Corrective Action Plans

Finding 387124 (2023-002)

Significant Deficiency 2023

KS

Student Financial Aid Reporting Significant Deficiency

Eligibility and Certification Approval Report (ECAR) Award Period: July 1, 2022 to June 30, 2023 Type of Finding: Significant Deficiency in Internal Control over Compliance; Other Matters Recommendation: We recommend the College review its reporting procedures surrounding updating the ECAR to ensure...

Eligibility and Certification Approval Report (ECAR) Award Period: July 1, 2022 to June 30, 2023 Type of Finding: Significant Deficiency in Internal Control over Compliance; Other Matters Recommendation: We recommend the College review its reporting procedures surrounding updating the ECAR to ensure reporting is accurate and completed. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Tabor College will ensure that ECAR is updated in a timely manner when there is a change in a position of an official for the institution. The two third-party collection agencies for Perkins were added to ECAR on October 31, 2023. Name(s) of the contact person(s) responsible for corrective action: Erica Clark, Director of Financial Aid Planned completion date for corrective action plan: March, 2024

View Audit 299430

Finding 387118 (2023-004)

None 2023

Eureka College

IL

Student Financial Aid Eligibility Matching / Level of Effort / Earmarking

2023-004 – Student Financial Aid Cluster – (a) Federal Pell Grant (b) Federal Supplemental Educational Opportunity Grant (c) Federal Work Study Grant (d) Federal Perkins Loan Program (e) Federal Direct Student Loans (f) Teacher education Assistance for College and Higher Education ALN No. (a) 84.063...

2023-004 – Student Financial Aid Cluster – (a) Federal Pell Grant (b) Federal Supplemental Educational Opportunity Grant (c) Federal Work Study Grant (d) Federal Perkins Loan Program (e) Federal Direct Student Loans (f) Teacher education Assistance for College and Higher Education ALN No. (a) 84.063 (b) 84.007 (c) 84.033 (d) 84.038 (e) 84.268 (f) 84.379 – Year Ended June 30, 2023 Condition: We examined 40 student files and we noted one student was not properly awarded their Pell grant. We consider this condition to be an instance of noncompliance relating to the Eligibility compliance requirement. Management Response: This was a student transferring from a college that had closed (Lincoln College) the Financial Aid staff did not calculate new PELL eligibility with the Eureka College COA and awarded Pell from the wrong matrix on the Pell payment chart. Corrective Action Plan: All pell awards are now being offered based on correct COA and Pell Grant matrix with the Eureka costs. Responsible Person: Tim Marten, Director of Financial Aid Implementation Date: Spring 2024

View Audit 299424

Finding 387117 (2023-003)

None 2023

Eureka College

IL

Questioned Costs Student Financial Aid Cash Management

2023-003 – Student Financial Aid Cluster – (a) Federal Pell Grant (b) Federal Supplemental Educational Opportunity Grant (c) Federal Work Study Grant (d) Federal Perkins Loan Program (e) Federal Direct Student Loans (f) Teacher education Assistance for College and Higher Education ALN No. (a) 84.063...

2023-003 – Student Financial Aid Cluster – (a) Federal Pell Grant (b) Federal Supplemental Educational Opportunity Grant (c) Federal Work Study Grant (d) Federal Perkins Loan Program (e) Federal Direct Student Loans (f) Teacher education Assistance for College and Higher Education ALN No. (a) 84.063 (b) 84.007 (c) 84.033 (d) 84.038 (e) 84.268 (f) 84.379 – Year Ended June 30, 2023 Condition: We examined 40 student files and we noted 3 out of 40 students were not properly awarded Direct Loans. One of these students was improperly awarded subsidized loans and instead should have received unsubsidized loans. Additionally, the College did not report actual loan disbursement dates to the Common Origination and Disbursement (COD) system for 1 of the 40 students in the sample (2.5%). We consider these conditions to be instances of noncompliance in internal control over compliance relating to the Eligibility compliance requirement. Management Response: Cost of Attendance (COA) calculations were not updated to ensure ratio of subsidized versus unsubsidized loans were correct. It looks like awards were not being recalculated as additional need based aid was added to awards for these students. Corrective Action Plan: New financial aid software (JFA) was implemented for the 2023-2024 academic year. A component of this software is a compliance check for COA and other issues. The compliance check for over awards should catch instances of the wrong sub/unsub ratio in the future. Responsible Person: Tim Marten, Director of Financial Aid Implementation Date: Fall 2023

View Audit 299424 Questioned Costs: $1

Finding 387116 (2023-002)

Significant Deficiency 2023

Eureka College

IL

Student Financial Aid Reporting Special Tests & Provisions

2023-002 – Student Financial Aid Cluster – (a) Federal Pell Grant (b) Federal Supplemental Educational Opportunity Grant (c) Federal Work Study Grant (d) Federal Perkins Loan Program (e) Federal Direct Student Loans (f) Teacher education Assistance for College and Higher Education ALN No. (a) 84.063...

2023-002 – Student Financial Aid Cluster – (a) Federal Pell Grant (b) Federal Supplemental Educational Opportunity Grant (c) Federal Work Study Grant (d) Federal Perkins Loan Program (e) Federal Direct Student Loans (f) Teacher education Assistance for College and Higher Education ALN No. (a) 84.063 (b) 84.007 (c) 84.033 (d) 84.038 (e) 84.268 (f) 84.379 – Year Ended June 30, 2023 Condition: The College did not report graduate status changes within 60 days for ten out of twenty students (50%) tested. We consider this condition to be a significant deficiency of internal control over compliance relating to the Special Tests and Provisions compliance. Management response: From October 2022 to August 2023, the Registrar's Office was short staffed (we only had one employee in the office). We also switched email service providers in the second half of May 2023. The degree file reminder email from the National Student Clearinghouse was missed by the Registrar in the email transition period and because of the change in calendar systems, it was also missed on the Registrar's calendar. When the email migration was complete, the Registrar had thousands emails that were showing as unread. By the time the email cleanup was complete, and the Registrar realized she had not submitted the May 2023 degree file, the 60 day window had passed. The file was submitted in late July as soon as it was discovered that it hadn't gotten submitted (15 days past the 60 day window) Corrective Action Plan: The Summer 2023 and Fall 2023 degree files were submitted on time. The Registrar's office is once again fully staffed and our email and calendar systems are stable again as well. Responsible Person: Kendi Onnen, Registrar Implementation Date: 7/27/2023

View Audit 299424

Finding 387115 (2023-001)

Significant Deficiency 2023

Eureka College

IL

Questioned Costs Student Financial Aid Significant Deficiency

2023-001 – Student Financial Aid Cluster – (a) Federal Pell Grant (b) Federal Supplemental Educational Opportunity Grant (c) Federal Work Study Grant (d) Federal Perkins Loan Program (e) Federal Direct Student Loans (f) Teacher education Assistance for College and Higher Education ALN No. (a) 84.063...

2023-001 – Student Financial Aid Cluster – (a) Federal Pell Grant (b) Federal Supplemental Educational Opportunity Grant (c) Federal Work Study Grant (d) Federal Perkins Loan Program (e) Federal Direct Student Loans (f) Teacher education Assistance for College and Higher Education ALN No. (a) 84.063 (b) 84.007 (c) 84.033 (d) 84.038 (e) 84.268 (f) 84.379 – Year Ended June 30, 2023 Condition: During our testing of forty individuals receiving federal work study, we noted 26 individuals (65%) that had timecards for hours worked that were not approved by a supervisor. We consider this condition to be a significant deficiency relating to the Activities Allowed or Unallowed compliance requirement. Management response: Timecard approval was completed by email notification. During 2022/23, a new email system was installed, and many emails related to timecards were lost. Corrective Action Plan: Starting in August 2023 all timecard approvals were documented in the payroll system (Paycor). HR prior to processing payroll requires all timecards be system documented as approved. Responsible Person: Kathleen Hermacinski, Human Resources Coordinator Implementation Date: August 2023

View Audit 299424 Questioned Costs: $1

Finding 387112 (2023-004)

Significant Deficiency 2023

Rutgers, the State University of New Jersey

NJ

Student Financial Aid Reporting Significant Deficiency

2023-004 Special Tests (Enrollment Reporting) Federal Agency: Student Financial Assistance Cluster - U.S. Department of Education Program Titles and ALN: Federal Pell Grant Program (ALN 84.063) and Federal Direct Student Loans (ALN 84.268) Federal Grant Numbers: E-P063P130272 (7/1/2022 - 6/30/2023...

2023-004 Special Tests (Enrollment Reporting) Federal Agency: Student Financial Assistance Cluster - U.S. Department of Education Program Titles and ALN: Federal Pell Grant Program (ALN 84.063) and Federal Direct Student Loans (ALN 84.268) Federal Grant Numbers: E-P063P130272 (7/1/2022 - 6/30/2023), P268K130272 (7/1/2022 - 6/30/2023) Contact Person: Jean McDonald Rash, AVP Enrollment Services, 848-932-2605 Corrective Action: The University Registrar will send a memorandum to all degree certifying officers at the University reminding them that degree certification must be completed by the appropriate date to be certain all students are included on the file that updates NSLDS with the graduation date. The Chancellor Unit registrars will be asked to send out reminders in the weeks leading up to the required submission date and to track the completion of degree certifications. A process will be developed to allow for the proper reporting of graduation information on the Program-Level Record to NSLDS even when the student remains currently enrolled at the University and is being reported as such on the Campus-Level Record. Anticipated Completion Date: The anticipated completion date for degree certifications is June 2024. The anticipated completion date for dual enrollment reporting statuses is January 2025.

View Audit 299417

Finding 387110 (2023-003)

Material Weakness 2023

Rutgers, the State University of New Jersey

NJ

Student Financial Aid Subrecipient Monitoring Cash Management

2023-003 Reporting (Financial) Federal Agency: Student Financial Assistance Cluster - U.S. Department of Education Program Titles and ALN: Federal Pell Grant Program (ALN 84.063) and Federal Direct Student Loans (ALN 84.268) Federal Grant Numbers: E-P063P130272 (7/1/2022 - 6/30/2023), P268K130272 ...

2023-003 Reporting (Financial) Federal Agency: Student Financial Assistance Cluster - U.S. Department of Education Program Titles and ALN: Federal Pell Grant Program (ALN 84.063) and Federal Direct Student Loans (ALN 84.268) Federal Grant Numbers: E-P063P130272 (7/1/2022 - 6/30/2023), P268K130272 (7/1/2022 - 6/30/2023) Contact Person: Jean McDonald Rash, AVP Enrollment Services, 848-932-2605 Corrective Action: OSFP was notified of the error in reporting the correct cost of attendance to the Common Origination and Disbursement (COD) system and the code was changed to prevent the error from reoccurring. The correct cost of attendances are now being reported to COD. A testing plan has been developed that includes confirmation that all system start and end dates align with the University’s published academic calendar. Anticipated Completion Date: Completed

View Audit 299417

Finding 387108 (2023-002)

Material Weakness 2023

Rutgers, the State University of New Jersey

NJ

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

2023-002 Eligibility Federal Agency: Student Financial Assistance Cluster - U.S. Department of Education Program Titles and ALN: Federal Pell Grant Program (ALN 84.063) and Federal Direct Student Loans (ALN 84.268) Federal Grant Numbers: E-P063P130272 (7/1/2022 - 6/30/2023), P268K130272 (7/1/2022 ...

2023-002 Eligibility Federal Agency: Student Financial Assistance Cluster - U.S. Department of Education Program Titles and ALN: Federal Pell Grant Program (ALN 84.063) and Federal Direct Student Loans (ALN 84.268) Federal Grant Numbers: E-P063P130272 (7/1/2022 - 6/30/2023), P268K130272 (7/1/2022 - 6/30/2023) Contact Person: Jean McDonald Rash, AVP Enrollment Services, 848-932-2605 Corrective Action: In order to correct the issue of students being awarded in excess of their cost of attendance, a weekly report has been developed to capture any student whose financial aid, from any source, exceeds the assigned cost of attendance. The Financial Aid Processing team in University Enrollment Services receives and resolves the issues in the report weekly to ensure that students are not awarded in excess of their assigned cost of attendance. In order to correct the issue of the incorrect calculation of the cost of attendance components, a testing plan has been developed that includes manually checking each program cost of attendance prior to signing off for production aid packaging. The script that caused the cost of attendance components to be doubled was corrected prior to the 2023-2024 aid year. Anticipated Completion Date: Completed

View Audit 299417 Questioned Costs: $1

Finding 387100 (2023-001)

Material Weakness 2023

Rutgers, the State University of New Jersey

NJ

Internal Control / Segregation of Duties Student Financial Aid

2023-001 Eligibility, Reporting (Financial) and Special Tests (Disbursements to or on Behalf of Students) Federal Agency: Student Financial Assistance Cluster - U.S. Department of Education and U.S. Department of Health and Human Services (DHHS), DHHS Health Resources and Services Administration Pr...

2023-001 Eligibility, Reporting (Financial) and Special Tests (Disbursements to or on Behalf of Students) Federal Agency: Student Financial Assistance Cluster - U.S. Department of Education and U.S. Department of Health and Human Services (DHHS), DHHS Health Resources and Services Administration Program Titles and Assistance Listing Numbers (ALN): Federal Supplemental Educational Opportunity Grants (ALN 84.007), Federal Work-Study Program (ALN 84.033), Federal Perkins Loans (ALN 84.038), Federal Pell Grant Program (ALN 84.063), Federal Direct Student Loans (ALN 84.268), Nurse Faculty Loan Program (ALN 93.264) and Scholarships for Health Professions Students from Disadvantaged Backgrounds (ALN 93.925) Federal Grant Numbers: E-P007A132602 (7/1/2022 - 6/30/2023), E-P033A132602 (7/1/2022 - 6/30/2023), E-P038A132602 (7/1/2022 - 6/30/2023), E-P063P130272 (7/1/2022 - 6/30/2023), P268K130272 (7/1/2022 - 6/30/2023), E-01HP28821-02-02, E36HP26092, E36HP25751, E26HP25748, E11HP27284 (7/1/2022 - 6/30/2023), 1T08HP393200100 (7/1/2022 - 6/30/2023), 5 T08HP39320-03-00 (7/1/2022 - 6/30/2023) Contact Person: Ellen Law, AVP OIT Enterprise Application Services, 848-445-5064 Corrective Action: Management has documented and implemented system release management practices for the OSFP system. All system change requests, updates and approvals are being tracked in a project tracking software. A dedicated Oracle Student Financial Planning (OSFP) administrator has been onboarded, to segregate duties within the technical team, with the capability of deploying changes to production. A new access role was implemented which limited some of the permissions, and the majority of the 35 users were moved to this more limited role. A recertification process was developed and the recertification was performed in July 2023. In the future, recertifications will be completed annually. Anticipated Completion Date: Completed

View Audit 299417

Finding 387003 (2023-004)

Significant Deficiency 2023

Lindenwood University

MO

Internal Control / Segregation of Duties Special Tests & Provisions Student Financial Aid

Finding 2023-004 Personnel Responsible for Corrective Action: Senior Vice President, Student Experience – Joseph Sallustio Anticipated Completion Date: March 2024 Corrective Action Plan: The University has completed its implementation of Anthology, a student information system, during the 2023-...

Finding 2023-004 Personnel Responsible for Corrective Action: Senior Vice President, Student Experience – Joseph Sallustio Anticipated Completion Date: March 2024 Corrective Action Plan: The University has completed its implementation of Anthology, a student information system, during the 2023-2024 fiscal year. The new system has several built in features that are supplemented with internal controls to ensure that exit interviews are completed with students in a timely fashion. There was also a transition in leadership during this time. The new leader did not realize the exits were being sent manually. The system has since been configured to send out exits upon graduation and an exit is triggered for when the student graduates, withdraws or drops to less than half-time.

View Audit 299379

Finding 387001 (2023-003)

Significant Deficiency 2023

Lindenwood University

MO

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

Finding 2023-003 Personnel Responsible for Corrective Action: Senior Vice President, Student Experience – Joseph Sallustio Anticipated Completion Date: March 2024 Corrective Action Plan: The University has completed its implementation of Anthology, a student information system, during the 202...

Finding 2023-003 Personnel Responsible for Corrective Action: Senior Vice President, Student Experience – Joseph Sallustio Anticipated Completion Date: March 2024 Corrective Action Plan: The University has completed its implementation of Anthology, a student information system, during the 2023-2024 fiscal year. During the go-live in Spring 2023, the University experienced critical system reporting issues which were addressed a quickly as possible. The new system has several built in features that are supplemented with internal controls to ensure enrollment reporting requirements are completed in a timely fashion. In Spring 2024, Anthology provided the University with a audit tool to review data before uploading to promote efficiency and accuracy.

View Audit 299379

Finding 386999 (2023-002)

Significant Deficiency 2023

Lindenwood University

MO

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

Finding 2023-002 Personnel Responsible for Corrective Action: Senior Vice President, Student Experience – Joseph Sallustio Anticipated Completion Date: March 2024 Corrective Action Plan: The University has completed its implementation of Anthology, a student information system, during the 2023-...

Finding 2023-002 Personnel Responsible for Corrective Action: Senior Vice President, Student Experience – Joseph Sallustio Anticipated Completion Date: March 2024 Corrective Action Plan: The University has completed its implementation of Anthology, a student information system, during the 2023-2024 fiscal year. The new system has several built in features that are supplemented with internal controls to ensure that changes in students enrollment status that trigger a return of title IV funds are completed within the required 45 day time period. During the transition of systems the report used to look at students who might need to be a withdrawal and have a R2T4 calculation performed needed to be rebuilt for the new system. During this process the report did not always work correctly. Those flaws have been fixed the report is being worked on a weekly basis.

View Audit 299379

Finding 386998 (2023-001)

Significant Deficiency 2023

Lindenwood University

MO

Student Financial Aid Subrecipient Monitoring Eligibility

Finding 2023-001 Personnel Responsible for Corrective Action: Senior Vice President, Student Experience – Joseph Sallustio Anticipated Completion Date: March 2024 Corrective Action Plan: The University has completed its implementation of Anthology, a student information system, during the 2023-...

Finding 2023-001 Personnel Responsible for Corrective Action: Senior Vice President, Student Experience – Joseph Sallustio Anticipated Completion Date: March 2024 Corrective Action Plan: The University has completed its implementation of Anthology, a student information system, during the 2023-2024 fiscal year. The new system has several built in features that are supplemented with internal controls to ensure financial aid is awarded correctly. The system automatically awards the student at full-time, the awards are then confirmed through a review process before sending out the award notification, and again before payment. The system compares the full-time award status with the actual enrollment and if they do not match the student will fail for payment and we will revise the award.

View Audit 299379

Finding 386962 (2023-006)

Significant Deficiency 2023

University of Central Missouri

MO

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

The University concurs with the above mentioned finding that, while University processes defined to address GLBA are in place, the Information Security Policy does not specifically address Gramm-Leach-Bliley Act (GLBA) security criteria. It is now understood that the defined processes that address ...

The University concurs with the above mentioned finding that, while University processes defined to address GLBA are in place, the Information Security Policy does not specifically address Gramm-Leach-Bliley Act (GLBA) security criteria. It is now understood that the defined processes that address and support GLBA security criteria need to be put into a format that is published for access by the UCM community. UCM has commenced the process to create and publish the written information security program that addresses all required elements of the GLBA.

View Audit 299298

Finding 386961 (2023-001)

Significant Deficiency 2023

Medical University of South Carolina

SC

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

Cause and potential effect as presented in the Summary of Findings and Questioned Costs: The University's internal controls for determining that a loan disbursement notification was sent for each disbursement made was not operating effectively. Accordingly, the University did not send a loan notific...

Cause and potential effect as presented in the Summary of Findings and Questioned Costs: The University's internal controls for determining that a loan disbursement notification was sent for each disbursement made was not operating effectively. Accordingly, the University did not send a loan notification for disbursements within the required timeframe nor with the required information. Narrative Explanation: The general Financial Aid Award letter-directing the student to view their Loan Disbursement information was insufficient to meet the requirement. While the students have direct access to their student accounts that show disbursement activity and the institution has posted to their website the required terms of loan disbursements, the federal direct loan disbursement notification was not sent to the student or parent within the required 30 days before or 30 days after the disbursement was credited to the student's account and did not include the necessary information regarding the student's right or parent's right to cancel per 34 CFR section 668.165. Corrective action: The Student Financial Aid office reached out to our software vendor Ellucian Colleague and similar peer institutions to create a Loan Disbursement Notification notice. Effective immediately, all term disbursements will receive Loan Disbursement Notification notices. The Financial Aid Transmittal process (FATR) is run each week on Tuesday morning. The notices will be emailed weekly using a date range from the last financial aid transmittal date to the current date. Should more than one FATR be run in a week’s time, the notices would increase in frequency and intensity. The documents will be archived in batches within our current Document Imaging System by date. Additionally, a section on the Student Financial Aid website will be dedicated to the Disbursement Information, including Loan Notifications and Right to Cancel Loan procedures. MUSC is currently in the process of implementing a new Student Information System with a go live date scheduled for February 2025. During implementation we will configure the new SIS to automatically send the Loan Disbursement notifications to the students when their funds have been credited to the student’s accounts. You may direct questions to me at freelan@musc.edu or by telephone at 843-792-4364.

View Audit 299296

Finding 386951 (2023-005)

Significant Deficiency 2023

Chicago State University

IL

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

Disbursement notification has been added to the responsibilities of the current staff member.

View Audit 299291

Finding 386946 (2023-004)

Significant Deficiency 2023

Chicago State University

IL

Student Financial Aid Matching / Level of Effort / Earmarking Cash Management

The application was submitted to Department of Education with our BankMobile link on 1/29/2024. The Department of Education has not updated our information yet.

View Audit 299291

Finding 386914 (2023-002)

Significant Deficiency 2023

Southern Illinois University

IL

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

2023-002. Finding: Student Enrollment Reporting– Both Campuses Response: The campuses have implemented processes to prevent further errors in enrollment reporting, despite the disconnects and system problems that have been observed. Corrective Action Plan: SIUC has implemented a process where in eac...

2023-002. Finding: Student Enrollment Reporting– Both Campuses Response: The campuses have implemented processes to prevent further errors in enrollment reporting, despite the disconnects and system problems that have been observed. Corrective Action Plan: SIUC has implemented a process where in each time an NSLDS roster is received (twice a month), it is run against a list of Title IV aid students to identify any that are not on the roster in order to remedy the omission as soon as possible. The current course of action at SIUE is to monitor students per term who are up for graduation but are not enrolled for the full semester. Students who are up for graduation will be enrolled in UNIV 500 for the remainder of the term after completing requirements earlier in the semester in which they are graduating. This would be in line with our Continuous Enrollment Policy 1L16. While this is currently a manual process, SIUE continues to look for ways to systematically indicate the student is withdrawn in later part of term in which they are graduating, or to withdraw the student from the later part of the term. Contact Person: Rachel Frazier (SIUC) and Patrick Sears (SIUE) Anticipated completion date: December 2023 (SIUC) and Spring 2024 (SIUE)

View Audit 299240

Finding 386731 (2023-001)

Significant Deficiency 2023

Champlain College Incorporated

VT

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

Management Response and Corrective Action Plan: The College runs weekly reports from the Ellucian Colleague system to identify students with CFlags and comment codes for loan limits. While reviewing the report if a student has comment codes for loan limits, the staff member running the reports wil...

Management Response and Corrective Action Plan: The College runs weekly reports from the Ellucian Colleague system to identify students with CFlags and comment codes for loan limits. While reviewing the report if a student has comment codes for loan limits, the staff member running the reports will research and assign the issue to the appropriate Financial Aid Assistant Director to adjust the loan accordingly. For the student identified, the loan limit was calculated incorrectly in the Colleague system and the student was awarded a federal direct loan that exceeded their maximum total aggregate outstanding loan debt by $2,500. It is our belief this was not an issue of identifying the CFLAG, it was human error with reduction of loans. To correct the issue this student was awarded institutional aid to cover the amount loans were reduced. To confirm that no other student’s were impacted by a similar issue, a CFLAG full audit report was run for 2022. The report was reviewed to determine if there were any other students that had an aggregate loan limit issues. It was confirmed that this student was the only issue. The Office of Financial Aid will be enhancing the rules in our Colleague system to prevent disbursement if the Loan Limit CFlag has not been fully resolved. Staff will also be trained to not solely rely on Colleague’s Loan information and to seek verification of loan limits directly from NSLDS. OFA member that reviews loan limits will need to include the students NSLDS record in the students folder, confirmation of and loan amounts, and detailed description of adjustments. A monthly audit will occur by an Associate Director or the Director to confirm accruary and completeness. Scheduled Date of Completion: 4/15/2024 Contact person responsible: Katrina Bennett, Director of Financial Aid

View Audit 299033 Questioned Costs: $1

Finding 386725 (2023-001)

Significant Deficiency 2023

Alverno College

WI

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

Finding: The College’s internal controls over compliance of special tests regarding the Gramm-Leach Bliley Act (GLBA) were not operating effectively in 2023 as the College did not have a comprehensive information security program in compliance with the Safeguards Rule prepared by June 9, 2023. The...

Finding: The College’s internal controls over compliance of special tests regarding the Gramm-Leach Bliley Act (GLBA) were not operating effectively in 2023 as the College did not have a comprehensive information security program in compliance with the Safeguards Rule prepared by June 9, 2023. The College is required to have a completed and approved information security program available on or before June 9, 2023. The College did not complete and review the information security program until fall 2023. The controls over GLBA compliance were not operating effectively to be in compliance as of June 9, 2023. Subsequent to year end, management finalized and approved the security program. We recommend the College ensure that individuals responsible for completion and review of the information security program are aware of the program requirements and complete the assessment annually with documented review prior to fiscal year-end. Corrective Action: Management agrees and has implemented necessary procedures and management oversight to meet the requirements.

View Audit 299031

Finding 386659 (2023-007)

Significant Deficiency 2023

Cabrini University

PA

Reporting Student Financial Aid Significant Deficiency

Student Financial Assistance Cluster – Assistance Listing No. 84.063, 84.268 Recommendation: The University should review its policies and procedures on reporting of enrollment status changes to NSLDS to ensure that all status changes are being reported accurately to be in compliance with regulatio...

Student Financial Assistance Cluster – Assistance Listing No. 84.063, 84.268 Recommendation: The University should review its policies and procedures on reporting of enrollment status changes to NSLDS to ensure that all status changes are being reported accurately to be in compliance with regulations. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Typically this sort of error does not occur with the NSC and its handling of transmitted data. However, the Registrar’s Office will check enrollment transmissions approximately two weeks following submissions, to affirm proper handling of transmitted data. Name(s) of the contact person(s) responsible for corrective action: Marita Hurst, Registrar Planned completion date for corrective action plan: April 1, 2024

View Audit 298971

Finding 386653 (2023-006)

Significant Deficiency 2023

Cabrini University

PA

Questioned Costs Student Financial Aid Significant Deficiency

Student Financial Assistance Cluster – Assistance Listing No. 84.063, 84.007, 84.268, 84.379, 84.033, & 84.038 Recommendation: We recommend the University review all R2T4 calculations to ensure the correct net disbursed amounts are entered for all Title IV aid. Explanation of disagreement with au...

Student Financial Assistance Cluster – Assistance Listing No. 84.063, 84.007, 84.268, 84.379, 84.033, & 84.038 Recommendation: We recommend the University review all R2T4 calculations to ensure the correct net disbursed amounts are entered for all Title IV aid. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Financial Aid Director will utilize the R2T4 Calculator on COD to determine the correct amount of earned aid when a student withdraws completely. Additional attention will make sure the adjustments are made in Banner & COD in an accurate manner. Name(s) of the contact person(s) responsible for corrective action: Sean Hudson, Interim Director of Financial Aid Planned completion date for corrective action plan: Corrective action plan has already been implemented.

View Audit 298971 Questioned Costs: $1

Finding 386651 (2023-005)

Significant Deficiency 2023

Cabrini University

PA

Student Financial Aid Reporting Significant Deficiency

Student Financial Assistance Cluster – Assistance Listing No. 84.063, 84.268 Recommendation: We recommend the University evaluate its procedures and policies around reporting to the COD to ensure that student information is reported accurately and timely. Explanation of disagreement with audit fin...

Student Financial Assistance Cluster – Assistance Listing No. 84.063, 84.268 Recommendation: We recommend the University evaluate its procedures and policies around reporting to the COD to ensure that student information is reported accurately and timely. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Currently, some files are being transferred automatically between COD & Cabrini by IT and some are being transferred manually by staff. Going forward all files will be transferred manually by the Financial Aid Director on a daily basis to ensure completion. Name(s) of the contact person(s) responsible for corrective action: Sean Hudson, Interim Director of Financial Aid Planned completion date for corrective action plan: April 1, 2024

View Audit 298971

Finding 386650 (2023-004)

Significant Deficiency 2023

Cabrini University

PA

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

Student Financial Assistance Cluster – Assistance Listing No. 84.268 Recommendation: We recommend the University evaluate its procedures and a policy around packaging Title IV based on need. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action ta...

Student Financial Assistance Cluster – Assistance Listing No. 84.268 Recommendation: We recommend the University evaluate its procedures and a policy around packaging Title IV based on need. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Staff will be retrained on packaging requirements and the importance of monitoring for over-award situations. The Financial Aid Director will also work with IT to make sure reporting mechanisms are set up to identify potential overawards for timely investigation and review. Name(s) of the contact person(s) responsible for corrective action: Sean Hudson, Interim Director of Financial Aid Planned completion date for corrective action plan: April 30, 2024

View Audit 298971 Questioned Costs: $1

Finding 386643 (2023-002)

Significant Deficiency 2023

Cabrini University

PA

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

Student Financial Assistance Cluster – Assistance Listing No. 84.268 Recommendation: The University should ensure all necessary employees receive proper training, support, and time to follow the University’s policies and federal requirements related to monthly reconciliations. There should be a pro...

Student Financial Assistance Cluster – Assistance Listing No. 84.268 Recommendation: The University should ensure all necessary employees receive proper training, support, and time to follow the University’s policies and federal requirements related to monthly reconciliations. There should be a process to maintain all reconciliations to support these were performed as required monthly. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: A monthly schedule will be established and staff assigned to the task of monthly reconciliation will be trained in the federal requirements. This training will include a review of where such files are to be retained. Name(s) of the contact person(s) responsible for corrective action: Sean Hudson, Interim Director of Financial Aid Planned completion date for corrective action plan: May 15, 2024

View Audit 298971

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