used for return of funds calculations will be reviewed by a separate individual in the Financial Aid Office. We will review each calculation as it is completed to verify that the number of days in the semester have been reported correctly for each student.

View Audit 300140 Questioned Costs: $1

Finding 388398 (2023-001)

Significant Deficiency 2023

Colgate University

NY

Cash Management Student Financial Aid § 200.516

COLGATE UNIVERSITY. Corrective Action Plan – Finding 2023-001. Responsible Official – Kyle Dombrowski, Director of Tax and Financial Reporting. We will perform and document a review of reimbursement submissions before they are processed to ensure that reimbursement requests are not in excess of fund...

COLGATE UNIVERSITY. Corrective Action Plan – Finding 2023-001. Responsible Official – Kyle Dombrowski, Director of Tax and Financial Reporting. We will perform and document a review of reimbursement submissions before they are processed to ensure that reimbursement requests are not in excess of funds disbursed for the period. After the error in the Federal Direct Loan reimbursement for November 2022 was identified, we implemented a new requirement that the Director of Tax and Financial Reporting or the AVP/Controller must review the reimbursement request calculated by the Assistant Controller/Director of Grant Accounting before it can be processed. As of June 30, 2023, this review was fully implemented. Anticipated Completion Date: 3/27/2024.

View Audit 300136

Finding 388351 (2023-001)

None 2023

Thiel College

PA

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

Federal Program: Student Financial Assistance Cluster - Federal Direct Student Loan Program Federal Agency: U.S. Department of Education Pass-Through Entity: Not applicable Assistance Listing Number: 84.268 Federal Award Year: June 30, 2023 Criterion: Title IV regulations (34 CFR 685.309b) require t...

Federal Program: Student Financial Assistance Cluster - Federal Direct Student Loan Program Federal Agency: U.S. Department of Education Pass-Through Entity: Not applicable Assistance Listing Number: 84.268 Federal Award Year: June 30, 2023 Criterion: Title IV regulations (34 CFR 685.309b) require that upon receipt of an enrollment report from the Secretary, Institutions must update all information included in the report and return the report to the Secretary; (i) in the manner and format prescribed by the Secretary; and (ii) within the timeframe prescribed by the Secretary. Unless it expects to submit its next updated enrollment report to the Secretary within the next 60 days, an Institution must notify the Secretary within 30 days after the date the Institution discover that: (i) a loan under Title IV of the Act was made to or on behalf of a student who was enrolled or accepted for enrollment at the Institution and the student has ceased to be enrolled on at least a half-time basis or failed to enroll on at least a half-time basis for the period for which the loan was intended; or (ii) a student who is enrolled at the Institution and who received a loan under Title IV of the Act has changed his or her permanent address. Condition and Context: For one student out of 25 selected for testing, the College did not notify the NSLDS in a timely matter for a change in enrollment status. Cause and Effect: The College failed to follow its procedures for reporting student status changes. The accuracy of Title IV student loan records depends heavily on the accuracy of the enrollment information reported by schools. If an institution does not review, update, and verify student enrollment statuses, effective dates of the enrollment status, and the anticipated completion dates, then the Title IV student loan records will be inaccurate in NSLDS. Recommendation: The College should implement a process and related to verify with NSLDS that all enrollment status information for all students is updated accurately and timely. Recommendation: The College should implement a process and related to verify with NSLDS that all enrollment status information for all students is updated accurately and timely. Corrective Action Plan The College will continue to work with the NSC Audit Response Team, Office of the Registrar, and Office of Information Technology to resolve the data reporting issues we are currently experiencing. Denise Owens, Student Loan Specialist and Debra Schreiber, Registrar will work together to provide manual data reporting to NSLDS in an accurate and timely manner. Responsible Persons Michelle Work, Director of Financial Aid Denise Owens, Student Loan Specialist Dr. Laura Pickens, Associate Dean for Academic Programs and Records Debra Schreiber, Registrar Anticipated Completion Date This is an ongoing process and will begin immediately.

View Audit 300134

Corrective Action Plans

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