Corrective Action Plans

Finding 391127 (2023-004)

Significant Deficiency 2023

SD

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

Identifying Number: 2023-004: U.S. Department of Education: Student Financial Aid Cluster – 84.268, Federal Direct Student Loans Finding: During testing of disbursement notifications, one student did not receive the notification in a timely manner. Corrective Action Taken or Planned: STC Financial A...

Identifying Number: 2023-004: U.S. Department of Education: Student Financial Aid Cluster – 84.268, Federal Direct Student Loans Finding: During testing of disbursement notifications, one student did not receive the notification in a timely manner. Corrective Action Taken or Planned: STC Financial Aid Office will continue to monitor disbursements and work to create a report of notifications sent or errors so that notifications are not missed. Contact person: Micah Hansen, Director of Financial Aid, Southeast Technical College Status of finding – The above corrective actions will be implemented beginning July 1, 2024.

View Audit 301715

Finding 391126 (2023-003)

Significant Deficiency 2023

Sioux Falls School District 49-5

SD

Questioned Costs Student Financial Aid Subrecipient Monitoring

Identifying Number: 2023-003: U.S. Department of Education: Student Financial Aid Cluster – 84.268, Federal Direct Student Loans Finding: For one student out of 61 students tested, an incorrect amount of subsidized and unsubsidized loan was awarded. Corrective Action Taken or Planned: STC Financial ...

Identifying Number: 2023-003: U.S. Department of Education: Student Financial Aid Cluster – 84.268, Federal Direct Student Loans Finding: For one student out of 61 students tested, an incorrect amount of subsidized and unsubsidized loan was awarded. Corrective Action Taken or Planned: STC Financial Aid Office will request a list of Build Dakota students and estimated scholarship amounts at the beginning of the academic year. This information will be added into the student’s financial aid packaging formula to review for potential changes needed in federal aid awards. Once the Business Office has completed applying Build Dakota funds for the term, the information will be shared with the Financial Aid Office to make adjustments to the original estimates used. Contact person: Micah Hansen, Director of Financial Aid, Southeast Technical College Status of finding – The above corrective actions will be implemented beginning July 1, 2024.

View Audit 301715 Questioned Costs: $1

Finding 391125 (2023-012)

Significant Deficiency 2023

State of Iowa

IA

Allowable Costs / Cost Principles Student Financial Aid

The Department will retrain staff on when an overpayment is needed, when to cancel a case and what to look for in the system when an alert is received about a child entering foster care. A reminder will be provided to all Income Maintenance staff providing the policies and procedures for duplicate ...

The Department will retrain staff on when an overpayment is needed, when to cancel a case and what to look for in the system when an alert is received about a child entering foster care. A reminder will be provided to all Income Maintenance staff providing the policies and procedures for duplicate benefits. This reminder will be emailed and also discussed at team staff meetings.

View Audit 301710

Finding 390876 (2023-001)

Significant Deficiency 2023

Spring Hill College

AL

Student Financial Aid Matching / Level of Effort / Earmarking Allowable Costs / Cost Principles

(Repeat) Federal Direct Student Loans, ALN 84.268; Grant period—Year ended June 30, 2023 Condition: There was lack of documentation related to disbursement notices and exit counseling for eight out of thirty-four students tested. Criteria: According to §668.165, before an institution disburses tit...

(Repeat) Federal Direct Student Loans, ALN 84.268; Grant period—Year ended June 30, 2023 Condition: There was lack of documentation related to disbursement notices and exit counseling for eight out of thirty-four students tested. Criteria: According to §668.165, before an institution disburses title IV, HEA program funds for any award year, the institution must notify a student of the amount of funds that the student or his or her parent can expect to receive under each title IV, HEA program, and how and when those funds will be disbursed. Additionally, according to §682.604, a school must ensure that exit counseling is conducted with each loan borrower and graduate either in person, by audiovisual presentation, or by interactive electronic means. Cause: The College was unable to locate the documents for the students as a result of transitioning softwares. Effect: Certain documentation for disbursement notices and exit counseling was lost during the transition of the College's software. Context: During the compliance audit testing of ALN 84.268, it was determined that documentation to confirm delivery of disbursement notices and performance of exit counseling could not be provided for certain students selected for testing. Recommendation: We recommend all required documentation be backed up to support compliance with certain requirements. View of Responsible Officials and Planned Corrective Action: The College is currently working with their IT department to make sure that all types of communication includes copying the financial aid department email to make sure the College has support for all communications to prevent this in the future.

View Audit 301577

Finding 390641 (2023-220)

None 2023

State of Idaho

ID

Questioned Costs Student Financial Aid Eligibility

Finding Number 2023-220: The Department failed to provide necessary supporting documentation for five Adoption Assistance Title IV-E eligibility determinations. Federal Programs: 93.659 – Adoption Assistance Related to Prior Finding: N/A Agency’s view: The Department agrees with this finding. ...

Finding Number 2023-220: The Department failed to provide necessary supporting documentation for five Adoption Assistance Title IV-E eligibility determinations. Federal Programs: 93.659 – Adoption Assistance Related to Prior Finding: N/A Agency’s view: The Department agrees with this finding. Corrective Action: The department agrees with the finding related to the critical importance of obtaining and maintaining documentation for all necessary background checks. Although the department was ultimately able to verify background checks were completed, we agree that we were unable to readily pull the needed documentation on these in a timely manner. The department will assure supporting documentation for Adoption Assistance Title IV-E eligibility determinations are maintained within the electronic filing system by adding an additional verification to the current process. When a supervisor reviews a departmental adoption for finalization, they will verify that a copy of the Enhanced Criminal History Background clearance letter for all adults residing in the home is uploaded to the prospective adoptive parents’ profile in eCabinet (the electronic case management system), and the signed copy of the adoption assistance agreement is uploaded to the child’s profile. The application process for Adoption Assistance Title IV-E eligibility for private adoptions will be updated to include the addition of the Enhanced Criminal History Background clearance letters for all adults residing in the home to the child’s eCabinet file. When a supervisor approves an adoption assistance agreement for a private adoption, they will verify a copy of the signed adoption assistance agreement is uploaded to the adoptive child’s profile. This will be completed by August 2024. Anticipated Corrective Action Date: August 2024 Responsible for Corrective Action: Cameron Gilliland, Division Administrator Cameron.Gilliland@dhw.idaho.gov 208-334-0641 Kelly Combs, Bureau Chief, Compliance Kelly.Combs@dhw.idaho.gov 208-334-5814

View Audit 301345 Questioned Costs: $1

Finding 390639 (2023-218)

None 2023

State of Idaho

ID

Questioned Costs Student Financial Aid Eligibility

Finding Number 2023-218: The Department failed to provide necessary documentation to support the eligibility determination for two foster care providers within the Foster Care -Title IV—E program. Federal Programs: 93.658 – Foster Care Title IV-E Related to Prior Finding: N/A Agency’s view: The D...

Finding Number 2023-218: The Department failed to provide necessary documentation to support the eligibility determination for two foster care providers within the Foster Care -Title IV—E program. Federal Programs: 93.658 – Foster Care Title IV-E Related to Prior Finding: N/A Agency’s view: The Department agrees with this finding. Corrective Action: The department agrees with the finding related to the critical importance of obtaining and maintaining documentation for all necessary background checks. Although the department was ultimately able to verify background checks were completed, we agree that we were unable to readily pull the needed documentation on these in a timely manner. To correct the issue, the department will add an additional point of verification that the Enhanced Criminal History Background Check clearance letter from the Background Check Unit’s system is uploaded to eCabinet, by having supervisors view the document within eCabinet prior to approving the initial foster care license. Supervisors will also confirm that all ICPC home studies address results of background checks for all adults in the home and any additional potential caregivers. This will be completed April 2024. Anticipated Corrective Action Date: April 2024 Responsible for Corrective Action: Cameron Gilliland, Division Administrator Cameron.Gilliland@dhw.idaho.gov 208-334-0641 Kelly Combs, Bureau Chief, Compliance Kelly.Combs@dhw.idaho.gov 208-334-5814

View Audit 301345 Questioned Costs: $1

Finding 390638 (2023-217)

Material Weakness 2023

State of Idaho

ID

Allowable Costs / Cost Principles Internal Control / Segregation of Duties Student Financial Aid § 200.303

Finding Number 2023-217: The Department does not have documented internal controls for adjustments processed to the Foster Care -Title IV—E program. Federal Programs: 93.658 – Foster Care Title IV-E Related to Prior Finding: N/A Agency’s view: The Office agrees with this finding. Corrective Act...

Finding Number 2023-217: The Department does not have documented internal controls for adjustments processed to the Foster Care -Title IV—E program. Federal Programs: 93.658 – Foster Care Title IV-E Related to Prior Finding: N/A Agency’s view: The Office agrees with this finding. Corrective Action: The Department will continue to record adjustment activity through Help Desk tickets, SharePoint documentation, and ESPI. The Department will ensure improved visibility to the adjustment and approval process and documentation by ensuring all roles who need access (including auditors), have access to all relevant systems and storage locations such as access to SharePoint and Help Desk tickets. This step will be completed by April 30, 2024. Anticipated Corrective Action Date: April 30, 2024 Responsible for Corrective Action: Cameron Gilliland, Division Administrator Cameron.Gilliland@dhw.idaho.gov 208-334-0641 Kelly Combs, Bureau Chief, Compliance Kelly.Combs@dhw.idaho.gov 208-334-5814

View Audit 301345

Finding 390571 (2023-003)

Significant Deficiency 2023

Lemoyne-Owen College

TN

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

Finding 2023-003 – U.S. Department of Education (USDE), Title IV Student Financial Aid Programs (Significant Deficiency): We observed the following condition in connection with our testing of the various U.S. Department of Education, Title IV, Student Financial Assistance Programs: • The College fai...

Finding 2023-003 – U.S. Department of Education (USDE), Title IV Student Financial Aid Programs (Significant Deficiency): We observed the following condition in connection with our testing of the various U.S. Department of Education, Title IV, Student Financial Assistance Programs: • The College failed to submit their Crime and Safety report for testing. The College should implement corrective actions to ensure that the above findings are resolved and will not recur in future periods. Corrective Action – A new CFO has been hired and is in the process of reorganizing Financial Aid Office operations, hiring additional staff, and training existing staff.

View Audit 301332

Finding 390567 (2023-002)

Significant Deficiency 2023

Lemoyne-Owen College

TN

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

Finding 2023-002 – U.S. Department of Education (USDE), Title IV Student Financial Aid Programs (Significant Deficiencies): We observed the following condition in connection with our testing of the various U.S. Department of Education, Title IV, Student Financial Assistance Programs: • The College h...

Finding 2023-002 – U.S. Department of Education (USDE), Title IV Student Financial Aid Programs (Significant Deficiencies): We observed the following condition in connection with our testing of the various U.S. Department of Education, Title IV, Student Financial Assistance Programs: • The College had differences in the following programs which were not reconciled to the general ledger: Federal Work Study, Federal Pell Grant and Federal Supplemental Educational Opportunity Grant (SEOG), which caused unreconciled data to be used on the Fiscal Operations Report and Application to Participate (FISAP). Citation: SFA handbook Ch. 5 CFR668.161 – 668.176. The College should implement corrective actions to ensure that the above findings are resolved and will not recur in future periods. Corrective Action – A new CFO and financial aid director have been hired. The CFO is in the process of reorganizing Business Office operations, hiring additional staff, and training existing staff to ensure the monthly reconciliations of all programs and accurate completion of required federal reports. The financial aid director as well as the controller will be responsible for maintenance of those monthly reconciliations.

View Audit 301332

Finding 390552 (2023-005)

Significant Deficiency 2023

Wilberforce University

OH

Student Financial Aid Matching / Level of Effort / Earmarking Eligibility

Views of Responsible Officials and Planned Corrective Actions: Management agrees with the auditors and has initiated the necessary corrective action plan to mitigate the deficiency from occurring again. The plan is to implement new procedures to ensure the reporting to the NSLDS is done on a timely ...

Views of Responsible Officials and Planned Corrective Actions: Management agrees with the auditors and has initiated the necessary corrective action plan to mitigate the deficiency from occurring again. The plan is to implement new procedures to ensure the reporting to the NSLDS is done on a timely basis. Implementation date: Immediately. Persons Responsible: Vice President of Business & Finance, the Registrars Office and the Director of Student Financial Aid.

View Audit 301315

Finding 390551 (2023-001)

Material Weakness 2023

Michigan Barber School

MI

Student Financial Aid

FINDING 2023-1- Missing Return-to-Title IV (R2T4) Calculations

View Audit 301309

Finding 390551 (2023-001)

Material Weakness 2023

Michigan Barber School

MI

Student Financial Aid

The Institute was unable to locate Return-to-Title IV calculations for six (6) students who withdrew during the audit period.

View Audit 301309

Finding 390551 (2023-001)

Material Weakness 2023

Michigan Barber School

MI

Student Financial Aid

A. Comments on Findings and Recommendations:

View Audit 301309

Finding 390551 (2023-001)

Material Weakness 2023

Michigan Barber School

MI

Student Financial Aid

The Institute agrees with the finding and Auditor’s recommendation.

View Audit 301309

Finding 390551 (2023-001)

Material Weakness 2023

Michigan Barber School

MI

Student Financial Aid

B. Actions Taken or Planned

View Audit 301309

Finding 390551 (2023-001)

Material Weakness 2023

Michigan Barber School

MI

Student Financial Aid

The Institute will re-perform the R2T4 calculations and determine if there were any refunds due back to the Pell Grant Program. Further, the Institute will perform a full-file review of all students withdrawing during the year ended June 30, 2023 to ensure the R2T4 calculation was performed and the ...

The Institute will re-perform the R2T4 calculations and determine if there were any refunds due back to the Pell Grant Program. Further, the Institute will perform a full-file review of all students withdrawing during the year ended June 30, 2023 to ensure the R2T4 calculation was performed and the refunds to the Pell Grant program were accurate.

View Audit 301309

Finding 390551 (2023-001)

Material Weakness 2023

Michigan Barber School

MI

Student Financial Aid

Status of Corrective Actions on Prior Findings

View Audit 301309

Finding 390551 (2023-001)

Material Weakness 2023

Michigan Barber School

MI

Student Financial Aid

The audit report contains the Auditors Comment on Resolution Matters relating to Prior Year Audit Findings.

View Audit 301309

Finding 390522 (2023-001)

None 2023

Saint Francis University

PA

Student Financial Aid Reporting

Condition The Federal Supplemental Educational Opportunity Grants and Federal Work Study Program sections of the FISAP (Part VI), contained several inputs that could not be reconciled to underlying supporting documentation. Corrective Action Plan Corrective Action Planned: The newly hired Director o...

Condition The Federal Supplemental Educational Opportunity Grants and Federal Work Study Program sections of the FISAP (Part VI), contained several inputs that could not be reconciled to underlying supporting documentation. Corrective Action Plan Corrective Action Planned: The newly hired Director of Financial Aid will be required to retain all data and reports related to the FISAP report which relates to the audit. The Director has been cross training the necessary Financial Aid Office Staff in process of obtaining and retaining all data related to the FISAP. The Director has taken the time to refer to previous reports, notes, and instructions in completing the 2023 FISAP. The sections in question have been completed correctly and have similar reporting to prior years. Name(s) of Contact Person(s) Responsible for Corrective Action: Tom Kendziora, Director of Financial Aid Anticipated Completion Date: September 30, 2023

View Audit 301276

Finding 390465 (2023-003)

Significant Deficiency 2023

Adrian College

MI

Student Financial Aid Significant Deficiency

Condition: Certain credit balances were not refunded to students within the required fourteen (14) days. Context - Of the 25 students tested, there was 1 student who had credit balances created by Title IV funds that were not refunded within 14 days. Planned Corrective Action: The Manager of Student...

Condition: Certain credit balances were not refunded to students within the required fourteen (14) days. Context - Of the 25 students tested, there was 1 student who had credit balances created by Title IV funds that were not refunded within 14 days. Planned Corrective Action: The Manager of Student Business Services, working with the Director of Financial Aid, will identify to the Vice-President of Business Affairs (VPBA) those students who are scheduled to receive special supplemental institutional aid (refer to Note below) and identify if that supplemental aid amount will place the student in a credit balance. The VPBA will then determine if the supplemental aid amount should be adjusted. If there is no adjustment, any credit balance will be processed for refund within the required fourteen (14) day period. Note: This finding relates to a certain classification of students who receive supplemental intuitional aid in the form of a special scholarship (“The Godard Scholarship”). The intent of the scholarship was to supplement other forms of financial aid available to students such that the student’s account balance would equal zero. The scholarship amount was not adjusted from that originally communicated to students resulting in some students having a credit balance on their account. Rather than reducing the scholarship amount, the administration elected to honor that amount initially communicated to the scholarship recipients. The timing of this decision contributed to refund payments being delayed beyond the allowable period for this certain classification of students. There were no questioned costs associated with the finding. Contact person responsible for corrective action: Jerry Wright VP Business Affairs/CFO Anticipated Completion Date: Academic Year 2023-2024

View Audit 301249

Finding 390464 (2023-002)

None 2023

Adrian College

MI

Student Financial Aid Reporting Matching / Level of Effort / Earmarking

Condition: The College did not report certain students’ status to the National Student Loan Data System (NSLDS) in an accurate and timely manner during the fiscal year. Context - There were two errors identified that attributed to this finding: 1) Of the 40 students tested, there were 10 students w...

Condition: The College did not report certain students’ status to the National Student Loan Data System (NSLDS) in an accurate and timely manner during the fiscal year. Context - There were two errors identified that attributed to this finding: 1) Of the 40 students tested, there were 10 students who withdrew or graduated whose status changes were not reported accurately to the NSLDS. The students were reported timely but with an incorrect effective date. 2) Of the 40 students tested, there were 33 students who withdrew or graduated whose status changes were not reported to the NSLDS within 60 days. Planned Corrective Action: The College corrective action plan implemented as of the time of this communication has included integrated feedback from multiple campus constituencies received through a series of meetings led by our Academic Dean in order to define a process focused on managing this particular compliance obligation. The participating departments included; Academic Affairs, Enrollment, Financial Aid, Business Office, IT, Registrar, Student Life, Academic Services and the President’s Office. The result was development of an internal policy with clearly defined protocols, procedures and timelines (referred to as the “Adrian College Data Integrity Notification Guidelines” policy document). Assessment will be periodically evaluated via the College’s internal audit process. Note: • Re status change for withdrawn or graduating students: The College submitted its report to the National Student Clearinghouse (NSC) twenty-eight (28) days prior to the sixty (60) day requirement to be received by the NSLDS. The College was subsequently notified by NSC that it had been the victim of a third-party security breach. We believe this event contributed to delay for the NSC to review, certify and post to the NSLDS; contributing to this finding. Re student reporting with incorrect effective dates posted: It appears that the effective dates submitted by the College to NSC were subsequently modified within the NSC database. We believe a third-party security breach identified to the College by NSC may have contributed to the posting of incorrect effective dates to NSLDS; contributing to this finding. There were no questioned costs associated with the finding. Contact person responsible for corrective action: Andrea Milner VP Academic Affairs/Dean Anticipated Completion Date: Academic Year 2023-2024

View Audit 301249

Finding 390445 (2023-004)

Significant Deficiency 2023

Oregon Tech

OR

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

Student Financial Assistance Cluster – Assistance Listing No. 84.038 Recommendation: We recommend that they assign the loans back to the Department of Education or have the students resign the loans via Electronic MPN or Paper MPN and retain those in the proper manner. Explanation of disagreement ...

Student Financial Assistance Cluster – Assistance Listing No. 84.038 Recommendation: We recommend that they assign the loans back to the Department of Education or have the students resign the loans via Electronic MPN or Paper MPN and retain those in the proper manner. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Management respectfully agrees on all findings and recommendations. Management will engage in additional staff training and is committed to consistent application of current policies and procedures to ensure all student loan documentation is maintained per the U.S. Department of Education policies. Management will assign the respective loans back to the Department of Education as to be in compliance with U.S. Department of Education requirements. Name(s) of the contact person(s) responsible for corrective action: Karissa Sultan Planned completion date for corrective action plan: June 30, 2024

View Audit 301235

Finding 390438 (2023-001)

Significant Deficiency 2023

Oregon Tech

OR

Student Financial Aid Subrecipient Monitoring Reporting § 200.303

Student Financial Assistance Cluster – Assistance Listing No. 84.268, 84.063, 84.007 Recommendation: CLA recommends that the University enhance its policies and procedures regarding enrollment reporting including additional monitoring over the third-party service provider to ensure that reporting i...

Student Financial Assistance Cluster – Assistance Listing No. 84.268, 84.063, 84.007 Recommendation: CLA recommends that the University enhance its policies and procedures regarding enrollment reporting including additional monitoring over the third-party service provider to ensure that reporting is completed accurately and timely. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Management respectfully agrees on all findings and recommendations. Management will engage in additional staff training and is committed to consistent application of current policies and procedures to ensure enrollment reporting and monitoring of third-party service providers results in accurate and timely reporting by the third-party service provider. While the third-party service provider has a national monopoly on enrollment reporting, with other institutions of higher education also facing similar reporting issues by the third-party service provider, Management believes that enhanced training and internal procedures over enrollment reporting will mitigate accuracy and timeliness errors made by the third party service provider, resulting in the University meeting U.S. Department of Education requirements. Name(s) of the contact person(s) responsible for corrective action: Ashlie Pence Planned completion date for corrective action plan: June 30, 2024

View Audit 301235

Finding 390420 (2023-005)

Material Weakness 2023

Delaware State University

DE

Matching / Level of Effort / Earmarking Student Financial Aid Material Weakness § 200.303

2023-005 Student Financial Assistance Cluster – Federal Assistance Listing Nos. 84.063, and 84.268 – Enrollment Reporting Recommendation: We recommend the University evaluate its procedures and review policies in overseeing submissions to the NSLDS completed by the third-party servicer. Additionally...

2023-005 Student Financial Assistance Cluster – Federal Assistance Listing Nos. 84.063, and 84.268 – Enrollment Reporting Recommendation: We recommend the University evaluate its procedures and review policies in overseeing submissions to the NSLDS completed by the third-party servicer. Additionally, 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 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: The Registrar’s Office will strengthen procedures and reporting practices to ensure timely submission to the National Student Clearinghouse (NSCL) & the National Student Load Data System (NSLDS). The Registrar’s Office will confirm and ensure the submissions to the National Student Clearinghouse (NSCL) corresponds with the timeframe the enrollment is rolled over to the National Student Loan Data System (NSLDS). Name(s) of the contact person(s) responsible for corrective action: Registrar, Dr. Genita Mangum Planned completion date for corrective action plan: July 2024

View Audit 301226

Finding 390410 (2023-002)

Significant Deficiency 2023

Metropolitan Community College Area

NE

Student Financial Aid Significant Deficiency Internal Control / Segregation of Duties

Student Financial Assistance Cluster Recommendation: We recommend the College reviews their policies to ensure all requirements from the Department of Education are met. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to findi...

Student Financial Assistance Cluster Recommendation: We recommend the College reviews their policies to ensure all requirements from the Department of Education are met. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: MCC SAP policy has been corrected and updated to meet federal requirements on calculating the pace a student must progress through their educational program. Moving forward Financial Aid Management will review their policies and procedures annually to ensure that we are meeting all Department of Education SAP requirements. Name(s) of the contact person(s) responsible for corrective action: Kelsey Scott Planned completion date for corrective action plan: Spring 2024

View Audit 301214

Corrective Action Plans

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